HomeMy WebLinkAboutVoIPReport_120516.pdf
The Federal Communications
Commission FCC defines VoIP as a
technology that allows users to make
voice calls using a broadband Internet
connection instead of a regular (or
analog) phone line.
VoIP
VOICE OVER
INTERNET PROTOCOL
IDAHO PUBLIC UTILITIES COMMISSION
1
December 5, 2016
Senator Brent Hill & Representative Scott Bedke
Idaho State Legislature
700 West Jefferson Street
Boise, Idaho 83720
Dear Senator Hill and Representative Bedke,
In response to a request from legislative leadership, the Idaho Public Utilities Commission (IPUC) undertook the
task of convening a group of interested parties to evaluate the status of Voice over Internet Protocol Service (VoIP)
in relationship to Idaho. The report included in this package is the culmination of that effort.
As background, the IPUC chose to contract with Joe Cusick to oversee this project. Mr. Cusick has decades of
experience in the telecommunications sector, which includes professional work within the industry and as a
regulator. He was instructed to develop an “honest broker” report that avoided taking a position on any options
that emerged.
The finished report is intended to be an easily accessible assessment of VoIP in Idaho. All effort was made to avoid
the morass of acronyms and jargon that litter the telecommunications sector. Hopefully, this report will
accomplish its goal of providing an easy to digest evaluation of the current status of VoIP and the possible paths
forward.
As another point of interest, the landscape at the federal level has changed dramatically since the initiation of this
project. Most notably, the results of the November elections could lead to potential congressional and regulatory
actions that might impact the telecommunications industry. The new administration will certainly have a different
relationship with Congress, and the composition of the Federal Communications Commission (FCC) will also
change.
While congressional action and directions are always difficult to predict, it is clear that future changes at the FCC
will have significant and more immediate impact on the telecommunications sector. Given the recent history that
most major FCC decisions were resolved by 3-2 decisions along party lines, a change at the FCC will likely result in
new directions as it relates to VoIP and other telecommunications matters. Future FCC decisions will undoubtedly
have impacts on jurisdictional matters that are currently administered at that state level.
Hopefully this report provides useful information to assist the Legislature. If additional information on this topic is
required, the IPUC is prepared to assist.
Sincerely,
Paul Kjellander
Commissioner
2
November 30, 2016
Joe Cusick
916 N. Fifth St.
Boise, ID, 83702
President Pro Tem Hill, Speaker Bedke and Idaho Legislators,
This report is submitted in response to the Legislature's request to Commissioner Paul
Kjellander dated March 28, 2016.
In its request, the Legislature asked the Commission for its aid and expertise in advising
the Legislature on “the question of preemption of regulation for VoIP and IP-Enabled
Services and the effect that action might have on the need for revision of other Idaho
statutes.”
This report is divided into four sections: Definitions, Current Status of VoIP Regulation,
Summary of Industry Views and Options for moving forward. Attached are copies of the
draft 2015 and 2016 AT&T proposed legislation.
I have presented three options for the Legislature to consider. Option 1 is to accept all
or part of AT&T's proposed legislation, Option 2 is to maintain the status quo, and
Option 3 is to add clarifying language to the Title 62 statutes.
As to the regulatory status if VoIP, as AT&T points out, 36 states have chosen to
deregulate VoIP. It is an issue that seems to be in constant litigation, as it is currently.
In Idaho, the PUC's approach to VoIP is best described as a hands-off approach.
The industry's views are part varied and part consistent. The stakeholders in this
proceeding are consistent in that they all agree that they would like to see deregulation.
However, they are varied in the conditions that should go along with deregulation. A
jaded view might be that deregulation is fine as long as I get what I want.
The definitions section attempts to define or explain some of the acronyms which
appear in the report. The telecom industry is replete with acronyms and has long given
the military a run for the money in this regard.
I have tried to provide the Legislature with a concise, yet accurate, view on the subjects
of VoIP and IP-enabled service as they pertain to Idaho today. I have consciously
attempted to avoid protracted and esoteric discussions on the legal status of subjects
such as whether VoIP is an information or telecommunications service or whether it is
3
under intrastate or interstate jurisdiction. If, at any point, Legislators would like to
discuss issues in further details, I remain at your disposal.
Sincerely,
Joseph W. Cusick
Curriculum Vitae Summary for Joseph W. Cusick
BBA Finance and Management - Idaho State University
Manager, Regulatory Affairs US West – Retired 1990
Staff Supervisor (Telecommunications) Idaho PUC – Retired 2013
Former Staff Chair, US West Regional Oversight Committee
Former Staff Chair, NARUC Telecommunications Subcommittee
Former Staff Chair, Joint Committee on Jurisdictional Separations
4
5
HEADE
6
DEFINITIONS
VoIP (Voice over Internet Protocol) – The Federal Communications Commission
(FCC) defines VoIP as a technology that allows users to make voice calls using a
broadband Internet connection instead of a regular (or analog) phone line. Some VoIP
services may allow users to call only other people using the same service, but others
may allow you to call anyone who has a telephone number - including local, long
distance, mobile, and international numbers. Also, while some VoIP services work only
over a computer or a special VoIP phone, other services allow you to use a traditional
phone connected to a VoIP adapter. The National Exchange Carrier Association
(NECA) defines VoIP as a technology that allows users to make telephone calls using a
broadband Internet connection instead of a regular (or analog) phone line.
Within VoIP there are also two distinct services: interconnected and non-interconnected.
Interconnected VoIP service - VoIP has four defining characteristics. It 1) enables
real-time, two-way voice communications; 2) requires a broadband connection from the
user's location; 3) requires Internet protocol-compatible customer premises equipment
(CPE); and 4) permits users to generally receive calls that originate on the public
switched telephone network (PSTN) and to terminate calls to the public switched
telephone network. Non-interconnected VoIP simply does not have the last
requirement to originate or terminate calls on the PSTN and is not subject to state
regulation.
VoIP may also be nomadic or fixed.
Nomadic VoIP is intended to be used at any location where a broadband connection is
available. A customer may use his or her service in Boise or Boston. That service is
regulated on an interstate basis only.
Fixed VoIP is intended to be used at the customer’s premises only and may be subject
to intrastate jurisdiction, depending on a state's statutes.
(For purposes of this report, fixed-interconnected VoIP is the service that will be
addressed.)
ITSAP (Idaho Telephone Service Assistance Plan) – Financial assistance is available
in Idaho to help qualified low-income individuals pay for telephone service. The program
offers a $2.50 discount on monthly telephone bills. A separate program, the federal
Lifeline program, offers an additional monthly discount of $9.25. Both ITSAP and
Lifeline are funded by a surcharge on all customers’ telephone bills.
LECs (Local Exchange Carriers) – Those carriers that provide local service to end-
use customers, aka telephone companies. LECs may fall into two categories: incumbent
or competitive. For our purposes, incumbents are those carriers that were providing
local service as of February 8, 1996, the implementation of the federal
7
Telecommunications Act of 1996 (TA96). Competitive LECs are those companies that
started providing local service after that date.
TRS (Telecommunications Relay Service) – TRS allows citizens who are hearing- or
speech-impaired to engage in telephone communications “in a manner functionally
equivalent to individuals without hearing or speech impairments.”
USF (Universal Service Fund) – Generally refers to Idaho's state Universal Service
Fund. Established to assist high-cost rural companies to achieve a fair rate of return
while keeping rates affordable for rural customers. This fund currently supports eight
rural companies in Idaho at an annual cost of $1,698,610.
8
CURRENT STATUS OF VoIP REGULATION
As stated in the letter asking the PUC to investigate VoIP regulation, 36 states thus far
have deregulated VoIP. One of the biggest motivators to get VoIP deregulated is the
FCC's refusal to address the issue. The FCC has avoided the question of whether VoIP
is a telecommunications service or an information service. That lack of action has
caused uncertainty in the market and has prompted providers, primarily AT&T, to
address the issue on a state-by-state basis.
Regardless of its regulatory status, the FCC does hold interconnected VoIP providers
subject to certain regulatory requirements, similar to other voice providers. VoIP
providers must provide:
911 Services: Providers of interconnected VoIP services – which allow users
generally to make calls to and receive calls from the regular telephone network –
do have 911 service obligations. However, 911 calls using VoIP are handled
differently than 911 calls using regular telephone service.
Portability: The FCC requires interconnected VoIP providers and telephone
companies to comply with Local Number Portability (LNP) rules.
Customer Proprietary Network Information (CPNI): The FCC limits
interconnected VoIP providers' use of customer proprietary network information,
such as telephone calling records, and requires interconnected VoIP providers to
protect them from disclosure.
Universal Service: The FCC requires interconnected VoIP providers to
contribute to the Universal Service Fund, which supports communications
services in high-cost areas and for income-eligible telephone subscribers.
Accessibility: Interconnected VoIP providers must contribute to the interstate
Telecommunications Relay Services Fund used to support the provision of
telecommunications services to persons with speech or hearing disabilities and
offer 711 abbreviated dialing for access to relay services. Providers and
equipment manufacturers also must ensure their services are available to and
usable by individuals with disabilities, if such access is achievable.
9
SUMMARY OF INDUSTRY VIEWS
Although many, if not all, of the participants favor deregulation, they generally do so on
a conditional basis. Each participant has its own interests it wants protected. Briefly,
here are the various positions of the parties. For those reading an electronic version of
this report, links to the parties’ entire comments are provided below. A complete text of
the parties’ comments can also be accessed on the commission’s website at
www.puc.idaho.gov. Under “Hot” items, click on “VoIP Regulation.”
AT&T
In its first comments, AT&T states that it believes Idaho's current practice of not
regulating IP or VoIP should be codified into state law. Doing so would create a more
stable regulatory environment that will promote greater investment, AT&T believes. The
company goes on to point out that 34 states and the District of Columbia have adopted
such legislation.
AT&T also supports the Legislature's request to limit the scope of the review and not to
undertake a broad sweeping review of Idaho's code. AT&T encourages the working
group to maintain a narrow focus on exempting IP and VoIP regulation.
In its second set of comments, AT&T states that it agrees with Verizon and the VON
Coalition on a number of matters, specifically: that VoIP is a service and not a
technology; that federal law clearly prevents state regulation of VoIP and IP enabled
services; that regulatory certainty will promote investment in VoIP and IP enabled
services; and that the report should focus on the narrow question as defined by the
Legislation.
A text of the parties’ comments can be accessed at www.puc.idaho.gov. Under “Hot”
items, click on “VoIP Regulation.”
AT&T Comments
AT&T Reply Comments
T-Mobile
T- Mobile is not opposed to VoIP deregulation and where market conditions justify,
would support it. The company is concerned about deregulation because it affects the
wholesale markets, which, T-Mobile believes, remain under monopoly control.
To the extent the proposal would remove regulatory protections in these legacy
monopoly wholesale markets, T-Mobile objects. Because wholesale markets remain
under monopoly control, monopoly-type protections and regulation should remain in
effect, under both federal and state law.
10
T-Mobile maintains the best way to preserve these protections is to draw a distinction
between retail and wholesale markets and apply the deregulatory language only to
retail. One could identify the specific elements of wholesale markets – such as special
access, interconnection and intercarrier compensation – but in order to ensure that the
proposed bill includes all of the wholesale elements, the language should simply apply
to only retail IP markets and not wholesale IP markets.
A text of the parties’ comments can be accessed at www.puc.idaho.gov. Under “Hot”
items, click on “VoIP Regulation.”
T-Mobile Comments
VON Coalition
The Voice On the Net Coalition (VON) believes that state regulation is currently
preempted under the FCC’s Vonage Preemption Order and that the Vonage order
extended to both nomadic and non-nomadic VoIP. VON also believes that the proposed
legislation aligns with federal law, which classifies VoIP as an information service.
Under federal law, information services are exempt from telecommunications
regulations, including state regulation.
VON further states that VoIP has continued to prosper under the FCC's light-touch
regulatory structure. Citing FCC reports, VON points out that subscribers have grown
nationally at an annual rate of 13 percent between June 2012 and June 2015.
Specifically, subscribers grew from approximately 40 million in June 2012 to 57 million
in 2015.
VON believes that regulatory uncertainty would decrease as a result of enacting safe-
harbor legislation. The Coalition also points out that 36 states have already deregulated
VoIP and that none of the states have repealed such laws once enacted.
A text of the parties’ comments can be accessed at www.puc.idaho.gov. Under “Hot”
items, click on “VoIP Regulation.”
VON Coalition comments
VON Coalition Reply Comments
Frontier Communications
Frontier Communications agrees with other parties that say VoIP/IP services should not
be regulated. However, Frontier is concerned about the lack of parity caused by
applying taxes, fees and surcharges to only one small subset of providers, mostly those
11
that provide local exchange service or long-distance and toll-free services. The
company believes this lack of parity – and the resulting higher rates their customers are
required to pay – has led to a steady erosion in the number of lines that LECs are
serving.
Frontier states that if the Legislature were to pursue preemption of VoIP/IP services, it
would be a great opportunity for a simultaneous and comprehensive revision of other
statutes that created these various funds and taxes. Such revisions could level the
playing field for all telecommunications providers, including VoIP, wireless and local
exchange.
A text of the parties’ comments can be accessed at www.puc.idaho.gov. Under “Hot”
items, click on “VoIP Regulation.”
Frontier Communications Comments
CenturyLink
CenturyLink supports the preemption of VoIP regulation at the state level, as long as the
legislation also mandates that VoIP providers and wireless providers pay the various
taxes, fees and surcharges that telecommunication providers are required to pay.
Payment of the various taxes, fees and surcharges needs to be nondiscriminatory and
competitively and technologically neutral; neither providing a competitive advantage for,
nor imposing a competitive disadvantage upon any voice service provider.
CenturyLink believes that, currently, these fees are discriminatory – some voice
providers pay and some do not. The Legislature should fix this during the 2017
legislative session, at the same time it addresses the preemption of VoIP regulation.
This is not only good public policy, but it can be done without a “broad sweeping rewrite
of Idaho’s code related to communications or telecommunications services.”
A text of the parties’ comments can be accessed at www.puc.idaho.gov. Under “Hot”
items, click on “VoIP Regulation.”
CenturyLink Comments
Attachment A
Attachment B
Attachment C
Attachment D
Attachment E
CenturyLink Reply Comments
12
Cable Providers
Both the Idaho Cable Telecommunications Association (ICTA) and Charter
Communications submitted comments that reflected similar views.
ICTA states that in 2015 it initially opposed AT&T’s draft legislation that would have
deregulated VoIP in Idaho. After revisions were made to that draft, the ICTA no longer
opposed, but did not support, the legislation. The ICTA remains of the opinion that
legislation to further deregulate VoIP services in Idaho is unnecessary.
The cable providers believe that Idaho was on the forefront of deregulating
telecommunications services with the Telecommunications Act of 1988, Idaho Code
§62.601 et. seq. The Act exempts CLECs and ILECs – including those that deploy VoIP
technology – from the more onerous or pervasive rate regulation provisions of Title 61
and instead provides a very light, yet important, scheme of regulation for CLEC VoIP
services. Several of these Title 62 provisions address important intra-industry issues
that remain relevant. In particular, statutory provisions that expressly authorize the
commission to implement and enforce federal interconnection obligations and other
wholesale rights, (§62-615), or resolve intercarrier disputes, (§62-613), could become
clouded by new and potentially conflicting deregulatory code provisions.
The cable providers believe that while AT&T has modified its proposed legislation to
carve out important areas where the commission should retain Title 62 jurisdiction, the
ICTA remains leery of unintended deregulatory consequences. Rather than bringing
further legislation to deregulate VoIP and then “adding back” certain Title 62 (and other
code) provisions that are exempt from deregulation, it seems that the better system is to
maintain the status quo of Title 62’s light regulatory scheme of all CLEC providers.
There is also the misconception that there was very little or no payment of state or
federal telecom fees by VoIP providers. Whether that is true or not for some CLECs,
such is not the case for cable companies offering VoIP services in Idaho. Cable One, for
example, provisions its orders through Level 3 which, in turn, remits the appropriate
taxes, fees and surcharges.
A text of the parties’ comments can be accessed at www.puc.idaho.gov. Under “Hot”
items, click on “VoIP Regulation.”
ICTA Comments
Charter Communications Comments
Idaho Telecom Alliance (ITA)
The ITA, which represents rural carriers, believes that regulation should be dependent
13
on the function of the service, not the technology through which it is delivered. For this
reason, the ITA's view is that voice telecommunications services provided through the
public switched network should have equal regulatory treatment regardless of the
technology used.
The ITA is sympathetic to the desires of the proponents of VoIP deregulation proposals
to minimize regulatory costs and burdens. However, the ITA does not believe that such
legislation is the best way to achieve these goals. ITA points out that there is already a
mechanism, under Title 62 of Idaho Code, to be freed from rate regulation and other
regulatory requirements.
ITA states that parity in regulation is important. Any changes that might be made should
continue to support the public switched network and not have the unintended
consequences of discouraging investment by ILECs and other providers of traditional
telecommunications service.
The ITA finally points out there is a great deal of controversy at the federal level
concerning the appropriate treatment of VoIP, broadband and universal service.
Because those issues are in flux, it believes it would be premature for the Idaho
Legislature to proceed with addressing only one component of a highly interrelated
telecommunications system until clarity of how support and regulatory treatment of the
whole system will be addressed by the FCC.
A text of the parties’ comments can be accessed at www.puc.idaho.gov. Under “Hot”
items, click on “VoIP Regulation.”
Idaho Telecom Alliance Comments
Verizon
Verizon does not support the approach proposed by some commenters, which would
entangle statutory memorialization of the exemption from regulation of VoIP/IP-enabled
services with an array of other policy issues. This contravenes the desire for limited
review expressed the by Legislature, which noted that past legislative consideration has
“extended beyond the narrow question of whether preemption should be enacted and
what form it should take.”
Some commenters have gone beyond this scope, Verizon said, by tying the codification
of preemption to 1) reform of the Idaho Universal Service Fund and Idaho
Telecommunications Service Assistance Program; 2) imposition of an array of new fees
on VoIP services; and 3) assertion of Commission jurisdiction over IP interconnection.
These proposed actions would increase the costs of providing VoIP services in Idaho,
resulting in higher rates for customers and potentially driving broadband investment to
other states that have already codified a “hands-off” approach to VoIP, with the
attendant lower costs of doing business.
14
For these reasons, Verizon cannot support AT&T’s proposed 2016 legislation as
presently drafted. However, the company could support it if the proposed revisions to
Idaho Code 62-610 and the entirety of proposed new Idaho Code 62-618A(5) were
stricken. It is inappropriate to impose a bevy of new regulatory fees on VoIP services
under the guise of exempting it from regulation. Doing so would discourage the very
investment that the legislation aims to incent.
Moreover, by permitting VoIP providers to draw USF subsidies for providing services
that are unsubsidized today, the legislation would encourage waste and unnecessarily
impose higher USF fees on Idaho consumers.
A text of the parties’ comments can be accessed at www.puc.idaho.gov. Under “Hot”
items, click on “VoIP Regulation.”
Verizon Comments
Level 3
Level 3 does not oppose the relaxation of retail regulation for VoIP services. Its
concerns center on maintaining regulatory jurisdiction over the wholesale market and
carrier-to-carrier interconnection agreements, intercarrier compensation tariffs, etc.
While some states have passed legislation addressing regulatory frameworks for VoIP
retail services, those regulatory frameworks continue to ensure that the role of state
commissions to address their respective state and federal obligations over
interconnection and wholesale issues, regardless of technology, remains intact.
Level 3 believes that failure to limit VoIP deregulation to just the treatment of retail
services threatens interconnection rights. These rights are essential for connecting
networks of various providers and ensuring fair dealing among competitors who must
work together to complete voice calls between customers. Limiting any proposed
deregulation of retail services provided by VoIP will 1) ensure fair and equitable
interconnection and traffic exchange regardless of service, capability, functionality,
application or technology used by carriers in the network, 2) preserve state authority to
consider issues/disputes among competitors and their impact on consumers and the
marketplace; 3) continue to foster and ensure a competitive marketplace for innovative
providers and future providers of advanced communications services.
A text of the parties’ comments can be accessed at www.puc.idaho.gov. Under “Hot”
items, click on “VoIP Regulation.”
Level 3 Communications, Inc. Comments
15
OPTIONS
Option 1 – Accept some or all of AT&T's proposal.
AT&T has provided sample legislation similar to what it proposed in the previous
legislative session. This proposal redefines VoIP as a service and removes it from
regulation under either Title 61 or Title 62 placing it entirely out of the PUC's jurisdiction.
AT&T believes that such legislation removes VoIP from regulatory uncertainty and will
help spur broadband investment.
Complete deregulation leaves questions to be answered. AT&T has addressed many
concerns by introducing a new section, 62-618A that would carve out provisions for
payment into the Idaho Universal Service fund, 911 fees, the Idaho
Telecommunications Service Assistance Plan and the state Telecommunications Relay
Service. One of the questions still to be addressed, however, is how does this
legislation affect a company's requirement to interconnect with other carriers. This has
historically been under the jurisdiction of the PUC and the Commission has heard
numerous cases to decide disputes between companies. Without this provision,
companies may be left with no choice but to take disputes to the FCC where such cases
can take years to resolve.
In addition, many issues remain unresolved at the federal level. The FCC has yet to
decide if VoIP is a telecommunications service or an information service (FCC 15-70
Numbering Policies Order). The jurisdictional aspect also remains a contested issue as
to whether or not VoIP is an intrastate or interstate service. Depending on decisions at
the FCC, states may well want to maintain some jurisdiction or VoIP service. If AT&T's
legislation were to be enacted, regaining state jurisdiction becomes an issue.
Finally, there is the law of unintended consequences. Although AT&T has attempted to
address many concerns, invariably issues come up that were not anticipated. This could
occur if future changes at the federal level require actions in Idaho that are no longer
available because of state statutory changes such as this.
Option 2 – Maintain the status quo.
One of the questions that continues to drive much of the current national litigation is the
question of whether VoIP is a telecommunications service or an information service.
AT&T, in its comments, claims that VoIP is an information service. However, the fact
remains that this still undecided at the federal level. In its most recent order on
numbering released June 22, 2015, (FCC 15-70) the FCC states that “the Commission
has not classified interconnected VoIP services as telecommunications services or
information services.”
Also, the question of whether VoIP is an interstate or intrastate service remains
16
undecided. States believe that fixed-interconnected VoIP is an intrastate service. Most
VoIP providers take the point of view that the Vonage Order (FCC Order 04-267)
classified it as an interstate service. States reason that the Vonage Order pertained only
to nomadic VoIP and not to fixed-interconnected VoIP. The criteria that the FCC used to
classify it as an interstate service – namely that with nomadic VoIP the originating and
terminating location could not be determined – is not true for fixed-interconnected VoIP.
These issues are waiting on the FCC to finally make a decision.
Under the current statutes, the decision of how to regulate a company is not done by
regulatory fiat but is the choice of the company. The rules under which a company is
regulated are determined by Idaho Code 62-604(2) and 62-622(2). Under 62-622(2),
competitive local exchange carriers are, by definition, regulated under Title 62. Under
62-604(2), incumbent local exchange carriers are given the choice to be regulated
under Title 61 or 62.
One stated reason for deregulation is the need for certainty to incent investment. That
said, nothing has been put forward to demonstrate that broadband deployment is being
suppressed by the current regulatory regime. Inarguably, in rural areas broadband
deployment lags but not because of regulatory treatment, but by simple economics.
Broadband deployment is increasingly done using fiber optic cable. This is a costly
proposition, and it is difficult to cost justify in very rural areas. Toward that end, the FCC
has established a Competitive Access Fund (CAF) to aid in rural deployment. This
program has been successful and has led to increased fiber deployment in Idaho's rural
areas.
In most urban areas, unlike rural areas, customers have multiple choices for broadband
service. Competition in the broadband market continues to be strong. Cable One in
Idaho now offers one-gigabit service in selected areas. Cellular 4G LTE service has
become the norm for all carriers. All this is happening within the context of Idaho’s
current regulatory structure. Changing the status of VoIP is not likely to significantly
impact the future deployment of broadband.
The regulatory uncertainty on the federal level and, consequently, the potential need to
make broad changes to the Idaho statutes when these issues are finally decided is the
primary reason to maintain the status quo.
Option 3 – Add Clarifying Language
A third option is to add language clarifying that interconnected VoIP is included for all
LECs regulated under Title 62. This language merely codifies what is current
Commission practice. Some companies oppose this language because it also codifies
VoIP as an intrastate telecommunications service, which has yet to be decided by the
FCC.
17
Add to 62-603(15): Interconnected Voice over Internet Protocol (VoIP) – A technology
that allows users to make voice calls using a broadband Internet connection instead of a
regular (analog) phone line. Interconnected VoIP allows users to receive calls that
originate on the public switched telephone network and to terminate calls to the public
switched telephone network.
Add to 62-604(2)(c): When a company choses to have its local exchange service
regulated under Title 62, interconnected VoIP is included in that election.
DRAFT LEGISLATION
Attached on the following pages are the 2015 and 2016 copies of the AT&T draft legislation. For
those reading the electronic version of this report, their links follow:
2015 AT&T Draft Legislation
2016 AT&T Draft Legislation