The regulatory treatment of voice-over-Internet protocol (VoIP) s...

that favors one method of providing voice service over another not only violates the principles of technological and competitive neutrality, it can place at risk the reliability of carriers’ underlying networks,” it said. OPASTCO expressed concern that although “at some point” most VoIP service providers “avail themselves of the highly reliable public switched telephone network (PSTN) to originate, transport or complete voice calls,” they “offer little or no financial support for the growth and upkeep costs of the PSTN.” It said long-term “favorable” regulatory treatment of VoIP service providers would “undermine the reliability of the nation’s ubiquitous telecommunications network.” It also expressed concern about the future of the Universal Service Fund (USF), saying if VoIP providers were exempted from contributing to the USF, “customers of other providers will have to pay more in order to sustain the integrity of the Fund. This places the Fund’s future viability at risk, and runs counter to Section 254(b)(5) of the 1996 Act, which calls for ’specific, predictable and sufficient’ mechanisms to preserve and advance universal service.” OPASTCO argued that the adoption of VoIP technology shouldn’t absolve any service provider of the obligation to compensate LECs adequately for access to the local loop. It criticized VoIP providers’ refusal to pay access charges, saying the VoIP technology did “not reduce the costs incurred by small carriers when they provide access services for these calls.” It said that although VoIP providers claimed to compensate LECs for access costs through the rates they paid as end users, such rates were “not designed to recover LECs’ costs of providing access.” OPASTCO said since many members obtained more than 60% of their operating revenue from access charges and universal service support mechanisms, “without adequate cost recovery from these revenue sources, the ability of small LECs to continue providing basic services at affordable rates would be seriously compromised” and would inhibit them from investing in the network upgrades necessary to provide advanced services. OPASTCO urged the Commission to “adhere to the principles of competitive and technological neutrality in order to avoid government policy, rather than consumer choices, determine the winners and losers in the marketplace. Clearly, services that provide direct substitutes for each other should not be subject to different regulatory classification.”