On July 15, 2011, the FCC issued a Public Notice requesting comment on a Petition filed by Time Warner Telecom Inc. ("TWTC") for a declaratory ruling that would entitle Voice-Over-Internet Protocol (VoIP)-based providers, like TWTC, to interconnect with incumbent local cxchange carriers (ILECs) in Internet Protocol (IP) format, in a manner consistent with the provisions of Section 251 of Telecommunications Act of 1996, which governs interconnection between carriers. Historically, VoIP-based providers have been required by the ILEC to convert their traffic to the traditional TDM format before exchanging that traffic with the ILEC.

Specifically, the Public Notice seeks comment on TWTC's request that the FCC declare that:

  • facilities-based VoIP services are a "telecommunications service";
  • facilities-based providers of VoIP services, as telecommunications service providers, are entitled under Section 251(c)(2) of the Communications Act, as amended, to establish direct IP-to-IP interconnection with the ILEC for the transmission and routing of VoIP traffic; and
  • intermediate carriers providing IP-in-the-middle voice services also have the right to establish direct IP-to-IP interconnection with the ILEC for the same purpose.

In general, VoIP-based providers prefer IP-to-IP interconnection for two reasons. First, IP-to-IP interconnection is more efficient because it requires fewer facilities and eliminates the expensive step of format conversion in the exchange of traffic, decreasing costs for carriers and customers alike. Second, service quality is improved because there is no need for the IP-to-TDM conversion, which may result in the loss of information associated with the call.

Comments on TWTC's Petition are due to the FCC by August 15, 2011. Reply comments are due August 30.