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Verizon can't count.

HB5709, amends the Emergency Telephone System Act changing Sections 2.12(d) and 15.3(c).

Section 2.12 is what we're first interested in.

2.12(a) states;

"network connections" means the number of voice grade communications channels directly between a subscriber and a telecommunications carrier's public switched network

Looks like that means individual phone lines. Any exceptions to this principle of a network connection equals one phone line? Yep, right there in 2.12(d).

2.12(d) states;

Where multiple voice grade communication channels are connected to a telecommunication carrier's public switched network through a private branch exchange service (PBX), there shall be determined to be one network connection for each trunk line capable of transporting either the subscriber's inter-premises traffic to the public switched network or the subscriber's 9-1-1 calls to the public agency. Where multiple voice grade communication channels are connected to a telecommunication carrier's public switched network through centrex type service, the number of network connections shall be equal to the number of PBX trunk equivalents for the subscriber's service, as determined by reference to any generally applicable exchange access service tariff filed by the subscriber's telecommunications carrier with the
Commission.

Looks like an exception for business lines. Connect a PBX and one network connection equals one trunk line. Definition of a trunk line is found in filed tariffs. PBX is define in Section 2.20 of the Emergency Telephone System Act.

Are ISP's equipment PBX's? Can't say from that definition, but it doesn't look like it. There is no definition of trunk line in the Illinois Compiled Statutes. Trunk line has to be defined from the tariffs, and must have a common meaning the way this legislature is written.

This is the first question for the ICC:

Under the exchange access service tariff filed by Verizon North, what is the definition of a trunk line?

This is the second question for the ICC:

Under Section 2.20 of the Emergency Telephone System Act are ISP's equipment defined as PBX's?

If trunk lines are T-1's or T-3's, and ISP equipment are PBX's, then we are defined under the exception listed in 2.12(d). If that is the case, then we have one network connection per T-1, and under Section 15.3(c) would be required to pay five surcharges per network connection, or 5 surcharges per T-1, or $12.50 per T-1.

If we are not listed under the exception in 2.12(d), then the 5 surcharges per network connection under 15.3(c) don't apply to us.

There are three possibilities;

1:) T-1's are trunk lines and ISP equipment are PBX's. Under 12.2(d) trunk lines count as one network connection, and under 15.3(c) pay 5 surcharges for each T-1.

2:) T-1's are not trunk lines and ISP equipment are not PBX's. Under 12.2(a) we would owe one surcharge for each phone line in a T-1, or 24 surcharges per T-1.

3:) T-1's are not trunk lines and ISP equipment are PBX's. Under 12.2(a) we would owe for one network connection for each phone line in a T-1, and under 15.3(c) we would owe 5 surcharges per network connection, or 120 surcharges per T-1.

Posted by dglynn at January 30, 2003 03:06 PM