As many know, the FCC directed non-dominant interstate telecommunications carriers to withdraw the publications (tariffs) they have on file at the agency containing the rates, terms and conditions of most of their service offerings. Domestic carriers were required to withdraw their tariffs by July 31; international carriers are currently scheduled to do so by January 28, 2002.

So where can a practitioner—or a telecommunications manager for that matter—now go to get information quickly and reliably on the rates, terms and conditions of service providers? First, remember that the FCC’s detariffing rules apply only to “non-dominant” carriers. Dominant carrier filings remain on file at the FCC. For example, the interstate access tariffs of the incumbent local telephone exchange carriers (ILECs) are available on-line via the FCC’s website at http://svartifoss2.fcc.gov/prod/ccb/etfs/. The tariffs of other dominant interstate and international carriers are available in paper or in electronic form at the FCC, through its commercial distributor Qualex International, or through commercial tariff information companies.

With respect to non-dominant carriers, however, practictioners can still obtain copies of rate information the “old-fashioned way:” by visiting their service provider’s office and asking to see this information. The FCC directed carriers subject to its detariffing requirements to publish their service rates and conditions through other means, such as in price lists or schedules made available at the carriers’ offices. I imagine, though, that obtaining rate information in this manner could be rather involved. Some offices might not have available all the information required or might refer the practitioner to other offices (some of which might be out of state). Others might have the information, but not in a format or within the time frame that meets the practitioner’s needs.

The FCC also directed carriers that maintain Internet websites to post rate information on their sites. But this information might be similarly incomplete or difficult to find. The FCC adopted only general rules to govern how carriers must post such information. And, indeed, my review of several websites was unsatisfying, as there were few (and sometimes no) direct links to sufficiently detailed rate information.

Luckily, a number of companies have developed subscription services to assist lawyers, telecom managers and even end users in detangling detariffing. Two in particular offer a solution through Internet-based services. The first is the Center for Communications Management Information (CCMI) accessible on-line at the URL http://www.ccmi.com or by calling Deanna Halton in Rockville, Maryland, at (301) 287-2610. The second is Valucom, Inc., reachable at http://www.tariffnet.com or by contacting Kathy Monson in Vienna, Virginia, at (703) 255-0700 ext. 312. Both companies have been in the business for many years (hence their expertise), but now more than ever can help practitioners unravel the rates, terms and conditions of both the general offerings and special customer arrangements of telecommunications carriers.

Their websites post a wide range of rate materials primarily from the largest carriers. These include not only interstate and international tariffs, but also most of the state tariffs. In addition, CCMI and Valucom provide a number of non-tariffed price lists and arrangements, including certain interconnection agreements. Their websites also post news items and links on the latest filings or rate changes made by selected carriers. Attorneys might find these items helpful to monitor carrier activities and alert clients when necessary.

What I find particularly helpful about CCMI’s and Valucom’s services is that they offer an option to view the actual pages of the carriers’ filings. These are presented either in Adobe PDF or text format and sometimes in both (and in Valucom’s case, these pages are unedited). Both companies also make a number of their products available on diskette, and Valucom will email materials at a customer’s request. As a lawyer, I like to see these “primary source” documents rather than a distillation or analysis that might be incorrect or misleading. In other words, I like to analyze the carriers’ publications myself.

But for those who do not have the time or do not want to search through hundreds or thousands of rate pages, these companies offer a variety of secondary source and value-added materials. For example, CCMI offers two tools it calls “TelView Express” and “Q-TEL 1000,” which provide excerpted rates (and references) for the individual service elements associated with selected carrier offerings. Valucom’s counterparts include “AccessPrice” and “ValuLocal,” which provide pricing information on private circuits and definitions and rates for local calling areas. Other tools provide detailed U.S. and international pricing information for major long distance companies, the Bell Operating Companies, and the ILECs. Such services help avoid the need to navigate through a maze of tariff pages and sections to find needed information.

CCMI’s and Valucom’s charges vary depending on the type of material and the amount of time that is needed. Access to lengthy information will cost more, of course, but it might not be as expensive as it would be to visit a carrier’s office or to send a paralegal to do so. For example, CCMI’s and Valucom’s base charge for on-line access on a per tariff basis starts at less than $100 per month. Discounts are available for quarterly and annual access. Both companies also offer heavily discounted rates for unlimited access to their entire tariff libraries. As a final matter, I’d like to mention that both companies go well beyond the provision of rate information. They publish a host of other telecommunications resources (e.g., area code and LATA maps, newsletters, directories), and Valucom will customize its products and databases to meet specific customer requirements. In addition, CCMI regularly holds seminars throughout the U.S. on telecommunications-related topics and issues.

There are bound to be some knots during the implementation of the FCC’s detariffing policies. I am certain, however, that these Internet-based services will serve to untangle the complexity of the rates, terms and conditions of telecommunications service offerings.

______________________________________________________________________ Mr. DeSoto is an attorney at the law firm of Wiley Rein & Fielding LLP. He practices in the areas of wireless and wireline telecommunications, telephone company ratemaking, and equipment authorization. He previously worked in the FCC's Common Carrier Bureau. 8/2001


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