I was noticing something earlier today when reading the USAC’s (Universal Service Administrative Company) interpretation of who must contribute to the USF (Universal Service Fund) according to FCC 06-94. The FCC 06-94 order specifically states that interconnected VoIP providers must pay into the USF, and they go on to define an interconnected VoIP provider as a service that: “(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 generally to receive calls that originate on the public switched telephone network and to terminate calls to the public switched telephone network.”

Note the use of ‘and’ in that statement to imply that in order to be considered interconnected, you must meet all the four criteria.

The USAC’s interpretation of this regulation, however, is vastly different from everyone else’s interpretation. According to the USAC, “The obligations established by the FCC apply to all VoIP communications made using an interconnected VoIP service, even those that do not involve the PSTN…” which reads as though they think that an interconnected VoIP provider is not necessarily one which connects to the PSTN.

This seems to be a somewhat radical interpretation of what an ‘interconnected’ VoIP provider is, expanding their interpretation to even directly VoIP to VoIP services that never touch the PSTN such as FWD or even MSN to MSN calls.

I note that their site was updated as of the 17th of July, 2007, and that the site archive doesn’t mention this interpretation prior to this date, so I’m wondering if this means they’re going to start to pressure VoIP providers that don’t actually provide connection with the PSTN to pay into the USF.

Always pushing the boundaries, I often wonder how long it will be before we see the USAC and the FCC attempting to charge users who send instant messages back and forth across states ‘interstate communications’ fees, or requiring companies such as AOL, MSN, and Google to pay into the USF for their AIM, MSN, and Gtalk IM services.