In order to formulate an informed, consistent regulatory policy, the Commission would like to obtain information about VOIP activity in Michigan. The Commission, therefore, requests comments on VOIP activity in Michigan on the following topics that may be affected by both state and federal law
a. The number and type of VOIP providers that are providing service in Michigan, including incumbent local exchange carriers, competitive local exchange carriers, and unlicensed VOIP providers.
b. Estimations of the proper degree of regulation, based on transmission method, to ensure Michigan citizens are protected while using VOIP, while allowing VOIP services to avoid unnecessarily burdensome regulations.
c. Information regarding the effect of VOIP on telephone numbering resources, including non-licensed VOIP providers’ access to numbering resources through licensed telecommunication carriers and VOIP end users’ ability to port their current landline or wireless telephone number to their VOIP equipment.
d. Access to emergency calling, including VOIP end users’ unrestricted access to 9-1-1, non-carrier charges for 9-1-1 access, and public safety answering points costs to geographically locate VOIP callers and provide a call back number.
e. Whether VOIP providers may participate in, and have access to, the federal Universal Service Fund (USF) to provide service to rural areas, hospitals, and schools; the ability of VOIP carriers to provide low-cost service similar to Lifeline and Link-up for low-income end users; and the need for VOIP end-users to contribute to the federal USF.
f. VOIP services’ effect on the current access charge structure.
g. The ability of VOIP services to provide abbreviated dialing (2-1-1, 3-1-1, 4-1-1, 7-1-1) programs and toll-free dialing (1+800) to end users.
h. Other technical issues, such as internet virus potential, power outage risks, consumer protections including privacy, quality of service, and accessibility by local, state and federal law enforcement.
The Commission recognizes that the FCC has commenced a rulemaking proceeding to determine the proper federal regulatory framework for VOIP and that this proceeding may affect the ability of the Commission to formulate a regulatory policy at the state level. However, the FCC’s Notice of Proposed Rulemaking has just been released, with comment dates yet to be determined, and the FCC may not promulgate a final rule until the end of this year or later.[4] The Commission has a responsibility to the citizens of this state to ask VOIP providers for comments on the topics identified above so that we are in a position to protect both users of VOIP and the customers who may be asked to assume the cost of maintaining a network that may not be supported by VOIP providers.
