Yacknin Draft Arbit. Rpt. on Level 3 Communications' application for arbitration of interconnection agreement with Pacific Bell Telephone Company

X. Signaling System 7

The Signaling System 7 (SS7) network is a data overlay network, separate from the public switched telephone network, that is used for (1) call set-up and routing, and (2) accessing call-related databases such as the 800, calling name, and calling card number query databases. SS7 quad links - the subject of this issue - are sets of data links that would connect SBC's and Level 3's SS7 networks if Level 3 were to deploy one.

SS7 is not an unbundled network element, and SBC therefore has no obligation to provide SS7 services to Level 3 under the Telecommunications Act. Nevertheless, the parties have nearly reached agreement for the sharing of costs associated with establishing SS7 quad links, and to exchange traffic through those quad links on a bill-and-keep basis. Level 3 proposes that SS7 quad links apply to interexchange carrier calls, and that parties pay each other appropriate access charges on a prorated basis. SBC maintains that SS7 quad links should be limited to calls that are subject to traditional access compensation; SBC further contends that, if Level 3 does not accept that limitation, SBC is not obligated to and will not enter into the arrangement at all.

As discussed with respect to the Coordinated Hot Cuts and Out of Exchange Appendix issues elsewhere in this report, to the extent that SBC is not obligated to provide a service, it is not subject to arbitration under the Telecommunications Act. There is no dispute that SBC is not obligated to provide SS7 service. Accordingly, the Commission does not have the authority to require SBC to provide the service in this arbitration.

Nevertheless, I note that this dispute may be resolved at least in part by virtue of the resolution of the intercarrier compensation issues regarding
IP-enabled services. SBC's stated concern focuses on attempting to segregate what SBC characterizes as Level 3's "CLEC" calls from what SBC characterizes as Level 3's "long distance IP calls" for the purpose of assessing access charges on the latter. However, as discussed and resolved in Section III.A, IP-enabled service traffic is subject to reciprocal compensation, not access charges. Therefore there doesn't appear to be a basis for barring IP-enabled services traffic from the parties' SS7 arrangement.