A CLEC Operations Consultant — continued

Headaches, not just cuts and roses
But being a CLEC isn't all cost cuts and roses. Plenty of headaches remain, including several CLEC-related regulator, bureaucrat, and telco issues.

Tague says it's tough to be a CLEC, and that many companies that have the certification never use it. "There are attorneys who will get you your state approval and negotiate an interconnect agreement for $5,000 to $8,000," he says. "I think of this as 'CLEC in name only' because when you've done it, you still don't have a network infrastructure, you don't even know how to order a circuit."

Ordering a circuit should be simple. You're the customer, right? The RBOC is there to serve you? It's not easy. You need industry codes and IDs and the procedure is not always obvious. (See, for example, Verizon's Anti-Business Bureaucracy.)

Some numbers come from databases that cost money. There are also cheaper resources (such as Telcodata, see Telco Data Goes Open Source). But however much research you do, Tague says, your application will probably get rejected the first few times.

Work arounds
Sometimes, rules can be waived. For example, a client in the state of Georgia (about whom, more later) was worried because the PSC requires a criminal background check for anyone applying to be a CLEC, and specifies which vendor must be used, and that vendor charges $10,000.

However, Tague did some research and found that you can get that requirement waived. "I picked up the phone and talked to the PSC. PSCs are usually friendly. They're not like the DMV. They're not swamped with applications. And many of them get few applications from local companies, so it counts that you're not a carpetbagger."

Many RBOCs require a deposit from every CLEC of about $10,000, which is too much money for most ISPs. However, Tague says, many local banks will provide an irrevocable letter of credit worth that amount for about $300.

Typical of the bureaucracies that CLECs have to deal with is the North American Numbering Plan Administration, currently run by NeuStar (which is a former subsidiary of Lockheed Martin). "It takes 66 days to get a phone number block, assuming you did everything perfectly right," says Tague.

"And if you didn't you'll find out, but not immediately. They'll wait 30 or 40 days and then reject your application."

"In our initial set of numbers, everything looked fine," Tague relates. "But there was a requirement for a Revenue Accounting Office (RAO) code, and I concluded that could be left blank. One of the tough things about forms is that many lines are left blank, and you have to figure out which ones can be left blank. We needed these phone numbers to implement our plan to reduce costs in the Frankfort area. We had an RAO code the next day, but they wanted to put us back in square one, and that would have cost us about $50,000, or maybe even more."

So Tague went to work, on a Friday evening. "I talked to a lot of people, starting up the chain. Their argument was that their government contract required them to follow the rules, and they couldn't make exceptions. Eventually I found a loophole, that the state PSC could order them to do it. I thought, 'oh great, I need a government bureaucrat to stick their neck out with zero hope of any reward at all.'So I called him. By this time it was Friday night and he was at home. It turned out nobody had ever called him at home before, and he was very nice. Maybe it's nice to be needed. But he said the commisioners would have to approve it."

So Tague kept on working, and eventually found that the NANPA rules have an expedite clause. "I wouldn't be surprised if the term 'expedite' comes from telecommunications. You can expedite anything in the telecom world. So I reached the president of NANPA, and I was pretty much screaming at him, because he was telling me they couldn't bend the rules, but the rules had an expedite clause."

Tague kept on working. "So then I called the president of his parent company about 1 AM. I didn't talk to him but I got a message to him, and he called me back on Saturday at 10:30 AM. So he was telling me about his faith and confidence in NANPA, but somehow, magically, on Monday morning, we were back in line and were not tossed back to square one."

1. A fire under our feet

2. Headaches, not just cuts and roses

>3. It's not a recipe, it's a way of life