Industry Divided on Scope of IP Transition Trials

"These proposed trials would be of little value,” said XO, calling managed IP interconnection trials “unnecessary and inappropriate,” geographic all-IP trials “without merit,” and copper retirement trials “not justified” (http://bit.ly/13zkftr). Trials will be “artificial” by their nature, XO said, arguing pertinent real-world information is readily available: “The use of IP technology in communications networks is not a new phenomenon.” The commission should be most interested in promoting consumer welfare and fostering “lasting competition” as networks evolve, XO said, by establishing a regulatory framework to govern requests for IP voice interconnection with ILECs. XO also called for new copper retirement rules, as preserving copper loops is “critical” for business and there have been recent developments of “innovative uses” of copper, the carrier said.

VoIP interconnection trials might help establish technical standards, but that’s not the sticking point in the industry, said Cbeyond, Earthlink, Integra, Level 3 and tw telecom (http://bit.ly/18Lj4s8): The real problem is ILECs’ “unwillingness to negotiate” VoIP interconnection agreements. The commission should not simply accept that trials are the best procedural mechanism to help the industry move to IP, the CLECs said, asking the commission to “require incumbent LECs to comply with their statutory duty to establish VoIP interconnection agreements on just, reasonable, and nondiscriminatory terms and conditions,” while constraining ILECs’ exercise of market power over last-mile connections to businesses.

"An IP interconnection trial is not needed,” said Sprint Nextel (http://bit.ly/14GUN23). “The Commission should complete the pending Intercarrier Compensation Further Notice of Proposed Rulemaking and immediately mandate the industry transition to the exchange of voice traffic in IP format.” They're unnecessary, Sprint said, as “carriers know how to interconnect voice traffic using IP.” What the commission should do is “compel the nation’s largest incumbent carriers to establish interconnection agreements and begin exchanging voice traffic in IP format with competing carriers.” Trial endorsement arose from parties “that stand to gain the most from delaying or denying the establishment of efficient, pro-competition interconnections.”

T-Mobile supports trials (http://bit.ly/13zr1zz), asking the commission to focus on eliminating the policy and commercial issues that most often stymie VoIP interconnection. “The trial should be conducted at a regional level, covering a number of states,” the carrier said. “Carriers should interconnect efficiently at a single location in the region,” such as through a recognized Internet exchange point that already carries non-voice IP traffic. “Interconnection rates and terms should be reasonable and efficient, and reached through an open and transparent negotiation process, and participants must have recourse to a regulatory arbiter in the event of any impasse,” the filing said. A trial would be “more efficient” than “existing ad hoc arrangements,” and would include carriers that have so far “declined to participate in open negotiations towards efficient rates and terms for IP interconnection, often because of ILEC financial incentives to retain existing TDM interconnections.” But it’s important to preserve competition without “unnecessary legacy regulation designed for a different era,” T-Mobile said.

AT&T pushed for adoption of its own proposed format for the trials (http://bit.ly/18LjCOt). The most important thing the commission can do is “sweep away rules that prevent carriers from retiring their legacy networks and services,” AT&T said. That’s best accomplished by authorizing limited geographic trials that let carriers transition from TDM to IP technologies, it said. “Several of the narrower trials proposed in the public notice would shed little light on the key challenges arising from the TDM-to-IP transition,” the carrier said. The FCC’s proposal of VoIP interconnection trials “effectively puts to rest any question that the proposed trial is necessary or appropriate,” AT&T said. Industry stakeholders have already begun developing standards for VoIP interconnection, it said; “especially in view of its backward-looking focus on the Commission’s potential role managing the underlying agreements, the VoIP interconnection trial envisioned in the Public Notice would serve no useful purpose, nor would it yield any useful or relevant information regarding the transition."

The transition to IP is already “well-underway,” said Verizon and Verizon Wireless (http://bit.ly/13zqBZO). “Given that customers already have and continue to extensively migrate from wireline services to wireless alternatives, it is not clear what purpose a ’trial’ would serve,” they said. “Any trials that do occur must not interfere with ongoing market-based solutions by attempting to shoehorn new technologies into old-model regulations, or by imposing obligations that will make further innovation less economically feasible.” There’s no need for an IP voice interconnection trial, which would “likely do more harm than good” as providers are already exchanging VoIP traffic in IP format, the carrier said. Verizon urged the commission to encourage business-to-business efforts. “Rather than locking companies into one, ’trial’ interconnection method, the Commission should encourage companies to develop and implement whichever methods of IP interconnection work best for two willing commercial partners.”

NCTA supports trials, but acknowledged it’s hard for cable operators to offer much input to the FCC because of the lack of proposal details (http://bit.ly/18LnYFi). “Cable operators already are using IP technology to provide voice service to their customers,” the filing said. In terms of a VoIP interconnection trial, cable operators are primarily concerned with how the trial will affect “existing interconnection and traffic exchange arrangements.” If a trial would “unduly jeopardize” the stability of the “stable arrangements” established after the 1996 Telecom Act, that would be a “cause for concern,” NCTA said. For example, carriers need to consider issues like transport costs and interoperability testing to ensure new interconnection arrangements work as intended.

The FCC should keep in mind six public interest objectives when developing the trials, said the Communications Workers of America: (1) Stimulate investment in high-speed networks; (2) Support quality jobs in the telecom industry; (3) Promote quality, affordable service all Americans; (4) Ensure network reliability; (5) Promote public safety; and (6) Protect consumers. “Some employers have used the introduction of new technology as an excuse to contract the work out to vendors, many of whom are located offshore, or to move the work to non-union subsidiaries,” CWA said (http://bit.ly/18LiOcC). “It is in the best interest of all to ensure that the low-road employment policies do not become the dominant market driver.” The FCC can use the transition to IP technologies to examine the trials’ impact on number and quality of jobs, and require trial participants to “provide a workforce deployment plan with the goal of maximizing the employment opportunities and minimizing the displacement of current workers,” CWA said.

The Edison Electric Institute, representing investor-owned electric utilities, underscored the importance of maintaining reliable and resilient communications networks (http://bit.ly/18LiavF). Electric utilities are among the largest users of telecom services, EEI said, and advanced communications technologies are essential to grid modernization and improved network reliability. “In the future utilities and the telecommunications industry will rely increasingly on IP-based communications” that are better equipped to facilitate advances like smart-grid technologies. Backup power remains a “key impediment” to be addressed that is particularly salient for utilities, it said.