The FCC’s Technology Transitions Task Force should promptly update the...

the process they should follow four major guidelines, the CLECs said: First, avoid redundant proceedings. Second, consider only those issues that “would not arise ‘but for’ a technology transition,” such as, for example, wholesale access to ILEC last-mile facilities, they said. Third, the FCC should prioritize issues based on their potential effect on consumer welfare. Finally, the commission should utilize “appropriate procedural mechanisms,” such as a rulemaking, to effectuate new rules. The CLECs also encouraged the FCC to reject AT&T’s petition to launch a proceeding on the IP transition, and its proposed wire center experiment where many of the interconnection rules would be lifted. Most of the issues raised in AT&T’s petition, such as service discontinuance, network change notification and federal eligible telecom carrier rules, are already the subject of pending FCC proceedings, the CLECs said. AT&T’s wire center tests are unnecessary, would divert FCC resources from updating existing competition policies, and wouldn’t help to identify the markets where ILECs have market power, the CLECs said. They also opposed NTCA’s petition for a new omnibus rulemaking proceeding to address the IP transition, arguing the rural association’s proposed “smart regulation” approach is too broad and will unnecessarily divert FCC resources. The CLECs did support NTCA’s request for clarification that ILECs must provide Session Initiation Protocol interconnection under Section 251 of the Telecom Act.