AT&T Fleshes Out Details of Wire Center Trial Proposal

Of the ILEC’s 4,700 wire centers, AT&T anticipates trials in only two or three, Hultquist said. Internally, AT&T would generate a list of wire center candidates and then ideally work with the FCC to develop a process to make final selections, he said. “Our thinking is we should be looking at wire centers that are not the same,” Hultquist said. The tested wire centers should have “different demographic [and] technological characteristics such that we can maximize the kinds of lessons we can learn.” Different wire centers fall in different places along a spectrum, he said, marked by differing consumer demographics, levels of competition, and investment by AT&T and its cable competitors, “all of which should ultimately play into how we manage the transition."

The proposed trials (CD Nov 8 p11) would “help illuminate” the technological and policy dimensions facing the industry as it moves toward all-IP services, he said, and a public comment process and FCC oversight would ensure that any problems are addressed. “Let’s actually gather data,” he said. The ultimate goal is to “create a template” that can then be rolled out on a broader basis, he said. “We have to figure out an orderly process for managing the end of the transition” from the time division multiplex (TDM) platform, he said.

Within the test centers, AT&T would identify the TDM-based services offered, and develop a set of timelines for discontinuing them, Hultquist said. For some services, “it might be unreasonable to abruptly eliminate the service” without giving customers time to modify their own equipment and prepare for alternatives, he said. Any timeline would have a couple of important milestones: no longer offering the service to a new customer, but grandfathering existing customers; forbidding customers from adding more lines; and ultimately ceasing the service altogether, he said. Customers would then be moved to “successor services,” he said. For example, there are several successor services available for basic local exchange service, such as wireless; VoIP from cable competitors; or AT&T’s own mobile services or VoIP home phone service, he said.

"You want to be able to force them into [IP services] in a discrete area, and then learn what?” asked Brad Ramsay, NARUC general counsel. “How they survive without the protections that are given to telecommunications services?” AT&T’s hope “would actually be … to get everyone to voluntarily change switched services, which of course they are doing at a very rapid rate,” Hultquist responded. “One thing we'd like to learn through the trial, would be, what kinds of notifications are most effective” in getting customers to switch to IP services. The goal is to reach customers who are the last adopters of new technology, he said. When a customer moves from POTS (plain old telephone) to VoIP, they had been previously subscribed to basic LEC, long distance, maybe caller ID and various other features, he said. “In the voice over IP world, all of that is flat,” he said. “There’s no long distance, you don’t pay extra for Caller ID. I think what we're moving to is a simpler set of services."

'Complementary’ Petitions

The IP transition petitions set forth by AT&T, USTelecom and NTCA are “complementary,” panelists from each organization agreed. NTCA’s petition, which seeks “smart regulation” that retains consumer protections while jettisoning regulations that have limited applicability in an IP world (CD Nov 21 p10), “could fit together” with AT&T’s petition, which is “largely a process one,” said Michael Romano, NTCA senior vice president-policy. AT&T looks at wire centers and proposes a “bottoms up” review, whereas NTCA starts from a “tops down” approach that would peel off unnecessary regulations, he said. “There’s a potential for complement within the petitions, but there’s some definition that needs to be fleshed out."

USTelecom’s petition, which seeks an FCC finding that ILECs are no longer “dominant” in voice service over switched networks (CD Dec 20 p3), is more “backward-looking” than AT&T’s petition, said Glenn Reynolds, USTelecom vice president-policy, but it has important implications for deployment of IP networks throughout the country. “Well over half of Americans never, or rarely, use a wireline telephone,” Reynolds said. It’s “impossible to conclude” that ILEC switched access services remain capable of exercising monopoly power, he said, yet they are still subject to “more onerous” tariffing and Section 214 obligations than any competitor.

CompTel is “not opposed to the trials,” said senior vice president-government relations Alan Hill. But next generation facilities must preserve the “critical rights” of interconnection and last mile access, he said. The FCC must confirm that Session Initiation Protocol interconnection and the obligations in Sections 251 and 252 of the Telecommunications Act still apply, he said. A change in technology doesn’t change the fact that competitors face barriers to entry, he said: Despite billions of dollars invested in infrastructure by CompTel members, they still can’t match the cost structure enjoyed by the incumbents. They also don’t have the same history of municipal rights and access to ducts and conduits, he said. “You need a pro-competitive, modern, last-mile access policy."

"We see the value in doing that sort of test” that AT&T seeks, said NCTA Vice President Steve Morris. But it’s important to consider “the effect of that transition on other providers,” he said. If AT&T transitions all its customers to IP, and all the cable operator’s customers are on IP, “it would be really good if those companies could exchange traffic in IP format,” Morris said. “But that’s not what AT&T is proposing, and we think that’s a bit of a lost opportunity if that’s the case.” To spend all this time and effort to convert TDM services to an IP network, but then exchange traffic with cable in TDM, which the other side then converts to IP to deliver to its customers, “seems very inefficient,” he said.

A “great, enormous frustration” with the FCC is that it’s working on a case-by-case basis, and has not said definitively whether VoIP is a telecom service subject to Title II, or an information service, said Ramsay. AT&T wants to substitute a service currently subject to several state oversight requirements with one that it says in its petition “is not subject to any of the state oversight, and an indeterminate amount of federal oversight, because we don’t know how far ancillary jurisdiction will go,” he said. The FCC should classify VoIP one way or another, he said: If the commission wants to classify it as an information service, “and they feel like they can take that to court and make it stick, please do so because then we know what framework has to apply."

AT&T’s petition “provides us with an opportunity to take a fresh approach,” said Public Knowledge Senior Vice President Harold Feld. But any approach to the IP transition must give consumers recourse when they have complaints about poor service quality, or overcharges, he said. As Title II services fall by the wayside, he asked, what will happen to rules regarding customer proprietary network information or truth in billing, which consumers depend on? “If you want to tell me we can do this without Title II, okay, fine I'm willing to listen,” he said. “But please don’t tell me that because I refuse to do Title II for VoIP, that therefore consumers are not entitled to protection anymore."

Public Knowledge is “not averse to trial runs, but AT&T needs to be very specific about what they're looking to do,” Feld said. “What is the trigger to pull the plug if things start to become very problematic? We're talking real people, real lives here. … If problems start to emerge, there has to be a way to scale back, and revert back to the traditional phone offering.” Feld hopes there will be consultations at a state and local level to make sure “these things are watched very carefully to make sure they do not spin out of control.”