ILECs Face Fierce Debate on IP Interconnection, FCC Trial Replies Show
The larger ILECs sparred with smaller companies and associations in reply comments before the FCC this week on the proper classification of Internet Protocol interconnection agreements and how they should factor into any potential technology transition trials. AT&T argued against the need for IP interconnection trials, as did the joint filing from Verizon and Verizon Wireless. Verizon advocated for commercial negotiations of IP interconnection agreements, in contrast to the strong advocacy for the Communications Act Sections 251 and 252 oversight that the CLECs of Comptel backed in their reply comments posted Wednesday (CD Aug 8 p10), as did many other parties in comments posted Thursday.
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"Verizon has consistently demonstrated its willingness to negotiate and enter into IP interconnection agreements for VoIP traffic,” its filing said (http://bit.ly/18e14TC). “Claims to the contrary are false.” It sent eight invitations to negotiate IP agreements this year and is negotiating with “at least” eight providers, it said, citing its history with CLECs in Massachusetts, Sprint, T-Mobile and others who have raised the issue.
But Sprint wants “unequivocal direction to the state commissions that the 251/252 mechanism is always available to force compliance for those incumbent carriers and their affiliates that are reluctant to engage in IP interconnection” (http://bit.ly/13Rbm90). It also said VoIP interconnection trials are unnecessary given what it called the feasibility of creating such agreements. Sprint underscored the difficulties entities have had of forming agreements with the biggest ILECs and called the terms set by the ILECs likely “self-serving and onerous.” In joint comments (http://bit.ly/179Fy1h), NTCA-the Rural Broadband Association and the Western Telecom Alliance advocated for sections 251 and 252 oversight and argued against the case for fewer points of interconnection in the IP era. The Competitive Carriers Association didn’t comment on the trials at all, but simply asserted that these sections should apply in an IP environment (http://bit.ly/19ezpH1). It outlined the struggle smaller companies have had with ILECs. The American Cable Association hit the same points on the need for regulation of such managed VoIP agreements but dismissed the idea of VoIP interconnection trials (http://bit.ly/19QqP0q). T-Mobile also sought clarification of the status of IP interconnection (http://bit.ly/133Lr3c). It pushed for regional IP interconnection trials and pointed to the need for “a regulatory arbiter for IP interconnection disputes during the trial,” shown by the record, without prejudging the legality of sections 251 and 252.
NARUC also emphasized the need for such oversight in its reply comments (http://bit.ly/1evqRsf). It said the FCC should classify managed VoIP as a telecom service and clarify IP interconnection ambiguities. It advocated for the key balance between state and federal authorities in conducting the trials and said the decision on them should be referred to the Federal-State Joint Board on Universal Service.
AT&T urged trials akin to what it proposed last November and disputed what it called the CLECs’ belief that AT&T only wants “a regulation free zone.” It argued the trials will show that “legacy regulation is unnecessary and, indeed, affirmatively harmful to consumers and competition.” The IP transition is “unstoppable,” AT&T said (http://bit.ly/18dXM2U), noting broad support for trials. “Geographically limited IP trials will provide the Commission, industry, and consumers invaluable real-world experience regarding the challenges of discontinuing TDM [time-division multiplexing] technology and services on which many Americans still rely even as many others already have made the switch to next-generation wireless and IP-based services,” the telco said. It called commenters’ concerns that replacement services may not be as reliable “fair questions,” if not a reason to reject the prospect of trials. They should present “a forum for identifying the types of operational, technical and logistical issues,” all while the “TDM safety net is still in place” overall, it said. On the trials, Verizon warned of “potential downsides, including diverting resources away from the technology transition itself and undermining consumer-driven initiatives that are already well underway.”
Parties raised many concerns about what purposes the trials should serve. Public Knowledge said the trials should serve and benefit consumers and urged the FCC to put trial proposals out for public comment (http://bit.ly/17Aigk3). It pointed to Verizon’s Voice Link service as well as rural call completion problems as evidence that transitions do not always yield better service. “With more moving parts, an all-in-one trial creates a higher risk that the causes of any unforeseen problems will be difficult to identify and fix,” PK said, saying the trials should inform policy, not set it. Free Press cautioned against “AT&T’s preferred path of destructive deregulation” and wants the FCC “to clarify, before moving forward with any trials, that IP-based networks and IP-enabled telecommunications services are governed by Title II,” it said (http://bit.ly/1evtytO). NTCA-the Rural Broadband Association and the Western Telecom Alliance backed “well-defined and carefully structured technical trials that examine service and interoperability issues, as opposed to the use of purported ’trials’ as a tactic to eliminate existing regulatory obligations or pre-judge pending or future regulatory issues.”