AT&T Says Its IP Transition Trials Will Yield Answers CLECs Seek
AT&T doesn’t have all the answers about how its proposed IP transition trials will affect consumers, but finding those answers is the whole point of its wire center trials, it said in FCC reply comments Friday. The telco was responding to criticism by CLECs, consumer groups and state commissions that its IP transition trial proposal was vague on key points, including assurances of continued availability of wholesale access when the copper is removed (CD April 2 p6). CLECs reiterated those concerns in their own reply comments Friday, and public interest groups challenged AT&T’s designation of certain portions of its proposals as “confidential.”
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"Their apprehensions are understandable,” AT&T said of the CLEC naysayers (http://bit.ly/1qJ3KAo). “Change, particularly changes in technology and services on which consumers have relied for more than a century, always will cause some anxiety. But these concerns do not provide a basis for rejecting AT&T’s proposed wire center trials.” AT&T doesn’t have an answer to every question posed by the IP transition, but “that is the point of the trials,” the telco said. “If we had all the answers, there would be no reason to conduct a trial."
AT&T framed what it saw as the chief complaint raised by commenters: Because some of AT&T’s IP-based replacement services are still in development, they cannot fully evaluate the impact of the trial on consumers. “AT&T’s proposed trials will provide a forum for addressing these questions and concerns,” and concerns over service quality, AT&T’s plans for serving low-income consumers, and the reliability of next generation services, it said. It’s important that the commission not “pre-judge” whether all the features and functions of TDM must be replicated in an all-IP world, AT&T said. “IP networks enable a variety of new services, features, functions and capabilities that will benefit consumers, and the economy as a whole,” it said. “The transition to all-IP networks and services necessarily will entail trade offs, and, in evaluating whether the transition is in the public interest, the Commission must consider whether the benefits outweigh any difference or purported diminution in features, functions and capabilities."
Several CLECs said they're concerned AT&T’s proposal is flawed, and unlikely to generate “accurate and meaningful data” about the impact of the TDM-to-IP transition (http://bit.ly/1n1rKRM). The proposal doesn’t include wire centers that encompass sufficiently diverse geographic areas, customer types and demographics, said Cbeyond, Comptel, Integra Telecom, Level 3 and tw telecom. Nor does it provide sufficient information on the types of data to be collected, metrics to be used or potential control groups, the CLECs said. “AT&T’s proposal must be changed in terms of experiment design and data collection if it is to yield any reliable and statistically significant information about the effects of the transition on customers in the AT&T territory.” Such changes should include more “appropriate” procedures to select statistically representative wire centers, and getting independent third-party verification of the data collected, they said.
"The AT&T Proposal does not comply with the requirements” in the IP transition order, XO said (http://bit.ly/1kenegd). Too many details of its experiment are “to be determined” with regards to wholesale services, the CLEC said. Similar comments in the docket “provide a road map for areas that need to be addressed” before AT&T’s proposal could be “of any real use” to the FCC, the public and the industry, XO said. XO also took issue with existing wholesale IP-based alternatives. Those are “inadequate substitutes for many of the wholesale inputs currently available to competitors,” XO said, echoing other CLECs.
Public Knowledge and the National Consumer Law Center challenged AT&T’s designation of certain portions of its proposal as confidential (http://bit.ly/1hyXnQz). The public interest groups challenged AT&T’s claims to confidentiality over the timeline of its proposed trials, and over the percentages of the population of Carbon Hill, Ala., that will have access to wireline or wireless services under the trial. The timeline for the trials is “critical to assessing the public interest aspects of the proposed trials,” the groups said. The percentage of Carbon Hill residents with access to a wireline broadband alternative, or LTE wireless service, should not be treated confidentially because AT&T has already disclosed this information to the media, they said.