As discussed in our blog dated 3/4/14 “AT&T Proposes TDM-to-IP Transition Trial,” AT&T has filed a proposal for a TDM to all-IP wire center trial in its Carbon Hill, AL, and Kings Point, FL, wire centers. Among other things, the proposal discusses in detail how wholesale customers will be affected by the trial. This includes the wholesale services and interconnection options that will be available and how the status quo ante on intercarrier compensation will be maintained.
Are Any Wholesale Carriers Operating In Those Wire Centers Today?
According to AT&T, non-affiliated carriers currently are purchasing wholesale services in both proposed test wire centers. In the Carbon Hill wire center, the bulk of the wholesale services purchased are either AT&T’s Local Wholesale Complete™ (LWC) commercial product or retail services for resale. However, some carriers are also purchasing DS1 special access circuits “for what appears to be wireless backhaul.” In the Kings Point wire center, the TDM-based products and services purchased are more diverse and encompass not only the commercial LWC product but also switched Ethernet services, legacy DSn-level special access services, unbundled network elements (including 2-wire voice grade loops, unbundled DSL capable loops, 2- and 4-wire digital loops, and DS-1 enhanced extended loops), and resold consumer and business retail services.
Will Wholesale TDM Services Still Be Available During The Trial?
During the first phase of the trial, participation by wholesale customers will be entirely voluntary. AT&T pledged that “[n]o customer will be forced to migrate to alternative services or products, or to alter its current wholesale arrangements with AT&T during the initial phase of the trials. In particular, the same wholesale customers that currently use AT&T’s network in these wire centers will continue to be able to do so during this phase of the proposed trials. There are no plans to change the types of wholesale access that customers who do not participate in the initial phase of the trial currently receive, or to alter the price or cost of that access.” AT&T said it would continue to meet its wholesale obligations under Section 251(c) of the Communications Act, including by making UNEs available through the current stage of the trial.
What If I Want To Participate In The Trial?
For companies that choose to transition to alternative technologies, AT&T has identified its Switched Ethernet (ASE) service as a alternative to the current TDM DSn-level special access services and high capacity loop and transport UNEs. (AT&T claims that its ASE service provides significantly higher, and scalable, bandwidth than the legacy TDM DSn service it replaces.) Wholesale customers will also have the opportunity to obtain bare copper loops and utilize their own electronics to provide high capacity services to their end user customers
AT&T said it is “working diligently to develop IP replacement services, which it intends to make available for resale to wholesale customers on commercial terms. AT&T’s objective is to complete those development efforts, as well as those aimed at developing an IP-based alternative to the LWC product, as soon as possible, although it is likely the final commercial products will not be available until the trials already are underway.”
What Interconnection Arrangements Will Be Available?
AT&T said that, during the first phase of the trial, no changes will be made to the interconnection arrangements necessary to carry traffic to and from either the embedded base of TDM customers or the customers electing to participate in the trial by utilizing either U-verse Voice or Wireless Home Phone service. The interconnection arrangements already in place to terminate traffic to AT&T’s VoIP voice customers or to its Wireless Home Phone customers will continue to be used for customers subscribing to the IP replacement services, albeit with differences in call routing. AT&T asserts that these changes in call routing are “nothing new because customers already are utilizing these existing trunking arrangements outside of the trials, and thus these types of changes in trunking and routing arrangements exist in the marketplace today without raising any issues. And AT&T’s proposed trials will not negatively affect that status quo.” AT&T also said that “any changes in costs associated with changes in these routing protocols already are being captured in the market” and that there “should be no material cost impact on interconnecting carriers attributable to this phase of the trials.”
Will The Trial Impact The Selection Of An IXC Or The Termination of Interstate Traffic?
AT&T said that retail customers who voluntarily choose to participate in the trials (and thus subscribe to either Uverse Voice or Wireless Home Phone) will not select a separate IXC to carry long distance calls. AT&T said that, “assuming it is even technically feasible, imposing such a requirement on these IP-based services would be prohibitively expensive and fundamentally at odds with the “any distance” nature of IP services themselves…Constraining those tests with anachronistic concepts rooted in discrete markets for local, intraLATA, interLATA and interstate traffic that no longer reflect customer preferences and marketplace conditions would be counterproductive.”
AT&T also said its trials would have no effect on how IXCs terminate interstate interexchange or international calls to customers participating in the experiment. Any such calls will continue to be routed to U-verse Voice and Wireless Home Phone customers as they are today.
How Will The Trial Affect Intercarrier Compensation?
AT&T pledged that will maintain the intercarrier compensation status quo ante in accordance with the FCC’s Access Charge Reform Order, including the transition to bill-and-keep in the two wire centers. As such, AT&T’s VoIP and Wireless Home Phone services will remain subject to the existing intercarrier compensation regimes for VoIP-PSTN or CMRS traffic, as appropriate. Intercarrier compensation revenues and obligations would change only due to customers’ shifts between services subject to different intercarrier compensation regimes rather than any impact from the trial itself (e.g., switching from wireline to wireless service.)
Interestingly, AT&T said it “does not and will not as part of the trial charge subscriber line charges (“SLCs”) or access recovery charges (“ARCs”) on VoIP or Wireless Home Phone services.”
As mentioned in TMI’s Blog dated 3/4/14, comments on the proposal are due March 31, 2014; reply comments are due April 10, 2014.
TMI’s Spring 2014 Telecom Regulatory Seminar & Workshop April 24 & 25