Earlier this week we noted that Iowa Network Services was the first and only company to propose an experiment to enable the FCC to evaluate how the industry will be affected by the transition from the current Time Division Multiplexing (TDM) network to one based on Internet Protocol (IP).  Since that time, there has been a flurry of proposals by various companies. However, there is only one proposal that is so detailed that it effectively lays out on a service-by-service basis the end of the TDM network by 2020. That is the proposal filed on February 27, 2014 in FCC Docket 13-5 by AT&T, which will evaluate the transition to IP in the wire centers of Carbon Hill, Alabama and West Delray Beach, Florida.

These communities were purposely selected to test how the IP transition will affect so-called “outlier” communities, since Carbon Hill is very rural and West Delray Beach has a large number of elderly residents. Thus, the experiment will provide a real world look at how the IP conversion would impact residents that it is speculated would be most resistant to change.

It is important to note that the experiment does not try to resolve or impose policy solutions on such thorny issues as how carrier interconnection will work in an IP environment, since the Commission is on the record as stating that policy issues will be resolved in other proceedings. However, for industry competitors and customers of AT&T, the experiment is very significant because, perhaps for the first time, it illuminates a world in which Feature Group D (FGD) switched access is no longer available and special access circuits and unbundled network elements (UNEs) are replaced with services such as Ethernet. Here are more details:

During the first phase of the experiment, participation by end user and wholesale customers is voluntary, however, AT&T states that during this phase, it plans to grandfather existing customers, and offer only next generation wireless and wireline IP-based services for new orders. Ultimately, existing customers would also have to upgrade to such alternatives, but that second phase would not begin until after the Commission has evaluated results of Phase 1 and permits AT&T to begin the full IP transition. 

Specifically, AT&T notes that, regarding wholesale access services, it intends to pursue additional phases of these trials that would include the complete withdrawal of all TDM-based wholesale services. AT&T would eliminate these services by filing section 214 applications with the Commission, which is the process by which ILECs obtain FCC approval to discontinue services. AT&T has identified with considerable detail the interstate TDM wholesale services for which it plans on filing these applications.

AT&T affirms that it will continue to meet its wholesale obligations under Section 251(c) of the Act by providing UNEs through the first phase of the trial.  In the future, however, “wholesale customers will [only] have the opportunity to obtain bare copper loops and utilize their own electronics to provide high capacity services to their end user customers — TDM or IP or any other technology the wholesale customer desires to provision.”

Switched access FGD wholesale service will be replaced with an IP interconnection for the exchange of traffic to reach all AT&T end user customers. 

Special access services such as DS1 and DS3 will be replaced by AT&T Switched Ethernet Service described as a service “for customers with multiple locations in a metro area with a variety of configurations to meet the customer’s needs with flexibility to grow and adapt as the needs change.”

AT&T’s description of product changes is detailed over 150 pages in Appendix E of its proposal. Although some key information about the number of customers affected is redacted, it is well worth it for everyone in the industry to read to get a clear idea of how they will be affected in the transition to the IP network.   Moreover, with switched and special access phased out over the next few years, it illustrates starkly the importance of interconnection in the IP world, with negotiated interconnected agreements obtaining supremacy in importance over tariffs. Thus, all carriers, for their own sake, better have a clear idea of their future wholesale needs and make plans to participate as the Commission determines the new rules for interconnection.

Industry comments regarding the AT&T experiment are due at the FCC on March 31. Reply comments are due on April 10.  If the Commission signs off on it, the AT&T experiment could begin soon after.