In response to the January 31, 2014 Order in Docket 13-5 in which the FCC announced that it would conduct a variety of experiments and data collection initiatives that would allow it 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), the first company to seek permission for such an experiment is Iowa Network Services (INS).

INS was formed in 1988 by a group of more than one hundred independent telecommunications companies that came together to provide centralized equal access (CEA) service throughout the state, providing rural Iowa residents access to a variety of long distance carriers for the first time.

INS will conduct the experiment to not only to study the impact on customers and rural communities as it converts its voice communications CEA service from a network based on TDM to a network using new IP technologies, but also to explore whether IP CEA can economically advance and accelerate IP conversion for the more than 140 rural LECs currently connected to INS' centralized platform, just as TDM CEA did for rural LEC equal access conversion.

The IP CEA experiment will involve three phases:

1. INS will perform IP to TDM conversion at its tandems in Des Moines. In this phase, INS will solicit voluntary IP interconnection by IXCs, wireless carriers, VOIP providers, and CLECs with INS' CEA network for both originating and terminating traffic that INS would convert from IP to TDM. INS would charge the same CEA rates that it does for other CEA traffic, consistent with the Commission's requirement that current inter-carrier compensation arrangements be maintained.
2. In the second phase, the traffic would be all-IP between IXCs (and other service providers that volunteer to participate in the experiment) and the LECs' switches that connect with INS' network on an IP basis.  INS would charge the same CEA rates that it does for other CEA traffic.
3. In the final phase, INS would test all-IP facilities from the originating end user located in a LEC's exchange subtending INS' tandems to the IXC selected by that end user (IP equal access) and, ultimately, to the called party located in the exchange of a second local exchange subtending INS' tandems. There would not be any IP to TDM conversion involved in this final phase. INS would charge the same CEA rates that it does for other CEA traffic. INS would identify subtending LECs, end users, and IXCs that would agree to participate in this final phase.

The IP CEA experiment would be completely voluntary for existing customers. 

It is interesting to note that the Commission’s request for companies to propose TDM-to-IP experiments is off to a surprisingly slow start. Proposals were supposed to be filed by February 20. However, INS is the only company to respond so far. AT&T is expected to propose at least one experiment, but to date, it has not done so.

If other companies do not step to the plate soon, the Commission will probably be forced to require certain companies to conduct IP transition experiments. How it would select the companies is anyone’s guess. 

By Andrew Regitsky, President, Regitsky & Associates