AT&T has filed a proposal for a TDM to all-IP wire center trial. Comments on the proposal are due March 31, 2014; reply comments are due April 10, 2014.
The proposal, which contains a Wire Center Trial Operating Plan (Plan) identifies the geographic areas in which AT&T will conduct the trial, the specific TDM-based services that ultimately will be discontinued, the wireless and wireline IP-based alternatives that AT&T will offer, and other competitive alternatives available to customers in the test-bed wire centers. The proposal also includes information about how AT&T will notify customers about the transition and migrate them to alternatives and address the “enduring values” specified by the FCC. This includes how it will satisfy its eligible telecommunications carrier (ETC) obligations and address wholesale access, interconnection, and intercarrier compensation during the trial.
Where Will The Trial Take Place?
AT&T selected two wire centers: one is a rural wire center in Carbon Hill, AL (CLLI: CRHLALNM); the other is a suburban wire center in Kings Point, FL (CILLI: DLBHFLKP). AT&T said it chose these wire centers so it could gain insight into some of the more difficult issues that likely will be presented by the TDM sunset. Carbon Hill is a sparsely populated wire center located in rural Alabama with particularly challenging economic and geographic characteristics and may qualify for Connect American Fund funding. By contrast, the Kings Point wire center has a large population of older Americans that, as a group, have been slow to migrate to newer technologies.
Wire Center Summary 
Which Competitors Currently Offer Service In Those Wire Centers?
AT&T identified the following competitors in the Carbon Hill wire center: Charter Communications, Verizon LTE, Sprint 3G, T-Mobile 3G, HughesNet, Dish Network, and DirecTV. In Kings Point, AT&T identified the following competitors “among others:” Comcast Communications, Verizon LTE, Sprint 3G, T-Mobile 3G, HughesNet, Dish Network, and DirecTV.
What Are The Objectives Of The Trial?
The trial is designed to:- Provide a process and forum for identifying and resolving the operational, technical, logistic, and other issues that could arise when existing TDM-based networks and services are discontinued and the customers remaining on those networks have to transition to next-generation wireless and wireline IP-based alternatives.
- Help AT&T further develop and implement processes for migrating customers off of traditional TDM networks and services and onto all IP platforms. Specifically, AT&T hopes to learn understand how to actually operationalize this effort efficiently, so there is as little customer disruption as possible.
- Ensure that customers, manufacturers, policymakers, and other stakeholders have sufficient education and notice regarding the impending transition so that they also have the opportunity to prepare for the time when TDM networks and services no longer are available.
- Allow AT&T to develop an actionable plan it can utilize to continue this transition in its approximately 4,700 wire centers across the country in order to meet its stated goal of completing the IP Transition by the end of 2020.
AT&T said that, “[f]or the most part, current federal and state rules will not stand in the way of these trials.” However, it will “work cooperatively with federal and state policymakers to retire the circuit-switched and TDM services that have served this country for so many years.”
What Services Will AT&T Replace During The Trial?
AT&T proposes to replace the vast majority of the TDM-based services in the trial wire centers over the next three years. Existing customers will be grandfathered. New customers will be offered only next generation wireless and wireline IP-based services. Ultimately, existing customers will also have to upgrade to such alternatives, but that second phase will not begin until after FCC authorization is obtained.
The following services will be offered in place of AT&T’s consumer TDM-based voice and Internet access transport services: AT&T’s U-verse Voice service, AT&T’s U-verse High Speed Internet services, and AT&T’s Wireless Home Phone service and Wireless Home Phone and Internet service. Business customers within AT&T’s wireline IP network footprint will be offered a variety of IP-based business-class voice services that include next generation calling features, and a variety of business-class Ethernet services. AT&T said it is in the process of developing a wireless business phone product that will enable business customers in AT&T’s wireless footprint to use their existing CPE to communicate over AT&T’s wireless network.
Will All Devices and Services Be Supported?
AT&T said that the wireless and wireline IP-based services it will offer in place of traditional TDM-based services will support the vast majority of the devices and applications enumerated in the FCC’s Order. However, it does not currently plan to support certain applications with rapidly declining market demand or applications that are based on outdated technology such as operator services functions (both live operators and collect calling), dial around calls, third party pay per call, DVR services, and elevator phones. AT&T is also developing enhancements that will allow its Wireless Home Phone with LTE to work with analog data devices, such as alarm monitoring, medical alert, and credit card applications. AT&T said it would not seek to grandfather its TDM-based voice services until these enhancements are available.
How Will Carriers Be Notified About the Trial?
AT&T will notify business customers (both wholesale and retail) about the trials through its business customer account teams and sales agents, using the customers’ preferred method of contact. AT&T will inform them of its plans to grandfather and/or sunset existing TDM-based services and the IP-based wireline and wireless alternatives available to them and will assist them in developing a migration plan. AT&T will also send notification letters before it proposes to grandfather, and before it proposes to sunset, any business services. In addition, AT&T customer account and sales teams will contact each business customer semiannually to provide them information regarding the trials and to consult with them regarding their migration plans.
Will Wholesale Customers Have To Participate In The Trials?
Wholesale customer participation would be voluntary during the initial stages of the trial. AT&T said it had 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. However, it “intends to pursue additional phases of these trials that would include, with the Commission’s authorization through the Section 214 process, the complete withdrawal of TDM-based wholesale services.”
AT&T said it would continue to meet its wholesale obligations under §251(c) of the Communications Act, including by making UNEs available through the current stage of the trial. However, eventually it intends to not only withdraw its legacy TDM services but also retire the TDM electronics and other facilities used to provide those TDM services (and UNEs). Watch for our upcoming blog on wholesale issues.
How Will Switched Access Services Be Affected?
AT&T plans to discontinue its ILEC-provided TDM-based interstate and intrastate switched access services in the trial wire centers. AT&T intends to offer wireless and wireline IP-based services in place of traditional TDM voice services in the trial wire centers. For customers that transition to AT&T VoIP services, AT&T will exchange traffic to or from end users on another provider’s network through that provider’s existing interconnection arrangement with AT&T’s access tandem. For customers that transition to an AT&T wireless service, AT&T will exchange traffic to or from end users on another provider’s network through that provider’s existing interconnection arrangement with AT&T’s access tandem. To the extent a provider has direct interconnection arrangements with AT&T Corp. or AT&T Mobility, the traffic will be exchanged over the existing interconnection arrangements.
AT&T said it would not take any steps to grandfather or sunset switched access services until the replacement voice services are available. Watch for our upcoming blog on wholesale issues.
How Will Private Line And Special Access Services Be Affected?
AT&T also intends to grandfather, and ultimately withdraw, intrastate private line and interstate and intrastate TDM-based special access services in the trial wire centers. AT&T Switched Ethernet (ASE) service and several new services that are in development, will replace those TDM-based private line and special access services in the trial wire centers.
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