With the Federal Communications Commission proposing a streamlined process for migrating legacy, copper-based voice services to newer IP-based infrastructure, incumbent telcos including AT&T (NYSE: T) and CenturyLink (NYSE: CTL) are hoping to guide that process a bit.
Representatives from both providers met with legal advisors for the FCC commissioners last week to discuss the regulator's Further Notice of Proposed Rulemaking, titled "Establishing Clear Standards to Streamline Transitions to an All-IP Environment."
AT&T argued in an ex parte that adjustments need to be made to network performance requirements within the proposed rule update, specifically regarding latency -- because, it says, alternative services like wireless voice and VoIP (voice over IP) can't reach the 100 millisecond threshold currently used by the FCC in determining eligibility for CAF II support for IP-based broadband buildouts. For the updated transition standards, "any such requirement should be no lower than 200 ms mouth-to-ear," the provider said.
The Tier 1 carrier added that 100 milliseconds should not be the threshold in Network Performance criterion for approving a 214 discontinuance of legacy voice "because the 100 ms threshold cannot be applied to wireless voice services." What's more, AT&T noted, consumers are "very satisfied" with VoIP call quality at average latencies of 200 ms, according to ITU Standard G.114; and millions of Americans "have already replaced POTS services with wireless voice."
AT&T has a keen interest in streamlining requests to discontinue legacy voice services: the carrier recently began trials for TDM-to-IP transition in two Southeast locations, Carbon Hill, Alabama, and Kings Point, Florida, and has filed requests with the FCC to discontinue legacy services like analog video in these communities.
CenturyLink, in the meantime, said it wants the current IP transition rules to remain the same, saying that "additional criteria the FCC is reviewing in the context of discontinuances related to technology transitions should be limited to the streamlined process for discontinuing voice services. CenturyLink supports having the option of using the existing process in all circumstances. In addition, we explained that any showing of alternative services should only cover areas where we have actual customers."
The telco also used its meeting time to get in a few more digs at the commission's ongoing BDS (business data services, or special access) rules revision. "We explained that the application of 'catch-up' and 'going forward' annual productivity factors would be inappropriate, especially in light of declining incumbent LEC network utilization," CenturyLink said in an ex parte published Friday.
What's more, the provider reiterated that the FCC needs to take a second look at the capabilities of cable MSOs that operate within CLEC footprints. "…recent revelations regarding cable providers' responses to the Commission's data request show that many cable companies were, in 2013, capable of providing Metro Ethernet service far more broadly than originally thought. This shift has dramatic implications for these proceedings, and the agency must account for the new information in conducting any competitive market analysis."
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