AT&T (NYSE: T) has joined the growing chorus of ILECs that say requiring them to give wholesale customers a year-plus notice before they discontinue service will delay the IP transition.
A number of CLECs and competitive industry groups such as XO and INCOMPAS have asked the FCC to mandate that an ILEC provide advance notice to a wholesale carrier customer when they plan to discontinue a TDM-based service.
INCOMPAS (previously known as COMPTEL) told the FCC that "incumbent LECs should be required to identify their replacement product(s); provide sufficiently detailed notification to wholesale purchasers with regard to the discontinuance of service and replacement product(s); have an active functioning replacement product; and allow for sufficient time for competitors to perform all necessary functions for transitioning customers -- at least one year -- prior to filing an application with the Commission."
Likewise, Preferred Long Distance (PLD) has asked that the ILECs should be required to provide notice to and work with wholesale customers at least 18 months before filing application to discontinue TDM-based services.
XO, which has an extensive and growing fiber network, has advocated that while it does not want to hinder the ILEC community's move to retire copper and TDM facilities and replacing them with fiber and IP, it said the the limited 90 days' notice could potentially leave one of its retail business customers without service.
Similar to Verizon, AT&T said in a FCC filing that proposals to extend the review process to discontinue services would hinder its and other telcos' IP service investments by forcing them to maintain more legacy TDM services.
"These proposals would needlessly delay ILECs' discontinuance of legacy TDM services, forcing them to expend significant resources to maintain existing facilities and services simply to meet the purported needs of their competitors, resources that could be used to develop and deploy the innovative services consumers actually want," AT&T said. "The CLECs and others demanding lengthy notice requirements are large and sophisticated customers that have been on notice for years that ILECs are planning to complete the transition from TDM to IP services and decommission obsolete TDM networks."
AT&T added that besides having ample notice when ILECs would shut down TDM-based services, wholesale CLEC customers have multi-year contracts that ensure service won't be inadvertently turned off.
"These customers typically purchase service pursuant to multi-year contracts, which provide them all the stability they need and ensure that ILECs cannot pull the rug out from under them," AT&T said. " In any event, AT&T (and undoubtedly other ILECs as well) values its wholesale and other large business customers, and has every incentive to retain their business following the IP transition. ILECs thus have compelling business reasons to ensure these customers have adequate notice to transition to IP services."
- see this FCC filing (PDF)
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