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Comptel, CLECs Protest AT&T's IP Transition Trial

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4/10/2014
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WASHINGTON, DC – COMPTEL, the trade association for the competitive communications industry, today joined with service providers Cbeyond Communications, LLC, Integra Telecom, Inc., Level 3 Communications, LLC, and tw telecom inc. to urge the Federal Communications Commission not to approve AT&T’s proposed technology transitions experiments in Carbon Hill, Ala., and Kings Point, Palm Beach County, Fla. without significant modifications. In a letter filed at the Commission, they noted AT&T’s proposal lacks critical information needed to conduct a meaningful review and, because of the specific wire centers targeted, the experiments will not generate the type of data necessary to fully understand the impact of the TDM-to-IP transition on residential, business and wholesale customers.

“In its own comments about service-based experiments proposed by other parties, AT&T noted that the FCC shouldn’t move forward unless the applicant can provide sufficient information to determine whether the experiment ‘ensures universal connectivity, consumer protection, public safety, reliability and competition’ and ‘will indeed provide the Commission with useful information concerning the IP transition,’” said Angie Kronenberg, chief advocate and general counsel at COMPTEL. “We agree, and, in this case, believe that AT&T has not provided the evidence necessary to show that its trials will provide the needed insight into how the natural evolution to IP technology will address the needs of wholesale customers, as well as retail consumer and business users.”

Of concern to COMPTEL and the service providers is the lack of detail about the replacement services AT&T will be make available to wholesale customers during the experiment and the timeline for enhancements to the replacement voice services that will be made available to residential and business customers. Additionally, they noted that the proposal does not provide any information about the rates, terms and conditions on which replacement services will be offered to wholesale customers during the experiment as required by the Commission’s January Order.

Without these important details, the commenters noted that AT&T’s proposal “precludes wholesale customers from conducting the business planning necessary to serve their retail customers, including small and medium-sized businesses. It also fails to ensure that, consistent with the Experiments Order, packet-based replacement inputs will be offered at rates, terms, and conditions equivalent to those currently offered for TDM-based unbundled network elements and special access services.”

The comments provided by COMPTEL and the service providers include a declaration by Joseph Lenski of Edison Media Research Inc., who evaluated AT&T’s proposal based on the basic tenets of experimental design and offered recommendations on how the experiments should be altered to ensure that reliable and statistically significant information is attained.

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