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AT&T Files Petition for Rulemaking Regarding Trial Replacement of TDM with IP

November 7, 2012. AT&T filed a petition for rulemaking [28 pages in PDF] with the Federal Communications Commission (FCC) regarding allowing incumbent local exchange carriers (ILEC) to replace time division multiplexed (TDM) with internet protocol (IP) facilities in select wire centers.

AT&T's Bob Quinn stated in a release that "We are asking for a proceeding and a beta trial to address all of the policy, technology, technical and operational questions that must be addressed to complete the transition away from the legacy TDM infrastructure".

He added that "Our plan will be to do our very best to provide our customers with services built on an IP broadband architecture.  And for those few we cannot reach with a broadband service, whether wireline or wireless, they will still be able to keep voice service."

In conjunction, AT&T announced plans to invest an additional $14 Billion over three years in its wireline and wireless networks. See, related story in this issue titled "AT&T Announces Additional Investment in Its Wireline and Wireless Broadband Networks".

Federal Communications Commission (FCC) Chairman Julius Genachowski stated in a release that "As we review AT&T's filing, we will focus on the principles that have guided our actions since I became Chairman: driving the virtuous cycle of private investment and innovation in the broadband ecosystem, promoting competition, and protecting consumers."

This petition states that the FCC should "eliminate, within the trial wire centers, outdated ``telephone company´´ regulations that may require carriers to maintain legacy TDM-based networks and services even after replacement services are in place."

This petition also states that to the extent that VOIP replaces legacy circuit switched telephony in the trial wire centers, the FCC should "preclude carriers (including carrier customers) from demanding service or interconnection in TDM format in those wire centers." (Parentheses in original.)

This petition also states that the FCC should "implement reforms to facilitate the migration of end-user customers from legacy to next-generation services", and "prevent a few customers from delaying that transition, as happened in the transition from analog to digital television and in the sunset of analog cellular services".

This petition also states that the FCC should "keep IP services free of legacy regulation so that the trial may proceed without the distorting and investment-chilling effects of such regulations".

This petition also states that the FCC should use it waiver and forbearance authority, and "preempt any state regulatory obligations that would interfere with these experiments or subvert ... a smooth and rapid transition to the all-IP broadband environment of tomorrow".

(Published in TLJ Daily E-Mail Alert No. 2,470, November 6, 2012.)