The National Broadband Plan viewed the transition to all-IP networks as a critical step to nationwide broadband deployment. Local wireline networks have lagged in this transition. In its “Petition to Launch A Proceeding Concerning the TDM-to-IP Transition” filed on November 7, 2012, AT&T requests the FCC grant local exchange carriers the option to conduct “trial runs of the transition to next-generation services, including the retirement of . . . [TDM] facilities and offerings and their replacement with IP-based alternatives.” AT&T is looking to eliminate regulations it believes impede this transition or extend legacy telecom regulation to the all-IP services environment. On the same date, AT&T announced “Project Velocity IP”, a series of multi-billion dollar investments intended to deliver broadband (either wireline or wireless) to all customers served by its legacy local telephone networks.
In many respects, AT&T is looking for deregulation (classifying most, if not all, IP services as information services, not extending carrier interconnection obligations to IP services, etc.) and preemption of state regulation, including carrier of last resort (“COLR”) obligations. A more conservative proposal for regulatory flexibility to support the migration to all-IP networks for local exchange carriers was offered by the National Telecommunications Communications Association. The two petitions diverge on multiple points, including interconnection obligations of ILECs with regard to IP traffic.
Not surprisingly, most competitors to AT&T (for local and interexchange services) opposed multiple aspects of its proposal. The adverse impact of a rapid migration to an all-IP network on the Nation’s air traffic control network was highlighted by Harris Corporation. Verizon offered vigorous support for AT&T’s petition. A large corporate user group opposed AT&T’s deregulatory proposals, arguing that AT&T and other price cap ILECs remain dominant in the local exchange and access services markets. Sprint supported the more measured suggestions offered by NTCA.