WTA Comments on IP Transition

Today, WTA filed comments responding to the FCC’s NPRM proposing forbearance of certain provisions of Section 251 that are currently imposed on ILECs.

WTA agrees with the FCC’s goal of accelerating the modernization of the telecommunications network by eliminating unnecessary impediments to the ubiquitous deployment of all-IP networks but is concerned that the proposal simply to forbear from applying two particular provisions of Section 251(c)(2) without reinforcing the remaining regulatory guardrails would do little to accelerate that process, and could actually be counterproductive to the FCC’s goal. Some of the larger ILECs demand that rural service providers, who have already upgraded to IP networks, interconnect with those larger carriers via TDM, thus imposing unnecessary (and rapidly increasing) costs on the rural service providers, as well as reducing the larger ILECs’ incentives to upgrade their networks to IP.

WTA believes that the FCC can address this problem by strengthening the current guardrails on the good faith negotiations that all LECs are required to engage in. WTA suggests some actions that could be deemed evidence of a lack of good faith in interconnection negotiations, and urges the Commission to issue a Further NPRM to flesh out and adopt appropriate regulations.

And while the IP interconnection issues raised in this proceeding are one element of the regulatory framework for IP implementation, there are also a large number of outstanding related issues that WTA urges the FCC to address in a holistic and coordinated manner.