WTA Discusses IP Transition with FCC

Last week, in conjunction with the FCC’s IP Transition Workshop, representatives from WTA and its member companies met with staff from the office of Chairman Carr and Commissioners Gomez and Trusty to discuss WTA’s filed comments in the pertinent proceedings.

WTA explained how all of the FCC’s proceedings regarding the IP transition are interrelated and emphasized that they should be addressed in a holistic fashion to ensure there is a smooth transition to all-IP networks without any adverse effects on rural customers. With regard to the IP Interconnection and Intercarrier Compensation (ICC) proceedings, WTA indicated that ICC was not the reason for IP transition delays, as the fact that 80% of WTA’s members have initiated or completed the transition to all-IP networks demonstrates. One of the significant reasons for complete transition is that PSAPs and access tandems still requiring TDM. Another is that ISPs will incur significant costs, some of which will be ongoing, before it realizes any savings from transitioning to an all-IP network.

WTA suggested a three-tiered deadline for completing the transition – three years for the largest ILECs, five years for mid-sized ILECs and seven years for small ILECs. Moreover, as an over-arching principle, the FCC must keep in mind that Congress directed the FCC in Section 254(b)(3) of the Communications Act to ensure that rates and services in rural areas are reasonably comparable to rates and services in urban areas.

A representative notice of ex parte can be found here.