An Update on the Transition to an All-IP Network

Overlay network diagram: IP layer (Photo credit: Wikipedia)

I have closely been following the transition of the PSTN to an all-IP network. Every client of CCG who has any voice traffic on their network will be affected by the changes made in that order.

On November 19 the new Chairman of the FCC, Tom Wheeler published a blog talking about his goals for this transition. In his blog he says that he is expecting that in January the FCC will vote on an Order for Immediate Action.

Chairman Wheeler laid out some expectations for the new transition to IP. He is referring to it as the Fourth Network Revolution. Rather than summarize what he said., I quote from his blog:

 “That Order should include recommendations to the Commission on how best to: (i) obtain comment on and begin a diverse set of experiments that will allow the Commission and the public to observe the impact on consumers and businesses of such transitions (including consideration of AT&T’s proposed trials); (ii) collect data that will supplement the lessons learned from the experiments, and (iii) initiate a process for Commission consideration of legal, policy, and technical issues that would not neatly fit within the experiments, with a game plan for efficiently managing the various adjudications and rulemakings that, together, will constitute our IP transition agenda.”

The following day the Technology Transitions Policy Task Force issued a statement

the following day giving interested parties instructions on how to meet with the Task Force to supply input.

I get asked by a client every few weeks about the IP transition. I think the Chairman’s blog makes it clear that the process is just starting and that we are at least several years away from getting the process started. The FCC is now looking at a goal of having such a transition fully implemented by 2018

If the FCC approves the Order for Immediate Action this will authorize the start of a few trials of the IP network. Expect such trials to be between AT&T, Verizon and a few large carriers in just a few markets. Even in those markets it is unlikely that they will want smaller carriers to take part in the trials.

As I have discussed earlier, CCG is very much in favor of the transition to an all-IP network as long as making the change doesn’t trample the rights of our many CLEC clients. Probably the most important right that a CLEC has today is the ability to interconnect with the incumbents at any technically feasible location. This right was established by the Telecommunications Act of 1996 and it is vital that this transition does not change this provision. We fear the large incumbents will use this as an excuse to force everybody to meet them at large statewide or regional IP POPs, at the CLEC’s cost. Such a change could greatly increase the cost to CLECs of interconnection.

We are also concerned that a change to an all-IP network will be an excuse for the RBOCs to try to get out of the historical practice of interchanging local traffic on a bill and keep basis. Historically the calling patterns from rural areas are that they send a lot more traffic to urban areas than what they receive. If such traffic must be brought to IP POPs at the ILEC’s cost or if such traffic becomes subject to transit traffic the costs to rural ILECs will increase tremendously.

CCG plans to file comments on these two issues with the FCC in this Docket and any of our clients interested in these two topics should let us know if you have any other specific concerns.

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