COMPTEL recently submitted comments to the FCC, with regarding the “AT&T Proposal for Wire Center Trials.” Although these trials only impact two wire centers, AT&T claims that its trial will replicate on a small scale the broader TDM sunset and migration to all-IP networks and services.
COMPTEL’s comments identified the gaps and deficiencies in AT&T’s proposal as it applies to the wholesale consumers. It mentioned a wide range of concerns, including lack of comparable Ethernet services and equipment, limited assigned phone numbers per port, significantly higher costs of alternative Ethernet product, and reduced quantity of assignable telephone numbers for AT&T’s comparable Ethernet product.
One more issue COMPTEL should have addressed is that AT&T’s proposal would have profound effects on how Competitive Communications Service Providers design their leased TDM networks. Although COMPTEL mentioned the Competitive Communications Service Providers frequently establish DS3 multiplexes to support multiple DS1 circuits, these carriers generally purchase DS3 transport components from other Competitive Carriers instead of leasing all DS3 network components from AT&T to minimize access charges.
It is not practical for Competitive Carriers to split access networks between other carriers and AT&T for delivering Ethernet service due to its rate structure. Thus, the cost of TDM transition will be far greater for Competitive Carriers and their customers than indicated by COMPTEL cost analysis. Additionally, there will be a large drop in Competitive Carriers’ revenue from selling DS3 transport services to other Competitive Carriers.
A mass scale TDM sunset and migration to all-IP networks and services, as AT&T plans today, will lead to cost increases for wholesale and retail customers. This transition will also eliminate a large portion of the revenues that Competitive Carriers receive from other Competitive Carriers. Finally, this change will result in fewer competitions and product choices.
If FCC’s goal is to maintain competition and provide choices for consumers, it needs to ensure AT&T develops a truly comparative service to TDM service that it plans to eliminate. Any comparative service that AT&T develops should not only meet pricing, terms, and conditions of TDM services, but also address impacts on Competitive Communications Service Providers that is based on how TDM access networks are set up today.