FCC's "All IP" Network Transitions Trials – What to Expect


At its January 30th Open Commission Meeting, the Federal Communications Commission  (FCC) voted to approve a petition AT&T had filed (in November 2012) to conduct trials of an “all-Internet Protocol (IP) network” that would eventually replace the PSTN and TDM networks now used extensively in the U.S.  The transition will be from plain Plain Old Telephone Service (POTS) delivered over 2 wire copper subscriber loops to feature-rich voice services using Internet Protocols, to be delivered over coaxial cable, fiber, or wireless networks. The TDM network that transports POTS and digital switched voice/data would be replaced by an IP based packet switched network.

The FCC press release on this initiative can be read here. The FCC says: “This is an unofficial announcement of Commission action. Release of the full text of a Commission order constitutes official action.”  But that FCC order has not yet been published.

Service Provider Trial Proposal Schedule and Requirements:

Described as a “set of voluntary experiments,” the FCC asked service providers to submit proposals for the IP transition trials. Such proposals are due by Feb. 20, 2014, followed by a public comment and reply period ending on March 31, 2014, with a final decision on the proposals to be made at the FCC’s May 2014 meeting.

The FCC’s evaluation of the trial proposals will be based on what it calls the “enduring values” underlying its stewardship of the nation’s communications networks:

  • Public Safety communications must be available, no matter what underlying network technology providers use;
  • Universal access so that all Americans must have access to affordable communications services;
  • Competition to ensure choices for consumers and businesses; and
  • Consumer protection: Service providers must accurately describe the terms on which they offer service and must treat consumers fairly.

The FCC hopes the trials will enable it to gather information in the following areas:

  • Service-based experiments: Providers are invited to submit proposals to initiate tests of IP-based alternatives to existing services in discrete geographic areas or situations;
  • Rural America: Experiments will focus on ways to deliver robust broadband service to rural areas. While most of the trial is focused on ILEC services, based on the news release and statements at the meeting, this component may permit competitive providers to obtain universal service funding to build broadband networks, separate from the “Connect America Fund” process under Section 254’s “Universal Service” mandate. The details of this aspect of the trial will be important, and will not be available until the formal order is released;
  • Disability access: Experiments will explore how to ensure that speech- and hearing-impaired Americans, and those with other disabilities, will continue to have access to quality communications services in an all-IP environment; and
  • Telephone numbering plan in all-IP network: a numbering test bed will address concerns raised about how to handle number assignment and the operation and maintenance of numbering databases (such as the local number portability database) in an all-IP world, without disrupting current systems.’
  • Data improvement including reform of the FCC’s consumer complaint and inquiry process to collect better data on how technological change is impacting consumer values.  Intergovernmental collaboration (state, local and tribal governments) is encouraged to better understand consumer impact. Collection and analysis of data on next-generation 911 systems in coordination with the U.S. Department of Transportation’s National 911 office and public safety associations.

The FCC stated, “The data gathered in these experiments will ensure that the ongoing public dialogue about technology transitions is based on solid facts and data. This discussion will guide the FCC as it makes complex legal and policy choices that advance and accelerate the technology transitions while ensuring that consumers and the enduring values are not adversely affected.”

What to Expect from the All IP Transition Trials:

In AT&T’s January 21st Notice of Ex Parte – IP Transition, GN Docket No. 13-5 a two stage process for service provider trials is described. In the first stage, participating carriers would file detailed plans that identify their existing TDM services, the IP network based replacements for those services; and when those IP networks would be available. As part of the first phase, the participating service provider would file petitions for authority to discontinue the affected interstate TDM based-service(s). After approval by the Commission, the provider would be permitted in the first phase of the trial to “grandfather” existing TDM services and allow existing customers to continue receiving those services, while permitting the carrier to fulfill all new orders for service in the relevant wire center using IP-based wireline and wireless alternative networks.

During Phase 2, the participating service provider could file a second application to withdraw the grandfathered interstate TDM services for existing customers. That application would identify how many customers remain for each TDM service to be discontinued and would provide a retirement plan, including the notice(s) to be provided to customers, the available wireline and wireless IP replacement services, and the timeframe for when the conversion of the wire center to all-IP services would be complete. Under this proposal, the FCC would have the opportunity to evaluate the results of the first phase of the trial before granting participating carriers approval to proceed with the withdrawal of TDM services for existing customers.

AT&T Reaction to FCC Sanctioned “All IP” Network Trials:

AT&T praised the FCC for moving forward with the IP transition experiments. The decision is “important and profound,” Jim Cicconi, AT&T Senior Vice President for External and Legislative Affairs, wrote in a blog post. “All Americans should applaud the FCC’s action, because all Americans, and generations yet unborn, will benefit from it.”

But AT&T will benefit a whole lot more. That’s because it would be alleviated of the burden of maintaining its POTs/PSTN/TDM network, which continues to lose subscribers with revenue steadily shrinking. In his blog post, Cicconi wrote, “The cost of maintaining the legacy architecture, with its rapidly declining subscriber base, was unsustainable for any company, and was pulling significant dollars away from broadband investment. That decline has only accelerated over the past fifteen months – AT&T’s consumer POTS access lines decreased from 15.7 to 12.4 million lines between 2012 and 2013, proving the truth of the FCC’s conclusions in stark numbers.”

Mr. Cicconi endorsed the FCC’s protection agenda by his closing comments:

“We need to make this transition in a way that preserves universal service, competition (including interconnection), public safety, network reliability and consumer protection. Chairman Wheeler has referred to this process as a Values Trial, and has stressed that our new IP communications system should reflect these underlying values as we transition to newer and better technologies. We agree, and are committed to work with the Commission and all other stakeholders to ensure that we preserve those values throughout this transition. We’re now embarking on a task that’s of vital importance to our Nation.  We have an obligation to do it right. And we will.”

Stay tuned for future coverage of this hugely important telecom transition initiative.


0 thoughts on “FCC's "All IP" Network Transitions Trials – What to Expect

  1. Thanks Alan for reporting on this very important meeting. Good summary of the discussion of the VoIP transition and implications.

    Thanks also for the reminder about the meeting. Listening to it live, I was impressed with the collegial atmosphere among the Commissioners.

    That they are replacing the Technology Transition Policies Taskforce, formed in December 2012, to the FCC Bureau and Offices is an indication of the maturation of the process. The way Wheeler put it, suggests a collaborative approach as they navigate the challenges of the PSTN to IP transition.

    “That’s why I have decided to replace the Task Force with a “mesh network” of Bureau and Office activities, including joint activities. Through this approach the Commission will enjoy the advantages of
    coordonation and leadership that the Task Force provided, while moving the work of the Bureaus and Offices to the front and center, where they belong.”


    1. Great summary of FCC’s Jan 30th meeting and superb follow on comment. What do you mean by a “collaborative approach..” Who’s collaborating- FCC and telcos? Where do equipment companies fit in, especially those that make POTS CO gear (e.g. class 5 switches and DLCs) or DSL modems/DSLAMs?

      1. Thanks for your comment. I believe the “collaboration” Ken referred to is internal to the FCC. Wheeler said he was replacing the Task Force with a “mesh network of Bureau and Office activities, including joint activities.” Have no idea what that means or if it will be more effective than a single Task Force.

  2. A couple of interesting references including one from friend Paul Feldman who points out that the experiments are open to anyone in his blog post:


    And the cogent article from CED that discusses some of the things that might be lost, such as the traditional meaning of lifeline power, in a PSTN to IP transition. The comment below the article makes an interesting point about back-up chargers. Implicit in his comments is that it might be a more efficient for every household to have a back-up battery pack, than to impose that burden on the wired communications infrastructure.


  3. Good informative article. I agree whatever AT&T is doing or would do is for its own benefits and interests. It is strictly dollars and sense.

  4. Here are a few recent posts on this topic:
    1. What Comes Next in the IP Transition: Experiments and Research Targeted to Network Values
    2. The FCC Gets Down to Details in IP Transition Trials
    3. What’s In The FCC Order About TDM-to-IP Transition Trials?

    Note: The author of these articles is available for consulting on the implications of FCC telecom policy- both wireless “incentive auctions” and the “all- IP” Transition plan. Contact: alan@viodi.com

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