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New FCC Chair Seems Ready to Move on Retiring PSTN

Action could be taken as early as January on AT&T's proposed "experiments" in small-scale decomissioning of the PSTN.

It's been almost 4 years since AT&T first petitioned the FCC to relieve the carrier of its obligation to provide service over the legacy PSTN, and a year since AT&T and others submitted comments to an FCC proceeding in the matter. Wednesday the new Chairman of the FCC signaled that he's ready to begin at least the prelude to the transition.

"We have listened, and now it is the time to act," FCC chairman Tom Wheeler wrote in a blog post.

Wheeler writes that the FCC's December 12 meeting will include a report on the issue from the Commission's Technology Transitions Policy Task Force, and that action could be taken in January 2014 to begin experiments and tests aimed at producing a plan for sunsetting the legacy PSTN.

The key document in this process is a petition filed December 7, 2012 by AT&T, proposing a set of "Wire Center Trials" to begin putting in place the logistics of the transition. The focus of the trials would be on understanding the technology, policy, and consumer impacts of the transition. Here's how that filing proposes the FCC implement the experiments in decommissioning:

First, the Commission would eliminate, within the trial wire centers, outdated "telephone company" regulations that may require carriers to maintain legacy TDM-based networks and services even after replacement services are in place...

Second, to the extent VoIP replaces legacy circuit-switched telephony in the trial wire centers, the Commission would preclude carriers (including carrier customers) from demanding service or interconnection in TDM format in those wire centers. Hence, as VoIP replaces legacy circuit-switched telephony, no carrier would be required to provide TDM-based dedicated transmission services, which would be replaced by Ethernet or other IP services. Carriers would also have no right to demand TDM-based interconnection or services, including TDM-based tandem transit services or SS7-based signaling.

Third, in the trial wire centers, the Commission would also implement reforms to facilitate the migration of end-user customers from legacy to next-generation services. Although the telecommunications ecosystem is moving quickly to an all-IP environment, many millions of consumers remain on TDM-based networks. And as the transition continues apace in the trial wire centers, the Commission would implement reforms designed to prevent a few customers from delaying that transition, as happened in the transition from analog to digital television and in the sunset of analog cellular services. In particular, the Commission would permit service providers to notify customers that such service providers will no longer provide them legacy services once the legacy TDM network is retired. Under this approach, customers would of course be given sufficient opportunity to establish alternative arrangements. Alternatively, if the Commission is concerned that non-migrating customers will be cut off (even temporarily) from service, it could allow those customers' existing service providers to switch them to an alternative service at the time of the technological transition.

Second, to the extent VoIP replaces legacy circuit-switched telephony in the trial wire centers, the Commission would preclude carriers (including carrier customers) from demanding service or interconnection in TDM format in those wire centers. Hence, as VoIP replaces legacy circuit-switched telephony, no carrier would be required to provide TDM-based dedicated transmission services, which would be replaced by Ethernet or other IP services. Carriers would also have no right to demand TDM-based interconnection or services, including TDM-based tandem transit services or SS7-based signaling.

Third, in the trial wire centers, the Commission would also implement reforms to facilitate the migration of end-user customers from legacy to next-generation services. Although the telecommunications ecosystem is moving quickly to an all-IP environment, many millions of consumers remain on TDM-based networks. And as the transition continues apace in the trial wire centers, the Commission would implement reforms designed to prevent a few customers from delaying that transition, as happened in the transition from analog to digital television and in the sunset of analog cellular services. In particular, the Commission would permit service providers to notify customers that such service providers will no longer provide them legacy services once the legacy TDM network is retired. Under this approach, customers would of course be given sufficient opportunity to establish alternative arrangements. Alternatively, if the Commission is concerned that non-migrating customers will be cut off (even temporarily) from service, it could allow those customers' existing service providers to switch them to an alternative service at the time of the technological transition.

If the FCC adopts the general outline of AT&T's proposed "experiments," there could be a rather immediate effect on enterprises. The proposed changes would happen sooner rather than later in the affected areas or "wire centers." What if one of your major (or not so major) sites is located in that wire center coverage area? Will you have to give up your PRIs and move to SIP trunks--even if this is not a transition you've prepared for enterprise-wide?

It's one thing for a consumer household living within a trial-area wire center to change from one technology to another. They may not like it (as AT&T notes many didn't in the digital TV and digital cellular transition), but they're only one user with one location, and no need to make their connectivity at home harmonize with a broader infrastructure. The enterprise clearly may find itself in a different situation.

The fact that most people envision the PSTN's sunsetting as a multi-year process obscures the fact that, under AT&T's proposal, it will actually be something closer to a flash cut in the proposed wire center regions. Enterprises would be well advised to follow these developments very closely, and, if AT&T's plan is substantially adopted, to understand exactly what geographies will be affected, and how.

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