AT&T pleads with FCC to streamline legacy data, voice retirement processes

AT&T has asked the FCC to realign the way it regulates how service providers shut down TDM-based data and retirement services with the hope of creating incentives for service providers to invest in next-gen services.

Being an incumbent telco with a 100-year legacy of services, AT&T and its Tier 1 counterparts have begun to shed older services that have either little or no use in their territories.

Specifically, AT&T has asked the FCC to consider streamlining the processes to discontinue data and legacy voice services.

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Under the FCC’s Declaratory Ruling and Further Notice of Proposed Rulemaking issued in November, the FCC proposed shortening the approval process for applications seeking to grandfather data services with download/upload speeds of less than 25/3 Mbps if the applying carrier provides data services of equivalent quality at speeds of at least 25/3 Mbps or higher throughout the affected service area.

AT&T said it agrees with the FCC that applications seeking authorization to grandfather data services should have a “comment period of 10 days and an auto-grant period of 25 days for all carriers.”

The service provider added that the proposed comment and auto-grant dates should not be limited to grandfathering data services or limited to data services with download/upload speeds of less than 25/3 Mbps.

“The streamlined process should apply to any data service so long as the applying carrier certifies that it provides alternative data services with at least equivalent quality and speeds,” AT&T said in its filing (PDF). “Further, the Commission also should adopt a streamlined auto-grant process for the discontinuance of any data services if the carrier sends customers notice at least 180 days prior to filing an application to discontinue the data service. Without such a process, the Commission’s proposal would unnecessarily require carriers to file two applications (the first to grandfather and a subsequent application to discontinue) before discontinuing these services.”

VoIP, mobile outpacing TDM voice

A key movement that’s driving AT&T and its counterparts to ask for the FCC to realign the rules in which telcos can shut down more of its traditional POTS voice services is a simple two-part equation: the adoption of VoIP and consumers using it.

As more consumers and businesses drop legacy TDM-based voice services and adopt mobile and VoIP products, AT&T says that streamlining the section 214(a) process “will remove needless regulatory barriers to this ongoing, market-driven transition.”

Fellow telco Verizon proposed to the FCC to shorten the section 214(a) discontinuance applications where a carrier certifies in two instances: It provides interconnected VoIP service throughout the affected service area, and at least one other alternative voice service is available in the affected service area.

According to data included in the FRNPM, “[a]s of June 2016, interconnected VoIP lines accounted for nearly half of all retail voice telephone service connections in the United States, [and] non-incumbent LECs operate[d] more than three quarters of these approximately 60 million interconnected VoIP lines.”

Additionally, a CDC survey for the second half of 2016 revealed that 51% of households had cut wireline voice service and replaced it with a wireless service.

AT&T said that “consumers, by their own actions, have established that these services are adequate (and arguably superior) replacements for legacy voice service.”

Further, the service provider suggested the FCC should create a modified version of Verizon’s proposal under which a service provider would get automatic approval of an application to discontinue legacy voice service if two conditions are met: A carrier provides interconnected VoIP service throughout the affected service area, or at least one other alternative voice service, e.g. wireless voice or interconnected VoIP, is available in the affected service area.

Untangling abandoned services

Besides refreshing the discontinuance processes for legacy data and voice, there’s a growing desire by carriers to untangle the process to shut down services that have no users.

AT&T, Verizon and other telcos have continued to make requests to shut down services that are not being used by any business or consumer.

“The rationale to forbear from applying Section 214(a)’s discontinuance procedures to services without existing customers is straightforward: When a service has no customers, it necessarily follows that the section 214 discontinuance processes are not necessary to ensure just and reasonable and nondiscriminatory terms of service, protect consumers or otherwise promote the public interest for the simple reason that customers have demonstrated by their actions in the marketplace that they don’t need or want the service,” AT&T said.

AT&T added that the “sooner that carriers can stop maintaining unused services, the sooner those carriers can increase their investments in next-generation services.”

In October, AT&T sought FCC approval to shut down its wholesale Inward Service. Over the past five years, AT&T experienced an 86.7% decline in the volume of its inward service as more customers have taken advantage of more modern technologies and/or services to communicate such as text messaging, instant messaging, social media and mobile calling, for example.