Cable Ops Raise Interconnection Concerns over IP TrialsTell FCC it Would be Unwise to Jeopardize Interconnection Regime 7/12/2013 7:53 AM Eastern
Cable operators continue to have concerns over the impact of the transition of incumbent local exchange carriers to IP delivery on interconnection.
In comments on various pilot program proposals -- AT&T's geographic trial proposal in particular -- cable operators large and small were unwilling to endorse them without more information.
In its comments, ACA made it clear that it was opposed to the AT&T test in particular, and any others to the degree that they compromised the "bedrock principle" that interconnection protections apply "regardless of technology."
Given the LEC's market power, says ACA, that it must continue to be able to rely on interconnection needs no testing and the FCC should make it clear from the outset that interconnection mandates that apply to traditional service will apply to IP delivery.
"In short, when dealing with these larger ILECs, cable operators providing managed VoIP service are at a disadvantage in negotiating reasonable and competitive rates and terms. ACA members already have experienced problems when seeking IP interconnection with ILECs," said ACA president Matt Polka. "Given this background, questions about the need for the interconnection provisions of the Act to apply to VoIP service do not lend themselves to trials."
The National Cable and Telecommunications Association said it supported trials, at least in theory, but that it did not have enough information on them. "At this stage of the proceeding, in the absence of any proposal that includes details regarding a trial (such as where it is taking place, precisely what will be tested, and how the test environment will differ from the status quo), it is difficult for cable operators to offer much input in response."
NCTA was not as definitive on the interconnection issue, but definitely was raising a yellow flag. "Over many years, through the process established pursuant to the 1996 Act, incumbents and competitors generally have developed relatively stable arrangements governing the interconnection of networks and the exchange of voice traffic. Any proposal that would unduly jeopardize the stability of those arrangements -- from an operational perspective or a financial perspective -- is likely to be cause for concern."
NCTA said that cable ops and others affected by the LEC's transition need to be able to review details of any proposals and have a seat at the table at any process for developing or implementing any trials, geographic or otherwise -- the FCC has also sought input on next-gen 911 and the replacement of wireline with wireless services.
Obviously, cable operators could be at a competitive disadvantage if LEC's did not have to offer them interconnection to their new IP networks on reasonable rates and terms, as FCC rules require of traditional voice service.