First in the door with a proposal: Iowa Network Services, with the help of one of our Fletcher Heald colleagues

As we reported last month, in late January the FCC released its Technology Transitions Order inviting proposals for service-based experiments designed to gauge the effects likely to be encountered as we shift from the legacy telephone network to an all Internet Protocol (IP) alternative. The target deadline initially set for proposals was February 20. And with lightning speed, the very next day the Commission released a public notice seeking comment on the first proposal, which had been filed on February 20.

We are pleased to report that that proposal, filed by Iowa Network Services, Inc. (INS), was prepared by our colleague (and occasional CommLawBlog contributor) James Troup on behalf of INS, an FHH client.

INS operates a statewide Centralized Equal Access (CEA) network in Iowa comprised of more than 2,000 miles of fiber optic cable and dual tandem switches. The network allows INS to aggregate rural traffic, centralize the provisioning of expensive features and functionalities, and help bring the benefits of advanced communications services and competition to rural areas of Iowa. INS connects service providers to more than 300 rural exchanges.

INS’s proposed experiment is designed to shed light on the impact on customers and rural communities as INS’s voice communications service converts to an all-IP network from a CEA network based on time-division multiplexed (TDM) circuit-switched technology. One particular area of inquiry: can IP CEA economically advance and accelerate the availability of new telecommunications technologies in rural Iowa by facilitating IP conversion for the more than 140 rural LECs currently connected to INS’s centralized platform? TDM CEA performed that role 25 years ago in equal access conversion that gave rural residents a choice of long distance telephone companies. Through its experiment INS hopes to determine whether an IP conversion will provide comparable benefits. Moreover, INS’s experiment will give the diverse network providers – IXCs, CLECs, CMRS providers, ISPs, IPTV providers – that rely upon INS’s CEA services as a bridge to rural exchanges the opportunity to prepare for and contribute to this historic technology transition. 

You can check out the INS proposal here. It consists of three phases:

  1. Voluntary interconnection with network providers, with INS converting their traffic      from IP to TDM at INS tandem switches.
  2. All-IP traffic between IXCs (and other service providers that volunteer to participate) and the switches of the LECs that connect with the INS network on an IP basis.
  3. Test of all-IP facilities from the LEC originating end user to the IXC selected by that end user, and ultimately, to the called party. 

INS has of course committed to fulfilling all of the value-based conditions and presumptions set forth in the Technology Transitions Order.   

While INS’s proposal was the first one in the door at the Commission, it was not the last. AT&T has since submitted a proposal which is now out for public comment as well.

FHH was pleased to be involved in the preparation and submission of the first IP transition experiment submitted to the FCC. We look forward to assisting not only INS, but other entities seeking to become active in the Technology Transition proceeding. (Comments on the INS proposal are due by March 21, 2014; reply comments by March 31. Anyone interested in submitting comments may do so electronically by uploading them at this site; the Proceeding Number is 13-5.)