Groups Warn FCC That Moving Away From TDM to All-IP Connections Won't Be Easy
Wireline and wireless associations and providers agreed in FCC filings this week about the importance of moving to all-IP technology and completing the technology transition, but they also acknowledged that getting rid of time-division multiplexing (TDM) interconnection won’t be easy. As USTelecom noted in early comments (see 2601160057), the transition is “a daunting task.”
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Most comments were posted Wednesday in docket 25-304. They responded to an NPRM that commissioners approved in October, proposing to sunset interconnection obligations for incumbent local exchange carriers (ILECs) on Dec. 31, 2028, and seeking comment on ways that the FCC can help a transition to all-IP interconnection for voice services (see 2510280024).
Incompas said the proceeding “raises fundamental questions” about how to complete the technology transition and update FCC rules “in light of evolving market realities.” The company predicted that the record “will reveal a troubling disconnect: competitive providers overwhelmingly support IP interconnection and have made substantial investments in IP-capable infrastructure,” while ILECs “continue to require competitors to rely on TDM-based trunk-side interconnection, including for mission-critical 911 services.”
NCTA called for a target deadline for completing the transition but also argued that providers need protections while the move progresses. While local traffic is still exchanged with ILECs at TDM tandems, “providers will need to purchase TDM transport to interconnect with those carriers -- and NCTA and others have documented the large price increases for such services that have accompanied recent grants of regulatory and pricing flexibility to ILECs.”
Those price increases are particularly harmful to providers that “have proactively deployed last-mile IP networks, including rural carriers and cable providers, as it exponentially compounds costs,” the group added.
T-Mobile said it has worked to move all its voice traffic to IP peering arrangements, but “these efforts have at times been frustrated by certain ILECs that have declined to engage in negotiations for IP interconnection arrangements.” The volume of T-Mobile’s traffic that's converted to TDM is about 15%, but the interconnection costs “dwarf T-Mobile’s costs for IP interconnection.” The carrier noted that its TDM interconnection costs have increased “by well over 1,000% in the last five years, and with some charges increasing by more than 3,000%.”
ILECs continue to own and control TDM-based tandems, the Competitive Carriers Association said, “which may be the only means to originate and terminate calls in certain areas.” The group's members use alternatives when available, “but in many rural areas, ILECs are the only option,” so members “are often held hostage to ILEC demands for TDM interconnection, forcing small rural carriers to accept ever-increasing costs to ensure end-user voice calls can be completed.”
NTCA said TDM interconnection is transparent, and the physical locations where the connections take place -- “as well as the relative apportionment of financial and operational responsibility among the parties -- are well known to all.” Moving away from TDM interconnection “without any clear plan” could mean “transferring costs and obligations to smaller and rural operators (or relegating them to second-tier service quality).”
The Telecommunications Industry Association agreed that the time was right to accelerate the transition. The group urged the FCC to develop an approach that “promotes market solutions, encourages ongoing investment, and limits regulatory intervention to what is necessary to promote those goals.”
In a joint filing, Public Knowledge, the Center for Rural Strategies and Communications Workers of America stressed the importance of classifying interconnected VoIP as a Communications Act Title II service and “creating a scalable framework for interconnection to replace the existing regime.” The classification question is “straightforward,” the groups argued. “Interconnected VoIP meets the statutory definition of telecommunications: the transmission, between or among points specified by the user, of information of the user’s choosing, without change in the form or content of the information as sent and received.”
The Voice on the Net Coalition said the commission should use its existing authority under Section 251 of the Communications Act “to require timely IP-IP interconnection for all numbered voice services.” The proceeding isn’t the best forum for resolving classification questions, the group added. Customers opt for VoIP over traditional telephone “because VoIP offers more robust services and features, such as enterprise cloud PBX [private branch exchange], AI integrations, multi-factor authentication and security features, voicemail-to-email, multichannel communications, and the ability to take phone numbers anywhere as calls can be received and originated over any internet connection.”