On November 7, AT&T filed a petition with the FCC requesting the Commission to launch a proceeding on the transition from TDM to IP networks. In the petition, AT&T asks the FCC to oversee a trial in which it would move all ILEC customers off the TDM network and onto an IP network in select wire centers in order "to facilitate an industry-wide dialogue on the appropriate regulatory framework" for the transition. AT&T's petition also includes a request that VoIP and other IP services remain "free of legacy regulations" and that carriers be barred from demanding TDM-based interconnection or services as ILECs replace circuit switched telephony with VoIP. In addition, AT&T makes no commitment to interconnect with competitors on an IP-to-IP basis.

While COMPTEL is intrigued with AT&T's petition, the association disagrees with AT&T's argument that consumer protection regulations are unnecessary in an all-IP world. COMPTEL believes that the FCC must ensure that pro-competitive policies and regulations remain in place as technology upgrades are implemented so that consumers can continue to have a choice of providers."