COMPTEL filed comments on January 28 responding to petitions by AT&T and National Telecommunications Cooperative Association (NTCA) regarding the transition of the public telephone network from TDM to IP technology.  COMPTEL points out that, since the trial proposed by AT&T does not include SIP interconnection or last mile access over packet-mode facilities, if adopted, the Commission would be sanctioning a test of a change in AT&T's internal network offerings free of obligations that protect consumers and competitions, not a trial of the PSTN's evolution to IP technology.  The trial transition plan suggested by AT&T would not result in the Commission's desired outcome of a future where consumers and small businesses continue to enjoy competitive choice and rapid innovation.  

Instead, COMPTEL noted that the NTCA filing presents a more sound footing to guide the Commission, as it recognizes the importance of sustaining "the already-ongoing IP evolution in a manner consistent with the core statutory objectives of protecting consumers, promoting competition and ensuring universal service."

COMPTEL believes that if the Commission were to adopt the model for this transition that AT&T is proposing, the Commission would be essentially rejecting competition and the importance of consumers having a choice in service providers.  In its comments, COMPTEL said that "in order to ensure that, while the technology moves forward, the market doesn't move backward to a time when consumers lacked competitive choice, it is important that two critical rights be preserved for the next generation facilities: (1) interconnection and (2) last mile access. Consequently, achieving these goals must be necessary elements of any trial conducted on the transition."

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