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Vol. 10, No. 14   April 14, 2014
In This Issue
TECHNOLOGY TRANSITIONS
E-RATE
CABLE MERGER
COMMITTEE MEETINGS
MEMBER NEWS








For more information about submitting member company news, please contact Gail Norris.
UPCOMING EVENTS

April 17-18
FCC DEADLINES

April 21

October 6

November 17
CAREER CENTER

The COMPTEL Career Center brings together leading communications service providers and vendors with talented individuals looking for new careers.

Special Offer: 
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Companies seeking to fill open positions can take advantage of COMPTEL's special "unlimited postings" offer. Each job will be listed for 30 days and be promoted in the COMPTEL Connection e-newsletter for three weeks. Cost for COMPTEL members is $295 per year, and non-members $495 per year.
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TOP OF THE NEWS
COMPTEL and Service Providers Urge FCC 
Not to Approve AT&T's Technology Transitions Experiments Without Significant Modifications

Proposed Wire Centers Will Not Provide Sufficient Data on Impact of
IP Transition on Residential, Business and Wholesale Consumers

Last week, COMPTEL joined with service providers Cbeyond Communications, LLC, Integra Telecom, Inc., Level 3 Communications, LLC, and tw telecom inc. to urge the Federal Communications Commission not to approve AT&T's proposed technology transitions experiments in Carbon Hill, Ala., and Kings Point, Palm Beach County, Fla. without significant modifications. In a letter filed at the Commission, they noted AT&T's proposal lacks critical information needed to conduct a meaningful review and, because of the specific wire centers targeted, the experiments will not generate the type of data necessary to fully understand the impact of the TDM-to-IP transition on residential, business and wholesale customers.

"In its own comments about service-based experiments proposed by other parties, AT&T noted that the FCC shouldn't move forward unless the applicant can provide sufficient information to determine whether the experiment 'ensures universal connectivity, consumer protection, public safety, reliability and competition' and 'will indeed provide the Commission with useful information concerning the IP transition,'" said Angie Kronenberg, chief advocate and general counsel at COMPTEL. "We agree, and, in this case, believe that AT&T has not provided the evidence necessary to show that its trials will provide the needed insight into how the natural evolution to IP technology will address the needs of wholesale customers, as well as retail consumer and business users."

Of concern to COMPTEL and the service providers is the lack of detail about the replacement services AT&T will be make available to wholesale customers during the experiment and the timeline for enhancements to the replacement voice services that will be made available to residential and business customers. Additionally, they noted that the proposal does not provide any information about the rates, terms and conditions on which replacement services will be offered to wholesale customers during the experiment as required by the Commission's January Order.

Without these important details, the commenters noted that AT&T's proposal "precludes wholesale customers from conducting the business planning necessary to serve their retail customers, including small and medium-sized businesses. It also fails to ensure that, consistent with the Experiments Order, packet-based replacement inputs will be offered at rates, terms, and conditions equivalent to those currently offered for TDM-based unbundled network elements and special access services."

The comments provided by COMPTEL and the service providers include a declaration by Joseph Lenski of Edison Media Research Inc., who evaluated AT&T's proposal based on the basic tenets of experimental design and offered recommendations on how the experiments should be altered to ensure that reliable and statistically significant information is attained.

Lenski explained that AT&T's proposed experiment is unlikely to generate accurate and meaningful data because it does not include wire centers that encompass sufficiently diverse geographic areas, customer types, population densities and demographics, and climates; nor do they provide sufficient information on the types of data to be collected, the metrics to be used, or the control groups to be selected.

To ensure that significant information results from the experiments, Lenski recommended that AT&T refine its proposal to ensure it is using appropriate procedures to select test wire centers that are statistically representative and define a control group via random selection. He also stated that AT&T must identify the types of data to be collected - including data on wholesale service quality, such as ordering, provisioning, maintenance, and repair intervals - and obtain independent third-party verification of the data collected. 
AT THE FCC
COMPTEL Comments on E-Rate Reform
On April 7, COMPTEL filed comments in the FCC proceeding on "Modernizing the E-Rate Program for Schools and Libraries." COMPTEL noted that the Commission "has a unique opportunity to affirmatively shape the program to meet the broadband needs of schools and libraries for years to come."

COMPTEL added that "the preservation of competitive bidding should be a priority, and the Commission should do everything it can to encourage all eligible providers to bid. We support the Commission's efforts to simplify the administrative processes so that providers of all sizes are motivated to bid for and offer services in the E-rate program." However, COMPTEL said the FCC should not mandate collaborative purchasing through consortia or only cover certain costs if applicants participate in consortia. Applicants should retain the flexibility to determine based on their individual locations and needs whether participating in a consortium is the most efficient and cost-effective means for them to obtain the high-capacity equipment and services necessary to serve their constituencies."
CABLE MERGER

Comcast and Time Warner File Merger Application

On April 8, Comcast and Time Warner filed their merger application and public interest statement at the FCC.

 

In a related move, the FCC released a Public Notice outlining the ex parte requirements related to the merger.  No filing deadlines have been established at this time. Stay tuned to the Connection for future updates.  

 

Senate Focuses on Comcast-Time Warner Cable Merger

Last Wednesday, the Senate Judiciary Committee hosted a hearing entitled, "Examining the Comcast-Time Warner Cable Merger and the Impact on Consumers."  Witnesses included David Cohen, executive vice president of Comcast Corporation; Arthur T. Minson Jr., executive vice president and CFO of Time Warner Cable Inc.; Gene Kimmelman, president and CEO of Public Knowledge; James L. Bosworth Jr., chairman and CEO of Back9Network; Richard Sherwin, CEO of Spot On Networks; and Christopher S. Yoo John H. Chestnut professor of Law, Communication and Computer & Information Science at University of Pennsylvania Law.
 
To view the webcast, Senate leadership statements and witness testimony, visit the Judiciary Committee website.
COMMITTEE MEETINGS 
All COMPTEL Committee meetings are held at the Association's headquarters, 1200 G St NW, Suite 350, Washington, DC 20005, unless otherwise noted.  All times listed are Eastern. For more information, call 202-296-6650.

April 15           Regulatory/Legislative Committee Meeting
2 p.m.              Contact Karen Reidy

April 22           Regulatory/Legislative Committee Meeting 
2 p.m.              Contact Karen Reidy
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