Pleading Cycle Established on AT&T and NTCA Petitions
Federal Communications Commission
445 12th St., S.W.
News Media Information 202 / 418-0500
Washington, D.C. 20554
Released: December 14, 2012
PLEADING CYCLE ESTABLISHED ON AT&T AND NTCA PETITIONS
GN Docket No. 12-353
Comment Date: January 28, 2013
Reply Comment Date: February 25, 2013
respond to the ongoing technological transition of voice networks.
On November 7, 2012, AT&T filed a petition requesting that the Commission open a proceeding
“to facilitate the ‘telephone’ industry’s continued transition from legacy transmission platforms and
services to new services based fully on the Internet Protocol (‘IP’).”1 AT&T requests that the
Commission consider conducting trials where certain equipment and services are retired and IP-based
services are offered, after a public comment period on how to conduct the trials and on “the ultimate
transition to all-IP networks and services.”2
On November 19, 2012, the National Telecommunications Cooperative Association filed a
petition requesting the Commission to “initiate a rulemaking to examine the means of promoting and
sustaining the ongoing evolution of the Public Switched Telephone Network” from TDM to IP.3 NTCA
urges the Commission to seek comment on whether certain regulations should be eliminated, retained or
modified to further the Commission’s statutory objectives of consumer protection, competition, and
Pursuant to sections 1.415 and 1.419 of the Commission’s rules, 47 CFR §§ 1.415, 1.419,
interested parties may file comments and reply comments on or before the dates indicated on the first
page of this document. Comments may be filed using the Commission’s Electronic Comment Filing
System (ECFS). See Electronic Filing of Documents in Rulemaking Proceedings, 63 FR 24121 (1998).
Electronic Filers: Comments may be filed electronically using the Internet by accessing the
Paper Filers: Parties who choose to file by paper must file an original and one copy of each
filing. If more than one docket or rulemaking number appears in the caption of this proceeding,
filers must submit two additional copies for each additional docket or rulemaking number.
1 AT&T Petition to Launch a Proceeding Concerning the TDM-to-IP Transition, at 1 (filed Nov. 7, 2012) (AT&T
2 Id. at 6.
3 Petition of the National Telecommunications Cooperative Association for a Rulemaking to Promote and Sustain
the Ongoing TDM-to-IP Evolution, at 1 (filed Nov. 19, 2012) (NTCA Petition).
4 Id. at 11.
Filings can be sent by hand or messenger delivery, by commercial overnight courier, or by first-
class or overnight U.S. Postal Service mail. All filings must be addressed to the Commission’s
Secretary, Office of the Secretary, Federal Communications Commission.
All hand-delivered or messenger-delivered paper filings for the Commission’s Secretary
must be delivered to FCC Headquarters at 445 12th St., SW, Room TW-A325,
Washington, DC 20554. The filing hours are 8:00 a.m. to 7:00 p.m. All hand deliveries
must be held together with rubber bands or fasteners. Any envelopes and boxes must be
disposed of before entering the building.
Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority
Mail) must be sent to 9300 East Hampton Drive, Capitol Heights, MD 20743.
U.S. Postal Service first-class, Express, and Priority mail must be addressed to 445 12th
Street, SW, Washington DC 20554.
People with Disabilities: To request materials in accessible formats for people with disabilities
(braille, large print, electronic files, audio format), send an e-mail to firstname.lastname@example.org or call the
Consumer & Governmental Affairs Bureau at 202-418-0530 (voice), 202-418-0432 (tty).
Filings and comments are also available for public inspection and copying during regular
business hours at the FCC Reference Information Center, Portals II, 445 12th Street, SW., Room CY-
A257, Washington, D.C. 20554. They may also be purchased from the Commission’s duplicating
contractor, Best Copy and Printing, Inc., Portals II, 445 12th Street, SW., Room CY-B402, Washington,
D.C., 20554, telephone (202) 488-5300, facsimile (202) 488-5563, or via e-mail at email@example.com.
The proceeding this Notice initiates shall be treated as a “permit-but-disclose” proceeding in
accordance with the Commission’s ex parte rules.5 Persons making ex parte presentations must file a
copy of any written presentation or a memorandum summarizing any oral presentation within two
business days after the presentation (unless a different deadline applicable to the Sunshine period applies).
Persons making oral ex parte presentations are reminded that memoranda summarizing the presentation
must (1) list all persons attending or otherwise participating in the meeting at which the ex parte
presentation was made, and (2) summarize all data presented and arguments made during the
presentation. If the presentation consisted in whole or in part of the presentation of data or arguments
already reflected in the presenter’s written comments, memoranda or other filings in the proceeding, the
presenter may provide citations to such data or arguments in his or her prior comments, memoranda, or
other filings (specifying the relevant page and/or paragraph numbers where such data or arguments can be
found) in lieu of summarizing them in the memorandum. Documents shown or given to Commission
staff during ex parte meetings are deemed to be written ex parte presentations and must be filed
consistent with rule 1.1206(b). In proceedings governed by rule 1.49(f) or for which the Commission has
made available a method of electronic filing, written ex parte presentations and memoranda summarizing
oral ex parte presentations, and all attachments thereto, must be filed through the electronic comment
filing system available for that proceeding, and must be filed in their native format (e.g., .doc, .xml, .ppt,
searchable .pdf). Participants in this proceeding should familiarize themselves with the Commission’s ex
For further information, contact John Visclosky, Competition Policy Division, Wireline
Competition Bureau at (202) 418-1580.
- FCC -
5 47 C.F.R. §§ 1.1200 et seq.
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