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FCC Seeks Comment on ATT Proposed Technology Transitions Experiments

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Released: February 28, 2014


Federal Communications Commission

News Media Information 202 / 418-0500

445 12th St., S.W.


Washington, D.C. 20554

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DA 14-285

Released: February 28, 2014



GN Docket Nos. 12-353 and 13-5

Comment Date:

March 31, 2014
Reply Comment Date:

April 10, 2014

In the Technology Transitions Order, the Commission initiated a proceeding for a diverse set of
experiments and data collection initiatives that will allow the Commission and the public to evaluate how
customers are affected by the historic technology transitions that are transforming our nation’s
communications networks.1 Among other things, the Commission established a framework within which
providers can conduct “service-based” experiments.2 The Technology Transitions Order invited
providers to submit voluntary proposals to test real-world applications of planned changes in technology
that are likely to have tangible effects on consumers.3 Proposals will be evaluated according to the value-
based conditions, presumptions and relevant factors set forth in the Technology Transitions Order and
described more fully in its Appendix B.
Expressing a desire to begin the experiments as soon as possible, the Technology Transitions
Order established a deadline of February 20, 2014 for submission of an initial round of service-based
experiment proposals, and encouraged additional proposals that are submitted after the initial deadline,
for up to one year after Commission action on any proposals submitted by the initial deadline.4 On
February 20, 2014, AT&T Services Inc. (“AT&T”) submitted a letter reporting that it would submit a
proposal for conducting service-based experiments in certain of its wire centers in its wireline footprint on
February 27, 2014.5 On February 27, 2014, the Wireline Competition Bureau released two protective

1 See Technology Transitions, et al., GN Docket No. 13-5 et al., Order, Report and Order and Further Notice of
Proposed Rulemaking, Report and Order, Order and Further Notice of Proposed Rulemaking, Proposal for Ongoing
Data Initiative, FCC 14-5 (rel. Jan. 31, 2014) (Technology Transitions Order).
2 A “service-based” experiment is one in which providers seek to substitute new communications technologies for
the TDM-based services over copper lines that they currently are providing to customers, with an eye toward
discontinuing those legacy services and in which others may propose new and innovative services that bring benefits
to consumers while preserving the enduring values of our nation’s communications networks. Id. at para. 22.
3 Id. at para. 30.
4 Id. at para. 81.
5 See Letter from Frank S. Simone, Asst. VP Fed. Reg., AT&T Services Inc., to Marlene H. Dortch, Secretary,
Federal Communications Commission, GN Docket Nos. 12-353, 13-5 (filed Feb. 20, 2014).

orders to govern the submission of certain proprietary or confidential, or highly confidential information.6
Also on February 27, 2014, AT&T submitted a Proposal for Wire Center Trials (the “AT&T Proposal”)
for experiments involving the transition of two wire centers – one rural and one suburban – to all IP
services and, in part, to wireless-based service.7
We seek comment on the AT&T Proposal. Comments are due by Friday, March 31, 2014. Reply
comments are due by Thursday, April 10, 2014.
Filing Instructions. 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 above.
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.
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.

6 See Technology Transitions, et al., GN Docket Nos. 13-5, 12-353, Protective Order, DA 14-272 (Wireline Comp.
Bur. rel. Feb. 27, 2014) (Protective Order),, Technology Transitions et
, GN Docket Nos. 13-5, 12-353, Second Protective Order, DA 14-273 (Wireline Comp. Bur. rel. Feb. 27, 2014)
(Second Protective Order),
7 See Letter from Christopher M. Heimann, General Attorney, AT&T Services, Inc., to Marlene H. Dortch,
Secretary, Federal Communications Commission, GN Docket Nos. 13-5, 12-353, at Attachs. (filed Feb. 27, 2014)
(AT&T Proposal for Wire Center Trials), (cover letter), (narrative proposal), (Wire Center Trial Operating Plan), (Exhibits).

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 or call the
Consumer & Governmental Affairs Bureau at 202-418-0530 (voice), 202-418-0432 (tty).
Ex Parte Presentations. As provided by the Technology Transitions Order,8 this proceeding shall
be treated as a “permit-but-disclose” proceeding in accordance with the Commission’s ex parte rules.9
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
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 parte rules.
For further information, contact Matt DelNero, Deputy Chief, Wireline Competition Bureau at
(202) 418-7433 or, or Tim Stelzig, Deputy Chief, Competition Policy
Division, Wireline Competition Bureau at (202) 418-0942 or
- FCC -

8 Technology Transitions Order at para. 231.
9 47 C.F.R. §§ 1.1200 et seq.

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