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FCC Seeks Comment on INS Service-Based Tech Transitions Experiment

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Released: February 21, 2014


Federal Communications Commission

News Media Information 202 / 418-0500

445 12th St., S.W.


Washington, D.C. 20554

TTY: 1-888-835-5322

DA 14-238

Released: February 21, 2014



GN Docket Nos. 12-353 and 13-5

Comment Date: March 21, 2014
Reply Comment Date: March 31, 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 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. On that date, Iowa Network Services, Inc. (INS) submitted a proposal to conduct a service-based
experiment concerning the TDM-to-IP transition for centralized equal access service.4 We seek comment on the
INS proposal, which may be found at Pursuant to the
timeline established in the Technology Transitions Order, comments on any proposal received by February 20, 2014
are due Friday, March 21, 2014. Reply comments are due Monday, March 31, 2014.

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 See Application of Iowa Network Services, Inc. for Authority to Conduct a Service-based Experiment Concerning
the TDM-to-IP Transition for Centralized Equal Access Service, GN Docket No. 13-5 (filed Feb. 20, 2014). Two
additional parties submitted expressions of interest or similar filings concerning service-based experiments. See
Letter from Jay Carpenter, President and Founder, WARNING Communications, Inc. to FCC, GN Docket No. 13-5,
Attachs. (filed Feb. 14, 2014); Dr. Salah Al-Chalabi, Chaltel Ltd., Experiments to Assess the Impacts of Technology
Transitions from Copper to Optical Fiber and from Analog Voice to VoIP in the Fixed Access Network, GN Docket
Nos. 12-353, 13-5 (filed Feb. 19, 2014). We welcome comment on these submissions as well.

On February 20, 2014, AT&T Services Inc. (AT&T) submitted a letter reporting that it will submit a
proposal for conducting service-based experiments in certain of its wire centers in its wireline footprint on February
27, 2014.5 We intend to issue a public notice seeking comment on AT&T’s proposal shortly thereafter. The notice
will set deadlines for the filing of comments and reply comments.
Filing Instructions. Comments and reply comments, or other submissions from interested persons, may be
filed on paper or electronically. All submissions must reference GN Docket No. 13-5. To the extent consistent with
the instructions of this paragraph, submissions may be filed using: (1) the Commission’s Electronic Comment Filing
System (ECFS) or (2) by filing paper copies.
Pursuant to sections 1.415 and 1.419 of the Commission’s rules, 47 C.F.R. §§ 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 ECFS:

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.
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,6 this proceeding shall be treated
as a “permit-but-disclose” proceeding in accordance with the Commission’s ex parte rules.7 Persons making ex

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). The filing of a proposal
for a service-based experiment on the date AT&T proposes would be consistent with the Technology Transitions
, which “encourage[s] 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. See Technology Transitions Order at
para. 81.
6 Technology Transitions Order, FCC 14-5, at para. 231.
7 47 C.F.R. §§ 1.1200 et seq.

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
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 -

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