Public Knowledge, the New America Foundation, and the Benton Foundation have filed CTC’s analysis of AT&T’s proposal for wire center trials in the Federal Communications Commission’s IP transition proceeding. This filing—“Response to AT&T’s Proposal for Wire Center Trials in the IP Transition Proceeding”—follows up on an earlier report we prepared on behalf of Public Knowledge —“A Brief Assessment of Engineering Issues Related to Trial Testing for IP Transition.”

In our analysis, we noted that AT&T’s Proposal for Wire Center Trials, which was filed in response to the FCC’s approval of the company’s Petition to Launch a Proceeding Concerning the TDM-to-IP Transition, is an adequate starting point for a proof of concept, but as a trial it is insufficient in its scope, fails to establish test thresholds, and lacks the transparency necessary for adequate peer review and the application of the testing regime to future transitions.

We identified shortcomings in AT&T’s proposal and outlined specific steps to ameliorate those shortcomings. Our focus is to establish an appropriately stringent testing program, to ensure that the results are replicable, and to ensure that the test results are transparent and publicly available as befits a trial.

More details on the filings are available here: http://www.publicknowledge.org/news-blog/blogs/public-knowledge-calls-for-more-data-and-consumer-protections-in-phone-netw