607 14th Street NW, Suite 400 • Washington, DC 20005-2073 • 202.326.7300 T • 202.326.7333 F • www.ustelecom.org

September 26, 2016

Ex Parte Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, SW Washington, D.C. 20554 Re: Technology Transitions (GN Docket No. 13-5) Dear Ms. Dortch:

On September 22, 2016, Diane Holland and Robert Mayer of the USTelecom Association and other representatives from AT&T, CenturyLink, and Verizon, met with staff from the FCC’s Wireline Competition and Public Safety and Homeland Security Bureaus to discuss certain requirements in the above-referenced proceeding that incumbent providers seeking to discontinue a legacy voice service and replace it with a new service must meet.1 In addition to explaining how the option for providers to demonstrate compliance with the latency benchmark described in Appendix B of the Second Report and Order is not feasible for use with incumbent providers’ managed voice services, we provided to staff the attached handout titled, “Technology Transition Second Report and Order: Concerns with Network Performance Testing Methodology.”

Please do not hesitate to contact the undersigned if you have questions or concerns.

Sincerely,

Diane Griffin Holland Vice President, Law & Policy

Attachment cc: Michele Berlove Megan Capasso Alexis Johns Carol Mattey Peter Saharko Jeffrey Goldthorp

1 See Ex Parte Letter from Diane Griffin Holland, USTelecom, to Marlene H. Dortch, Secretary, FCC, WC Docket No. 13-5 (filed Sep. 23, 2016).

Technology Transition Second Report and Order: Concerns with Network Performance Testing Methodology

September 22, 2016

Concerns with Network Performance Testing Methodology

• The recent Tech Transition Order allows carriers to use CAF II testing methodology that will measure download/upload speeds and latency between the customer location and Internet Exchange Point (IXP)

• CAF II latency measurements are designed to ensure the suitability of government funded broadband services for Over-The-Top VoIP applications if the customer chose to use services like Vonage or skype

• ILEC voice replacement services are generally native/managed VoIP or wireless services

• IXPs are not in the call path of native/managed VoIP or wireless services

• Calls originating on one carrier’s network and terminating on another’s utilize managed interconnection - IXPs are still not in the path of the call

• The replacement service latency requirement should be:

o Per ITU G.114, 200ms mouth-to-ear for On-Net calls

o For Off-Net calls, 100ms between user device and PSTN media gateway or the peering point with the directly interconnected VoIP service provider.

• It is impractical to conduct continuous testing on a subscriber’s voice line 24x7 for 30 days, as the subscriber would have no use of their service during that entire period

CAF II Measurement Path

RG

RG

GPON ONT

Fixed Wireless

Internet

RG

Performance Collection Servers in IXP

Performance Collection Servers in IXP

Performance Collection

Servers in IXP

Measurement traffic path

Internet- Other Entities

IXP

IXP

IXP Internet- Other Entities

ISP wireless/wireline Data Centers

ISP IP Core Network

Copper NID

Fiber NID

VoIP and CMRS Call Paths It is technically infeasible to implement the testing methodology set forth in Appendix B for managed VoIP or CMRS, as neither service has connectivity to an Internet Interexchange Point.

RG

RG

GPON ONT

Wireline VoIP Data Center

CMRS Switching Center

PSTN

Wireless

Wireless

Internet

Call Path

VoIP IP Core Network

Other VoIP Provider

CMRS Core Network

Phone Adapter

Copper NID

Fiber NID

Performance Collection Servers in IXP

Phone Adapter

ECFS Confirmation

https://www.fcc.gov/ecfs/filings/confirmation[9/26/2016 11:58:25 AM]

Welcome to the FCC’s new Electronic Comment Filing System, ECFS 3.0, launched June 20, 2016. This system contains theentire history of docketed proceedings from 1992 to the present. New submissions here will be added to the public record.We will continue to refine this system in response to user feedback. Please tell us about your experience using this system bysending an email to ECFSfeedback@fcc.gov.

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FILING REVIEW CONFIRMATION

Proceeding: 13-5

Confirmation #: 20160926254718522

Submitted: Sep 26, 2016 11:57:54 AM

Status: RECEIVED

Name(s) of Filer(s) United States Telecom Association (USTelecom)

Law Firm(s)

Attorney/Author Name(s) Diane Holland

Primary Contact Email dholland@ustelecom.org

Type of Filing NOTICE OF EXPARTE

Presented To Wireline Competition Bureau, Public Safety & Homeland SecurityBureau

File Number

Report Number

Bureau ID Number

Address of Filer

Address 607 14th Street NW, Suite 400, Washington, DC, 20005

Email Confirmation Yes

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