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We’ve already seen one failed experiment. Moving forward, the FCC needs to make sure that the trials are valuable to all parties involved, not just the carriers.
In May, the FCC solicited comments on a proposal to implement a series of pilot programs relating to ongoing transitions in the phone network. The proposed trials are intended to give the Commission a better understanding of how technological changes to the phone network will affect Americans.
Yesterday we gave the FCC our two cents on the proposal: apply PK’s Five Fundamentals in designing the trials in order to ensure that the programs produce meaningful data and include strong protections for consumers – who won’t be able to choose whether or not to participate.
But First, a Note on Verizon's Failed Voice Link Trial
It's hard to think about the Commission's proposed trials without acknowledging that we are already witnessing one carrier in the midst of its own failing "pilot program" in Fire Island, New York.
The Commission should view Verizon's Voice Link deployment in Sandy-ravaged communities as a vivid example of how not to run a pilot program, and a strong reminder of how any future pilot programs must be handled responsibly.
After Hurricane Sandy damaged the copper infrastructure in some coastal towns, Verizon decided to replace its traditional wireline network with a fixed wireless technology called Voice Link.
The New York Public Service Commission has now received hundreds of complaints from residents who had their voice service involuntarily changed to the experimental wireless network, and it is clear that Fire Island residents really were depending on the services that Verizon's new infrastructure no longer supports, like calling cards, medical alerts, faxes, internet access, and guaranteed network reliability (which is perhaps most important in emergency situations).
How to Build a Responsible Pilot Program
Here are the elements that we see as essential to creating a trial program that will provide meaningful information to the Commission while also protecting the needs of customers of the participating carriers:
1. The pilot programs need to be structured to gather specific data rather than treated than as policy-setting processes in and of themselves. The Commission must not let the trials become a glide path to deregulation; they need to structure the pilot programs so that they provide useful data that can inform the Commission’s policy-making going forward.
2. The Commission needs to make sure that the trials are transparent – both in the process of designing the programs and in sharing the information gained through the programs after completion. The phone network transition promises to impact network uses across the entire nation, and it is vital that every interested stakeholder have the opportunity to review, comment, on, and use the data collected during the pilot programs.
3. It’s important that the Commission collaborate with state and local entities in designing and implementing the trials. Partnering with local public interest groups and local government institutions will allow the Commission to determine the best possible methods for informing consumers about the trials and for soliciting their feedback, especially in areas with diverse geographic and socioeconomic characteristics. It will also ensure that any state or local regulations providing protection to consumers continue to operate throughout the trials.
4. The Commission needs to have a clear plan for winding down the trials and ensuring that consumers can return to their old service if they want. The Commission also needs to be sure the programs include provisions to terminate the trials immediately if problems arise causing serious harm to subscribers.
We Can’t Leave This Up to the Carriers to Do on Their Own
Experimental transitions initiated by carriers themselves are no substitute for structured pilot programs designed by the FCC. If carriers can just launch their own private, unsupervised trials and control what information reaches the public, the FCC won’t be able to get the type of data it needs, and consumers who are forced to participate in the trials will be at risk of losing access to crucial services upon which they currently depend.
Instead, the FCC should apply PK’s Five Fundamentals for a successful phone transition in implementing these trials:
- Service to all Americans,
- Interconnection and competition,
- Consumer protection,
- Network reliability, and
- Public safety
As the Commission considers each particular trial, it should evaluate how that trial serves or fails each of the Five Fundamentals, and keep adjusting its pilot plans to ensure that this effort will put consumers first and prevent the transition from becoming a step backward for any user.
A link to the full text of PK’s comments can be found here.
Original image by Flickr user IronRodArt - Royce Bair.