Background: Today, Public Knowledge filed comments in the Federal Communications Commission's Technological Transition of the Nation’s Communications Infrastructure docket concerning the transition to an all-IP infrastructure.

In its filed comments Public Knowledge lays out a plan relying on "Five Fundamentals" of the current telephone system that need to be upheld as we transition into a new IP based infrastructure:

Service to All Americans: The Commission must ensure the benefits of these technologies flow to all Americans - regardless of race, color, religion, national origin or sex. The U.S. must not be the first industrialized nation to retreat from the goal of achieving 100% penetration of basic voice service.

Interconnection and Competition: Competing networks must continue to accept each other’s traffic and terminate each other’s calls in a manner that both preserves call quality throughout the country and actively promotes a robust and competitive environment. In particular, subscribers to different networks must not find themselves the victims of “peering disputes” that cut off communications and vital services.

Consumer Protection: Competition does not always ensure consumer protection. The Commission must ensure that consumers are protected - including effective recourse for the timely resolution of complaints – throughout and after the IP transition.

Network Reliability: We must be able to rely on the phone network to function consistently and reliably. Recent events like Hurricane Sandy show that an IP based infrastructure may not be as reliable today as we had hoped. In the future, the Commission must ensure that even in a natural disaster, consumers will be able to make phone calls and stay connected.

Public Safety: The transition to an IP based infrastructure must facilitate emergency communications. Consumers should be able to call 9-1-1 in any emergency with confidence that the call will be connected.

The following statement may be attributed to Harold Feld, Senior Vice President at Public Knowledge:

"AT&T is right that the time to have this conversation is now. For nearly 100 years, we have had a social contract between phone providers and the country based on these "Five Fundamental" principles. 'Phone providers get rights of way, subsidies and other benefits, we get service for all Americans and a reliable network.' That basic bargain created a phone system that serves as the gold standard for the rest of the world.

"A framework relying on the same "Five Fundamentals" -- service to all Americans, interconnection and competition, consumer protection, network reliability, and public safety -- can build a digital future that will make our digital infrastructure the envy of the world. The technology changes, but the social needs and goals stay the same. Whatever new rules we adopt to reflect the changed reality of the digital world must be built on the same Five Fundamentals framework."

A link to the PSTN comments can be found here.

Background: Today, Public Knowledge filed comments in the Federal Communications Commission's Technological Transition of the Nation’s Communications Infrastructure docket concerning the transition to an all-IP infrastructure.

In its filed comments Public Knowledge lays out a plan relying on "Five Fundamentals" of the current telephone system that need to be upheld as we transition into a new IP based infrastructure:

Service to All Americans: The Commission must ensure the benefits of these technologies flow to all Americans - regardless of race, color, religion, national origin or sex. The U.S. must not be the first industrialized nation to retreat from the goal of achieving 100% penetration of basic voice service.

Interconnection and Competition: Competing networks must continue to accept each other’s traffic and terminate each other’s calls in a manner that both preserves call quality throughout the country and actively promotes a robust and competitive environment. In particular, subscribers to different networks must not find themselves the victims of “peering disputes” that cut off communications and vital services.

Consumer Protection: Competition does not always ensure consumer protection. The Commission must ensure that consumers are protected - including effective recourse for the timely resolution of complaints – throughout and after the IP transition.

Network Reliability: We must be able to rely on the phone network to function consistently and reliably. Recent events like Hurricane Sandy show that an IP based infrastructure may not be as reliable today as we had hoped. In the future, the Commission must ensure that even in a natural disaster, consumers will be able to make phone calls and stay connected.

Public Safety: The transition to an IP based infrastructure must facilitate emergency communications. Consumers should be able to call 9-1-1 in any emergency with confidence that the call will be connected.

The following statement may be attributed to Harold Feld, Senior Vice President at Public Knowledge:

"AT&T is right that the time to have this conversation is now. For nearly 100 years, we have had a social contract between phone providers and the country based on these "Five Fundamental" principles. 'Phone providers get rights of way, subsidies and other benefits, we get service for all Americans and a reliable network.' That basic bargain created a phone system that serves as the gold standard for the rest of the world.

"A framework relying on the same "Five Fundamentals" -- service to all Americans, interconnection and competition, consumer protection, network reliability, and public safety -- can build a digital future that will make our digital infrastructure the envy of the world. The technology changes, but the social needs and goals stay the same. Whatever new rules we adopt to reflect the changed reality of the digital world must be built on the same Five Fundamentals framework."

A link to the PSTN comments can be found here.