The FCC Gets Down to Details in IP Transition Trials

February 6, 2014

Federal Communications Commission has given more details about the trials it
will use to gather information about the transition of our communications
networks to Internet Protocol.

One important step in the transition of our phone network from
traditional TDM-based technology to IP (and in some cases from copper networks
to fiber or wireless) is to figure out exactly how those new technologies are
going to impact consumers. The FCC has now set out plans for a series of experiments on various aspects of the network transition.

Right off the bat, the FCC starts on the right foot by setting
out the core values that establish the purpose of the trials: “public safety,
ubiquitous and affordable access, competition, and consumer protection.” Public
Knowledge agrees with this approach—in fact, our own Five Fundamentals for
the network transition
agree with much of what the FCC has adopted.

The FCC Order sets out three directions for the upcoming trials:

Voluntary Service-Based Experiments

The FCC asked providers to submit detailed proposals to test the
real-world applications of the new technologies they would like to substitute
for the traditional phone service Americans rely on. Every proposal will be
opened to public comment before the FCC decides whether to approve it.

Importantly, the FCC established that these initial trials will
not force customers onto new technologies. This is a huge triumph for
consumers. By making the trials voluntary for the individuals using the
network, the FCC is protecting those who depend on the existing network for its
reliability or ability to support services like Life Alert, fire alarms, credit
card processing, and internet access. Those who want to test out new
technologies are free to do so, while those who can’t risk moving onto an
untested technology remain protected.

The FCC also set out a list of specific conditions and
presumptions each trial proposal must meet, guided by the core values of the

  • For public
    safety and national security
    , the experiments must: preserve 911 and Next
    Generation 911 capabilities; immediately restore service if there is a public
    safety failure; continue to support national security and public safety
    systems; protect the network from cybersecurity threats; ensure adequate backup
    power; and report network outages.
  • To ensure universal access, the experiments must: maintain universal service;
    prevent any reduction in quality of service; ensure access for persons with
    disabilities; and protect specific populations, like the elderly, those with limited
    English proficiency, low-income communities, Tribal lands.
  • To promote competition, the experiments must: maintain wholesale access to
    competitors and maintain interconnection and intercarrier compensation.
  • Finally, to ensure consumer protection, the trials must protect consumer privacy; comply
    with truth-in-billing, slamming, and cramming rules; maintain local number
    portability; and preserve call routing reliability.

The FCC also required providers to give clear and timely notice
to customers of the experiments, and will make these trials “open data”
experiments to increase public input.

Targeted Experiments and Cooperative Research

The FCC also announced several more targeted experiments to
examine particular aspects of the network transition:

  • Rural
    Broadband and Phone Service.
    As we hear more interest from carriers in
    deploying fixed wireless services in rural areas, and more interest from
    consumers in all areas in obtaining access to fiber networks, the FCC announced
    experiments to use funds from the Connect America Funds to test different
    technologies in unserved areas. These tests will help us understand what
    technologies customers and anchor institutions actually prefer, what aspects of
    the network they value, and which business models could achieve robust
    deployment to everyone.
  • Experiments
    for the Transition and Persons with Disabilities.
    FCC is structuring and funding research to continue to improve relay services
    used by customers with hearing disabilities. This research will be conducted
    with other agencies like the National Institute on Aging.
  • Numbering
    The FCC is starting a telephony numbering testbed to explore
    technical options and opportunities in an all-IP network. This testbed would be
    an engineering “sandbox” that examines security, number authentication, traceability,
    efficiency, portability, reliability, competition, predictable dialing
    protocols for users, and emergency dialing protocols.

Ongoing Data Initiative

Finally, the FCC is exploring ways to improve its data gathering
efforts. This includes improving the consumer complaint process, conducting
structured observations of NG911 deployment and otherwise improving information
on key questions about consumer values. As part of this, the FCC will work with
state, local, and Tribal governments to better share data. The FCC also asked
for comments on how to deal with the “observer effect,” where entities change
their behavior because they know they are being watched, and is seeking comment
on experiments that examine the implications of the transition on health care.

The transition of our communications network to IP is a
tremendous undertaking, and it is critical that we understand how to
protect consumers and make sure the network continues to serve its users first
and foremost. The FCC’s proposed trials are necessary first steps to gathering
information about the transition, so it can arrive at the right policies that
continue to preserve our basic values throughout and after the transition.

Photo by Flickr user Kim Carpenter.