Drilling Down the Details for Pilot Programs

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Public Knowledge is putting forward its recommendations for useful, consumer-focused trials for the phone network transition.


As the Federal Communications Commission (FCC) moves closer to conducting trials to test certain aspects of the phone network transition, Public Knowledge has been doing more thinking about what those trials should actually include. Today PK submitted an analysis prepared by CTC Technology & Energy [pdf] identifying particular attributes that should be tested during the trials (cover letter here and one-page summary here).

Where Are We Now?

As Harold has explained in more detail, our phone network is currently in the middle of a massive transition from traditional technologies to IP-based systems and wireless networks. The FCC, now headed by new Chairman Tom Wheeler, is preparing to set up trials to evaluate new technologies and determine whether and how those technologies can be used to replace our traditional phone system.

We at PK have supported the trials, but repeatedly cautioned the FCC that the trials must be narrowly designed and carefully executed or else they would risk derailing consumer confidence in the entire transition. We emphasized that the trials should be used strictly to gather facts, not to set policies, and the trials themselves must have consumer protections to support the customers who will be participating in the experiments. 

The trials cannot and should not answer policy questions in and of themselves, but should ensure that new technologies can continue to support our values. The trials do not determine what those values are, but if done correctly can give us useful information about how to serve those values. This also means that the trials should be designed to make an honest, thorough examination of the technology at issue. The trials should not shield us from asking the hard questions about how new technologies operate across the board, not just when they are functioning at their best.

Recommendations for Technical Trials

Because PK believes that technical trials are important to ensure that the transition of the PSTN from circuit-switched to packet-switched IP technology goes smoothly for all users, PK has submitted to the FCC an analysis prepared by CTC Technology and Energy, an engineering and business consultancy firm, on PK’s behalf. CTC prepared this report for PK on a pro bono basis and, like PK, CTC does not have a financial stake in the outcome of the PSTN transition.

CTC has identified ten attributes that require particular testing during the trials:

  1. Network capacity, 
  2. Call quality, 
  3. Device interoperability, 
  4. Service for the deaf and disabled, 
  5. System availability, 
  6. PSAP and 9-1-1 access, 
  7. Cybersecurity, 
  8. Call persistence, 
  9. Call functionality, and 
  10. Wireline coverage.

The FCC should examine each of these areas during its trials in order to ensure that we obtain the most useful data possible before we make any decisions that would impact the future of the network.

The Trials Must Be Voluntary

Additionally, any trials must be voluntary for the users involved. Especially when we are first conducting trials and don't quite know how they will turn out, it would be insane to involuntarily convert users depending on traditional technologies to support their heart monitors or Life Alert systems when we don't know if those features will work on the new networks or if the new networks are reliable enough for such important applications.

We've already seen some glimpses of what can happen when entire populations--regardless of each individual's specific needs--are forced to convert to new untested networks. It turns out that when residents and local businesses can't rely on new technologies to run their medical alerts, security systems, credit card readers, or fax machines, they get really upset. The same goes for when they can't rely on the new network to provide internet access or connect to 911 reliably. For example, when Verizon deployed Voice Link to replace its copper wireline service in Fire Island, the outcry of hundreds of residents (and inquiries by the FCC and New York Public Service Commission) eventually persuaded Verizon to offer fiber in addition to Voice Link.

Once we have found solutions to users' legitimate concerns, then carriers can begin the process of switching those customers over to new networks. But for now, the purpose of the trials is not to see whether users can adapt to a new network technology with diminished capability, but to ensure that new technologies continue to serve users' need.

The Trials Must Be Reversible

Finally, it's important to remember that these are trials, and the FCC must therefore make them reversible. A trial that can't be undone is not a trial at all, and it spells disaster for the customers participating in the trial if something goes wrong. Specifically, this means that carriers must not remove, destroy, or disable existing equipment and infrastructure and should retain the capacity to bring it back online.

Especially if a trial involved shutting down or changing a wire center, where local providers exchange traffic with each other, an unanticipated problem in the trials would have wide-ranging consequences. It could shut down access to public safety answering points for 911 service, and may impact the functionality of local cellular providers and cable operators. The effects would even radiate far beyond that particular wire center. People wouldn't be able to call into the impacted area, and it isn't foreseeable what broader impact a network failure might have on other wire centers. It is the nature of a network that it is interconnected, and an unanticipated technology failure in one wire center may have ripple effects in other wire centers.

Running permanent “trials” would also pre-judge the outcome of the pilot programs with regard to the adequacy of the technologies tested. If we don't know whether a new technology will be good enough to serve all of the public's varied needs, how can the FCC give the go-ahead for a carrier to impose it on a community forever?

Especially at this early stage, it is critical that the trials be conducted responsibly. If trial procedures are insensitive to the real and legitimate needs of consumers and other end-users, they could undermine public confidence in the transition as a whole. With these qualifications, PK is supports responsibly-conducted technical trials, which will be a useful way for the public and policymakers to find ways to ensure that the phone network transition serves consumers first.

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