The FCC Needs a Framework for the Phone Network Transition First


As the debate surrounding the technological transition of the public switched telephone network (PSTN) to an all-IP network continues, it’s becoming fairly obvious that the guardians of the phone network need to handle this transition by establishing fundamental principles to guide our country’s policies moving forward. Today, Public Knowledge filed reply comments with the Federal Communications Commission urging the FCC to do just that.

Already, many different stakeholders have submitted specific requests to the FCC to either keep or eliminate particular rules. Even at this early stage, we’re seeing unanticipated complications pop up, like Federal Aviation Administration service providers’ reliance on the traditional network, concerns for alarm systems that are geared to work on the existing infrastructure, and the need for the new IP-based phone networks to continue to improve access for users with hearing disabilities. There will likely be many other examples of uses that depend upon the current network infrastructure in particular ways that have until now flown under the radar, and we must be ready with a framework that can handle those surprises.

A single, principled framework would also help the Commission evaluate the proposals of all of the many parties in a deliberate, coherent way. That way, instead of just arbitrating between the wish lists of the many companies involved in this transition, the Commission can actually move forward based on affirmative principles that reflect the fundamental values of our national communications policies.

In our replies we’ve also noted that Comcast—and Comcast alone—has proposed complete deregulation of the phone network after the technological transition. As PK’s Harold Feld has so aptly explained, this is a sobering reminder of how the Commission must remain on alert for carriers trying to use the transition as an opportunity to leverage their market share against smaller companies and consumers. If companies try to handle the phone network the way they treat IP interconnection or subscription video services, disputes could easily prevent consumers from using the phone network to contact emergency 9-1-1 services, conduct business, and reach out to loved ones. The Commission cannot wait for disaster to strike before it affirms that every American can expect the post-transition network to continue to offer a basic level of network reliability and public safety services.

At the end of the day, the Commission must adopt a framework that lays out the fundamental principles that will guide every aspect of this transition. In a previous filing, PK proposed that the Commission establish five fundamental principles for guidance, focused on service to all Americans, interconnection and competition, consumer protection, network reliability, and public safety. It’s encouraging now to see signs from the FCC supporting similar principles. The Commission must follow through with these principles to ensure that the phone network continues to attend to the same social needs and goals that we have always expected our communications network to serve.

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