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The FCC is currently considering and seeking comments on two providers’ service-based experiments for transitioning our current phone network to newer IP-based technology. Public Knowledge has supported the use of carefully constructed trials to responsibly gather data that will help inform policymakers’ decisions on how best to ensure the phone network continues to serve certain fundamental values, such as service to all Americans, interconnection and competition, consumer protection, network reliability, and public safety during and after the transition. The FCC should now use the lessons learned from Fire Island to ensure the network transition trials include robust consumer protections and lead to objective information that actually informs the policies guiding the transition.
Broadly speaking, there are two main points to keep in mind during these trials. First, the entire purpose of these trials is to collect specific objective, usable data that will help inform policy decisions. If we fail to rigorously collect reliable and objective data, or allow the trials to be hijacked and turned into phase-ins of new technologies before we fully understand them, the trials will have failed. Second, the trials must continue to protect the people who will be living in the testbed communities. We need to learn about these new technologies, but we also must make sure we do not compromise everyday Americans’ ability to use the network to reach loved ones, conduct business, or call 911 while the trials are going on.
To achieve that second point of continued consumer protection, it is useful to learn from the experience of Fire Island residents last year, when Verizon briefly attempted to retire its copper lines and move an entire community over to its fixed wireless voice-only service Voice Link after Superstorm Sandy struck in October 2012.
The proposed permanent switch to Voice Link prompted unprecedented consumer outcry, particularly after the New York State Public Service Commission (NYPSC) required Verizon to publicly file its Voice Link Terms of Service. As hundreds of customer complaints revealed, Voice Link does not provide its own power—as the copper network had—and is not compatible with alarm systems, medical monitoring services, fax machines, credit card machines, collect calling services, and some international calling cards. Unlike the copper network, Voice Link does not provide internet access, and Voice Link’s Terms of Service disclaimed liability if 911 calls failed to go through due to network congestion.
Although Verizon ultimately backed off from its Voice Link push and deployed fiber to Fire Island, we will eventually have to address the current limitations of the technologies carriers wish to use to replace traditional phone service. For example, the wireless home phone offering AT&T wants to deploy in trials in Alabama and Florida has many of the same limitations Verizon’s Voice Link does, like having no ability to self-power and being currently incompatible with medical alerts, security alarms, credit card processing services, 800-number services, dial-around calls, and collect calls (for details see page 14 of their operating plan, including the footnotes).
That’s not to say we can’t collect more information about AT&T’s wireless home service and figure out whether and how it can be made comparable to or better than the basic service people rely upon now. But it means we should approach this and other trials with a mind to the lessons we learned during the ill-fated Fire Island deployment.
So what are those lessons?
New Communications Technologies
- Customers can recognize when new services are inferior to what they had before. Fire Island residents’ outcry over the limitations of Voice Link make it clear that customers are paying attention when carriers transition their networks, and customers know when new “next generation” networks don’t actually serve all of their needs as well as the previous networks did.
- New, untested services can have serious problems. Verizon marketed its Voice Link service to customers as being basically the same as the phone service they had before, but customers soon discovered it had serious limitations compared to the copper-based phone service they had always relied on.
- Supposedly “outdated” technologies can still have a significant number of people relying on them. We can’t dismiss the value of pre-existing technologies simply because the percentage of the population depending on them is below some arbitrary threshold of importance. A minority of the population uses wireline phone service to support their Life Alerts, but that percentage will fight for Life Alert support as if their lives depend on it—because they do. And while the percentage of the population solely using landline phone service for their communications has decreased, those users have stuck with the copper network precisely because it offers benefits to them they can’t find anywhere else.
Transitioning to New Services
- Do not use natural disaster victims as guinea pigs for a new type of communications network. When residents are rebuilding or repairing their homes and local businesses are deciding whether it is worth it to rebuild their presence in a community, reliable access to voice and internet services is a prerequisite for a strong recovery.
- Forcing conversion to new services upsets customers. The best way to transition these customers onto a new network is to offer them compelling solutions that continue to serve the same needs as the previous network, not forcing customers to migrate to new services without knowing whether their needs will be met on the new network.
- Carriers need guidance on how to repair or replace their networks after natural disasters. This is why Public Knowledge and 18 other public interest organizations have filed a letter with the FCC asking the FCC to start a proceeding to provide this guidance, so that all carriers—and more importantly, all Americans—know what to expect when rebuilding their communities.
The Role of Regulators
- Both federal and state agencies need to be able to protect consumers. Without the New York State Public Service Commission (NYPSC) and the FCC providing regulatory oversight, nothing would have stopped Verizon from rolling out whatever service they thought “good enough” for a local community, regardless of what the customers wanted or needed. Considering that trials are being proposed in heavily deregulated states like Alabama and Florida, the trial designs will need to compensate to make sure the voice o the local community is heard.
- Federal and state agencies are critical in making carriers explain their plans to the public. Without the NYPSC and FCC, the public may never have obtained access to this level of information, which would have hobbled their ability to make well-supported arguments against the forced conversion to Voice Link.
- Customers can make a difference when they speak out to their governments. This is why we need to make sure the trials have robust and reliable mechanisms for receiving and responding to consumer feedback. The best way to know whether a new technology satisfies consumers is to ask whether it satisfies consumers.
As more communities across the US find themselves facing the advent of new communications networks that may not have all of the capabilities and protections consumers are accustomed to on the traditional phone network, users, regulators, and carriers must remember the lessons we can learn from the events in Fire Island. The phone network transition holds great potential, but it is up to the public and their representatives in government to make sure the transition is a true step forward and the network continues to serve users first.