The FCC Gets Down to Details in IP Transition Trials

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The 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:

(1) 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 network.

  • 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.

(2) 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. The 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 Testbed. 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.

 (3) 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.

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