What’s In a Pilot Program?

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Pilot programs for the phone network transition must first and foremost protect everyday consumers.


As the conversation about the phone network transition to Internet Protocol (IP)-based technologies continues, the Federal Communications Commission (FCC) is figuring out how to construct pilot programs to collect data about certain aspects of the transition. We at Public Knowledge have emphasized how this transition must be a step forward--not a step backward--for everyone. That applies just as much to the proposed pilot programs as it does to the overall transition.

The FCC's pilot programs must first and foremost protect the everyday Americans who use the network for business, to communicate with loved ones, and to call 911 during emergencies.

Unfortunately, the waves of consumer complaints that have poured out over Verizon's Voice Link deployment in Fire Island, NY show all too clearly that we can't simply assume that new technologies will offer services as good or better than what customers had before. And when customers have no option to stay with tried-and-true technologies when an untested technology turns out not to support the features they need (like how Voice Link does not support consumers' medical alert systems) or offers sub-par access to 911, the phone network transition could even threaten the health of consumers. This is not to say that new technologies don't offer the opportunities for new and better services, but if we want the next networks to be a true step forward for everyone we must demand it.

This is why the FCC's pilot programs must include strong protections to make sure no one is left behind. The pilot programs should operate under the same basic consumer protection rules that consumers have come to rely on, like truth-in-billing and privacy rules. When possible (like in a wireline-to-wireless trial), customers should be able to opt-out if the new network fails to provide the reliability or features they need. And the FCC must have predetermined mechanisms to recognize when the trial is harming consumers and shut the trial down to prevent further damage.

These may seem like simple, common sense ideas, but some stakeholders are instead asking the FCC for pilot programs that let carriers try what experiments they want (with real people as the guinea pigs) without the FCC fulfilling its traditional role of overseeing the process and protecting users.

For example, AT&T's comments propose a "trial" that is mandatory, permanent, and implements all aspects of the IP transition at once after the FCC has eliminated the rules that would protect everyday Americans if something went wrong. That's not a trial, that's data-free deregulation. Any proposal that essentially asks the FCC to let carriers dive head first into significant network changes without a lifeguard on duty can't actually be treated as a serious proposal.

AT&T also continues to promise a forthcoming plan that actually sets out of the details of the trial it would like to conduct, and we welcome the opportunity to review and publicly discuss that plan--after AT&T has actually submitted it. Until then, the FCC should focus on the actual proposals before it: specific, narrowly designed pilot programs that are carefully constructed to gather data while protecting consumers. That is, after all, the point of pilot programs--gathering specific facts that inform policy.

These trials can't, however become a vehicle to circumvent the broader policy debate over the transition and leave consumers worse off. That is why the FCC should continue on its course to constructing carefully circumscribed trials that gather specific data and put consumers first. After all, the entire point of this transition is to build new networks that serve everyday Americans better than the old networks did. We must all demand that our phone network continue to be a network you can count on at every step along the way.

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