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In May, the FCC solicited comments on a proposal to implement a series of pilot programs relating to ongoing transitions in the phone network. The proposed trials are intended to give the Commission a better understanding of the effects of these changes, including VoIP interconnection and transitions from wireline to wireless service and from copper to fiber.
Yesterday, Public Knowledge filed comments with the FCC in response to the proposal. The filing urges the Commission to apply PK’s Five Fundamentals in designing the trials in order to ensure that the programs are carefully designed to produce meaningful data and include strong protections for Americans – who won’t be able to choose whether or not to participate.
The following can be attributed to Harold Feld, Senior Vice President:
"It's hard to think about the Commission's proposed trials without acknowledging that we are already witnessing one carrier in the midst of its own failing "pilot program" in Fire Island, New York. The public outrage expressed in the New York Public Service Commission's (NYPSC) proceeding on Verizon's Voice Link deployment shows a vivid example of how not to run a pilot program to the FCC. This is a strong reminder that future pilot programs must be handled responsibly.
"The pilot programs need to be carefully circumscribed to gather specific, useful data rather than treated as policy-setting processes in and of themselves. The Commission must not let the trials become a glide path to deregulation; they need to structure the pilot programs so that they provide meaningful and useful data that can inform the Commission’s policy-making going forward. The trials must also be transparent, include participation from state and local entities, and have clear mechanisms for shutting down the trials if the transition creates unanticipated harms to the public.
"In designing the trials, the FCC should apply PK’s Five Fundamentals:
- Service to all Americans
- Interconnection and competition
- Consumer protection
- Network reliability
- Public safety.
"As the Commission considers each particular trial, it should evaluate how that trial serves or fails each of the Five Fundamentals to ensure that the trials produce the sort of meaningful data the Commission needs to guide its policy-making without causing harm to the American public."
A link to the full text of PK’s comments can be found here.