Today is a step forward for the 303 million people residing the in U.S. who depend on some kind of phone service for their personal, business, and emergency communications. This morning the Federal Communication Commission voted to move forward on two proposals that examine the future of the phone network and 911 emergency services. This vote builds on the FCC’s bipartisan, unanimous consensus around core network values that include public safety, universal access, competition, and consumer protection.
Public input to the FCC will be instrumental in developing federal guidance for the phone network transitions that protects consumers and vulnerable populations. The open comment period is an opportunity for people who care about phone service to make their voices heard. Rural voices, grassroots organizations, consumer advocacy groups, and state agencies who have been vocal on this issue should continue to highlight the importance of a reliable, affordable, and universally available network that includes all communities. This stakeholder input will be critical in ensuring that the digitally underserved do not become the permanently unserved.
The FCC’s Next Steps to Protect the Network Compact
In 2012, AT&T’s announced that it would be upgrading its Plain Old Telephone Service (POTS) to all IP architecture. Since then, Public Knowledge has worked with other consumer advocacy groups, technology policy experts, and advocates for the elderly and disabled, as well as providers to establish network values. These values have been at the core of PK’s work as we urge Congress and the FCC to establish guidance for carriers and protections for consumers through the technology change used to provide basic phone service.
In May of 2014, Public Knowledge partnered with The Utility Reform Network (TURN), as well as many other state and grassroots advocates to call on the FCC to investigate nationwide reports of consumers being involuntarily moved to fiber or IP-based services, which failed to serve all of the consumers’ needs or were more expensive. Reports from California, Maryland, Illinois, the District of Columbia, and New York reveal a narrative of consumers being left behind by network upgrades of major carriers, including Verizon, due to inadequate notice of network changes, lack of consent, poor service quality, and lack of comparability to copper based service.
We emphasized the importance of FCC leadership in protecting people’s access to basic phone service in states where legislatures have removed state-level authorities’ ability to enforce obligations or collect consumer complaints. The removal of this authority is part of a larger deregulation pattern across states, pushed by carriers, to remove consumer protections and rural call completion requirements for rural communities. Many of these vulnerable populations do not have the luxury of switching providers and depend on the reliability of their local phone-service provider.
In response to these concerns, today’s vote signifies the next long awaited step establishing the guidance consumers and carriers need to ensure the success of the phone network transition. The item will propose a carrier checklist for network changes, seek comment on copper retirement rules, and clarify the customer complaint process. The item examines whether the FCC should adopt specific battery backup requirements, which are critical in power outages and natural disasters. Through this proposal, the FCC will consider the appropriate division of responsibilities between carriers and consumers for public education surrounding the limitations and requirements of battery replacement.
The proposal is important for competitive providers who need to maintain affordable access to wholesale services they depend on to deliver innovative services and bring competition to the market. Preserving competitive access is important for small businesses, libraries, and other entities that rely on communication services at reasonable rates. These entities should receive sufficient notice and comparable replacement services when copper networks are shut off.
Finally, the FCC clarified when carriers need to file for FCC approval to transition their networks. In examples like the confusion surrounding Verizon’s post-Sandy Voice Link deployment in Fire Island and other carriers’ legal filings at the FCC, it was evident the Commission needed to clarify that carriers do indeed need to file when, for example, changing their networks from traditional copper-based service to untested, voice-only fixed wireless services. In this ruling, the FCC took a functional, common-sense approach to interpreting the relevant law, which protects consumers while giving all stakeholders more certainty.
Despite Increased Wireless Adoption, People Still Care About The Phone Network
A recent survey and report commissioned by Public Knowledge examines how and why millions of Americans rely on existing network technologies. The survey results confirm it is important for policymakers to ensure people relying on the network are not left behind in the transition. Despite widely reported trends regarding smart phone adoption and households eliminating their landline, our survey concluded most Americans still have a landline at home. Roughly 5% or 15 million people rely solely on copper, including elderly users, small businesseses, and competing carriers.
Among people who have both a cell phone and a landline, 65% say their calls at home are mostly through their landline, with this number increasing to 72% for households with income below $25,000. 82% say they keep their landline for its reliability, 73% for its connection quality, 45% because it will works during power outages and 36% cited either fax machines, medical alerts, or home security systems as a reason to keep it. Users who are online see the phone as an anchor for household and emergency communications, with 89% of those users believing it is an important household service.
Proposal Examining Future of 911 Should Protect Life Saving Service
This morning the FCC also voted on proposed rules to ensure reliability and accountability in 911 service. We’ve already seen warning signs of what can go wrong without clear guidance for transitions. Last April, a preventable software error by a third-party vendor led to a 911 outage that impacted seven states and blocked over 6,600 calls to 911 over 6 hours. The second proposal discussed at today’s meeting will seek comment on the how the FCC’s rules can keep pace with changing technology in four key areas. These include providing public notification of major changes to 911 services, ensuring IP-based 911 services are reliable and accountable to the public, promoting situational awareness and coordination during 911 outages, and expanding the FCC’s 911 reliability certification requirements.
The Coming Policy Debate
To be clear, this is a policy debate as much as technical one. Any future failure of the phone network, or elimination of service for communities who previously had access before a technological transition, will be the fault of bad policy. We have an opportunity to preserve the values that expanded phone service from coast to coast and cannot be the first industrialized nation to step back from a communications network that effectively served all households for the past 100 years.
Public Knowledge will continue to urge the public and Congress to support the FCC’s step forward in protecting the phone network’s core values, and ensuring that this technology transition does not widen the communication gap in this country but serves instead as an upgrade for everyone.
Image credit: Flickr user lokate366