Moving Forward on The Phone Transition: Trials and Conclusion
Moving Forward on The Phone Transition: Trials and Conclusion
Moving Forward on The Phone Transition: Trials and Conclusion

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    Yesterday we recapped the transition of the phone network thus far and touched on what to expect. Today we discuss the technical trials and what happens next.

    Technical Trials:

    For those unfamiliar with the terminology, a “wire center”
    is the place where all the wires for telecommunications service in a specific
    area come together. That’s not just all the residential subscribers on the
    AT&T system. It’s the place where AT&T exchanges traffic with the other
    providers (such as the local cable operator and whoever offers cell service),
    the 9-1-1 access point, and the source of “special
    access” circuits
    for enterprise customers and other carriers.

    The argument about trials has unfortunately
    broken down largely into two sides
    . AT&T and its supporters, who want
    to see AT&T convert a wire center under terms defined by AT&T, and
    everyone else, who thinks we don’t need trials at all. Public Knowledge
    supports well constructed trials that actually further the debate. We’ve
    written at length on our problems
    with the current AT&T proposal
    and what we’d
    like to see in a real set of technical trials

    Wheeler’s blog post
    indicates that he intends for the FCC to authorize “experiments,” and focuses
    on numerous details that such experiments would need to cover – such as
    reporting requirements and consumer notice. I take from this that Wheeler would
    prefer to start with something less broad than “lets convert an entire wire
    center and see what happens.” At the same time, there are definitely going to
    be technical experiments of some kind, so everyone who insists on the “no
    trials no way no how” position might want to reconsider that and start thinking
    about what limits they feel they need to prevent AT&T from creating ‘facts
    on the ground’ that would pre-judge the transition.

    Also of note, Wheeler makes it clear he plans to run the
    experiments concurrent with digging into the legal and policy questions. Trials
    are not going to be a delaying tactic either to delay essential policy
    decisions while AT&T creates facts on the ground, or for those who don’t
    want to see the IP Transition move forward.

    Other Policy
    Specifics Up For Grabs.
    Wheeler’s blog post lists the other policy
    specifics that remain up for grabs. Most notably the question of Commission
    authority. I read this as a challenge to those who want the Commission to avoid
    classifying voice-over-IP (VOIP) as a Title II telecommunications service. “Look,”
    this blog post seems to me to be saying. “We’re going to have rules to make
    these values a reality. Maybe not the same rules we have now, but some kind of
    rules. That means we need a clear basis for authority. If you don’t want Title
    II, you need to come up with something else that will work.”

    Also up for grabs are what, specifically, the new rules will
    be. Wheeler very carefully does not tip his hand on this question – which is of
    course what everyone in D.C. really wants to talk about. Instead, Wheeler believes
    the Commission Order in January will “set forth the
    best process
    that the Commission can initiate so that, in parallel, it
    may decide the legal and policy questions raised by this network revolution.”
    (Emphasis added.)

    In other words, those expecting to see things
    like “will we have mandatory interconnection for IP-based calls” decided in
    January are likely to be disappointed. The January Order will likely queue up
    important questions like these, with a method for how to decide them. It may
    have some tentative conclusions and proposed rules, but I believe – reading the
    tea leaves here — it will focus heavily on exploring the right overall

    Which, as we at PK have repeatedly urged, is
    the right way to go. The FCC needs to kick this up to a Commission level,
    assert control, and start moving us down the path of phasing out the old
    technology. But the process is sufficiently large and complicated that any
    attempt to grapple with it seriously quickly gets bogged down in a hundred
    details of equal urgency. Worse, as we have already seen with problems like rural call
    and caller i.d.
    , unexpected problems will keep coming up
    throughout the transition.

    So at this stage, we need a road map for how we
    plan to transition the phone system rather than simply a bunch of random
    decisions that we hope work out for the best. That doesn’t mean endless study
    and contemplation. Even in the January Order, I would expect to see some
    decisions on how to move forward. But don’t expect to see a master document
    that resolves all the outstanding issues.

    What Happens Between Now And the January FCC Meeting?

    Well, I expect a fair amount of lobbying of the FCC –
    particularly after the December 12 task force presentation. We will also
    undoubtedly see members of Congress starting to weigh in on this – probably
    focusing on specific hot-button issues.

    The big unknowns are the states, the local governments,
    federal agencies and Indian Tribes. So far, to the extent these constituencies
    have weighed in at all, it has teneded to be at a high level policy concern
    (see this
    most recent letter
    from the Small Business Administration Office of
    Advocacy, for example). Wheeler notes in his blog post that the FCC needs to
    develop outreach strategies to these branches of government for them to
    consider their needs as consumers of telecommunications services. How that
    plays out remains to be seen, since no one has really focused on it until now.


    After a long slow start, things on the phone transition appear
    to be picking up speed. As I’ve noted
    since first discussing this topic
    , the broad nature of this process and the
    lack of any central proceeding makes it difficult for people to focus on the
    decisions that need to be made. Hopefully, that will now change.