We’ve already seen one
failed experiment. Moving forward, the FCC needs to make sure that the trials
are valuable to all parties involved, not just the carriers.
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 how
technological changes to the phone network will affect Americans.
Yesterday we gave the FCC our two cents on the
proposal: apply PK’s Five
Fundamentals in designing the trials in order to ensure that the programs
produce meaningful data and include strong protections for consumers – who
won’t be able to choose whether or not to participate.
First, a Note on Verizon’s Failed Voice Link Trial
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 Commission should view Verizon’s Voice Link
deployment in Sandy-ravaged communities as a vivid example of how not to
run a pilot program, and a strong reminder of how any future pilot programs
must be handled responsibly.
After Hurricane Sandy damaged the copper
infrastructure in some coastal towns, Verizon decided to replace its
traditional wireline network with a fixed wireless technology called Voice Link.
The New York Public Service Commission has now
of complaints from residents who had their voice service involuntarily
changed to the experimental wireless network, and it is clear that Fire Island
residents really were depending on the services that Verizon’s new
infrastructure no longer supports, like calling cards, medical alerts, faxes,
internet access, and guaranteed network reliability (which is perhaps most
important in emergency situations).
Build a Responsible Pilot Program
Here are the elements that we see as essential
to creating a trial program that will provide meaningful information to the Commission
while also protecting the needs of customers of the participating carriers:
pilot programs need to be structured to gather specific data rather than
treated than 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 useful data that can inform
the Commission’s policy-making going forward.
Commission needs to make sure that the trials are transparent – both in the
process of designing the programs and in sharing the information gained through
the programs after completion. The phone network transition promises to impact
network uses across the entire nation, and it is vital that every interested
stakeholder have the opportunity to review, comment, on, and use the data
collected during the pilot programs.
important that the Commission collaborate with state and local entities in
designing and implementing the trials. Partnering with local public interest
groups and local government institutions will allow the Commission to determine
the best possible methods for informing consumers about the trials and for
soliciting their feedback, especially in areas with diverse geographic and
socioeconomic characteristics. It will also ensure that any state or local
regulations providing protection to consumers continue to operate throughout
Commission needs to have a clear plan for winding down the trials and ensuring
that consumers can return to their old service if they want. The Commission
also needs to be sure the programs include provisions to terminate the trials
immediately if problems arise causing serious harm to subscribers.
We Can’t Leave This Up
to the Carriers to Do on Their Own
Experimental transitions initiated by carriers
themselves are no substitute for structured pilot programs designed by the FCC.
If carriers can just launch their own private, unsupervised trials and control
what information reaches the public, the FCC won’t be able to get the type of
data it needs, and consumers who are forced to participate in the trials will
be at risk of losing access to crucial services upon which they currently
the FCC should apply PK’s Five Fundamentals for a successful phone transition
in implementing these trials:
- Service to all
- Interconnection and
- Consumer protection,
- Network reliability,
- Public safety
the Commission considers each particular trial, it should evaluate how that
trial serves or fails each of the Five Fundamentals, and keep adjusting its
pilot plans to ensure that this effort will put consumers first and prevent the
transition from becoming a step backward for any user.
A link to the full text of PK’s comments can
be found here.
Original image by Flickr user IronRodArt – Royce Bair.