Pilot Programs for the Phone Network Transition Must Protect Customers First
Pilot Programs for the Phone Network Transition Must Protect Customers First
Pilot Programs for the Phone Network Transition Must Protect Customers First

    Get Involved Today

    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
    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
    received hundreds
    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).

    How to
    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:

    1. The
    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.

    2. The
    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. 

    3. It’s
    important that the Commission collaborate with state and local entities
    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
    the trials.

    4. The
    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:

    1. Service to all
    2. Interconnection and
    3. Consumer protection,
    4. Network reliability,
    5. 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.