What We Need to See in a Pilot Program Proposal
What We Need to See in a Pilot Program Proposal
What We Need to See in a Pilot Program Proposal

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    Carriers proposing phone network transition pilot programs must explain to the Federal Communications Commission and the public how they’d like to run a trial in meaningful detail before we can even begin to consider their ideas.

    Last week we talked about some key consumer protections that must be included in the FCC’s pilot programs to test-run specific aspects of the phone network transition. In addition to proposing certain pilot programs itself, the FCC used its Public Notice to ask any carriers and other stakeholders that want to see other types of pilot programs submit detailed plans explaining exactly what those trials would entail.

    In part, this seemed like a response to AT&T, which has been asking the FCC to let it run trials since last November but has yet to give any meaningful details about what these trials would actually look like, what information they would give us, and how they would be conducted.

    AT&T continues to promise that at some point it will submit an actual trial proposal to the FCC, but since we’ve yet to see that proposal it could be useful now to go through what kind of information needs be included in any forthcoming pilot program proposal so the FCC and the public can evaluate the merits of the proposed trial.

    So what actually needs to be in a pilot program proposal? There are a few basic categories of information that AT&T or any other stakeholder proposing a trial would need to set out so the FCC and the public can figure out whether the proposed trial would responsibly collect information to guide policy decisions during the transition.

    First of all, a trial proposal needs to specify in detail what technical data the trial would collect and how this data would be useful in setting policy in the phone network transition. Collecting useful information that informs the FCC’s policy is, after all, the entire point of the trials. It’s not enough to simply promise that a proposed trial will teach us all sorts of wonderful lessons–anyone proposing the trials needs to actually spell out what specific data the trial will collect so the FCC can determine the usefulness of that data and weigh it against the costs and risks of the trial.

    Very similar to detailing what information the trial would glean, a pilot program proposal must explain–in detail–what participating carriers would actually be doing during the trial. What changes would they make to their networks? What parts of the network would be impacted by the trial? Would consumer equipment be affected, and how? Would the trial involve changing contracts between carriers? If so, how would those changes be implemented and supervised? What changes would be made relevant to 9-1-1 services, or internet access, alarms, medical alerts, or other services that run over the network?

    A trial proposal must also include a plan for identifying and notifying customers who would be impacted. The notice should explain what changes the trial will make to their network and tell the customer who she can contact to give feedback on the trial or opt-out. Similarly, the proposal should explain how the carrier will work with local and state officials before and during the pilot program.

    And of course, a trial proposal must establish the mechanisms by which the FCC could identify serious unforeseen problems during the trial and shut it down to protect consumers. Or, if the trial operates according to plan, the trial proposal should explain how the trial will eventually end. Will consumers have the option to return to the network they had before? Will all customers be returned to the existing network, or will they be able to continue using the new infrastructure set up during the trial?

    A trial proposal wouldn’t be complete without explaining how it would collect consumer feedback about the network changes. How would the carrier solicit feedback from users? What questions would the carrier ask users? Who would the carrier work with to develop its feedback mechanisms?

    And finally, a trial proposal must explain how the information it collects will be made available to the public. Will the FCC be the depository of all information from the trial? How and when will the public gain access to the data? To what extent will this information be mediated or selected by the carrier?

    As you can see, a pilot program proposal will need to include a fair amount in the way of detailed plans before we can even begin debating its merits. This is, of course, absolutely reasonable when you recall what’s at stake here. Real people are depending on these networks to conduct business, contact loved ones, and call for help in an emergency. If the FCC is going to let carriers make significant trial changes to the network so many are relying on, the FCC needs to know exactly how the trial will happen and what we will gain from it.

    If we want to talk seriously about new pilot program proposals, we must move past carriers simply asking the FCC to delete all of its rules and let the carrier do what it wants without any supervision. A serious pilot proposal will focus on the details of the work to be done, not the contents of a carrier’s deregulatory wish list. The FCC should expect no less than these basics from any future pilot proposal if it wants the pilot programs to actually move the debate over the phone network transition forward.