Federal Communications Commission.
Notice.
In this document, the Technology Transitions Policy Task Force (Task Force) seeks comment on several potential trials relating to the ongoing transitions from copper to fiber, from wireline to wireless, and from time-division multiplexing (TDM) to Internet Protocol (IP). The goal of these trials would be to gather a factual record to help determine what policies are appropriate to promote investment and innovation while protecting consumers, promoting competition, and ensuring that emerging all-IP networks remain resilient and reliable. Towards this end, the public notice seeks comment on a set of potential trials, including targeted trials on Voice over Internet Protocol (VoIP) interconnection, Next Generation 911 (NG911) and the transition from wireline to wireless service in certain geographic areas. The public notice also invites parties in favor of conducting a trial in which one or more providers make a general switch to all-IP traffic in a geographic area to submit a detailed and comprehensive plan laying out how such a trial would work. It also seeks comment on whether other trials should be considered, such as additional numbering trials, trials to facilitate better access for persons with disabilities, and whether there are additional trials concerning the TDM to IP or copper to fiber transitions that should be evaluated. Finally, it seeks comment on how best to work with state, local and Tribal governments and how to ensure successful trials while also avoiding potential harmful impacts to consumers.
Comments are due on or before July 8, 2013. Reply comments are due on or before August 7, 2013.
You may submit comments, identified by GN Docket No. 13–5 by any of the following methods: (1) The Commission's Electronic Comment Filing System (ECFS) or (2) by filing paper copies. See Electronic Filing of Documents in Rulemaking Proceedings, 63 FR 24121 (1998).
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• Filings can be sent by hand or messenger delivery, by commercial overnight courier, or by first-class or overnight U.S. Postal Service mail. All filings must be addressed to the Commission's Secretary, Office of the Secretary, Federal Communications Commission.
• All hand-delivered or messenger-delivered paper filings for the Commission's Secretary must be delivered to FCC Headquarters at 445 12th St. SW., Room TW–A325, Washington, DC 20554. The filing hours are 8:00 a.m. to 7:00 p.m. All hand deliveries must be held together with rubber bands or fasteners. Any envelopes must be disposed of before entering the building.
• Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority Mail) must be sent to 9300 East Hampton Drive, Capitol Heights, MD 20743.
• U.S. Postal Service first-class, Express, and Priority mail must be addressed to 445 12th Street SW., Washington, DC 20554.
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In addition, one copy of each pleading must be sent to the Commission's duplicating contractor, Best Copy and Printing, Inc., 445 12th Street SW., Room CY–B402, Washington, DC 20554,
Patrick Halley, Acting Deputy Director, Technology Transitions Policy Task Force, at 202–418–7550, or by email at
The Task Force proposes to move forward with real-world trials to obtain data that will be helpful to the Commission. The goal
The Commission has a long history of using trials and pilot programs to help answer questions regarding technical concerns and to gather data and develop appropriate policy recommendations. Indeed, the Commission recently unanimously authorized a 6-month trial to examine providing interconnected VoIP providers direct access to telephone numbers. Stakeholders have also requested that the Commission initiate trials to explore technology transition issues.
In the spirit of these prior initiatives, we seek comment on a set of potential trials to assist the Commission in ensuring that policy decisions related to ongoing technology transitions are grounded in sound data.
Some parties have advocated a trial in which one or more providers make a general switch to all-IP traffic in a geographic area, potentially transitioning from wireline to wireless technology in part of the area, but also making a number of other simultaneous transitions. We have previously sought comment on this general approach. We seek further comment on this idea in the context of the three potential trials discussed above, including whether the trials discussed herein should be conducted in a single geographic area, if there is information to be gained from a general geographic trial that would not be gathered from the more targeted trials discussed here, and the costs and benefits of the alternative approaches. We invite parties in favor of conducting a broader geographic trial to submit a more detailed and comprehensive plan laying out how such a trial would work.
We also seek comment on whether there are other trials we should consider, such as additional numbering trials, trials to facilitate better access for persons with disabilities, and whether there are additional trials concerning the TDM to IP or copper to fiber transitions that we should evaluate. We also seek comment on the general structure and design of any trial, and legal and administrative issues. We recognize the important role that states and Tribes continue to play in these ongoing technology transitions and therefore seek comment on how to best work with state and local entities in selecting and implementing potential trials and ideas as to other ways that we can effectively coordinate with state and local agencies in this area.
We are mindful of the fact that, while participation in any trial would be voluntary for providers, all consumers in trial regions would likely be affected, either directly or indirectly. As consumer protection is a core principle guiding the work of the Task Force, comments in support of any trial proposal should address how best to ensure a successful trial while also avoiding potential harmful impacts to consumers.
We also seek comment on ways to obtain useful data in addition to trials. For instance, the Commission is currently collecting data regarding special access through a mandatory data request. Are there other data collections that the Commission should undertake to obtain data necessary to guide sound policymaking regarding the ongoing technological transitions?
Several commenters have urged the Commission to initiate a trial for VoIP interconnection to ensure that technical and process issues are understood and resolved. We seek comment on whether to conduct such a trial so that the Commission can gather real-world data on the need and scope for technical or industry standards for the exchange of voice traffic in Internet protocol formats. We note that interconnection for voice (and possibly other real-time services) using Internet protocols at the application layer is distinct from and raises different technical and administration issues than general peering and interconnection for layer-3 IP data services, and we emphasize that the trial we propose today does not reach layer-3 peering issues.
More recently, in 2012, the FCC's Technological Advisory Council (TAC) examined the issue of VoIP interconnection and concluded that, although “VoIP Interconnect[ion] is happening all over the world, at a rapid rate,” implementation in the United States has been “delayed” aside from the efforts of some cable companies and competitive local exchange carriers (CLECs). Finally, as noted above, the Commission recently adopted an Order and NPRM regarding providing interconnected VoIP providers direct access to numbers. Among other things, that item sought comment on the status of VoIP interconnection arrangements in the United States. We look forward to receiving updated information as we evaluate the framework for these potential trials.
We seek comment on these approaches. Should we allow providers to negotiate and, if they cannot resolve disputes, then no agreement is reached? Or, should there be a process for arbitrating or mediating disputes? If so, should the state be responsible for arbitrating the agreements, or should the Commission or an independent entity arbitrate or mediate any disputes? Should any VoIP interconnection agreements reached during the trial be the basis for future agreements or could doing so impact the negotiations during the trial? If we undertake a trial under the section 251/252 framework, should the existing rules be applied or should they be modified?
The NG911 architecture differs significantly from the legacy 911 TDM model. For example, the number and nature of hand-off points for 911 calls to the public safety emergency services IP network (ESInet) differs from the current approach of routing all calls through a selective router. Similarly, with nomadic, mobile, and over-the-top VoIP applications, conveying accurate caller location data to the 911 call center,
Any trial of this kind should provide data on both the challenges of transitioning from E911 to NG911 and the operational performance characteristics of NG911 call handling. Thus, we propose that participants in the trial document the design and conversion process, including effort and time required, and gather data on call handling performance, interoperability issues, location accuracy, and any system failures related to call or location delivery. We seek comment on how best to address these issues and whether there are other aspects that should be documented or evaluated.
Finally, we also seek comment on the impact of consumer migration to wireless and IP-based services that are dependent on commercial power and network resiliency and public safety services generally. Participants in the Commission's recent field hearings following Superstorm Sandy consistently raised this issue and the need to establish adequate back up power solutions. How should this issue be integrated into the Commission's technology trials and other data gathering efforts?
We seek comment on conducting trials to assess the impact on residential and business customers when they are transitioned from wireline voice and broadband products to wireless alternatives. We propose to compare wireline and wireless offerings across a number of dimensions, including: quality and terms of service, price, product functionalities, E–911 performance, accessibility options, reliability, and potential carrier cost savings in the delivery of voice and data services to higher cost areas. While there is potential for some service quality degradation if not properly transitioned, the move to wireless-only networks also could enable improved voice quality and reliability and broadband investment in areas not likely to be served in the near future with wireline technology, or at higher speeds than existing wireline offerings, among other potential benefits. We want to analyze the consumer experience, including challenges and benefits for consumers, of a wireless-only option as part of a trial. In this section we seek comment on how to structure any such trials.
We seek comment on whether customers that participate in such a trial should have the option of wireline or wireless service during the trial or whether the LEC should be able to require all customers in the LEC service territory trial area to move to a wireless-only product. We propose that customers would be informed of when they will be allowed to switch back to their previous wireline products and that they may do so at no charge for some pre-established period, including after the trial period end date. Furthermore, we seek comment on whether LECs participating in the trial should disclose any differences between a customer's existing wireline and new wireless service prior to the customer switching. These differences may include price, data usage allowances, terms of service, 911 capabilities (including location accuracy), accessibility, calling features, incompatibilities with fax machines or other customer premises equipment, or any other differences. We seek comment on whether such a trial would result in obtaining useful information and how long it should last.
In its petition, AT&T proposes that technology and policy trials be conducted at the wire center level. The record reflected a general support that this as an appropriate level of geography. Therefore we are considering a trial at the wire center level and seek comment on whether wire centers are appropriately sized for this specific trial or whether an alternative unit would be more appropriate. We also seek comment on what factors should be used to select trial markets.
We seek comment on whether LECs participating in a trial should collect network reliability measures for both their wireline and wireless product offerings in the trial areas. We seek comment on whether, in addition to the network reliability measures that the Commission currently collects for wireline services, participating carriers should submit such information on network reliability for all product offerings in the relevant trial area during the trial period. In addition to these metrics, we seek comment on whether providers should submit the number of dropped and blocked wireless calls and data sessions for participating customers. Furthermore, we propose that participants describe how they address service continuity issues in the event of a power outage through the use of battery backup and other measures. Should we collect alternative or additional network reliability measures? If so, what should these measures be? We also seek comment on the public safety and accessibility issues raised by these trials.
AT&T and others have proposed an “all-IP” wire center trial. We have already sought comment on this general proposal, and an extensive record has been compiled addressing it. Each of the trials discussed above—VoIP interconnection, NG911, and wireline to wireless—address aspects of AT&T's proposal. Are there other aspects of moving from TDM to IP that a geographic trial of the kind AT&T has proposed would elicit helpful data—such as the ability to transition special-purpose TDM services?
We invite carriers interested in pursuing such a trial to submit a more detailed, comprehensive plan of how such a trial would work, including the design of the trial, the data that would be collected, the rules that would need to be waived and the role of the states and Tribes. In presenting a detailed roadmap for how such a trial would work, carriers, at a minimum, should list: (1) All of the services currently provided by the carrier in a designated wire center that the carrier would propose to phase out; (2) estimates of current demand for those services; and (3) what the replacement for those services would be, including current prices and terms and conditions under which the replacement services are offered.
Are there other trials we should conduct that focus on consumer protection and universal service? Should we have a trial that focuses on how to improve access to communications services for low-income Americans? For example, as the transition from wireline to wireless rapidly progresses, an increasing number of Lifeline participants are selecting wireless as their preferred method of communication. Given these demographic shifts, and building off of the success of the
We also seek comment on whether we should have any trials that focus specifically on the delivery of services to consumers and communities on Tribal lands. We generally seek comment on any potential issues associated with trials taking place on the lands of American Indian Tribes, Alaska Native Villages, or on Hawaiian Home Lands.
We seek comment on the role of states and Tribal governments. We note that NARUC has created a Presidential Task Force on Federalism and Telecommunications to focus on many of these same issues related to technology transitions, and we are committed to coordinating as effectively as possible with this and other state efforts. We also note that the Commission's Intergovernmental Advisory Committee (IAC) has offered to play a role in working with states and localities on issues related to technology transitions. How should states and Tribal governments be involved in the trials? Should the NARUC Task Force, the IAC, or any other Commission advisory committees, be involved in the selection of applications or areas? Does it depend on the nature of the trial? Should states or Tribal governments be involved in selecting geographic areas? Should non-governmental consumer-focused organizations be involved in the trial selection process or the implementation and monitoring of trials?
We generally seek comment on how to work cooperatively with the states and Tribal governments with respect to each trial and the nature of their involvement, including how to address issues where the state commission lacks jurisdiction over IP-based or wireless services. We also seek comment on providing states and Tribal governments with access to data collected during the trial, and what role states and Tribal governments should have in analyzing the data and providing recommendations to the Commission.
We seek comment on the process of establishing, structuring, and gathering useful data from these possible trials. How should the Commission structure the trials to address concerns about incumbent LECs operating on “best behavior” during the trials? We seek comment on the process for selecting the geographic areas for the trials. We seek comment on the timing and duration of each trial. Should the timing differ based on the type of trial? How should each trial wind down, and what would be grounds for terminating a trial altogether before its anticipated completion date?
We seek comment on how to acquire the most useful data from these trials. What sort of reporting should we require from participants and what sort of automated or non-automated data collection would be useful in each trial? Should the Commission require trial participants to collect the same data in certain non-trial areas to allow comparison with a control sample? To what extent should the Commission gather quantitative data and when is qualitative data preferable? We seek comment on the usability of the trial data. What sort of protections should apply to potentially sensitive data? Should information be confidential, filed pursuant to protective orders, or generally open to the public? Should we, as the Commission required in the
We seek comment on whether any Commission rules or statutory provisions are implicated by the proposed trials. For example, entities participating in the wireline to wireless trial would need to file section 214 discontinuances. Section 214(a) of the Act requires common carriers to obtain Commission authorization before discontinuing, reducing, or impairing service to a community.
Pursuant to sections 1.415 and 1.419 of the Commission's rules, 47 CFR 1.415, 1.419, interested parties may file comments and reply comments on or before the dates indicated on the first page of this document. All comments are to reference GN Docket No. 13–5 and may be filed using: (1) The Commission's Electronic Comment Filing System (ECFS) or (2) by filing paper copies. See Electronic Filing of Documents in Rulemaking Proceedings, 63 FR 24121 (1998).
Filings and comments are also available for public inspection and copying during regular business hours at the FCC Reference Information Center, Portals II, 445 12th Street SW., Room CY–A257, Washington, DC 20554. They may also be purchased from the Commission's duplicating contractor, Best Copy and Printing, Inc., Portals II, 445 12th Street SW., Room CY–B402, Washington, DC 20554, telephone: (202) 488–5300, fax: (202) 488–5563, or via email
This matter shall be treated as a “permit-but-disclose” proceeding in accordance with the Commission's