The IP Transition: From Phone to Fiber

The New Network Compact: Making the IP Transition Work for Vulnerable Communities

The U.S. finds itself on the verge of a bold digital opportunity. The growing use of Internet protocol (IP)-enabled communications networks in this country could give every American -- regardless of zip code, race, disability or income -- a chance to tap into a world where voice, video and information are available faster and in more and better ways than ever before. However, ensuring that prospect exists for all remains a major hurdle.

The Federal Communications Commission is now in the beginning stages of what will be a years-long process to improve the nation’s infrastructure to better suit America’s 21st century communications needs. But what will become of the tens of millions of Americans who already face hurdles in accessing existing telephone and broadband networks? How can we ensure them easy and affordable access to future networks? Will everyone be able to tap into robust, resilient, fast and affordable IP networks or have access to affordable and competitive voice and video services that take advantage of the IP network infrastructure? Eventually, all telecommunications infrastructure likely will be IP-based. In order to ensure that everyone will have access, policymakers will need to take pragmatic steps to understand the opportunities and barriers; ensure that everyone can access benefits; and ensure that our newest technologies continue to support some of our oldest values.

On January 30, 2014, the FCC invited voluntary IP transition experiments meant to ensure that the nation’s communications networks continue to provide the services consumers want and need. The trials would be voluntary and ensure that no consumer loses access to current services in the process. FCC Chairman Tom Wheeler pointed out that these are not technical trials -- "We know how to build an IP network," he said. Instead the FCC was framing the experiments as a way to ensure that the traditional values embedded in telecommunications policy continued through these transitions. Chairman Wheeler said consumers have come to expect certain things, and a right to expect those things, from their networks.

The FCC hoped to address:

  • The level of interest in deploying high-speed scalable infrastructure;
  • The characteristics of areas where service providers would offer wireless data services at prices comparable to urban wireline carriers;
  • How anchor institutions would be impacted; and
  • How working with other organizations can advance shared objectives of deploying next-generation networks.

The experiments would gather information in three broad areas:

  • Service-based experiments: Providers were invited to submit proposals to initiate tests of providing IP-based alternatives to existing services in discrete geographic areas or situations. Proposals were due by Feb. 20, followed by a public comment and reply period ending on March 31, and final decision on the proposals were made at the FCC’s May meeting.
  • Targeted experiments and cooperative research: These experiments to explore the impact on specific values, including universal access and competition.
    • Rural America: Experiments to focus on ways to deliver robust broadband to rural areas.
    • People with disabilities: Development and funding of interagency research on IP-based technologies for people with disabilities.
    • Telephone numbering in an all-IP world: A numbering test-bed to address concerns raised about number assignment and databases in an all-IP world, without disrupting current systems.
  • Data improvement:
    • Reform of the FCC’s consumer complaint and inquiry process to collect better data on how technological change is impacting consumer values
    • Intergovernmental collaboration (state, local and Tribal governments) to better understand consumer impact
    • Collection and analysis of data on next-generation 911 systems in coordination with the U.S. Department of Transportation’s National 911 office and public safety associations

The FCC also initiated two new proceedings to collect more input from the public on numbering research and the rural broadband experiments.

AT&T proposed experiments in Carbon Hill, Alabama, and Delray Beach, Florida. New customers in those cities would not be allowed to sign up for traditional, landline-based service. AT&T wants new and existing customers to eventually use broadband service, mobile phones or a conventional phone that connects to a router-like box. The box plugs into an electrical outlet and zaps signals to a cellphone tower. But in Carbon Hill about 4 percent of residential customers live too far away from the center of the sparsely populated area to receive broadband service. And, in Delray Beach, about half of the people are at least 65 years old, the age group slowest to embrace new phones. It also isn't clear how AT&T plans to work around the reliance on old-fashioned telecom technology by 911 emergency-response systems, burglar alarms, pacemakers and even systems used by air-traffic controllers. In addition, in both locales, the AT&T experiments raised issues of:

  • How to deliver a street address to 911 using the wireless-based service;
  • Making replacement offerings compatible with alarm systems, medical alerts, fax machines and devices used to validate credit cards; and
  • Making replacement products text telephone (TTY) accessible. (TTY is a special device that lets people who are deaf, hard of hearing, or speech-impaired use the telephone to communicate, by allowing them to type messages back and forth to one another instead of talking and listening.)

On July 11, 2014 the FCC made up to $100 million available for rural broadband experiments:

  • $75 million to test competitive interest in building networks that are capable of delivering 100 Mbps downloads and 25 Mbps uploads – far in excess of the current Connect America Fund (CAF) standard of 4 Mbps /1 Mbps -- for the same or lower amounts of support than will be offered to incumbent carriers in Phase II of Connect America;
  • $15 million to test interest in delivering service at 10/1 speeds in high cost areas; and
  • $10 million for 10/1 service in areas that are extremely costly to serve

On December 5, 2014, the FCC announced the bidders that have been provisionally selected subject to the post-selection review process. These bidders are seeking support to serve diverse geographic areas with different cost characteristics. Collectively, they have bid on support to cover 26,867 census blocks in 25 states and Puerto Rico:

  • 19 entities seeking support to build networks that are capable of delivering 100 Mbps downstream and 25 Mbps upstream to all locations in the project census blocks in Arkansas, California, Colorado, Delaware, Illinois, Indiana, Iowa, Kansas, Michigan, Minnesota, Nebraska, Nevada, New Mexico, North Dakota, Oklahoma, Puerto Rico, and Texas.
  • 12 entities seeking support to build networks capable of delivering 10 Mbps downstream and 1 Mbps upstream to all locations in the project census blocks in Colorado, Idaho, Iowa, Kansas, Kentucky, Michigan, North Carolina, Ohio, Tennessee, Texas, Virginia, and Washington.
  • 9 entities seeking support to build networks capable of delivering 10 Mbps downstream and 1 Mbps upstream to all locations in project census blocks that are extremely costly to serve in California, Illinois, Maryland, Michigan, North Dakota, Kansas, South Dakota, and Texas.

In November 2014, the FCC proposed rules to preserve reliable 911 service. The FCC noted that technology transitions, including the move to IP-based networks, can vastly improve 911 calling and help first responders during emergencies. However these transitions also present potential new vulnerabilities to 911 service. The process of routing and completing a 911 call now often involves multiple companies, sometimes geographically remote from where the call is placed. Outsourcing and consolidation of critical 911 network infrastructure means that a single 911 outage can affect more people in more places than before, and can also complicate restoration efforts. The FCC adopted a Notice of Proposed Rulemaking (NPRM) asking for public comment on specific proposals in four key areas to set the nation on a path towards reversing the trend of large-scale 911 outages:

  1. Requiring 911 providers to make public notification of major changes to 911 service, so that 911 call centers and other stakeholders are aware of potential impacts, and to seek approval if they intend to discontinue critical 911 services;
  2. Requiring entities seeking to offer new 911 capabilities and services to certify that they have the technical and operational capability to do so reliably;
  3. Clarifying roles to promote situational awareness, information sharing, and coordination among multiple service providers during 911 outages; and
  4. Updating the FCC’s 911 reliability certification requirements to account for new technologies and network architectures.

Also in November 2104, the FCC FCCproposed to update rules ensuring access to public safety. Traditional phone service on copper networks usually works even during broader power outages because the copper wires are powered separately by the phone company. While modern fiber and cable networks have many advantages, they do not provide power to the handset. Instead, during a power outage, consumers must rely on a battery back-up in their own homes.

Another NPRM:

  • Proposes a framework to establish reasonable expectations for when providers should bear responsibility for providing a backup power solution for the communications equipment at a customer’s home during a power outage;
  • Seeks comment on different back-up power technologies and solutions in the marketplace today; and
  • Examines potential strategies for providing back-up power during lengthy commercial power failures.

Separately, the FCC proposed to update rules protecting consumers faced with network changes and discontinuation of services and preserving wholesale access to last-mile networks by competitive providers serving businesses and large institutions.

While new networks can provide a wealth of innovative features, many consumers and small businesses rely on services that may not be supported following a transition. The expected frequency of network changes and discontinuances requires the FCC to modernize its rules regarding consumer notice and input in the event of network changes and discontinuances.

This NPRM:

  • Proposes greater transparency, consumer protection, and opportunities for consumer input when carriers are planning to shut down (or “retire”) their existing copper networks;
  • Sets in motion a process to ensure that new services meet the needs of consumers before carriers are allowed to remove legacy services from the marketplace;
  • Asks for facts and data about whether carriers are, in effect, retiring copper networks without giving notice simply by failing to maintain them; and
  • Asks about allegations that carriers are not being clear with consumers about the options available when the copper network is shut down.

Small and medium-sized businesses, schools, hospitals, and other government institutions often rely on services delivered by competitive broadband and phone providers. Yet competitive providers may no longer be able to reach customers if incumbent carriers withdraw certain “last mile” services.

The NPRM:

  • Tentatively concludes that carriers seeking to discontinue a service used as a wholesale input should be required to provide competitive carriers equivalent wholesale access going forward; and
  • Proposes to update the FCC’s rules so that competitive carriers receive sufficient notice of when copper networks are being shut off, so that they can continue to serve their customers effectively.

The FCC also adopted a Declaratory Ruling clarifying that the circumstances under which a carrier must seek approval to discontinue a service depend upon the practical impact of its actions, not the fine print of an aging tariff filing. This ensures that there will be a public process to evaluate a proposed discontinuance before a choice is removed from the market, regardless of how the carrier has written its tariff.

Concerning these actions, Chairman Wheeler said, “This is not a matter of old vs. new technologies. Rather, it concerns a simple question: as we reach the tipping point at which the older networks and services are turned off, will the transitions to the next generation networks benefit all Americans or will we allow some to fall through the cracks? I firmly believe that we can facilitate the transitions, even while ensuring that the benefits accrue to everyone.”

For all the news on the FCC's efforts on the IP transition in 2013-14, see A Year in Review: The FCC and the U.S. Phone Transition (Part I and Part II)