Dear FCC: Stop Talking and Start Doing – Its Time to Put A PSTN Transition Plan in Place

The FCC held its first Technology Transition workshop on Monday March 18, 2013.  The purpose of the workshop was to solicit input on three critical ongoing transitions: 1) TDM to IP; 2) copper to fiber and 3) wireline to wireless.

Per the FCC Chairman (Genachowski) - “while technological advances can change markets, they don’t change the FCC’s mission” and any policy decisions will be driven by four guiding principles: 1. Competition; 2. Consumer Protection; 3. Universal Service and 4.  Public Safety.

Interestingly enough, AT&T – who has been quite vocal about the need for the FCC to accelerate the transition to All-IP was not a participant in this first workshop.  Otherwise, participants were a mix of ILEC, CLEC, IOC, and Cable MSOs, along with assorted technology equipment vendors.

Transition to IP is Occurring On its Own

It is clear that the IP transition is occurring – all you have to do is look at the latest U.S. Access Lines data that multiple FCC commissioners highlighted in their remarks.  Whether it is cord cutters completely eliminating a fixed line or consumers taking a VoIP option – this transition is occurring without any policy decisions.

AccessLinesSource:  FCC, broadbandtrends

But despite this naturally occurring phenomenon, the FCC continues to simply investigate this issue which has been debated since 2010.  While the FCC claims it has made progress in this area – most notably by switching the focus of USF (now called CAF) from voice to data – there has been no action on the regulatory side to change the regulation associated with the PSTN to reflect this transition to IP.

To date, only Commission Pai has been bold enough to state that “we (FCC) should conduct an All-IP Pilot Program that will allow forward-looking companies to choose a discrete set of wire centers where they could turn off their old TDM electronics and migrate consumers to an all-IP platform”.   In his opening remarks he stated that “he hoped our panelists today will share their views on how we should structure the Pilot Program” – there was never any discussion on this particular issue.

In fact, outside of Pai’s remarks, I do not believe ANYONE even mentioned the Pilot Program.

Instead, we learned that  operators would love to deploy fiber to every home and business, but no operator can justify the return on investment – but in the places it has been deployed – it has met all ROI objectives.

We learned that wireless could be a suitable alternative for fixed line broadband in rural markets – give the right deployment scenarios and implementation of techniques like Mega-MIMO (aka distributed MIMO) as well as better utilization of spectrum.

We learned that equipment obsolescence, cost to maintain, physical space (power, cooling, etc.) lack of skill sets. as well as an increasing cost per customer were all challenges that multiple operators face with the current circuit switched network.

In short, there wasn’t anything new that was discussed, disclosed or debated.

FCC Ignoring Recommendations from the TAC?

What is unclear, is why the FCC seems to be ignoring the recommendations of its Technological Advisory Council – which included a PSTN Working group.  Many of the issues discussed in this recent workshop have already been highly debated and documented by the TAC which issued the following recommendations in December 2011:

1. Develop a detailed plan for an orderly transition from the current PSTN system of record to a service rich network for achieving key national goals. The plan should include:

a. A public-private partnership with industry, providers, and relevant organizations and stakeholders.

b. Coordination mechanisms for the ongoing evolution of the network to rapidly incorporate new technologies and capabilities.

2.Establish a task force to conduct a thorough policy and regulatory analysis and review as it relates to the PSTN which results in policies for the new communication environment (Interoperability, Interconnect, E.164, numbering, reliability,…).

3.Identify mechanisms and a migration plan for critical services currently provided by the PSTN. Therefore, ensuring that critical services that need to be carried forward are met by well understood solutions. (E911, Disability access,…)

4.Commit to ensuring ongoing universal access to evolving communication services to enable all Americans to participate in the nation’s economy

5.Investigate the need for the use of incentives to accelerate the transition to new services.

6.Create a communications and outreach program to educate the public about the transition.

a. Provide the public with the vision of what we are transitioning to: New services and capabilities which can greatly exceed the current services of the PSTN

b. Provide a roadmap and communicate the urgency to take action to avoid the loss of capability to support critical services.

These recommendations make sense.  If the FCC wants to hold more workshops – let’s start using these recommendations as the foundation for any future discussions.  But at this stage it is really time to stop talking and start doing.

[Full disclosure:  I continue to use (and prefer) a wireline voice service - although I do use Skype for international long-distance.]

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