Department of Defense Urges Caution in IP Transition Technology Trials
The Department of Defense warned the FCC Monday that any potential technology transition trial from traditional to Internet Protocol-based telecom services could have a major impact on public safety and national security interests. DoD said it “embraces” advances and “applauds” the FCC for promoting new technologies, but cautioned that any trials need to be “absolutely seamless” for the military and other federal agencies. State commissions wrote to underscore the importance of their having an integral role in the transition process.
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DoD continues to “rely heavily” on wireline TDM-based networks and services, and “will do so for the foreseeable future,” it said on behalf of itself and other federal executive agencies (http://bit.ly/1dbtNti). “The Commission should carefully consider potential adverse consequences on public safety and national security interests” by requiring DoD and other agencies “to prematurely transition to different technologies or services,” it said.
Most of the telecom services provided to federal government customers go through the General Services Administration Networx program, DoD said. The majority of the $68 billion Networx contract was awarded to ILECs AT&T, Verizon and Qwest, for telecom services that have traditionally relied on TDM technology, such as basic voice, private line and circuit switched data, DoD said. “The telecommunications services purchase by these Federal agency customers generally support national security interests, public safety, Federal government operations and military readiness,” it said. Certain necessary functionalities that customers get over wireline/TDM networks “may not be available through wireless or IP-based networks,” DoD said, pointing to “ISDN-PRI products” DoD purchases to serve federally-owned switches.
"Transitioning away from TDM to all-IP and/or wireless networks and services would be an enormous undertaking,” DoD wrote. Any transition must be done in a “careful and non-disruptive manner,” and must come with “significant” funding to upgrade or replace networks and train personnel on new procedures, it said. “There should be no forced ‘flash cut’ for DoD” or loss of functionality, it said. DoD also asked to be involved in the trial selection process, lest the trial impact “critical missions."
The Indiana Utility Regulatory Commission spoke of the importance of telecom reliability during power outages (http://bit.ly/1dbosCb). “No issue is more important than the continued, and even further hardened, reliability of telecommunications services in the event of public electric power outages,” IURC said. In the prospective technology transition trials, the FCC must “account for the vital importance” of reliable power regardless of whether a telecom network is PSTN or IP, the state commission said, urging the FCC to “outline steps to improve the reliability of backup power supplies.” State commissions might have a role in the trials, it said, as they are “uniquely positioned” to be “fully aware” of competing interests of carriers and consumers. The commission looks forward to “a cooperative federalism approach” to the trials, it said.
"Replacing and subsequently discontinuing the existing circuit switched wireline networks as part of a trial could have profound effects on consumers, competitors, and other stakeholders,” said the Massachusetts Department of Telecommunications and Cable (http://bit.ly/1dboMRE). The FCC and the states should work as “partners,” MDTC said. “The FCC should not act alone in selecting the site and evaluating the outcome of the proposed trials,” it said. MDTC also asked the task force to propose metrics and collect data on the effects of trials into discontinued wireline networks, especially as they are replaced by wireless services. “The FCC should compare the level of equivalency between the services on issues such as availability, quality, price, regulatory oversight, and available consumer protections to understand how the services differ and understand the tradeoffs that consumers will be experiencing,” it said.
The New York State Public Service Commission supports gathering data to assist in developing policy recommendations on the copper to fiber and wireless transition, it said (http://bit.ly/1dbtij2). “It is important to balance the interests of continuing customer protections while exploring the use and expansion of new technology,” it said. “Paramount to this interest is the principle that wireline-to-wireless trials are conducted only where a safety net exists for customers.” For example, a competing wireline service should be available for customers to choose in lieu of participating in the trial, it said. And customers who do participate in trials “will have much of the same expectations” as they did before the trials, it said, calling for continued administration of consumer protections by service providers and regulatory agencies.
States should play “an integral role” in the proposed trials, said the Nebraska Public Service Commission (http://bit.ly/1dbtf6B). State commissions should get the chance to help select the geographic trial areas and evaluate the trial-related data, it said. State commissions have a “closer relationship to consumers” and a “familiarity with the competitive landscape” that would be useful to the FCC, it said. The trials should “generate an expeditious classification” of VoIP services, NPSC said. “The current lack of clarity as to the requirements of VoIP providers relative to consumers and other carriers continues to undermine consumer protections and encourages carriers to find loopholes to undercut their competitors.”