Washington, D.C. (May 13, 2013): The Minority Media and Telecommunications Council (MMTC) is pleased that the FCC has begun its research on the IP transition.
The FCC’s approach addresses four key areas related to the IP transition: VOIP Interconnection, TDM to fiber, wireline to wireless, and next-generation 911, and asks whether additional trials are needed. The technology transition to IP-enabled services is already underway, and it is critical that federal regulators address all of the technical, policy, and regulatory questions in an open, transparent, and expeditious process that includes civil rights and consumer advocacy organizations, public safety, state regulators, and industry.
In Comments filed in January 2013, sixteen national minority organizations, including MMTC, endorsed the “relief requested” in AT&T’s IP transition petition – i.e., beta tests in specific geographic markets. Inasmuch as the transition is underway and consumers need it to proceed rapidly, the Commission should accelerate its research efforts and plan to start beta tests by the fall of this year.
As broadband offerings evolve, requiring ever-increasing speeds and bandwidth capacity, next-generation IP broadband will become increasingly central to our communication needs. As the Commission declared in its 2012 National Broadband Plan, the transition to all-IP networks is “the great infrastructure challenge of the early 21st Century.”
From a cost allocation standpoint, the IP transition will be progressive by tending to shift the ultimate responsibility for huge fixed capital expenditure costs, attendant to maintaining redundant copper facilities, away from low-income consumers. MMTC enthusiastically supports progressive cost allocation and revenue generation policies that help lift the poor out of poverty rather than push them deeper into poverty.
We commend Public Knowledge for thoughtfully identifying what could go wrong for consumers if the fiber, satellite, or wireless technologies being tested prove to be unready for prime time. In that spirit, all of the Commission’s research should be undertaken with particular regard for the “human subjects” protections due to consumers who, unavoidably, could be impacted, positively or otherwise, by an experiment being performed in their communities.
At the same time, we agree with AT&T, TechFreedom, and others who have noted that the IP transition is already underway and that it’s overwhelmingly in the interest of consumers and public safety that government and industry work together to proceed rapidly with the transition. To protect consumers – especially those in underserved communities – during the transition, the Commission should move with great expedition toward the next phase of its work: comprehensive, holistic, and transparent beta tests undertaken with the cooperation of civil rights and consumer organizations, the business sector, tribal authorities, public safety officials, and state regulators.
All of the Commission’s research should incorporate metrics on minority business participation, and on service to underserved urban, rural, and tribal populations. The Commission’s ultimate goal should be to ensure high rates of service adoption across all levels of income, race, and primary language, while promoting service affordability and the availability of competitive alternatives in the marketplace.
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The Minority Media and Telecommunications Council (MMTC) is a national nonprofit organization dedicated to promoting and preserving equal opportunity and civil rights in the mass media, telecommunications and broadband industries, and closing the digital divide. MMTC is generally recognized as the nation’s leading advocate for minority advancement in communications.