Reality Check: Dissecting the FCC’s guiding principles in an IP world

Editor’s Note: Welcome to our weekly Reality Check column where C-level executives and advisory firms from across the mobile industry share unique insights and experiences.
While we all continue to witness the evolution of the communications industry toward an all-IP world, there is still much work to be done to help manage this evolution in an orderly fashion. This is the task at hand for the Federal Communications Commission and is it a big one. The PSTN-to-IP transition will include widespread innovation and expanded carrier capabilities in dynamic, creative ways, but for this to happen most effectively, the FCC must stick to its core principles to ensure consumers come out ahead in the process.
The FCC is encouraging the industry to experiment and gather data that can arm the FCC with greater insights into real-world scenarios, but in controlled testing environments. Testing of discrete PSTN-to-IP transition situations in real-world deployments should give regulators and industry members a clearer view of how to proceed responsibly.
However, the true measures of success of the experimentation will be the value of insights gained implementing and conducting the tests, and then applying those insights to the effective implementation of necessary reforms. Consistent with these considerations, FCC Chairman Tom Wheeler has been emphasizing the guiding principles they intend to follow during the trials and beyond. The guiding principles and some of the challenges that confront them are outlined briefly below.
Universal access: Communications networks are strongest when everyone can access them – whether they live in urban or rural communities. IP networks need to be both comparably available and reliable for everyone. As the PSTN of the past continues to fade, we must confront the universal access implications for the next generation IP network. IP technology must enable economic developments in under-served markets rather than diminish them. Ensuring that comparable services are reasonably available to all, regardless of economic status or geographic location, has been a bedrock policy of the PSTN for decades. Yet, while very few would disagree with the fundamental premise of these policies – maintaining comparable capabilities in an all-IP world is already proving to be an enormous challenge. As business models shift to embrace IP technology, the regulatory underpinnings of universal access are eroding. Therefore, striking the right balance between regulation and innovation very quickly will be paramount.
Public safety: Public safety remains a critical focus. However, the transition of 911 calling to an all-IP environment presents its own unique challenges. During the PSTN-IP transition the emergency service capabilities currently available via the PSTN must remain steady. Then, over time, IP-rich features should become more and more ubiquitous within the 911 community, which will profoundly improve emergency services to end-users in an all-IP environment. In the interim, small steps, such as the FCCs experiments noted above, will happen, but we can’t predict when emergency communications will be fully transitioned.
The FCC has outlined four categories to focus on for public safety during the IP-transition:
“(1) day-to-day public safety operations in an all-IP world; (2) disaster preparation and responses in an all-IP world; (3) additional risk factors from cyber exploits on commercial, public and government networks; and (4) the impact of technology transitions on national security and federal government systems.”
Focus on these objectives will open the door for robust next-generation 911 services such as text-to-911 and emergency video calling. The transition to next-generation 911 will take time though. During the transition process there will be regulatory developments to pay close attention to. The FCC is hosting a series of workshops now to consider technology transitions and public safety to help the industry progress toward more secure, robust and reliable communications in an all-IP environment.
Competition: Allowed to thrive, IP technology opens up the door to new types of service providers that offer voice and texting services as over-the-top applications instead of the more familiar incumbent models, where carriers sell phones and calling plans. Just as “the IP cloud” has helped businesses get started with innovations like Rackspace and Amazon, now innovative competitors can enable voice quickly and cost-effectively with software, benefiting end-users with more choice and lower costs. To continue progressing, regulators must cultivate, not stifle, innovation.
In managing technology trials, regulators should allow consumer choice to guide wise public policy decisions. Otherwise, the marketplace will inevitably be shaped by the incumbent providers’ will, and the full potential of IP-based communications may never be realized.
Consumer protection: Consumer protections from abusive practices of all sorts have always been at the core of the FCC’s mandates, and they must continue to be as technologies evolve that disrupt markets and consumer expectations. Consumer privacy and security should not be sacrificed in the inevitable shift to an all-IP environment. As more people access communications functions on IP networks, they should have confidence that they are not subject to abuse from bad actors in the process.
With these core principles as a guide, the FCC can advance innovation and economic progress for a communications industry in the midst of arguably its greatest transition ever. The FCC is responsible for managing this transition, but it will take the entire industry to ensure consumers are rewarded along the way. As the IP Transition evolves, it will be fascinating to see just which telecom players are truly able to meet consumers’ demands and re-invent communications.
Greg Rogers is deputy general counsel for Bandwidth in Bandwidth’s office in Denver, Colo. As deputy general counsel, Rogers is primarily responsible for Bandwidth’s regulatory and public policy matters. Bandwidth is a CLEC with an interconnection footprint that spans the 48 continental states. Bandwidth is also a wholesale and retail provider of VoIP, 911 and SMS services. Among its retail service offerings, Bandwidth operates Republic Wireless, an exciting new mobile VoIP and wireless mobile virtual network operator hybrid service. Rogers has been deputy general counsel at Bandwidth since 2010. Prior to joining Bandwidth, Rogers was senior corporate counsel for Level 3 Communications and was a deputy district attorney in Fort Collins, Colo., prior to that. Rogers is a graduate of the University of Colorado School of Law.