Public Knowledge cautioned against potential confusion that may...

a 214(a) request for “permission to permanently discontinue copper-based TDM service in portions of Fire Island and other areas impacted by Superstorm Sandy,” as the telco has said it’s in the process of requesting. The filing described a meeting between Public Knowledge Senior Vice President Harold Feld and Dave Grimaldi, chief counsel to acting Chairwoman Mignon Clyburn, focused on Verizon’s plans to replace some of its Fire Island copper landline service with the fixed-wireless offering of Voice Link, a decision made in the wake of Sandy’s damage. The confusion is “over whether the FCC requires providers of TDM service to file a 214(a) to permanently discontinue copper-based TDM service after a natural disaster destroys the lines,” Feld wrote. “This confusion is reflected by line staff informing members of the public that Verizon’s actions are ‘acceptable,’ without also informing the public of the procedures to file objections to Verizon’s 214(a) notice.” It “undermines” the transition and causes false beliefs in companies about their ability to “engage in self-help” rather than “participate in structured pilot programs,” he said. The FCC needs to offer more guidance on these filings, which should be required simultaneously with state filings, Public Knowledge said. It urged the FCC to “conduct a proceeding to adopt a special 214(a) process” on these issues and to “set standards for what constitutes an adequate replacement service, ensuring that consumers are adequately protected.” It asked the FCC to treat replacement services the same way as traditional ones to avoid any prejudgment of the transition outcome.