Public Knowledge elaborated on its proposal (CD June...
Public Knowledge elaborated on its proposal (CD June 12 p10) for the FCC to establish a process for telcos to rebuild damaged copper with new services, in a Monday meeting with several members of the commission’s Technology Transitions Policy Task…
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Force (http://bit.ly/13Heip9). Because the existing Telecom Act Section 214(a) process is “not very well-suited” to situations where carriers choose not to rebuild copper plant in response to a natural disaster, the commission needs a “post-disaster network change process” robust enough to “absorb unanticipated challenges in disaster recovery,” PK said. The commission should first establish that carriers are required to submit a filing discussing their new anticipated services, PK said. Carriers should also have to establish that the replacement services will be “adequate substitutes” for the services consumers get over copper, including calling card and collect call capabilities, PK said. The commission should also establish that it will continue to treat the replacement service as a Title II telecom service “at least until the Commission has resolved the complex issues raised by the phone network transition,” PK said. “The Commission cannot let natural disasters become opportunities for carriers to shortcut the deliberations currently underway to comprehensively consider how best to handle the phone network’s transition to IP-based technologies.” Verizon’s intended Voice Link fixed wireless replacement on Fire Island, for instance (CD May 13 p9), should be treated as a Title II telecom service and the commission should determine how best to apply obligations like those found in Sections 251 and 271 of the Telecom Act, PK said.