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‘Sandboxes’

IP Transition Trials to Have Short Timelines, Seek Rolling Submissions of Specific Ideas

January’s order on the IP transition will “invite, on a rolling basis, service-based experiments with short timelines for submission,” Jon Sallet, interim director of the FCC Technology Transitions Policy Task Force, told commissioners at Thursday’s agency meeting. Commissioners Ajit Pai and Michael O'Rielly have emphasized the need for speed, Sallet noted, so the deadline to submit experimental ideas will come up quickly. Later, companies can propose more experiments that the commission would process on a rolling basis, he said. By “service-based,” Sallet means trials where real customers with real services will see those services transition to IP, he said.

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January’s order will also establish criteria for experiments that focus on the impact on consumers, and create a speedy process for public comment and commission evaluation, Sallet said. The order will recommend commission actions to support targeted experiments and research; describe ways to make structured observations collect data; and establish a timeline to adopt a framework to resolve important legal and policy questions raised by the tech transitions, he said.

"There are going to be many different proceedings that are touched by the IP transition,” Sallet said. The January order will suggest a timeline that would lead to “a framework by which staff will come to you” and “tee up issues as you instructed them to be teed up,” Sallet told the commissioners.

The task force announced creation of a “memorandum of understanding” with the National Institute of Aging, as it and the FCC will work to assess the effect of new IP technologies on IP relay services and other technologies frequently used by the elderly. Another MoU is in the works with the National Science Foundation, officials said. It’s important to realize that the IP transition “is bigger than any one company,” said Jonathan Chambers, chief of the Office of Strategic Planning and Policy. “It’s bigger than the FCC. It involves all of us."

Commissioners were pleased with the upcoming order. FCC Commissioner Jessica Rosenworcel compared the experiments to “sandboxes” encoded by programmers to allow experimenting without harming the rest of the program. “Why not put it to work in government in Washington,” she asked. The IP transition is “a terrific candidate for the sandbox,” she said. Rosenworcel called for “location-specific trials” and “service-specific ways” -- soon, she said, because networks are currently involved in a profound transition.

O'Rielly said he supports trials as long as they don’t lead to delay or inaction. He asked Sallet if existing rules or proceedings would need to be frozen while trials and experiments are conducted. “We support your conclusion” that the trials shouldn’t slow things down, Sallet said. The draft order will instruct sponsors of experiments to offer a timeline for initiation and conclusion of experiments, he said.

"We appreciate the focus and energy that Chairman [Tom] Wheeler and the commission are bringing to this transition,” said USTelecom President Walter McCormick. “Removing barriers to innovation and investment in delivering broadband and IP services to American consumers and businesses will produce benefits throughout our economy.” The Benton Foundation said it was pleased to see “the emphasis the FCC is placing on the universal deployment of broadband networks, promoting public safety, protecting consumers, and preserving and enhancing competition and interconnection. There’s strong consensus that the transition must embrace these core values."

"It’s fair to say that time-division-multiplexed services over copper landlines are becoming a bit like VCRs or typewriters,” said Pai: “Once almost ubiquitous, but now an outdated holdover given better alternatives.” Pai said he’s “especially pleased” with the recommendation that the commission move forward with targeted experiments in January. “If, as our former colleague Blair Levin has said, ‘an experiment is worth a thousand pleadings,’ we will gain valuable insight indeed."

AT&T said it looked forward to working with the commission as it implements its “ambitious” agenda. “These IP trials will give policymakers and all stakeholders the ability to observe and learn from the facts on the ground, rather than being frozen by false fears,” said Senior Vice President-Federal Regulatory Bob Quinn in a statement. “Ultimately, the IP trials will ensure that no one is left behind as the country moves forward to an Internet-enabled future."

The American Cable Association thinks the commission “needs to affirm that its interconnection regime applies to managed VoIP traffic, a key service for the customers of many ACA Members,” said President Matthew Polka in a statement. “There is no need to wait on addressing that issue while the trials are underway.” Comptel also emphasized the importance of interconnection. “As legacy carriers begin to more fully embrace IP technology and the Task Force explores a variety of issues related to this network evolution, it is important that the fundamental goal of the [Communications] Act -- to provide consumers with greater choice through competitive options -- is not diminished,” said General Counsel Angie Kronenberg. “As legacy carriers begin to more fully embrace IP technology and the Task Force explores a variety of issues related to this network evolution, it is important that the fundamental goal of the Act -- to provide consumers with greater choice through competitive options -- is not diminished.”