Voluntary IP Transition Trials Less Useful Than Mandatory Ones, Pai Adviser Says
The FCC’s eighth-floor wireline aides are eager to hear ideas about potential IP transition trials, they told an FCBA audience at a brown-bag lunch at commission headquarters Wednesday. Intricate, voluntary proposals like one offered by Public Knowledge will be considered, they said, but purely voluntary trials might not be the best way to do things. An order has been circulated that would set procedures for proposing and evaluating IP transition trials, and is likely to be supported by all the commissioners (CD Jan 10 p1).
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Public Knowledge last week suggested the FCC take an approach commonly taken in clinical trials (CD Jan 10 p12). The public interest group proposed a voluntary trial with a “blind” and “cross-population” protocol, in which some customers are given IP technology and some keep the existing TDM technology, but customers wouldn’t know which group they were in. After a few months, customers should be switched to the opposite technology. Nicholas Degani, wireline aide to Commissioner Ajit Pai, encouraged groups to propose ideas like that, but pointed out some potential issues. “If somebody has a heart monitor,” which works well with the old system, “those people aren’t going to volunteer,” Degani said. “You'd be crazy to volunteer and possibly sacrifice your health to be part of an experiment for the FCC."
Another problem with “purely voluntary” trials, said Degani, is that they might mostly attract people who are likely already switched over to VoIP, and who are not likely to have problems. Dealing with the problems is “where it gets interesting,” he said. It’s also important to tackle the task of transitioning full wire centers, Degani said, paraphrasing Public Knowledge: Transitioning one customer is like mending an arm; transitioning an entire wire center is like open heart surgery. “We're not going to learn anything about open heart surgery until we do it,” Degani said.
"We want folks to come forward” with trial ideas, said Daniel Alvarez, wireline aide to Chairman Tom Wheeler. “We want as many as possible.” Alvarez said the commission would definitely consider trials like that proposed by Public Knowledge -- “I'd love to hear it, if somebody has a really good idea like that” -- but a blind study might run afoul of the commission’s rules on customer notification. Such a proposal would have to account for that, he said.
The aides also advised on how best to make use of limited time for ex parte meetings. “The most effective people I've met with anticipate the other side -- they've read those ex partes -- and they come in and have answers to all those points and questions,” said Priscilla Argeris, aide to Commissioner Jessica Rosenworcel. It’s also helpful to come prepared not just with “what your concerns are, but what your proposed ask is,” said Rebekah Goodheart, aide to Commissioner Mignon Clyburn. Don’t make the aide try to figure out what the commission should do, she said. For Alvarez, who is relatively new on the job, “I just want to be educated,” he said.
"The least effective meetings” are those where the first 20 minutes are spent talking about the company’s general business, Degani said as the other aides nodded in agreement. “We don’t care that much,” Degani said. “We want to know what’s the issue? What are the good arguments?” Knowing a company covers 800 square miles versus 1,000 square miles “really isn’t going to change the way my boss thinks about an issue,” Degani said of Pai. “Just because you serve a lot of very sympathetic people does not mean we're just going to give you the world. … Cut to the chase.” Added Amy Bender, aide to Commissioner Mike O'Rielly: “And when you cut to the chase, back it up with facts and figures.”