CWA to FCC: protect good jobs, networks, consumers during IP transition

The Communications Workers of America (CWA) filed comments at the Federal Communications Commission (FCC) in support of an FCC proposal to adopt clear criteria to evaluate a telecom carrier’s request to discontinue, reduce, or impair service. As communications infrastructure changes, the fundamental goals of communications policy remain the same: universal service, consumer protection, public safety and national security, and competition – goals best advanced by a skilled, career communications workforce with workers’ rights and protections on the job.

CWA supports eight criteria proposed by the FCC to evaluate whether alternative technologies constitute adequate substitutes for copper landline services:

1) Network capacity and reliability;

2) Service quality;

3) Device and service interoperability;

4) Service for individuals with disabilities;

5) PSAP and 911 service;

6) Cybersecurity;

7) Service functionality; and

8) Coverage

In addition, since customers don’t consider service alternatives that cost significantly more than existing services as adequate substitutes, CWA urges the FCC to give particular weight to the issue of affordability in its evaluation of a carrier’s application to discontinue services.

Finally, the FCC must be particularly vigilant of carriers that attempt to avoid service regulation through de facto retirement and discontinuance, or neglecting copper networks – and therefore copper-network customers – until service is effectively unusable. Verizon is the poster child of de facto copper retirement and discontinuance, as CWA notes, “neglecting copper and copper-network customers in the non-FiOS areas in its local exchange footprint, leaving as many as eight million urban and rural customers in these areas with poor voice and slow or no broadband service.” The FCC should protect customers from this corporate tactic.

As CWA members work in all sectors of the communications industry and consume communications services, CWA has a deep interest in protecting good jobs in the industry, quality communications networks, and consumers through this FCC proceeding.

Comments of CWA (FCC, Oct. 20, 2015)