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CWA supports good jobs, good networks in IP transition

29 Nov, 2015

The Communications Workers of America (CWA) filed reply 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 legacy service. As communications infrastructure changes from copper to fiber, the fundamental goals of communications policy remain the same: universal service, consumer protection, public safety and national security, and competition. These goals are 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


CWA urged the FCC to add an additional criteria: affordability. If an alternative service is more expensive -- such as wireless with data caps or satellite service for Internet access -- then it is not an adequate substitute to legacy wireline service.


The filing builds on CWA’s initial comments, which urged the FCC to 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, and 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.

Reply Comments of CWA (FCC, Nov. 24, 2015)

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