First comments, FCC Technology Transition Trial

On May 10, the FCC said that their Technology Transitions Policy Task Force was looking toward “real world trials to obtain data that will be helpful to the Commission.” And to do that the FCC would “... seek comment on several potential trials relating to the ongoing transitions from copper to fiber, from wireline to wireless, and from time-division multiplexing (TDM) or circuit switching to IP (Internet Protocol).”

On July 8, the initial comments came in. CWA's filing endorsed the technology trials as a way to determine how the FCC can protect consumers and workers in this momentous changeover. CWA wrote:

“The transition from copper to fiber, wireline to wireless, and TDM to IP networks is taking place, and it is imperative that the Commission adopt policies that foster the statutory and public interest goals of communications policy to ensure network reliability, public safety, universal affordable quality service, consumer protections and job-creating investments in high-speed broadband networks.”

Overall, CWA articulated six public interest goals that must guide policy in any trials. The changeover must:

1. stimulate investment in high-speed networks
2. support quality jobs in the telecommunications industry
3. promote quality, affordable service to all Americans
4. ensure network reliability
5. promote public safety
6. protect consumers

CWA emphasized the FCC's role in making sure that the transition to new technologies builds upon existing investments in a skilled workforce. As CWA wrote:

“We have seen in the telecommunications industry that incumbents respond to competitive threats. When they respond with more investment, better service, and lower prices, the result is a virtuous circle of consumer benefits. In contrast, we have also seen the negative impact on consumers when the response is a cut in service, the offshoring and degradation of jobs, and the disruption of career ladders. It is in the best interest of all to ensure that the low-road policies do not become the dominant market drive.”

CWA urged the Commission to collect data on the employment impacts of the technology trials, and to prohibit outsourcing of work in any of the pilots in addition to detailed data on the impact on service reliability, prices, broadband adoption and investment.

In the end, CWA wants this transition to be guided by the goals of the Telecommunications Act of 1996, “to secure lower prices and higher quality services for American telecommunications consumers and encourage the rapid deployment of new telecommunications technologies.”

Technology Transitions Policy Task Force Seeks Comment On Potential Trials (FCC news release, May 10, 2013)
 
Comments of Communications Workers of America (Before the FCC, Jul. 8, 2013)