Pluses and Minuses of Wheeler’s IP Transition Post

A blog post about the TDM-to-IP transition from the new FCC chairman Tom Wheeler has a tone of urgency, noting that “The impacts on networks have already begun and will be profound.” In the post Wheeler pledges that in January the commission will adopt an order “for immediate action.”

The specific actions he promises, however, are largely of the “let’s study this further” variety. The order, he says, should include recommendations on how best to:

• Obtain comment on and begin a diverse set of experiments that will allow the commission and the public to observe the impact on consumers and businesses of such transitions (including consideration of AT&T’s proposed trials)

• Collect data that will supplement the lessons learned from the experiments

• Initiate a process for commission consideration of legal, policy and technical issues that would not neatly fit within the experiments, with a game plan for efficiently managing the various adjudications and rulemakings that, together, will constitute our IP transition agenda

Back in May the FCC issued a specific proposal for a TDM-to-IP transition trial, but has not yet made a plan to implement that trial.Wheeler’s use of the term “experiments” appears to be a reference to trials of this sort.

If so and if one parses Wheeler’s comments, it doesn’t appear that we will be any closer to starting trials in January than we are now.  Wheeler is talking about providing “recommendations” on how best to “begin” and “obtain comment on” the experiments.

Perhaps it’s not surprising that a new chairman would not simply rubber-stamp a proposal presided over by his predecessor – and to his credit, Wheeler does put forth his own vision and even his own nomenclature surrounding the complex topic of a TDM-to-IP transition.

“What some call the ‘IP transition’ is really a series of transitions,” he said. Also included in this transition are fiber replacement of copper and wireless replacement of wireline, he said.

“This is what I have called the Fourth Network Revolution, and it is a good thing,” wrote Wheeler, noting that such a revolution could “catalyze innovation, investment, ideas and ingenuity.”

Another term in his lexicon is “the Network Compact,” which he defines as the “set of values” that preserves the “attributes of network services that customers have come to expect” amid this transition.

Also to his credit, Wheeler seems to be encouraging teamwork, acknowledging the three commissioners with the most seniority on the commission and citing comments each has made on the TDM-to-IP transition topic.

“Comissioner O’Rielly and I are the new kids on the block,” he said humbly, adding “With the commission now at full force it is time to act with dispatch.”

There are relatively few specifics in his blog about what form the TDM-to-IP transition might take. But he did say that in addition to determining how to approach the “experiments,” the order should address how consumers would be informed and protected and should explain how the commission can obtain “accurate and useful information about the technology transition” from resources such as other federal, state and tribal agencies; crowdsourcing; and outside expertise and advisors.

Reading between the lines it was also interesting to note that Wheeler referenced bonding technology in the opening paragraph, noting that it is “showing interesting possibilities with regard to the nation’s traditional copper infrastructure.” Competitive carriers have argued that incumbents should not be allowed to simply abandon their existing copper connections because the competitors might want to use them and Wheeler’s comments suggest he might agree.

It was also interesting that Wheeler said the January order should consider AT&T’s proposed trials but did not in that context mention trials proposed by NTCA– The Rural Broadband Association.

In a statement, NTCA CEO Shirley Bloomfield opted to put a positive spin on Wheeler’s comments, stating that the NTCA “welcomes” the commission’s intent to move quickly on the TDM-to-IP transition. She also noted that the NTCA’s petition highlighted “core principles related to universal service, competition and protection of consumers” which she said “must be seen as cornerstones of any regulatory reviews, trials or structured observations of technical trends underway.”