TDM-to-IP Transition: Does Copper Deterioration Equal Copper Retirement?

The Federal Communications Commission is seeking input on whether it should require telecom service providers retiring traditional copper phone wiring to provide and monitor batteries providing backup power to customer premises equipment. Additionally the commission is considering whether a service provider that lets its copper infrastructure deteriorate should be considered to have retired that equipment.

These are just a few of the ideas discussed in a notice of proposed rulemaking about the TDM-to-IP transition adopted by the FCC on November 21 and released publicly last week. As usual the NPRM includes some requirements that the FCC indicates it anticipates imposing, while other ideas are simply put forth for discussion.

Proposed TDM-to-IP Transition Requirements
Among the requirements the FCC indicates it anticipates imposing are:

• A requirement for service providers replacing copper-based service with a fiber-based alternative to provide eight hours of backup power for the new customer premises equipment (for discussion is whether service providers would need to educate end users about this), to ensure that customers would be able to reach emergency services during a power outage
• Requiring end users to provision their own battery backup to meet requirements beyond the initial eight-hour period as long as consumers would have “ready access, through standard commercial outlets, to replacement batteries or other backup power technology”
• Defining copper retirement to include “removing and disabling of copper loops, sub-loops and the feeder portion of loops”
• Service providers would not have to obtain approval from the FCC before retiring copper loops but would have to meet various notification requirements, including advising the commission and “each telephone exchange service provider that interconnects with the incumbent LEC’s network” of the planned change
• Service providers would have to supply a “neutral statement of the various choices that the [company] makes available to retail customers affected by the planned network change” – a requirement aimed at preventing incumbents from upselling customers to bundled replacement services

The commission’s reasoning for not requiring pre-approval on copper retirement is that such a requirement “would undesirably harm incentives for fiber deployment.”

Ideas for Discussion
Ideas that the FCC is not currently recommending, but about which it requests more information include:

• How to achieve “some level of standardization” in power systems and interfaces for VoIP services – a task the FCC said might be achieved in cooperation with standards bodies such as CableLabs or the Broadband Forum
• Methods by which the commission could facilitate the sale of retired copper assets to other service providers
• Whether the eight-hour backup requirement should be extended to 24 hours
• Whether mobile cell phone charging stations could be feasible in addressing prolonged power outages in more rural areas