TDM to IPIs the FCC trying to eat its cake and have it too when it comes to the TDM-to-IP transition?

Two different carrier organizations suggested the answer is yes in comments filed with the FCC last week. At issue is how closely carriers will have to replicate traditional line-powered phone service as they transition to IP-based alternatives based on broadband and VoIP.

Traditional voice service is powered from the central office, which means that the service works even during a power outage at the customer premises. In December the FCC adopted a notice of proposed rule making about the TDM-to-IP transition and asked stakeholders for input about its plans, including a proposal that carriers transitioning to newer technologies should be required to provision backup power to customer premises equipment and potentially to provide and monitor backup batteries.

The proposal also calls for providers to undertake a consumer education program about backup power.

ITTA’s Critique
“There is no demonstrated need for the commission to adopt rules in this area,” wrote ITTA – The Voice of Mid-Size Communications Companies in its filing last week. “The industry has responded to marketplace demand and consumer needs by voluntarily deploying devices that are capable of maintaining standby backup power, typically for up to eight hours.”

As a result, the ITTA argued that “under the circumstances, rules that would impose an affirmative legal obligation on affected providers to provide CPE backup power or undertake a comprehensive consumer education plan are unwarranted and a waste of resources that would be better directed toward broadband deployment and adoption.”

The ITTA also noted that “consumers in most cases are more than capable of acquiring replacement batteries or other backup power technology through standard commercial outlets, just as they do with respect to alarm clocks, flash lights, radios and other equipment often needed or utilized during power outages or times of emergency.”

Additionally, the ITTA expressed concerns that proposed requirements might not be technologically neutral, as the association said it is unclear from the NPRM whether fixed wireless service providers would face the same requirements.

The ACA Weighs In
The American Cable Association in its filing last week said it was “dismayed” that nowhere in the TDM-to-IP transition NPRM did the FCC provide a “complete picture” about how the voice service market already has evolved. Forty-four percent of households no longer take traditional voice service and even among those that still take the service many have been transitioned to fiber-based infrastructure that doesn’t offer the same line powering capability of copper, the ACA noted. As a result only about one quarter of homes currently have line-powered voice service, the ACA said.

“The commission seems to imply that the consumers’ transition away from obtaining voice service using central office line power copper is a recent [phenomenon], which requires special attention for its impact on access to emergency communications during power outages,” the ACA wrote. “Clearly this is not the situation.”

The ACA also criticized the FCC for not delving deeper into consumer use of cordless phones with no battery backup and for “barely raising the role of mobile wireless service in providing emergency communications during power outage.”

A smaller cable operator with 10,000 subscribers would spend two million dollars to meet the FCC’s backup power provisioning requirement, the ACA estimated. And that, the ACA said, is equal to the average annual capital budget for an operator of that size.

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