What Comes Next in the IP Transition: Experiments and Research Targeted to Network Values

In a previous post, we looked at the Federal Communications Commission’s (FCC) recent decision to invite voluntary, service-based experiments to evaluate how customers are affected by the historic technology transitions that are transforming our nation’s voice communications services. Those experiments will examine the impacts on consumer values when providers substitute a new technology or service for a legacy one, with an eye toward discontinuing the legacy service in the post-transition world. In this article, we examine the FCC’s additional proposals for targeted experiments and cooperative research to explore the impact of technology transitions that focus on universal access. These proof-of-concept initiatives are focused on new technologies for particular groups of consumers, aspects of network functions, or more effective ways to reach all Americans.

The FCC is attempting to mitigate the risks of what’s generally called the IP Transition – the move from a traditional telephone network based on time-division multiplexed (TDM) circuit-switched voice services running on copper loops to an all-Internet Protocol (IP) network using copper, co-axial cable, wireless, and fiber as physical infrastructure. To examine the impact of the IP Transition on public safety, ubiquitous and affordable access, competition, and consumer protection, the FCC is taking these three steps:

1. The FCC seeks proposals to bring advanced services to rural Americans, including residents of Tribal lands, with support from the Connect America Fund, which will allow the FCC to examine different approaches to ensuring universal access to these advanced services in an all-IP world.
2. The FCC is working to commission research on how the technology transitions impact persons with disabilities by establishing a budget and setting forth a process for soliciting an initial set of research proposals.
3. The FCC authorized the creation of a numbering testbed, separate from legacy databases and systems, to spur the research and development of the next generation standards and protocols for number allocation, verification, and call routing. The testbed will allow the FCC to examine approaches to preserving and enhancing the network values inherent in our existing numbering systems in an all-IP world.

I. Experiements in Rural America

Rural areas offer special challenges to broadband access and adoption:

• By definition, rural areas are geographically dispersed, with lower population density.
• Often they are in areas with geological and topographical challenges.
• Some rural areas experience particularly extreme seasonal and meteorological conditions.
• Rural areas have a higher percentage of elderly residents, who tend to have lower broadband adoption.
• Rural areas have been home to a disproportionate number of low-income Americans.
• And many of these factors are exacerbated on Tribal Lands – the percentage of Americans residing on Tribal lands in rural areas without access to fixed broadband at a speed of 4 Mbps/1Mbps is more than eight times the national average.

In the last several years, the FCC has undertaken major reforms to each of its universal service programs to modernize those programs in light of marketplace changes and technological advancements:

• In the USF/ICC Transformation Order, the FCC adopted comprehensive reforms to modernize the existing high-cost program and accelerate the transition from circuit-switched to IP networks.(1)
• In 2012, the FCC adopted a broadband pilot program to determine whether and how the Lifeline program could be modified to promote the adoption and retention of broadband services by low-income households. (2)
• In 2012, the FCC recognized that access to high quality, secure and high-bandwidth connectivity is critical to the delivery of health care and disaster preparedness. (3)
• In 2013, the FCC initiated a review of the E-rate program (more formally known as the schools and libraries universal service support mechanism), focusing on how to ensure that our nation’s students and communities have access to high-capacity broadband connections. (4)

Although all these efforts are contributing to increased broadband availability and adoption, the FCC is seeking data on the impact of technology transitions in rural areas, including Tribal lands, where residential consumers, small businesses and anchor institutions, including schools, libraries and health care providers, may not have access to advanced broadband services. The FCC is seeking proposals to build robust last-mile broadband to offer service to a wide range of end users in rural communities and, specifically, in rural areas lacking Internet access service that delivers 3 Mbps downstream/768 kbps upstream. Funding for these experiments will be made available from the FCC’s Connect America Fund.

The FCC hopes to collect useful information from these experiments to answer four interrelated questions:

1. The FCC seeks to test the assumption that the geographic and demographic characteristics of certain rural areas, including Tribal lands, economically preclude the deployment of high-capacity fiber-based services that deliver higher speeds to those communities, absent some level of governmental support. The FCC wants to gauge the extent of interest among new providers, potentially with assistance from the Connect America Fund, and to learn which specific measures to streamline the eligibility process will encourage such entry by new providers. The FCC wants to learn whether providers are willing and able to deliver services with performance characteristics well in excess of the minimum standards that current carriers are required to offer to all locations in universal service funded areas, for the same amount or less support.
2. The FCC wants to develop a greater understanding of the geographic and demographic characteristics of areas where service providers (both new and old) would choose to offer wireless services at pricing reasonably comparable to urban wireline offerings. The FCC also wants to identify the likely features of such wireless services and the characteristics of wireless services that residential consumers would find to be an acceptable substitute for fiber-based broadband service.
3. The FCC wants to understand how the IP Transition will impact anchor institutions and the people they serve. What types of services will be offered to schools, libraries, health care providers, and other anchor institutions that are served by next generation networks financed in part with Connect America support, and at what price? The FCC wants to know how the business case for deployment in rural areas, including Tribal lands, can be improved by securing the participation of anchor institutions to serve as key customers of next generation networks. The FCC hopes to identify strategies to ensure that community-based institutions in rural areas, such as schools, libraries and health care providers, have access to next generation services.
4. The FCC seeks to work cooperatively with other governmental agencies to advance our shared objectives of ensuring that consumers, businesses and anchor institutions have access to next generation services. How can States, localities, Tribal governments, and other non-federal governmental bodies provide assistance through matching funding, in-kind contributions or other regulatory approvals and permits, to improve the business case for deployment of next generation networks?

In evaluating proposals, the FCC will employ an application-based competitive bidding process with objective selection criteria in part to help the Commission to design a more effective nationwide competitive bidding mechanism for the Connect America Fund, whether that mechanism ultimately takes the form of a reverse auction or some other form of competitive bidding with a limited number of objective, defined selection criteria. The FCC also will use the application-based competitive bidding process to consider how better to ensure that all of our universal service programs are working together effectively to ensure that residential consumers, small businesses, and anchor institutions have access to evolving services delivered over scalable networks. The FCC encourages proposals from a wide range of entities and consortia of entities, including State and regional authorities, research and education networks, municipalities, Tribal governments, cable operators, telephone companies, fixed and mobile wireless providers, wireless Internet service providers, and utilities.

The FCC is particularly interested in projects that strive to ensure universal availability of modern networks capable of providing voice and broadband service to homes, businesses, and community anchor institutions. “We also are interested in learning how to best leverage the support available from all of the Commission's universal service programs to comprehensively serve the needs of rural communities, including their educational and health care needs,” the Commission states.

The application process will be conducted in two stages: a nonbinding expression of interest stage and a formal proposal stage. The first round of expressions of interest are due March 7, 2014 (although additional expressions will be accepted later). Formal applications will be due shortly (perhaps 60 days) after the FCC decides the overall budget available for these experiments and selection criteria. An expression of interest should include:

• The nature of the submitting entity or entities (e.g., telephone company, municipality, utility, cable operator, wireless provider);
• Identification of the proposed service area for the experiment, including census block number, with any relevant information regarding the number of locations that could be served, including schools, libraries, and other anchor institutions;
• The broadband technology or technologies to be deployed;
• Contemplated service offerings (e.g., description of voice service, broadband speed tiers, nature of video service, if any) and pricing of such offerings;
• If known, expected State and/or local or Tribal governmental participation in and/or support for the project (e.g., expedited permitting, access to rights of way, matching funds, etc.); and
• Whether the proposal is expected to require one-time or continuing funding and a high-level estimate of the amount of funding requested.

Because of funding constraints, only a small number of projects will be selected. Applicants may select one-time Connect America support or request recurring support for up to 10 years. Providing a longer term of support in the experiment, the FCC concluded, could provide the Commission with valuable information regarding how to elicit greater participation in the Connect America competitive bidding process, which will help ensure that funding is targeted efficiently to expand broadband-capable infrastructure throughout the country.

Now potential applicants for these funds need not apply to be what’s called an eligible telecommunications carrier (ETC). However, before receiving any Connect America funds, the provider must receive ETC designation either from the FCC or their state’s public utilities commission. And that means that the application must offer voice telephony service at reasonably comparable rates as part of the experiment. It also means that the provider must comply with all relevant universal service rules that the FCC has adopted or may adopt in the future, including but not limited to ETC requirements to the extent that they apply to recipients of high-cost and Lifeline support, reporting requirements, audits, and enforcement mechanisms for non-compliance with rules.

II. Research for Persons With Disabilities

On December 12, 2013, the FCC and the National Institute on Aging, a part of the National Institutes of Health, announced an agreement to partner on research into the use of modern IP technology to improve and make more accessible phone service to Americans who are deaf, deaf-blind, or hard of hearing. Currently, persons with disabilities rely on certain existing legacy services for access to the communications network. On January 30, the FCC took additional steps to structure and fund research designed to further the Commission’s multiple goals of ensuring that Telecommunications Relay Service (TRS) is functionally equivalent to voice telephone services and improving the efficiency and availability of TRS. Available in all 50 states, TRS is a telephone service that allows persons with hearing or speech disabilities to place and receive telephone calls. The FCC will now move forward on selecting research projects for funding that:

• Are focused on exploring the impact of IP-based technologies and services on persons with disabilities;
• Are intended to further the Commission’s goal of ensuring that TRS is functionally equivalent to voice telephone services; and
• Are intended to improve the efficiency and availability of TRS.

The budget for the research is $3 million.

In addition, the FCC is beginning to gather and incorporate stakeholder input on the types of research needed to improve the functional equivalency and efficiency of TRS through workshops, stakeholder roundtables, or other means. The FCC and the National Institute on Aging will host a workshop on February 18 to gather and incorporate stakeholder input on the types of research that are needed to improve the functional equivalency and efficiency of TRS. The focus will be on developing a platform for the delivery of IP-based relay services and the development of new and improved relay services during and after the IP transition.

III. A Numbering Testbed

In the all-IP network, telephone numbers will be one set of addressing identifiers among many, which include domain names, IP addresses, and service specific identifiers. The IP Transition raises challenges and opportunities for the assignment of telephone numbers within the North American numbering plan and for the features, capabilities, and security of numbering-related databases. Getting these numbering systems right is essential to preserving core values of competition and consumer protection.

• Number portability, for example, encourages competition by allowing consumers to respond to providers’ price and service changes without losing their phone numbers.
• Numbering databases allow for efficient interconnection among providers, furthering competition and entry of new providers.
• Call routing and call completion policies fulfill consumers’ valid expectations that by dialing a telephone number they will successfully reach whomever they wish to call.
• The integrity of numbering information is crucial for securing voice-related services, e.g., to prevent or reduce telephony denial-of-service attacks, phishing, illegal telemarketing practices or fraud, thus furthering public safety and consumer protection goals.

The FCC aims to ensure that these values, which are embedded in our current numbering systems and policies, are preserved and enhanced.

On January 30, the FCC began the process of developing a telephony numbering testbed for collaborative, multi-stakeholder research and exploration of technical options and opportunities for telephone numbering in an all-IP network. The numbering testbed is intended to be a proof of concept. Developing ideas in a testbed avoids disrupting current systems and would allow interested parties to work through technical feasibility constraints to allow for the broadest range of policy options and outcomes.

The testbed goals would be to enable research into numbering in an all-IP network, unencumbered by the constraints of the legacy network. Such a testbed might address number allocation and management as well as database lookup for call routing. The testbed will run for about a year with a public review at the six month mark and when the test is completed. The FCC is asking if it should fund the testbed and other research into numbering management, and if so, what should be the source of funding and budget. The FCC also seeks comment on how to best identify any further research that should be facilitated by the Commission to supplement the work of stakeholders participating in any testbed and under what timeframe that research should be performed.

The FCC expects to convene one or more workshops to facilitate the design and development of the testbed. These workshops are intended to be engineering working sessions, modeled after ‘hackathons’ in which groups of technical experts collaborate intensively to work through technical challenges and create prototype systems. Participation is open to any and all technical experts, but particularly software engineers with experience implementing telephony-related systems.

As noted above, we’ve already looked at the FCC’s proposal for service-based experiments http://benton.org/node/174005 . Our next post will explore the Commission’s proposal on data collection to help inform the IP Transition.

Notes:

1. USF/ICC Transformation Order, 26 FCC Rcd at 17669-70, paras. 6-10.
2. Lifeline Reform Order, 27 FCC Rcd at 6794-6807, paras. 321-54.
3. Rural Healthcare Support Mechanism, WC Docket No. 02-60, Report and Order, 27 FCC Rcd 16678, 16832, Appx. B (2012) (Healthcare Connect Fund Order).
4. Modernizing the E-rate Program for Schools and Libraries, Notice of Proposed Rulemaking, WC Docket No. 13-184, 28 FCC Rcd 11304, 11310-11, paras. 11-12 (2013) (E-rate Modernization NPRM).