Verizon has filed its request to the FCC to discontinue copper service in certain communities on Fire Island, NY and the Barrier Island of NJ, as required by Section 214(a) and 47 C.F.R. 63.71. You can find a copy here. At some point, the FCC will put this out on Public Notice and then folks can file objections if they want.
In some ways, this is a little thing impacting only a few communities. In other ways, it is a very big deal. If there is a single moment to point to and say “This is it! This is The Day We Started To Shut Down The Phone Network,” that day is today. With this little routine barely noticed filing for an administrative procedure that impacts a handful of communities.
Why? Because for the first time, the local phone company has said “once the old copper lines come down, they are not coming back — ever. We are out of the traditional phone service on Fire Island and Barrier Island and no one else is going to provide it either.”
Yes, there are other services that will sell you voice service. They will tell you its a phone. Each of these does many things the old phone system does, and most of these services do amazing things the old phone system could never do.
But like any transition — especially one that rests on a social contract people have relied upon for 100 years — we must expect a lot of disruption as well as anticipate the potential benefits. Verizon should not need to maintain an increasingly expensive and antiquated copper network until the end of time. Nor should they be required to rebuild copper they expect to shut down again in a few years time.
At the same time, we don’t just throw people under the bus — or send them suddenly scrambling for expensive alternatives. I’ve objected before to the way Verizon has moved forward with Voice Link because Sandy victims should not be guinea pigs for Voice Link’s first ever mass deployment. At Public Knowledge, we’ve also had some concerns about what Verizon says Voice Link doesn’t do that the old copper service did do. Some of these can be addressed relatively easily, and Verizon has stated publicly it is working on improvements in things like battery life and using commercially available double AA batteries. Services that are considered vitally important by some communities, such as the ability to use international calling cards and receive collect calls, would require more work.
The question isn’t whether we transition the phone system or don’t. The question is how we transition. This is why my employer Public Knowledge has supported using a Framework of Five Fundamental Principles to guide the transition: Service to All Americans, Consumer Protection, Reliability, Public Safety, and Competition. This is why we have supported AT&T’s call to engage in dialog on the transition, and endorsed the idea of carefully conducted technical trials that protect consumers and genuinely inform the process.
As the FCC and state regulators evaluate Verizon’s application to end copper wire service entirely and replace it with Voice Link, it should evaluate Voice Link under the Five Fundamentals Framework. Does Voice Link provide adequate service to all members of the community, including the poor and vulnerable who have depended most heavily on the “copper safety net” of the old phone system? Does it adequately protect consumers? Will it function reliably in an emergency? And what are the implications for competition?
Above all else, the transition of the phone system and the end of the old copper network must not be a step backward. Handled properly, the transition can benefit everyone. There is nothing magical about copper. All the fundamental principles we have relied on for 100 years — service to all Americans, consumer protection, reliability, public safety, and competition — were the result of deliberate policy choices. We can maintain these principles as we move forward to new wireless and IP-based networks, or we can chose to discard them.
Verizon and AT&T, understandably, have stressed everything we have to gain from the networks of the 21st Century. It falls to the regulators — and the public that holds them accountable — to make sure these gains do not come by sacrificing the poorest and most vulnerable.
Stay tuned . . . .