NASUCA, Others Ask FCC to Reconsider Tech Transition 'Technical Guidance'

require adequate voice replacement services when telcos seek streamlined discontinuance of legacy phone services under Section 214 of the Communications Act. "But the technical guidance in Appendix B is inconsistent with the rules and does not achieve the Commission’s objective that technology transitions result in consumers receiving service with comparable service quality and performance to that provided over the Public Switched Telephone Network," said the National Association of State Utility Consumer Advocates (NASUCA), Maine Office of the Public Advocate, the Maryland Office of People’s Counsel, and The Utility Reform Network of California, in a filing posted Wednesday in docket 13-5. "The technical guidance does not recognize that the PSTN is an end-to-end experience. The Commission cannot hope to preserve PSTN quality if it only tests a portion of a phone call." They said Appendix B also "presumes that the replacement service is an over-the-top (OTT) service, rather than a managed-VoIP service," like those offered by cable providers or incumbent telcos. "Commission data indicates that OTT services collectively serve a minuscule 0.8% of the VoIP lines provisioned by the ILECs that would seek a section 214 discontinuance," they wrote. "Finally, the technical guidance ignores the serious complications introduced when calls can be expected to traverse -- as they will during the nation’s extended transition to new technology -- different technology platforms and the networks of multiple carriers." The FCC didn't comment.