The National Association of State Utility Consumer Advocates outlined the values it deems important in the IP transition, detailing them in an ex parte filing with the FCC as well as a white paper it commissioned. The IP transition is definitely underway, NASUCA said in Monday’s filing. “However, this transition does not eliminate the underlying public policy objectives that regulators have promoted -- affordable rates, high quality services, 911 access, or broadband deployment,” it said (http://bit.ly/1eAwJBs). “It is reasonable, indeed necessary, to anticipate an ongoing need for policy oversight of the IP transition, including the need for a reasoned determination of when regulation may be needed to correct market failures, and to enable rapid resolution of market conflicts, including between customers and carriers.” It listed seven areas of concern: affordability, competition, reliability and service quality, access to emergency services, carrier of last resort and universal service, and consumer education. States should have a role, NASUCA said. Trevor Roycroft, an associate professor at Ohio University’s School of Information and Telecommunication Systems, wrote the NASUCA-sponsored attached 24-page white paper (http://bit.ly/1ai6h0a), which purports to rebut the arguments Anna-Maria Kovacs has made on behalf of the Internet Innovation Alliance (CD Nov 19 p18).

FCC Commissioner Ajit Pai is contacting major hotel chains to ensure 911 works wherever it’s dialed. In letters sent Monday to the CEOs of major U.S. hotel chains, Pai spoke of a December incident in which a child tried to dial 911 when her mother was being strangled by her estranged husband. The child “tried to call 911 four times but never reached emergency personnel” because the hotel required her to dial 9 first to get an outside line, wrote Pai. “The hotel’s phone system failed her, her mother, and her entire family.” Pai said the mother ultimately died from the attack. “It appears that dialing 911 alone doesn’t work in many hotels and motels across the country,” he said. “This is unacceptable.” Pai asked the CEOs to respond to his inquiries, including whether simply dialing 911 would connect guests to emergency personnel. “What is your company’s plan for remedying this situation?” Pai asked. “If you do not have a plan, why not?” Pai intends over the coming months to ensure 911 always works when dialed from hotels, he said in a related written statement (http://bit.ly/1az9kkV).

FCC IP transition trials should use a “phased in” approach that leaves “oddball cases” for subsequent rounds, Public Knowledge told General Counsel Jonathan Sallet Wednesday, an ex parte filing said (http://bit.ly/1fgokIp). “Nothing will crash the transition of the phone system to new technologies like a headline that someone died because of a poorly planned or recklessly implemented study.” A phased-in approach should also start with a voluntary trial pool, for consumers are “highly resistant to a forced conversion,” PK said. Incentives, like free or discounted service, could help overcome resistance, it said. Delaying the transition of complicated cases -- such as customers with heart monitors or other crucial legacy equipment -- would mirror the approach commonly taken in clinical trials conducted by the Food and Drug Administration, where initial trials generally exclude subjects with “complications beyond the target condition,” PK said. The public interest group suggested trials that follow a “blind” and “cross-population” protocol, in which some customers are given the new technology and some keep the existing technology, but customers wouldn’t know which group they were in. After a few months, customers should be switched to the opposite technology, PK said. “This approach is common in clinical trials to normalize the data across the entire study population while still maintaining a valid control group.” Importantly, businesses and government facilities create “unique concerns,” as they are most dependent on traditional copper-based services, and a mandatory trial could disrupt normal operations, PK said. The FCC needs to take their needs into account when implementing trials, PK said.

Two cable associations challenged the FCC’s special access data request, in a Paperwork Reduction Act (PRA) filing with the Office of Management and Budget. The American Cable Association said the data collection would impose “excessive burdens on small cable operators in relation to the value of the information requested,” thereby violating the PRA. ACA’s members will need to spend “significant time and resources” to create databases of information requested by the FCC that the cable operators don’t currently have, the association said. The new efforts lie principally in the collection of data for fiber maps, location information, and billing and revenues information, ACA said. NCTA also challenged the order, calling the proposed data collection a violation of the letter and the spirit of the PRA. “It is a massive exercise in paperwork creation that will impose substantial new burdens on thousands of companies that have never before been subject to recordkeeping or reporting requirements with respect to the services that are the subject of the collection,” NCTA said. “The FCC has underestimated the burden of the collection by hundreds of thousands of hours and tens of millions of dollars.” Changes made by the FCC in response to its initial PRA notice have increased, not decreased, the overall burden on cable operators, NCTA said. In terms of hours required to comply with the request, this data collection is one of the 10 largest “on the entire roster of OMB-approved FCC collections,” it said. Making matters worse, “much of the requested data has no practical utility because it is too voluminous and too granular for the FCC to analyze in a meaningful and timely manner,” NCTA said.

Pay Tel, an inmate calling service (ICS) provider, petitioned the FCC Wednesday for a waiver of the interim prison calling rate caps (http://bit.ly/KysX2o). Pay Tel “cannot recover its costs on a holding company level” if required to charge such low interstate rates, it said. The “rate cap framework does not adequately address Pay Tel’s demonstrated costs of providing ICS, and a waiver of the cap rules is therefore appropriate,” Pay Tel said. “The Order adopts rate caps for interstate ICS based generally on Pay Tel’s demonstrated average costs, meaning that Pay Tel will be legally prohibited from recovering more than its company-level average costs from interstate calls. However, the Order fails to preempt below-average-cost intrastate rate constraints, thereby leaving Pay Tel unable to recover its total-company costs and placing Pay Tel in an economically unsustainable situation."

Experimentation with “two-sided markets” should be limited to the provision of “specialized services,” and not allowed in connection with the provision of broadband Internet access services, the Center for Democracy & Technology told FCC acting General Counsel Jonathan Sallet on Friday, an ex parte filing said (http://bit.ly/19bKGYL). CDT also suggested the FCC examine the extent to which direct interconnection between two carriers is necessary to optimize performance, as the telecom industry transitions to all-IP.

The Virgin Islands Telephone Corp., doing business as Innovative, plans to pursue a request for waiver of the National Exchange Carrier Association’s rolling 24-month adjustment period, it said in an ex parte filing Thursday (http://bit.ly/1crhgUR). Without the waiver, the telco’s 2011 high-cost loop support (HCLS) would be determined “based on inaccurate data,” it said. Under NECA pooling arrangements, carriers have a 24-month window in which they can make adjustments to their line counts and cost studies. Innovative didn’t discover a problem with its line counts until that 24-month period expired. “The financial impact to Innovative associated with the calculation of the company’s 2011 HCLS is significant. Specifically, unless the Commission waives NECA’s rolling 24-month adjustment period, Innovative will lose $565,860 in HCLS for 2011 -- a loss that would negatively impact Innovative’s operations."

The IP transition must prioritize “enduring values” including consumer protection; affordable, high-quality service; promotion of competition; and consumer education, the American Association of Retired Persons told FCC officials Dec. 16, according to an ex parte filing released Thursday (http://bit.ly/1hYNDMO). Access to emergency services, carrier-of-last-resort obligations and universal services policies remain important as well, AARP said. Any IP transition “experiments” should be “conducted in an environment of informed consent for the subjects of the experiments, including the full awareness of potential challenges, length of the experiment and the resources available should problems arise,” AARP said.

The FCC seeks comment on CenturyLink’s proposed compliance plan for forbearance relief from cost assignment rules, the agency said in a public notice Thursday (http://bit.ly/1coVZeg). The FCC in May conditionally granted forbearance to price cap carriers from rules requiring them to assign costs and maintain the network and revenue from services provided to specific categories, the notice said. But that grant was expressly conditioned on Wireline Bureau approval of a compliance plan to be filed by price cap carriers, “describing in detail how the price cap carrier would continue to fulfill its statutory and regulatory obligations,” it said. Comments in WC docket 12-61 are due Jan. 16, replies Jan. 30.

Cincinnati Bell wants to discontinue its Primary Rate Interface service and Plain Old Telephone Service provided over Cisco 5400 equipment network connectivity by Jan. 31, the FCC said Tuesday. Cincinnati Bell said its PRI service has fewer than five customers, and only a “small number” of its POTS subscribers would be affected by discontinuing the Cisco 5400 connectivity. Cincinnati Bell notified affected customers in late November; those customers have the opportunity to subscribe to similar services from Cincinnati Bell or change providers, the FCC said. The commission is seeking comment on Cincinnati Bell’s proposal through Jan. 15.