Some recent public notices from the FCC have been a bit like multiple-choice tests or consumer surveys which invite participants to “check all that apply.” A recent request for comment about measuring broadband adoption, for example, contained 50 questions it said respondents might want to consider.
In contrast, the commission’s request for comment about the transition from circuit-switched to all-IP network issued December 1 is more like an essay test, with few hints given as to how respondents are expected to answer. Respondents have until December 21 to help “identify the relevant policy questions . . . in order to assist the commission with how best to monitor and plan” for the transition from circuit-switched to all-IP communications technology.
Based on this input, the commission said it may take the additional step of issuing a notice of inquiry “relating to the appropriate policy framework to facilitate and respond to the market-led transition in technology and services.” The FCC noted that “No longer is broadband simply another service—it is a growing platform over which the consumer accesses a multitude of services, including voice, data and video in an integrated way across applications and providers.”
Likening this transition to earlier technology changes, such as the shift from analog to digital mobile service, the FCC noted that in such transitions “policy has played an important role in ensuring consumers were protected from loss of essential services and were informed of the choices presented by the transition.” The commission also noted that policy has played a role in providing a “glide path” for all industry players, enabling more efficient planning and adjustment over the course of the transition.
The only specific ideas mentioned in the request for comment involved ensuring appropriate protections for people with disabilities and a short sentence saying respondents might ask the FCC to reconsider carrier of last resort obligations.
The FCC issued the request for comment to help in meeting its requirement (under the American Recovery and Reinvestment Act of 2009) to create a national broadband plan by February 17, 2010. Quoting the act, the FCC said it hoped respondents’ comments would help meet the requirement to provide “an analysis of the most effective and efficient mechanism for ensuring broadband access by all people of the US.” The comments also would be used to help provide “a detailed strategy for achieving affordability of such services and maximum utilization of broadband infrastructure and service by the public.”



