As it transitions more of its network from copper to fiber and IP, Verizon (NYSE: VZ) says that the FCC should create what it calls a "safe harbor" for discontinuation of legacy TDM-based services.
With this safe harbor process in place, service providers would have the certainty and the ability put a plan in place.
In an FCC filing, the service provider has asked the FCC to modify a number of its proposed new criteria in assessing whether a replacement service is a "reasonable substitute for a legacy service that a carrier seeks to discontinue."
"Regardless of what the Commission decides to do with those criteria, the Commission should adopt a safe harbor approach outside of those criteria for discontinuances of outdated or largely unused services or for services for which there is no means to continue them, when discontinuing those services will not affect the ability to call 9-1-1," Verizon said in a filing.
Further, Verizon argues that any service that is within this safe harbor structure, the FCC should grant any service providers' applications automatically after being given notice.
"This safe harbor should apply to all Section 214 discontinuances, regardless of whether they are in the context of a technology transition," Verizon said.
There are some concerns with such a structure. One of the issues often raised is whether a consumer will be able to dial 911 during an emergency.
Verizon pointed out that a number of the services that it and other incumbent telcos want to discontinue will not affect 911 calling since they don't involve voice or because customers have adopted a wireless or VoIP service. Another issue is that a number of service provider's vendors may no longer offer equipment to support a particular service.
"Many services that providers seek to discontinue do not affect this priority, because they do not involve voice or because customers themselves have already abandoned them in favor of other services," said Verizon. "Also, sometimes a provider may have no control over the decision to discontinue. When a service relies on the use of a particular piece of equipment or an input that a vendor is discontinuing, for example, the provider often cannot continue providing that service and must discontinue it even if there are customers still using it."
- see this FCC filing (PDF)
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