Verizon’s ongoing copper retirement efforts may be controversial, but the telco says the process would be more efficient if it could provide the notifications electronically.
In a recent FCC filing (PDF), Verizon asked the regulator to clarify its copper retirement notification requirements by confirming that telcos can provide interconnection partners and local public utility commissions a paper copy of the notice and a hyperlink to a searchable online list of addresses or locations where copper is to be retired in lieu of a paper copy of the address list.
Verizon has also petitioned the FCC to waive any requirement that any affected party be served with a paper address list when providers instead provide a copy of the notice and a hyperlink to a searchable online list.
However, Verizon said that will “continue to send paper copies of its copper retirement notifications, excluding the address lists, to state public utility commissions, state governors, tribal entities, the Secretary of Defense, and all interconnecting entities operating in the state in which the copper retirement will occur.”
Under the current FCC rules, incumbent ILECs are required to provide “a copy” of the copper retirement notice to its interconnection partners, state public utility commissions, state governors, tribal entities and the Secretary of Defense.
Every one of Verizon’s copper retirement notices includes a list of the location(s) at which the changes will occur. In order to comply with the requirement to provide “a copy” of its copper retirement notice, Verizon said it mails paper copies of the notice to the required parties.
However, Verizon noted that the “paper address list currently provided is often unwieldy for interconnecting parties to search, and can significantly increase the costs of paper and postage.”
What makes the paper notification process more complex is the diverse nature of the copper retirements.
A number of Verizon’s September 2016 copper retirement notices contained more than 400 pages of hard copy lists of addresses, for example.
“While in some cases a provider may seek to retire copper at the wire center level, in other instances a provider may instead choose to retire copper at the individual address level,” Verizon said. “Thus, depending on the copper retirement notice, the address list may be thousands of discrete locations covering many pages.”
A number of Verizon’s interconnection partners that are affected by their copper retirement plans say they would prefer an online notice.
Verizon said “a number of carriers contacted both Verizon’s notice contact person and their respective Verizon account team to ask if they could receive searchable electronic documents to determine if they would be impacted by the copper retirement within a specific wire center,” while other parties “explained that paper copies were less convenient for their systems.”
Even as Verizon transitions to an electronic format for copper retirement notifications, the service provider would continue to communicate with any affected party.
As part of this correspondence, Verizon said it would discuss potential impact to “their specific circuits/services and describing a timeline for migration.”
“We continue to work with interconnecting carriers to help them identify their end users who need to migrate services and to coordinate the timing of those moves,” Verizon said.