COMMISSIONER AJIT PAIRe:
Technology Transitions, GN Docket No. 13-5; AT&T Petition to Launch a Proceeding
Concerning the TDM-to-IP Transition, GN Docket No. 12-353; Connect America Fund, WC
Docket No. 10-90; Structure and Practices of the Video Relay Service Program, CG Docket No.
10-51; Telecommunications Relay Services and Speech-to-Speech Services for Individuals with
Hearing and Speech Disabilities, CG Docket No. 03-123; Numbering Policies for Modern
Communications, WC Docket No. 13-97.
The IP Transition is upon us. Each year, millions of Americans are leaving the public-switched
telephone network (PSTN), instead opting for IP-based services. Indeed, the American people are leading
the way to the all-IP future. This is good news. IP networks provide better service quality and increased
network capacity. They hold the promise of more effective emergency response through Next Generation
911, better healthcare through telemedicine, and improved educational outcomes through distance
Almost a year ago, I called on the Commission to move forward with an All-IP Pilot Program,
one that would give forward-looking companies a path to turn off their old TDM electronics in a discrete
set of wire centers and migrate customers to an all-IP platform.1 Why? Because we cannot continue
requiring service providers to invest in both old networks and new networks forever. Every dollar that is
spent maintaining the networks of yesterday is a dollar that can’t be invested in the networks of
tomorrow. And our goal should be to maximize investment in IP infrastructure so that high-speed
broadband extends to every corner of our country.
But we cannot just turn off the PSTN overnight. Instead, we need to beta test the concept first.
We need to see what works and what doesn’t. Albert Einstein had it right: A “pretty experiment is in
itself often more valuable than twenty formulae extracted from our minds.” With real-world experience
and hard data in hand, we will be much better positioned to make the broader transition to an all-IP future.
I am therefore pleased that today’s order adopts an All-IP Pilot Program consistent with the four
principles I set forth last year. First, carrier participation should be voluntary—and today, we announce
that “[n]o provider will be forced to participate in an experiment.”2 Second, trials should reflect the
geographic and demographic diversity of our nation—and today, we “seek experiments that cover areas
with different population densities and demographics, different topologies, and/or different seasonal and
meteorological conditions.”3 Third, no one can be left behind—and today, we declare that “no consumer
[may] lose access to service or critical functionalities”4 and that residential and business customers must
receive “clear, timely, and sufficient notice of any service-based experiment.”5 And fourth, we must be
able to evaluate an all-IP trial with empirical data—and today, we seek “experiments that collect and
provide to the Commission data on key attributes of IP-based services.”6 With these core principles in
place, I am optimistic that the trials will be a success.
I am especially happy that today’s order moves forward with the All-IP Pilot Program on a
unanimous, bipartisan basis. As I said last year, this isn’t an issue that divides the left from the right or
Republicans from Democrats. And accordingly, the order reflects our consensus that companies should
1 Remarks of FCC Commissioner Ajit Pai, “Two Paths to the Internet Protocol Transition” at 5 (Mar. 7, 2013),
available at http://go.usa.gov/B4gB.
2 Order at para. 32.
3 Order at para. 30.
4 Order at para. 54.
5 Order at para. 70.
6 Order at para. 74.
have the opportunity to go all-IP. What is more, today’s order demonstrates that reaching an agreement
does not mean compromising your values. Even if each of us would have preferred a somewhat different
order, we were able to work collaboratively and meet in the middle—a testament to good government,
and one that hopefully bodes well as we continue moving to an all-IP future.
Speaking of compromise, I appreciate the willingness of my colleagues to make clear that the
rural broadband experiments proposed in this item will not undermine—and just as importantly will not
delay—moving forward with the second phase of the Connect America Fund to bring access to next-
generation technologies to millions of rural Americans. And I welcome their willingness to propose
redirecting the funding the Commission set aside in 2012 for a skilled nursing facility program.7 I
dissented from establishing that program and said at the time that it was unlawful and a mistake.8 I hope
that the record will help steer us toward a more constructive use of that funding.
Finally, today’s order is just one step on the path to an all-IP future. We are only beginning to
embrace the IP Transition. We must still repeal the many outdated rules on our books based on the
principles of 19th century railroad regulation. We must still press forward with the consumer protections
that will remain necessary in an all-IP world. We must still revisit and revise the architecture of the
telephone network, following up on our recently completed VoIP numbering trials. And we must still
turn to Congress for further guidance on our role in the 21st century communications marketplace. In
other words, there is still much to be done on the IP Transition, and I am looking forward to doing it.
7 See Rural Health Care Support Mechanism, WC Docket No. 02-60, Report and Order, 27 FCC Rcd 16678, 16816–
18, paras. 346–50 (2012).
8 Id. at 16919 (Statement of Commissioner Ajit Pai, Approving in Part and Dissenting in Part).
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