COMMISSIONER MIGNON L. CLYBURNRe:
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.
I say this quite often when it comes to technology that this is an exciting time to be in this space.
While walking the floor at the Consumer Electronics Show (CES) earlier this month, I had a first-hand
view of new and innovative products that are game-changing, mind boggling, and life-altering. Full
color, 3-D printed confections (yes, I am still a bit fixated on customized sweets), a device that augments
previously inaudible sounds which could help wounded soldiers improve their hearing and quality of life.
The concept cars of yesterday are the smart cars of today and hold the promise of saving lives and
avoiding collisions. Technological advancements and innovation abound with limitless potential.
I am proud to say that during my tenure, the Commission has taken a number of actions to
promote investment and innovation in this area. The National Broadband Plan will celebrate its fourth
anniversary in March. It set forth a blueprint for the nation to move from legacy telephone services to the
broadband enabled era in all sectors, including health and education, and recommended that the
Commission update its policies to promote and reflect IP networks.
Today’s action, is another in a series that the Commission has undertaken to implement many of
these recommendations, including the landmark, bipartisan reform of universal service and intercarrier
compensation. In acting on these recommendations the Commission found that these legacy systems not
only were subsidizing services of a bygone era, but also were deterring the transition to IP networks. The
Commission provided a path to “promote innovation by eliminating barriers to the transformation of
today’s telephone networks into the all-IP broadband networks of the future.”1
In the two years since the Commission adopted the USF/ICC Transformation Order, providers
have increased their deployment of IP equipment and facilities so much so that today we launch a process
for interested parties to submit proposals for experiments, which would shift entirely away from legacy
equipment and facilities. I am pleased that the Order recognizes what I have maintained all along – that
the core values embodied in the Communications Act – competition, consumer protection, universal
service and public safety, do not change as technologies evolve, and must guide the Commission’s
process going forward. While the transition holds potential for the introduction of next generation 911,
with features such as video call and more reliability and redundancy, there is also a risk of unintended
consequences for consumers, public safety, and competition. The parameters for these experiments,
including protections for these core values as well as the means to identify data that would be useful for
experiments should provide the Commission and the states information needed to make decisions going
1 See Connect America Fund; A National Broadband Plan for Our Future; Establishing Just and Reasonable Rates
for Local Exchange Carriers; High-Cost Universal Service Support; Developing an Unified Intercarrier
Compensation Regime; Federal-State Joint Board on Universal Service; Lifeline and Link-Up; Universal Service
Reform – Mobility Fund, WC Docket Nos. 10-90, 07-135, 05-337, 03-109, GN Docket No. 09-51, CC Docket Nos.
01-92, 96-45, WT Docket No. 10-208, Report and Order and Further Notice of Proposed Rulemaking, 26 FCC Rcd
17663, 17680 para. 648 (2011) (USF/ICC Transformation Order), pets. for review pending sub nom. In re FCC 11-
161, No. 11-9900 (10th Cir. filed Dec. 8, 2011).
forward. I am also pleased that the Order instructs the Commission to consult with states and Tribal
governments in geographic areas where entities propose a trial.
At the same time, we must acknowledge that not everyone in this country has the luxury of being
able to take advantage of those products, devices and applications I saw at CES. Most of us in this room
are fortunate to have the ability to be the first adopters, but millions cannot because they live in rural
areas. Millions more have access but cannot afford to do so. The Commission has a duty as provided in
section 254 of the Telecommunications Act to close digital divides and ensure that all Americans,
including low-income consumers and those in rural, insular and high cost areas have access to advanced
telecommunications and information services reasonably comparable to those in urban areas.
I remain firmly committed to ensuring that the Commission lives up to this Congressional
mandate, and I believe the rural broadband trials in the Order and Further Notice could be a vehicle to
help achieve these goals. The USF/ICC Transformation Order sets up a process to give incumbent
carriers the right of first refusal to accept or decline state-wide support using a forward-looking cost
model to provide broadband and voice to unserved areas. The Commission sought comment on the
competitive process for the distributing Connect American Fund Phase II support in areas where the
incumbent declines its right of first refusal. These rural broadband trials could help facilitate the
Commission’s ability to structure the competitive process, while the Order makes clear that the
distribution of Phase II support under the forward-looking model continues on a parallel track without
These rural broadband experiments and the technology transitions, present an incredible
opportunity to explore how best to achieve the Commission’s goals adopted in the USF/ICC
Transformation Order of “ensur[ing] universal availability of modern networks capable of providing
voice and broadband service to homes, businesses, and community anchor institutions.”2 Connecting
anchor institutions was something I strongly advocated leading up to the adoption of the USF/ICC
Transformation Order. I believe the Commission should leverage the Connect America Fund to achieve
all of our obligations in section 254 including serving rural and low-income consumers, and connecting
anchor institutions and health care facilities. This Order invites experiments to further explore these
issues, to ensure that the goals of connecting anchor institutions in the USF/ICC Transformation Order
I appreciate the support of my request for comment on healthcare broadband experiments which
could ensure that consumers and health care providers in rural areas have access to advanced telemedicine
and other remote monitoring services. Technological advancements are transforming the delivery of
healthcare, and some Americans stand to be left behind because they either lack access, or the means, to
these services. I believe our universal service mandate includes ensuring that consumers have access to
these advanced services, and hope to work with the Chairman and my colleagues to move quickly to
adopt an order approving these healthcare trials.
With regard to disabilities access, I am excited that the Order adopts the $3 million budget
proposed in the Video Relay Services Reform Order for research focusing on the impact of IP-based
technologies and services for persons with disabilities. The goal is to ensure, that the
Telecommunications Relay Services, offer functionally equivalent voice services, and improve the
efficiency and availability of TRS. Research here could focus on the specific needs of this community
including effects on different demographics, and the relationship with health care. The technology
transitions have opened tremendous doors and opportunities for persons with disabilities and I strongly
2 USF/ICC Transformation Order, 26 FCC Rcd at 17873, para. 48.
encourage all interested parties to submit research proposals for the Commission’s consideration to
evaluate how to improve our TRS services.
Finally, I am pleased my colleagues agreed with my suggestion to seek the input of the Federal-
State Joint Conference on Advanced Telecommunications Services a request to help improve the
Commission’s own consumer complaint processes, by learning best practices from the states. I believe
we can learn from our state partners, particularly on consumer complaints, something that states know
This item is comprehensive in scope, and I want to thank the Chairman for his leadership, and the
dedicated team of public servants, who worked so diligently. While the list includes many talented staff
in virtually all of the Commission’s Bureaus and Offices, allow me to specifically thank, Jonathan Sallet,
Stephanie Weiner, Jonathan Chambers, Nick Alexander, Matthew Quinn, Julie Veach, Carol Mattey, Tim
Stelzig, Admiral David Simpson, and Henning Schulzrinne.
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