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NTIA Still Concerned About FCC IP Transition Rules' Potential Downside for Federal Entities

NTIA welcomed FCC efforts to spur the IP transition but noted continuing concern about the impact on federal entities of some copper retirements and telecom service discontinuances. Network modernization can "significantly reduce carriers' operating and maintenance costs and enable carriers…

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to expand and enhance the services," said its filing Thursday in docket 17-84: But "streamlined regulatory requirements may place federal departments and agencies that rely on services subject to discontinuance in the untenable position of losing access to critical national security and public safety communications functionality." It noted many federal agencies have offices and installation in remote or less-populated areas -- or receive services outside of certain contract structures -- from carriers not facing competitive pressures. Often, such carriers "lack the incentives that exist in more populated areas and, thus, negotiation alone may not produce the contractual provisions that adequately serve federal users' needs," it said. NTIA is encouraged by FCC statements expecting continued industry collaboration with customers, "especially utilities, and public safety and other government customers, to ensure that they are given sufficient time to accommodate the transition" to next-generation services with key functionalities intact. It construed certain FCC order language "as a commitment to sanction conduct impinging on ... critical functions when it occurs." It wants copper retirement held in abeyance "if a federal user credibly alleges that the carrier's proposed retirement due date does not give the user 'sufficient time to accommodate the transition to new network facilities such that key functionalities are not lost.'"