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ISE Columnist Tom Maguire, Network Transformation

The Reality of NT in the Field

April 1, 2018
I’m so glad it’s spring! (Well, actually it is still winter as I am writing this in January.) Unfortunately, this has been another nasty winter for many — especially in […]

I’m so glad it’s spring! (Well, actually it is still winter as I am writing this in January.) Unfortunately, this has been another nasty winter for many — especially in the northeast. But continuing bad weather should come as no surprise to anyone keeping tabs on recent weather trends — some of which have been truly disastrous. According to the NOAA National Centers for Environmental Information: "In 2017, there were 16 weather and climate disaster events with losses exceeding $1 billion each across the United States. These events included . . . 2 flooding events, 1 freeze event,8 severe storm events, 3 tropical cyclone events . . . The 1980–2017 annual average is 5.8 events (CPI-adjusted); the annual average for the most recent 5 years (2013–2017) is 11.6 events (CPI-adjusted)." (

As we discussed in the January 2018 column, these storms wreak havoc with copper cables. But, thankfully, their fiber counterparts continue to perform as designed. This enhanced resiliency is one of the reasons we talked about the need (not want) to move people over to the latest technologies wherever possible as quickly as possible (i.e., before the copper fails).

In this column, I’d like to highlight some of the issues that are hampering the service providers’ ability to migrate their customers as quickly and efficiently (from all perspectives) as possible.

When I first started pulling together my thoughts as to how to approach this, I intended to share plenty of examples of things that needed to change on the regulatory front. Interestingly, the FCC recognized that there was an ongoing shift in the telecom landscape, and took steps in late 2017 to simplify the rules governing the Network Transformation (NT) process. The FCC’s goal was to "enable carriers to more rapidly shift resources away from maintaining outdated legacy infrastructure and services" in favor of "next-generation broadband networks." (FCC-CIRC1711-04)

Much of the FCC’s work focused on:
• The network change communication processes: eliminating cumbersome notification requirements that cost the providers time and money.
• The copper retirement process: including the elimination of the nonsensical de facto copper retirement argument introduced by parties with their own unique agenda.
• Making it easier to discontinue legacy services that may not make sense to provision over fiber.
• The reduction of the required waiting periods before copper can truly be retired.

Will Johnson, Verizon SVP for Federal Regulatory and Legal Affairs said "we’re very pleased that the FCC continues moving forward on policies that will encourage investment and deployment of next-generation broadband networks. We encourage the Commission to continue to move forward quickly on other needed reforms to infrastructure policy."

Though the FCC’s actions clearly represent a significant step in the right direction, there is more to be done. To this end; AT&T recently asked the FCC to continue its work to streamline legacy data and voice service retirement processes.

Frank Simone, AT&T VP for Federal Regulatory, noted that the Commission’s recent Order "will help accelerate the deployment of next-generation networks by streamlining the regulatory processes associated with modernizing networks. These changes align its regulatory regime with its objective to encourage private investment in new networks and bring next-generation services to as many Americans as possible."

Food for Thought from Our 2022 ICT Visionaries

Beyond federal regulation, things also need to change on the state and local levels — and not just on the regulatory front. Thankfully, many states recognized the shift taking place in the telecom market and took steps to ensure a smooth transition for providers and customers alike. These states should be applauded for their actions.

Unfortunately, other states were not as forward-thinking, failing to grasp that a change in the outside plant (OSP) was good for current and future telecom customers. Some of the misunderstandings in fact, were pretty extreme. In my experiences, one senior state regulator could not differentiate between OSP transformation and the shift to VoIP. This complicated things greatly. Another state commission insisted that the antiquated copper infrastructure be maintained not because anyone was using it (few customers, if any, were) but because someone might want to use it at some point in the future. Frankly, I found this to be truly bizarre.

I struggle to think of any industry that is forced to maintain a product or service that has outlived its practical usefulness in the event that someone might decide to take a giant step backwards in the future. Consider this simple question: are any utilities (power, water, gas) required to maintain their old infrastructure when installing new? I think not.

Keep in mind that I’m not talking about requiring people to purchase something new to replace something old. In my previous role at Verizon, we simply wanted to migrate the customers’ existing service to a new, more reliable facility, without any additional cost to the customer.

The last set of issues that providers face in the network transformation world are the customers that are set to migrate. Despite an abundance of data indicating that their service will improve, customers oftentimes resist change, putting themselves in a tenuous position.

Coincidentally I just saw an example of this on the news. A small business in a major city lost their critical telephone service because they failed to react to repeated notifications from the local provider to migrate to fiber. (It should be noted that these notifications fell under the old FCC NT rules so they continued repeatedly for months, followed up by numerous phone calls by the local provider.) Unfortunately, the small business never agreed to migrate, and the copper cable feeding their shop failed in the wake of a severe storm and they lost service.

Realizing this is not a unique situation, I reached out to Janet Gazlay Martin, who has been running point on Verizon’s NT customer outreach program. Janet has a bird’s eye view of things — the good, the bad and the truly ugly.

"We work closely with any customer to address their questions or concerns, sometimes sending managers to their location to go over the migration process," said Janet. "Despite our best efforts, some customers believe that they can stay on copper forever. When their copper fails due to storms, steam leaks, or other uncontrollable events, they think we did something to cut them off. This is never the case. Our goal is to improve, not disrupt."

Janet and her team maintain contact with customers that need a little TLC throughout the process, assuring the smoothest possible transaction. They firmly believe that continuing education and an open dialogue are critical to the success of all NT programs.

My next column looks at some of the unique things that she and her counterparts in other companies are doing to help educate customers on the benefits of NT.

About the Author

Tom Maguire

Tom Maguire was the recent SVP of National Operations Support for Verizon. He has more than 36 years of experience in wireline operations, legal/regulatory, and finance. For more information, please email [email protected].