NTIA, as the President’s principal adviser on domestic and international telecommunications policies, and on behalf of federal agency purchasers of telecommunications services, respectfully petitions the Commission to reconsider or to clarify certain parts of its Second Report and Order (Second Report) in the Technology Transitions, et al. proceeding. NTIA and the federal government fully support the “tech transition” and we applaud the Commission for the leadership shown in the Second Report. The framework the Commission sets out is a thoughtful and reasonable approach to allow the transition to continue while minimizing harmful impact on customers.
Federal government agencies, however, face some particular challenges as customers of telecommunications services. Federal users are different from many other customers given the budget and procurement challenges they face and the mission-critical activities they perform for the public benefit. To address these circumstances, NTIA requests that the Commission: (1) clarify whether, if at all, or under what circumstances, services such as T1 and Integrated Service Digital Network (ISDN) fall within the meaning of “legacy voice service”; (2) reconsider its interoperability protection requirement to define a list of “low speed modems” and create a presumption that devices that use such modems are entitled to interoperability protection; (3) prescribe limited testing requirements for small carriers; and (4) use its “public interest” review of carriers’ section 214 discontinuance applications to promote greater information exchange and more cooperative planning between carriers and their federal customers about network transitions, to reduce the potential impact such transitions may have on critical government operations.