FCC IP transition trials should use a “phased...
FCC IP transition trials should use a “phased in” approach that leaves “oddball cases” for subsequent rounds, Public Knowledge told General Counsel Jonathan Sallet Wednesday, an ex parte filing said (http://bit.ly/1fgokIp). “Nothing will crash the transition of the phone system…
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to new technologies like a headline that someone died because of a poorly planned or recklessly implemented study.” A phased-in approach should also start with a voluntary trial pool, for consumers are “highly resistant to a forced conversion,” PK said. Incentives, like free or discounted service, could help overcome resistance, it said. Delaying the transition of complicated cases -- such as customers with heart monitors or other crucial legacy equipment -- would mirror the approach commonly taken in clinical trials conducted by the Food and Drug Administration, where initial trials generally exclude subjects with “complications beyond the target condition,” PK said. The public interest group suggested trials that follow a “blind” and “cross-population” protocol, in which some customers are given the new technology and some keep the existing technology, but customers wouldn’t know which group they were in. After a few months, customers should be switched to the opposite technology, PK said. “This approach is common in clinical trials to normalize the data across the entire study population while still maintaining a valid control group.” Importantly, businesses and government facilities create “unique concerns,” as they are most dependent on traditional copper-based services, and a mandatory trial could disrupt normal operations, PK said. The FCC needs to take their needs into account when implementing trials, PK said.