May 5, 2022
Rumors surrounding POTS replacement have been greatly exaggerated.
Vendors, partners and customers have been eyeing Aug. 2, 2022, which the Federal Communications Commission (FCC) enacted as a deadline three years ago. According to many parties in the telecommunications industry, the FCC mandated the decommissioning of plain old telephone services (POTS) lines by this date. One prominent telecommunications media outlet in December wrote that the FCC had mandated the POTS line replacement by Aug. 2. Searching “FCC POTS mandate” on LinkedIn shows a plethora of carriers and sales partners asserting that the FCC has required the mass decommissioning of all POTS lines.
But these assertions are based in misinformation and scare tactics, partners tell Channel Futures. An FCC representative confirmed via email that the Commission has not mandated POTS replacement by Aug. 2. Sources clarified that the ruling will apply to a very small subset of POTS lines, many of which lie outside the bounds of what channel partners sell.
MOReCOMM’s Jay Morris
“There are 38 million POTS line still out there on various ILECs and CLECs, and none of them are mandated by the FCC to be shut off or transitioned to IP telephony,” said Jay Morris, chief aggregation officer of MOReCOMM Solutions. “Not previously, not now, not in the near future.
The FCC issued its 19-72 Memorandum and Order in response to a 2018 USTelecom petition for forbearance from two obligations set forth by the 1996. Specifically the trade association sought forbearance from UNE Analog Loop Obligations and Avoided-Cost Resale obligations outlined in the Act. The Avoided-Cost Resale Obligations required ILECs to “offer for resale at wholesale rates any telecommunications services that the carrier provides at retail to subscribers who are not telecommunications carriers.” In addition, UNE Analog Loop Obligations forced ILECs unbundle their analogue voice-grade copper loops.
The Commission granted carriers forbearance from these obligations, citing the importance of facilitating technology transitions and promoting broadband deployment.
“We find that it is no longer necessary to require price cap LECs to bear these once-upon-a-time market-opening obligations that today amount to disparate regulatory burdens that frustrate the transition to advanced communication services offered over next-generation networks,” the Commission wrote on Aug. 2, 2019.
The Ruling Defined
In addition, the 2019 FCC order instructed all local exchange carrier customers to move from their UNE Analog Loops to an alternative service by Aug. 2, 2022. But UNE Analog Loops only apply to a specific use case, according to Ross Artale, president and chief operating officer of Spectrotel.
Artale told Channel Futures that the FCC order impacts facilities-based providers and their co-located wholesale customers. The ruling would not affect any of the ILECs’ own POTS lines, Artale said.
Spectrotel’s Ross Artale
“It’s a small sliver of the collective total of those 38 million lines. I don’t have an exact number, but I would estimate that this ruling effects probably, at best, 200,000 lines,” he said.
Moreover, the order pertains to …
… resale discounts rather than commercial agreements. And the channel engages far more with the latter.
“Very few carriers or CLECs took advantage of UNEL, and those who did have either moved those facilities already back to straight resale product via their commercial agreements or they’ve transitioned those of those customers to some sort of IP telephony,” Morris said.
Yet the messaging that has emerged on social media paints the picture of a impending, full-scale POTS decommissioning.
And customers are hearing it.
“I had a Fortune 100 customer call me in a panic. They read one of these posts and said, ‘I have to replace my network by August,'” Artale said. “And I said, ‘No, you don’t. There’s maybe a small subset of lines that we have to move from one service type to another, still over copper. Don’t panic. There’s no impending doom.’”
Artale said customers will ultimately see through the misinformation. And for the channel partners who have adopted the incorrect messaging from their vendor partners, their credibility is at stake.
“Customers are going to see through that. They get a little upset when they learn about what’s really happening,” Artale said.
Not everyone in the channel has run with the misinformation. For example, Allstream notes on its website that the FCC did not mandate POTS retirement. But Morris said he has seen a steady stream of partners and direct sales reps relaying the message of a mandated POTS sunset.
“Don’t sell your products based on scare tactics,” he said. “Whatever it is you sell, sell it on the merits of the product, the need it fills, the value if offers, and why your company should fulfill that need.”
Neither Morris nor Artale deny that POTS is declining. Carriers are investing less in the service, and support has waned. Artale said that in a time gone past, you could put in a ticket for a service outage and get help from dispatch the same day. That time has extended to at least three days now, Artale said.
So yes, POTS investment and support are plummeting. But that does not mean the FCC has ordered a shutoff.
“When you’re looking at a product that has no investment, that goes down when it rains, takes three days to fix, takes longer to provision, and then you have rates going up exponentially, it’s really an economic issue and a service quality issue than it is a regulatory issue,” Artale said.
On the other hand, the benefits of transitioning off POTS include visibility, network analytics and the ability to consume a managed solution.
Allstream argued in its blog that pricing deregulation will combine with ILEC copper retirement plans to eventually phase out POTS. However, Artale said any sort of catch-all mandate for POTS replacement is years out.
“Yes, it’s in everyone’s best interest to have a strategy to transform off of copper,” he said. “But let’s do it at a reasonable timeframe that makes sense for each customer. And let’s communicate things accurately.”
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