Today, the FCC asked for comments on initial trials for a transition from outdated switched telephone networks to Internet-based (IP) alternatives. Instead of studying the full range of issues the IP transition will raise by conducting well defined and complete trials as we urged in comments filed in February, the FCC proposes to narrowly focus on the transition to VoIP, next generation 9-1-1 systems, and the switchover from wired to wireless phones.

The following statement can be attributed to Larry Downes , author and consultant; Berin Szoka , TechFreedom President; and Matt Starr , TechFreedom Legal Fellow:

The FCC is anxiously putting one toe halfway in tepid water with today’s proposal. Facilitating the transition from outdated switched telephone networks to native Internet alternatives should be embraced boldly and proudly by the agency. Instead, the Commission buried today’s announcement on a Friday afternoon, and for good reason.

A true IP transition trial would start by completely replacing traditional switches with native IP infrastructure in a small test area to see what, if any, technical or service problems arise. Instead, what the FCC calls a “trial” is simply more delay — investigating three specific issues related to the Transition by simulating conditions likely to occur.

VoIP interconnection, Next Generation 9-1-1, and replacing some wireline services with wireless alternatives are important pieces of the IP Transition. But conducting trials on just these three issues will tell the agency little about the logistics of a real transition. It only serves to delay the inevitable, to the benefit of no one, least of all to consumers.

The FCC defends its painfully slow pace by saying it wants to be “smart” as it proceeds to “structure” trials to develop more “data” about a future transition. But the agency seems blissfully unaware that the transition is already happening. Consumers are cutting the cord, abandoning obsolete switched networks in favor of VoIP and mobile alternatives in accelerating numbers. The FCC is content operate in a regulatory vacuum, forcing wireline carriers to waste money maintaining the old network for a dwindling number of customers — money that would be better spent speeding up deployment of replacement IP-based alternatives consumers rightly demand.

We are disappointed that the Commission decided not to conduct true trials as we and Commissioner Pai urged. True trials could have shed light beyond the three questions the FCC’s limited trials would examine — and allowed policymakers and companies to address whatever issues might arise. The FCC’s delays mean consumers will have to wait longer and pay more for a transition that is technologically inevitable and growing needlessly more expensive. Consumers deserve an FCC that embraces and enables change, not one that delays it.

Downes, Szoka, and Starr are available for comment at . Read their earlier FCC comments on the IP transition here .