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FCC: Time to end yesterday?

By: Scott Bradner

Back in December the FCC asked for comments on "transition from circuit-switched network to all-IP network." (http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-09-2517A1.pdf) Aside from the factually incorrect title (there are currently more than one circuit-switched network and there will be more than non all-IP network in the futures) this request for information is likely to produce interesting, and maybe useful, results.

I've not been able to find a repository of responses on the FCC web site (logically there should be one) but searching the web does result in finding a number of responses that were posted by the responders themselves or by others. The response that has gotten the most press has been AT&T's (http://www.dslreports.com/r0/download/1503622~0fa0fb3f2dd773f72771c0ac40094cee/Copper.pdf) but Cablevision (https://portal.neca.org/portal/server.pt/gateway/PTARGS_0_0_307_206_0_43/http%3B/prodnet.www.neca.org/publicationsdocs/wwpdf/122409cable.pdf), "CTIA-The Wireless Association" (http://files.ctia.org/pdf/filings/091222_CTIA_NBP_PN__25_IP_Comments_FINAL.pdf), the National Cable & telecommunications Association (NCTA) (www.ncta.com/DocumentBinary.aspx?id=871) and the Organization for the Promotion and Advancement of Small Telecommunications Companies (OPASTCO) (www.opastco.org/doclibrary/1935/PSTN-IP.pdf) have also responded.

Some of the responses, AT&T's included, asked for the FCC to set a date when the old telephone network should die. This seems to be a poor idea to me. I can understand a rule to say that a phone company must be able to exchange calls over IP by some date certain but why should it make any difference to the world how that phone company actually uses old-fashioned circuit-switched technology within its network? The more serious question that AT&T is pushing at concerns when they can be relieved of the requirement to support circuit-switched services for its existing customers. I'm not sure that this is even a legit question - maybe the question should be 'how long must a telephone company that has had essentially a protected monopoly continue to provide services that its existing customers can use with their existing phones?' I have no reason to care how AT&T might implement a voice service as long as my mother's phone can still work. Since many VoIP services today, for example Vonage, work by having a small box that connects an "old" telephone to an IP network this should not be a big deal. Unless, of course, the real question from AT& is 'when can we stop serving those currently low-value customers that enabled us to exist all these years?'

A number of responses pointed out that universal service, as current implemented, depends on over charging people who have old-style switched-circuit telephone service. If that were to go away then universal service would be in a world of hurt. But, since universal service is basically a way that the Feds have developed to tax some phone users to pay telephone companies outrageous fees to do what they should be doing anyway I fully expect that the FCC will figure out some way to keep the gravy flowing.

There is one very basic flaw in all the responses I found and, to some degree, in the FCC request. There seems to be an assumption that a customer will get their voice service from whatever company is providing their broadband service. One of the most important features of the Internet is that there is no requirement for any such binding. With VoIP there is no technical reason for the big carriers (read AT&T and Verizon) to stick to their own territories and there is no technical reason for a customer of an AT&T broadband service to not subscribe to Vonage or any other voice service they want to. That is unless congress and the FCC fail at their public interest responsibilities and leave us all surfs of whatever carrier brings us the bits - but that is not a technical issue.

disclaimer: There are major parts of Harvard that deal with Layer 9 (political layer) issues but I have not seen any official opinion on this topic so the above observation and review is my own.