Liberating the Net from Telephony

Yesterday the FCC released a public notice seeking comment on the “transition from circuit switched network to all-IP network.” (Here’s the .pdf. Here’s the .txt version.) Translation: from the phone system to the Internet.

This is huge. Really. Freaking. Huge.

Or maybe not. Could be it’s all just posturing or worse. But I don’t think so. Or I hope not.

Either way, it matters. For better and worse, the Internet reposes in legal as well as technical infrastructures.

The money text:

The intent of this Public Notice is to set the stage for the Commission to consider whether to issue a Notice of Inquiry (NOI) relating to the appropriate policy framework to facilitate and respond to the market-led transition in technology and services, from the circuit switched PSTN system to an IP-based communications world.

In the spirit of understanding the scope and breadth of the policy issues associated with this transition, we seek public comment to identify the relevant policy questions that an NOI on this topic should raise in order to assist the Commission in considering how best to monitor and plan for this transition.

In identifying the appropriate areas of inquiry, we seek to understand which policies and regulatory structures may facilitate, and which may hinder, the efficient migration to an all IP world. In addition, we seek to identify and understand what aspects of traditional policy frameworks are important to consider, address, and possibly modify in an effort to protect the public interest in an all-IP world.

The italics are mine.

There is a high degree of presumption here. I mean, are we really migrating to an all-IP world? All? Most of us still watch plenty of television. And, in the immortal words of Wierd Al Yankovic, we all have cell phones. Neither TV nor cellular telephony are even close to an “all-IP world.” IP might be involved, but … there is some distance to cover here. And not much motivation by phone companies to make the move.

Still, we can see it happening. Your smartphone today is a data device that happens to run a lot of applications, which include both telephony and television. Yet the bill you get for using your phone (no matter how smart it is) comes from a phone company. The underlying infrastucture, including 3G, is largely a phone system. It handles data, and it’s mostly digital, but it is not fundamentally a data system. It’s a phone system built for billing by the minute. Or even the second.

Can we change phone systems into all-IP data systems? I would hope so.

But before I go any deeper, I want to plug my panel tomorrow morning (8:30am Pacific) at Supernova (#sn09). The title is Telecom as Software. Any questions you want me to ask, or topics you want me to cover, put them below.


  1. Esme Vos’s avatar


    I don’t have a television screen. I watch “TV” on the Internet. Is that TV or not? I use Skype via Wi-Fi – is that telephony or not? I think this is what the FCC is trying to get at because it goes to the heart of their reason for being and ultimately the tasks that they have been given by Congress.

    What does it mean to be a “broadcaster” now? How does the FCC penalize “broadcasters” for swear words and Janet Jackson’s unfortunate wardrobe accident, and how do they impose their ratings scheme (18+, PG-13, etc.) when I am watching “TV” or video on the Internet? Does it even make sense to do that? In the past, it made sense because everyone, including kids, watched the same 3, the only 3 TV networks.

    Everyone had to go to a cinema to watch a movie. Later, when CDs and DVDs came out, everyone had to buy or rent the CD or DVD from a store which was charged with enforcing these ratings restrictions.

    But when video is circulating around the Internet available on demand from entities beyond the jurisdiction of the FCC and when broadcasting is meaningless, the FCC is pretty much meaningless too. Their only task is to regulate frequency spectrum but that’s going away too when cognitive radios become our reality.

    Esme Vos

  2. Mike Warot’s avatar

    I didn’t know what your title of the discussion meant… so here’s the copy from the Agenda:

    As the Internet model of decentralized open systems takes over communications, what will change and what will stay the same? Who will thrive and be threatened? And what new possibilities will open up?

    I’m a technician at heart, so I worry about troubleshooting. If everything goes IP, there won’t be an option to use a POTS line as a backup any more, in the event of total systems failure at a site. What tools will be available to help troubleshoot systems if all of the communications goes over one pipe?

    Remember, 99% uptime is good enough for most of us, as long as it’s 99% on a given system, twitter, skype, gmail, etc… we can actually survive a few DAYS of downtime a year if we have a way to route around things… I really worry if we have to put all of our eggs into one basket, no matter how expensive or gold plated the hardware is.

    Also… what will serve as the equivalent to a straight POTS line for troubleshooting around a problem, to see where the fault really lies? No VoIP system is perfect, and you have to have something to compare against as an aid to diagnostics.

    Monocultures are bad, how can we maintain some diversity, in the name of national security, if nothing else? We have to make a choice the goes beyond seeking the lowest cost, because failure has a high price.

    Thanks for the retweet… it was VERY fun to feel like I was part of the crowd at the session today.

  3. Doc Searls’s avatar

    Esme, check out what I wrote here about a year ago. Leads to the same place.

  4. Doc Searls’s avatar

    Mike, when Verizon installed fiber to our place near Boston, they took out the copper from the pole to the house. At the house they put a fresh RJ-11 on the existing copper wiring and plugged it into the POTS jack (labeled exactly that) on the Optical Network Terminal outside the house. Inside the phone had a number and a dialtone just like any old POTS phone. Except the analog signal turned into bits at the ONT. Between the switch and my house was an all-digital network (much of it IP) which, for legacy purposes, faked being POTS wiring.

    My point: even the carriers don’t want to screw with “straight POTS lines” any more.

    Beyond that, dunno what to say. Which is why we’re having this session this morning.

    Jump on the IRC during the session (freenode, #supernova) and participate if you like.

  5. Mike Warot’s avatar

    I think the FCC will always have to serve a role to regulate the standards and operation of the airwaves consistent with the rules. A world of appliance radios is ok.. but you still need standards enforcement to make sure all of those radios actually follow the rules, and to watch for abuse.

  6. Tristan Louis’s avatar

    I would argue that the concept of migration to an all-IP world is correct, in the long run. Think about it: phone signal can now be carried over IP (voice Over IP); TV signals, having been digitized, can be distributed over IP. Radio signals could be distributed over an IP network too.

    In a way, this is about making the internet the critical underpinning to everything that is being distributed.

    We are at a critical juncture in this migration, with substantial portion of the network already routing some traffic over IP networks.

    The direction the FCC is taking is correct. How it goes about it further down the line will warrant close examination to ensure that the core principles of openness and net neutrality still exist in that new world.

  7. KD’s avatar


    Re: Verizon removing the copper when installing FIOS

    I remember a story about that a year or more ago. I don’t know whether it was true, but the writer’s claim was that Verizon was removing the copper lines not because of any technical or financial problem with maintaining them, but as a ploy to destroy the copper network. They were obligated to grant access to the copper to CLECs, but they are not obligated to grant access to the fiber to the CLECs. How better to eliminate pesky competition?

    If true, and I don’t know whether it is, it illustrates something that I wish we could prevent. I think companies should compete by providing better goods and services, not by sabotaging competitors. I wish that could be the law, but I kind of doubt a law about that could be worded well enough to cover enough possible methods of sabotage to be effective, and even it it could, I wonder how well it could be enforced.

    If FIOS ever shows up in my neighborhood, I’d be tempted to sign up, but I probably won’t because I try to support businesses that compete on the basis of providing good products, not by sabotaging their competitors. But such companies are becoming harder to find. Or are we just more aware of the dirty tricks?

  8. Doc Searls’s avatar

    I don’t know exactly why Verizon removes copper when they install FiOS. In my case it was, literally, because my landlady wanted to minimize the number of wires to the house. She stood there and insisted on it.

    But, to be real, I don’t think Verizon, or anybody selling fiber to the home, has competition from alternative copper providers. The old POTS distribution system is dead, especially where there is also fiber and coax cable on the same poles. The old copper just can’t compete. Nor should it. Therefore it makes no sense to say anybody is out to “destroy” it.

    If I were Verizon, and replacing copper distribution with fiber, and retaining copper for drops to houses that don’t elect to get fiber the whole way, it only makes sense to remove the last length of copper when customers choose fiber and won’t have any more use for copper anyway.

    But I don’t know what Verizon’s actual policy is there. I do know that FiOS is far better than the alternatives where I live (Cox cable and RCN fiber at lower speeds).

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