I made a passing reference to the rural call completion problem in a post about 2 months ago. I’ve now written a much longer piece explaining the problem of rural call completion, and the nature of the problem, for the Daily Yonder. You can find the article, and the very nice illustrations they added, over here.
To give a very brief recap for why y’all should click through to learn the details of rural call completion — rural call completion is an unexpected side effect of the transition of the Public Switched Telephone Network (PSTN) to an all-IP based network. Using IP-packets gives you greater flexibility to pick how you route calls. To avoid very expensive rural termination fees (which subsidize rural systems and keep them operating), Least Call Router systems can send calls through lots of hops, creating latency or even trapping the call in a perpetual loop. As a result, calls to some rural systems don’t go through, or quality degrades to where rural areas may not be able to have reliable phone service or reliably reach 9-1-1. The FCC has issued a Notice of Proposed Rulemaking to address the problem, and every Commissioner has emphasized that making sure the phone netwok remains reliable is a core mission of the FCC.
I and my Public Knowledge colleagues have emphasized both network reliability and service to all Americans as part of our “Five Fundamentals Framework” to guide the transition of the PSTN to all-IP. The rural call completion problem demonstrates precisely why we need a framework to guide us, rather than jumping right away into the “deregulation v. regulation” fight so many people want to have instead of focusing on the real issues.
It is also an example of a phenomenon I call “network neuropathy,” how problems in networks may first manifest themselves in failures of service around the extremities.
More below . . . .
No one anticipated the rural call completion problem. It didn’t happen because anyone misused their market power or tried to do anything bad. It happened because IP-based voice service gives companies a way to save money by selecting from a choice of possible routes. For the vast majority of IP-based services, this kind of flexibility works fine. But for services that are not tolerant of latency, like voice, problems come up unexpectedly. Worse, because the problem — at least initially — impacts a relatively small number of calls as measured against the overall number of calls completed every day, it takes a long time for the problem to get noticed, properly diagnosed, and hopefully corrected. During that time, the problem keeps getting worse.
Even now, the FCC doesn’t really have a terribly good handle on the problem. That’s why the FCC Notice of Proposed Rule Making (NPRM) focuses on reporting requirements, and why the recent settlement with Level 3 relies primarily on Level 3 taking responsibility for routing calls and making sure it keeps records on call routing until it demonstrates that it has restored reliability. The FCC already tried fixing the problem by saying “don’t mess up rural calls.” It didn’t work. Now the only way to fix the problem is by very thoroughly and systemically working through the way voice calls get handled to make sure that at every step the voice packets get properly routed so that rural calls go through.
Why We Need To Get The Framework Right.
This is only the first of many hiccups that will come up as we convert something as enormous and complicated as the phone system to an all-IP system. Yes, things have worked very reliably until now, because everyone operated in an environment where everyone understood the rules (both explicit from agencies and the unwritten rules of conduct that always emerge in a long-standing stable system), knew what was expected of them, what they could get away with, and what not to try. As the old way of doing things falls away, everyone is groping to find the new way of doing things. That process of discovery – for all of its positives – also means that you get new and unexpected problems that the market does not work out, like rural call completion.
When that happens, we need the FCC (and the states) to step in and diagnose the problem and determine what (if anything) needs to be done. Because, as the rural call completion problem illustrates, “the market” isn’t automatically going to work everything out. We need someone who can step in when the market doesn’t work, and we need a framework based on values to guide the analysis and decisions.
We could approach rural call completion in two ways. We could say: “This impacts a relatively small number of calls in a system that handles millions of phone calls every hour. It impacts a tiny fraction of the population, and a minute number of actual calls. How can that possibly justify imposing expensive and intrusive reporting requirements and gasp regulation on the market as a whole – especially when no one has deliberately done anything wrong?” Or we could say: “It is a foundational principle that we keep the telephone system functioning reliably for all Americans. That means that when we have a systemic problem that is making the phone system behave unreliably for a portion of the population, we treat that as a Big Deal and we take it seriously. We look into it, and if necessary we do something about it to make sure that calls get reliably completed.”
What tells you which way to respond is whether you actually have a framework and a set of principles and what they say. If you don’t have any framework at all, you have no way to judge which answer is the right answer. If the focus is just “regulate or deregulate” without any guidelines for what we care about, what needs we’re trying to address, or what problems we want to avoid, then you end up with no one with the ability or authority to diagnose the problem or prescribe the right solution.
Even if you have a framework to guide you, you need to make sure the framework is actually focused on principles, not outcomes. If your framework is “encourage investment at all costs” or “we must not apply traditional regulation to new technologies” then you don’t address the problem because the only way to actually figure out what’s going on and fix it requires imposing some costs (which might deter investment) and actually regulating. By contrast, if your framework is “service to all Americans” or “the network must remain reliable,” then this is big deal and you take action.
Lessons For the Future: Network Neuropathy
The other important question is whether to treat rural call completion as a one off problem that teaches us nothing applicable to anything else (what I call the “Snowgons Are Bad News” Rule) or whether we should look at Rural Call Completion as a wake up call about the need to proceed with the IP transition mindfully, and with appropriate backstops for when things go wrong.
In medical science, there is a condition called “neuropathy.” Problems in the central nervous system manifest themselves initially as a loss of sensation in the extremities. People with Parkinson’s or Hansen’s or diabetes lose sensation in their hands and feet, or constantly get the “pins and needles” sensation of the hands and feet. Peripheral neuropathy can lead people to injure their extremities without realizing it, and can also be the first warning sign of a deeper problem that, if left unattended, will work its way into the central nervous system not just the periphery.
Rural call completion is an example of what I like to call “network neuropathy.” It is a loss of functionality at the edges, an unraveling at the extremities of the network. It is also a warning sign, that no matter what the benefits of the IP transition, it can also produce unanticipated problems.
I’m glad the FCC is acting on the rural call completion problem. The question is whether we will treat this as a one off that, once addressed, we can safely ignore or whether we will learn a more applicable lesson. We need to have the tools to deal with these problems as they emerge. We need to have an FCC (and state regulators) with a set of guiding principles that tells how to evaluate these issues, and has the authority to address them as they emerge. If we continue to make the focus of this transition about eliminating or keeping a specific set of regulations, we are going to keep injuring ourselves without understanding why. If we focus on our fundamental framework, on getting the core values and goals, then we will be able to address the problems in the transition as they emerge.
Stay tuned . . . .