Shutting Down the Phone System: Five Fundamentals Framework For Managing the PSTN Transition.

As I wrote back in November, AT&T’s decision to upgrade its network from tradition phone technology (called “TDM”) to an all Internet protocol (IP) system has enormous implications for every aspect of our voice communication system in the country. To provide the right framework for the transition, Public Knowledge submitted to the Federal Communications Commission (FCC) our proposed “Five Fundamentals” Framework: Service to All Americans, Interconnection and Competition, Consumer Protection, Network Reliability, and Public Safety.

To recap briefly, AT&T filed a Petition arguing that transitioning from its existing TDM-over-copper to a voice over IP (VOIP) service would move it from being a “telecommunications carrier” to an “information service” provider, and asked the FCC for a glide path for the transition.


But when everyone is IP and no one is a “traditional phone service,” what happens?


While we agree with AT&T that the time has definitely come to rethink the rules for 21st Century phone network, we disagree with AT&T’s argument that a technology upgrade radically changes everything. Technology changes, but the social needs and goals remain the same.


Service to all Americans. We must not become the first industrialized nation to walk back from the commitment to 100% accessibility. For century, we have believed that everyone in the United States is entitled to a basic level of communication service. If you live in a rural “high cost” area, you can get phone service. If you have a physical disability, we provide a service that accommodates that. If you are poor, we offer a “lifeline” subsidy. As we move forward in the all-IP world, we must make sure that all Americans, regardless of race, sex, income level or geographic location, participate in and benefit from any upgrades to our telecommunications networks.


Interconnection and competition. ”Interconnection” is the requirement that any phone provider must attach to a rival network, send calls from its network to the rival network, and accept calls from the rival network for its subscribers. Without this rule, network providers such as AT&T could squeeze out smaller competitors by refusing to interconnect, so that phone calls from the smaller networks don’t go through. Unless we want to return to the days of regulated “natural monopoly,” the FCC must make sure that the IP universe supports competition and requires interconnection among providers.


Furthermore, if the FCC loses its authority because of the conversion to IP, disputes between larger providers might create serious disruptions in the phone network. When AT&T and Comcast/NBCU can’t agree on the price for NBC programming and lose access to “The Tonight Show,” that’s annoying. But if AT&T Wireless and Comcast have a “peering dispute” and AT&T subscribers can’t call Comcast landlines, that is a disruptive disaster. The FCC must retain enough authority over interconnection to make such a situation impossible.


Consumer Protection. Consumers expect that their phone calls stay private, that phone companies must comply with “truth-in-billing” rules, and that they have recourse when they have complaints about things like service quality or overcharges. Consumers must not lose their existing protections because of the change in phone technology.


Network Reliability. Above all else, the phone network actually works. It does so repeatedly, time after time after time, in the same predictable and reliable way. That needs to keep happening. Certainly that includeshardening the network against storms and other weather events. But we forget just how much we rely on our basic telephone service on a daily basis, and how that reliability comes from state and federal regulators making sure network providers don’t cut corners.


Just last week, a software upgrade in AT&T’s U-Verse service knocked out voice service for days for subscribers. As one U-Verse customer lamented: “You go on U-verse, and the old handy dandy landlines that would work no matter what? . . . . That’s not happening any longer.”


The reason “that’s not happening any longer” is a policy choice. We can, indeed we must, make the all-IP network as reliable as the traditional phone network.


Public Safety. Finally, we must make sure that the next generation of technologies does not mess up 9-1-1 or other emergency communications. Ideally, the upgrade in technology should improve our emergency communications capability. While the FCC has already made progress on this in its Next Generation 9-1-1 proceedings, we must make sure the decisions made in those proceedings work with the transition as a whole.


Using this Five Fundamentals Framework, the FCC (and eventually Congress) can both facilitate the upgrade to an all IP network while simultaneously ensuring that we do not compromise on any of the fundamental principles that have made our phone system the envy of the world.


This isn’t an engineering problem – it’s a policy choice. Now is the time to make the policy choices that will form the foundation of the all-IP network for the 21st Century, just as our decisions to adopt these five fundamental principles shaped the hone network of the 20th Century.


We must not keep old rules that no longer serve us simply because they are comforting and familiar, but we must not be so dazzled by the promise of new technology that we forget the foundational principles on which these networks must be built. The technology changes, but the social needs and goals remain the same.