All-IP Network Transition Plan at FCC's Jan 30th Open Commission Meeting

Introduction:

[dropshadowbox align=”right” effect=”raised” width=”270px” height=”” background_color=”#ffffff” border_width=”1″ border_color=”#dddddd” ][/dropshadowbox]During his January 8th speech at the Computer History Museum (CHM) , FCC Chairman Tom Wheeler told the CHM audience that the U.S. was in a transition to a “4th Network Revolution” that would be led by a transition to an “all-IP” network.   The 4th Network is actually a multi-faceted revolution based on  IP based packet communications (for voice, data and video) replacing digital circuit switching and analog transmission. Communications protocols are moving from circuit-switched Time-division Multiplexing (or TDM) to IP packet switching.  At the same time, 3G and 4G wireless access networks are increasingly prevalent, empowering consumers to connect at the place and time of their choosing.

Wheeler said, “The transition to an all-IP network is important in its own right, but it also is important because it demonstrates that the Commission (FCC) will adapt its regulatory approach to the networks and markets of the 21st century.”

The FCC Chairman then said that no one would use a network without being able to make a 911 phone call (to report emergencies and seek help from law enforcement). That implies that the all-IP network must support 911 calls in a consistent manner.

From the FCC Web site, an image of FCC Chairman, Tom Wheeler
FCC Chairman, Tom Wheeler (image courtesy of FCC.gov)

Wheeler told the CHM audience:

“The best way to speed technology transitions is to incent network innovation while preserving the enduring values that consumers and businesses have come to expect. Those values are all familiar: public safety, interconnection, competition, consumer protection and, of course, universal access. They are familiar, and they are fundamental.”

Continuing, he said: “At the January 30th Commission meeting, we will invite proposals for a series of experiments utilizing all-IP networks. We hope and expect that many proposed experiments, wired and wireless, will be forthcoming. Those experiments will allow the networks, their users, the FCC and the public to assess the impact and potential of all-IP networks on consumers, customers and businesses in all parts of our country, including rural America.”

All-IP Network Topic at the FCC’s January 30th Open Commission Meeting:

The all-IP network transition will be the number one agenda item at the FCC’s January 30th Open Commission Meeting  Advancing Technology Transitions While Protecting Network Values is all about the transition to an all-IP network.  “The Commission will consider a Report and Order, Notice of Proposed Rule making, and Notice of Inquiry that invites diverse technology transitions experiments to examine how to best accelerate technology transitions by preserving and enhancing the values consumers have come to expect from communication networks.”

In a November 19, 2013 blog post Wheeler provided an overview of the all-IP network migration.  He wrote: “The way forward is to encourage technological change while preserving the attributes of network services that customers have come to expect – that set of values we have begun to call the Network Compact.”

Wheeler noted various FCC Commissioner comments in that blog post:

  • “Commissioner Pai said that the FCC should ‘Embrace the future by expediting the IP Transition.’
  • Commissioner Rosenworcel told us that, ‘As we develop a new policy framework for IP networks, we must keep in mind the four enduring values that have always informed communications law — public safety, universal access, competition, and consumer protection.’
  • Commissioner Clyburn has called upon the Commission, ‘To carefully examine and collect data on the impact of technology transitions on consumers, public safety and competition.’”

AT&T Petition and FCC Technology Transitions Task Force are encouraging trials:

On November 7, 2012, AT&T petitioned the FCC to “Launch a Proceeding Concerning the TDM-to-IP Transition,” GN Docket No. 12-353 (AT&T Wire Center Trials Petition).

That document requested the FCC to “open a new proceeding to conduct, for a number of select wire centers, trial runs for a transition from legacy to next-generation services, including the retirement of TDM facilities and offerings” and that “the Commission should also seek public comment on how best to implement specific regulatory reforms within those wire centers on a trial basis.”

AT&T requested that the FCC consider conducting trials where certain equipment and services are retired and IP-based services are offered. These geographically limited trial runs, conducted after a public comment period on how they should be carried out, would help “guide the Commission’s nationwide efforts to facilitate the IP transition.” Such an approach, AT&T notes, will “enable the Commission to consider, from the ground up and on a competitively neutral basis, what, if any, legacy regulation remains appropriate after the IP transition.”

AT&T has set a date of 2020 to retire its TDM network and has been upgrading its IP-based service capabilities in its wireline markets via Project Velocity IP (VIP).  AT&T presented a progress report on the Project VIP at the June 2013 IEEE ComSocSCV meeting.  It can be read on pages 3-4 of this article: Telco Tours & Seminars Top ComSoc-SCV Activities.

Technology Transitions Policy Task Force” which was tasked to move forward with real-world trials to obtain data that will be helpful to the Commission. The goal of any trials would be to gather a factual record to help determine what policies are appropriate to promote investment and innovation, while protecting consumers, promoting competition, and ensuring that emerging all-Internet Protocol (IP) networks remain resilient.   The FCC task force is seeking public comment on several potential trials relating to the ongoing transitions from copper to fiber, from wireline to wireless, and from time-division multiplexing (TDM) to IP based packet switched networks.

Technology Trials Proposed:

The FCC task force has proposed the following trials related to the all-IP network transition:

  • VoIP Interconnection
  • Public Safety – NG911
  • Wireline to Wireless
  • Geographic All-IP Trials
  • Additional trials: numbering and related data bases, copper-to-fiber transition, retirement of copper?

 The US Telecom Association was very supportive of such trials as well as the previously referenced AT&T petition. In comments submitted on January 28, 2013, the trade organization wrote:

“The idea that the Commission should conduct real-world trials in order to better inform itself as to the technological and policy implications of the IP-transition is a way the Commission can continue its commitment to data-driven policy making. The Commission itself has urged carriers to ‘begin planning for the transition to IP-to-IP interconnection’ and the Commission-guided trials urged by AT&T would facilitate this effort.”

“In particular, the AT&T Petition offers an opportunity for the Commission and state regulators to conduct informative, but geographically limited, trial runs for regulatory reform in discrete wire centers. AT&T correctly notes that such an approach will enable the Commission to consider, from the ground up and on a competitively neutral basis, what, if any, legacy regulation remains appropriate after the IP transition.”

US Telecom’s comments can be read here.

Important Unanswered Issues for an all-IP network:

Transition to an “all-IP” network implies retiring the PSTN/POTs, TDM/circuit switching and all wireless networks other than 4G with VoIP over LTE. That is a huge undertaking that will be incredibly disruptive and take many years, if not decades, in our opinion.  Here are just a few points to ponder about this monumental transition:

  • Telcos and MSOs must universally deploy broadband for wireline VoIP to be ubiquitous. Currently, they make their deployment/build out decisions strategically- based on reasonable ROI.  Not every area in the U.S. has or will have wired broadband as a result.
  • Many rural areas have little or no wireless coverage and certainly not 4G-LTE.  What happens to people who live in those areas, e.g. Arnold, CA?
  • Even if wired or wireless broadband is available in many regions, there is likely to be only one or two network providers at most.  Hence, there is little or no choice in service which is effectively a monopoly. Santa Clara, CA is in the heart of Silicon Valley, yet we now have only two choices for wired broadband – AT&T or Comcast.
  • There is currently no Universal Service Fund/Lifeline or discounted rate (for low income folks) for VoIP service.  Lifeline service is ONLY available for the PSTN/POTS.
  • If an individual or family doesn’t want or can’t afford high speed Internet and/or broadband TV service, then it will most likely be uneconomical for the Telco/MSO to ONLY provide VoIP service over broadband access. This is the case for many poor people and older Americans!
  • Battery backup is required for an all-IP network to make emergency phone calls when power is lost.  There is a substantial monthly charge for a battery backup box for AT&T’s U-Verse VoIP service. An AT&T subscriber must also have battery backup power for the Wi-Fi gateway to enable your AT&T U-verse services to function during a power outage.
  • There will be a huge impact on business customers that use digital circuit switched networks if the proposed all-IP changes happen soon in the affected areas or “wire centers.” What if a company’s main or branch office site(s) are located in an all-IP wire center coverage area?  In that case, the business customer would have to give up it’s digital PBXs or hosted ISDN PRI voice trunks and move to SIP trunks–even though the company is not nearly ready for a total enterprise-wide transition to an IP voice network.
  • What happens to faxes, which are still overwhelmingly based on the analog PSTN and not IP fax? The death of fax has been predicted for over a decade, yet it is still alive and kicking!
  • There will be a huge impact on business customers that use digital circuit switched networks if the proposed all-IP changes happen soon in the affected areas or “wire centers.” What if a company’s main or branch office site(s) are located in an all-IP wire center coverage area?  In that case, the business customer would have to give up it’s digital PBXs or hosted ISDN PRI voice trunks and move to SIP trunks–even though the company is not nearly ready for a total enterprise-wide transition to an IP voice network.
  • The transition from the classic PSTN to an all IP infrastructure will mandate the end of Signaling System 7 and the entire infrastructure that supports it. This is a substantial undertaking, the consequences of which are not fully understood. Can SS7-based functions be replicated on a broadband IP-based network? What would be the equivalent of a “voice grade” circuit? Is a SIP connection a functional equivalent for the key functionalities of SS7 switches? What about SMS/texts?
  •  The telephone numbering system provides a way for callers served by virtually any service provided in the world to reach one another. What will replace that system has yet to be determined. It surely won’t be an IP address which is often dynamic and allocated for temporarily reaching IP endpoints.
  •  Interconnection and Inter-operability between IP and TDM networks is a work in progress-for both voice and data.
  •  Quality of Service/Reliability/Resiliency is largely unknown with an all IP network, which would need to scale to replace and reach all PSTN/TDM endpoints. What would constitute an “outage,” and how should “outage” data be collected and evaluated? Here again, the battery back-up on power fail would need to be made mandatory and low cost or no cost to consumers and enterprises.

For sure, the above issues will challenge equipment vendors, regulators, business and consumers. We think the transition from PSTN/TDM/digital circuit switched to an all-IP packet network will take much, much longer than many expect.

0 thoughts on “All-IP Network Transition Plan at FCC's Jan 30th Open Commission Meeting

  1. Excellent post, Alan. Thanks for reporting on this important speech, as well as bringing in the other important points about the transition from the PSTN to VoIP.

    As he alludes to in his talk, the transition goes beyond voice and points to the idea of moving from fixed pipes to the dynamic nature associated with packets. The other aspect of this is the distributed intelligence that makes for a more powerful network, particularly when large bandwidths are combined with computing power.

    He indicates that this IP transition points to better ways to manage the spectrum in his so-called 4th generation network (printing press, railroad and electronic communications (that began with the telegraph) being the first 3, by his definition).

    “The analog inspired spectrum silos have become an impediment to advancement…….Slavishly sticking to analog age concepts of spectrum allocation can become, in the digital age, a government imposed choke point that burdens competition and innovation by creating unnecessary and artificial scarcity of this essential resource.”

    Although he emphasizes the fourth generation network, CES provided a glimpse of the fifth generation network. This will be the network that uses telecom to create a signaling network that makes for a more efficient and safer network of transporting people and goods.

  2. From an attorney specializing in FCC Policy litigation:

    “Many of your comments are well taken. That is why competitors to AT&T and the other ILECs have argued for maintaining Section 251 obligations on an “all-IP” world. As we see with the retirement of copper facilities, many services run perfectly well over that infrastructure, from the mundane like fax and alarm monitoring to advanced Ethernet over copper technologies. AT&T and USTA really are pushing for deregulation based on technology, not based on market forces.

    Nevertheless, Chairman Wheeler is moving forward with “test beds” and “trials” to study the effects. We will not know for a while how meaningful these activities really are.”

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