Five Fundamentals, Values For A New Phone Network
Five Fundamentals, Values For A New Phone Network
Five Fundamentals, Values For A New Phone Network

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    As we 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

    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

    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 includes hardening 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

    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.