Shutting the phone network off while you’re running out of internet protocol numbers

January 20th, 2012 by kc

I ended 2011 with a short (20 December) visit to a pleasantly warm Washington, D.C. for my 5th FCC Technical Advisory Council meeting. Some of the discussions from the third meeting were extended, others cut off for lack of time. We spent over an hour on the suggestion made by the Legacy Transition working group two meetings ago to advise the FCC to move forward in sunsetting (although we shunned that term at this meeting — “It’s a new beginning, not an end!”) the public-switched telephone network (PSTN). Many questions have arisen repeatedly in the discussions over the course of the last two meetings (and two FCC workshops in between), notably, “What happens to the telephony numbering system?” The initial strategy was imprecise, “The numbering plan will continue to exist but governance and allocation process needs to be considered.” Another repeated question has been “What exactly do we mean by PSTN?”

Interestingly, at this meeting the FCC staff themselves presented some thoughts on the way forward for the PSTN, before the working group got to present, thus some redundancy ensued. Still no resolution on numbering, or its post-PSTN replacement “identification”. Several TAC members including Vint Cerf and Dan Reed emphasized the importance of naming conventions for an expansive set of services now displacing what we used to call voice. Furthermore, since most people still use mobile phones in the same small set of locations, the permanent connectivity or attachment of the phone number to the individual is even more fundamental to the architecture than constant mobility.

As the working group emphasized back in July, the PSTN transition is neither a TAC nor an FCC initiative — consumers are driving it, i.e., dropping their landlines with alacrity. There was rough consensus on the need to consider several technical and policy issues, including: promoting competition; universality and carrier of last resort (including USF and reciprocal compensation); transitioning services that depend on the PSTN; reliability, continuity, accessibiity, 911; homeland security/CALEA; and privacy/personal security. Open questions include those as mechanical as “What replaces RJ11?” and as economic as “What/Where are the most efficient points of interconnection?” (Well, both questions bear mechanical and economic considerations.) The industry still lack IP-based technical standards to ensure quality and reliability of voice, and the FCC’s regulatory posture carries an embedded assumption — understandable given its century of commissioned responsibility — that voice is something to specifically protect rather than treat as another bucket of data being transported across the network.

Tom Wheeler captured a less surprising industry opinion that unencumbering industry from the body of laws and court precedents based on the PSTN would facilitate the advance of market forces. Marvin Sirbu was worried we might be overestimating the speed at which citizens are really moving to VOIP. While there was disagreement over details, there was broad consensus that IP was going to be the mechanism for most end-to-end carriage.

Less time, about 15 minutes, was spent discussing the IPv6 working group’s results (a “benchmarking document”) and recommendations, mostly punting the problems to next year starting with a joint workshop with NTIA in February. There was only time for one comment, from Vint, before the FCC chairman spoke, after which we went on to the next topic. Vint had four rapid-fire points: (1) IPv6 is NOT a transition, but rather introduction of an additional capability; (2) there is a very real threat of a cascading NAT environment; (3) NIST should be involved in IPv6 measurement; (4) OMB should be involved in government procurement guidelines for IPv6 network services. I disagree with his first point, but the lack of government coordination and consistency is painfully clear. OMB already has an IPv6-related mandate, but there are no IPv6 support conditions on the broadband stimulus money or other sources of USG funding (IPv6 conditions on USF funding are being discussed). My bigger concern with benchmarking is that current IPv6 measurement activities send mixed signals to industry — customers are not planning since the best available data implies that carriers are not planning to deploy it in the next 18 months.

The best suggestion I have heard so far (from Geoff Huston) is for the FCC to ask of its own constituency to publish their 24-month IPv6 deployment objectives so that current and potential customers of their services are aware of their plans, and then in 18 months ask the same set of to folks publish their actual IPv6 deployment achievements and what their objectives are for the ensuing 24 months. This recommendation would be consistent with the FCC’s “transparency and disclosure” approach to other issues. But there was no time to discuss IPv6 at this meeting, maybe next time. Hopefully I will have some results to report from CAIDA’s IPv6 growth scenario computational modeling study.

We agreed to narrow the set of TAC study topics for 2012 to three: IPv6; the PSTN transition; and receiver standards to support sharing. Next meeting in March 2012.

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