A Framework for the PSTN TransitionA Framework for the PSTN Transition

I do not want to see the future IP-based phone network retrench and offer less service and quality than the PSTN offers today.

We know that the PSTN as a TDM copper-wire-based network is losing ground. Some say it is dying, others say it is being killed by IP-based networks. What we do and when will have an impact on business, government, education, and consumers. This is not a new issue. AT&T and other carriers have been lobbying for the closure of the PSTN, but for reasons other than just economics.

The PSTN was built and maintained as a very reliable, wide-ranging network. There are, however, some attributes and capabilities that should be imposed upon any IP network substitute for the PSTN.

I posted an article in April 2010, "PSTN Closure, the End of POTS, the Challenges," predicting some of the issues for closing down the PSTN. One issue I still see existing is that of Carrier of Last Resort (COLR). Part of AT&T's request is to terminate the PSTN regulatory infrastructure and remove AT&T as the Carrier-of-Last-Resort. This means eliminating existing regulation and policies. Terminating the COLR policies may be the real goal of AT&T. NoJitter has looked at this issue with Eric's blogs "AT&T's Call to Sunset the PSTN", "More on the PSTN ", and "Cellular as the New PSTN".

The advocacy group Public Knowledge has released a white paper on America's phone network transition titled, "Five Fundamentals for the Phone Network Transition." The paper looks at the transition from a copper-based infrastructure to an IP-based network. The paper explains how the phone network is transitioning into new technologies. The transition does not change the needs of Americans nor does it change the responsibilities of carriers.

The paper provides historical and background information on the PSTN and the policies that were enacted during the 20th century to connect a phone to every farm and home. Public Knowledge's white paper shows that adhering to basic fundamental values that we take for granted could ensure that our next phone system meets the needs of Americans. The paper was written by Senior Vice President Harold Feld and Senior Staff Attorney Jodie Griffin.

There are basic five fundamentals proposed in the white paper that should be part of the framework for the transition to and ultimate operation of an IP-based public network. These fundamental issues, according to Public Knowledge, are at stake and without oversight, may not be satisfied when the PSTN-to-IP transition occurs.

Service to All Americans
The principle goal of PSTN service is that all Americans have access to telephone communications whether they live in rural or urban areas. The goal also includes those with any physical disability that would interfere with communication. It applies to all users regardless of their level of income. This goal has been part the telephone regulation and is supported by the Universal Service Fund and the concept of the Carrier of Last Resort (COLR).

At the present time, it appears that no carrier wants to be the COLR once the PSTN is closed. That means service to all Americans is in jeopardy. The FCC and Congress have to create an actionable set of regulations that will ensure COLR. Otherwise schools, libraries, homes, and health care providers may be cut off or have to pay high rates and fees to communicate.

Competition and Interconnection
Interconnection and other competition policies are at the center of the development of a competitive phone service. A lack of mandatory interconnection of diverse phone networks will encourage monopolies as the largest carriers gain anticompetitive advantages by withholding access to their customers from competitors. This was the case 100 years ago as well.

Carriers are migrating toward all-IP networks. Regulators must determine how to achieve interconnection and competition among providers when the PSTN is closed. These policies are critical to producing and maintaining an interconnected network and a competitive market.

Consumer Protection
Competition does not produce consumer protection. In the eyes of the providers, these are unrelated. It is up to regulators to deliver the rules and policies for consumer protection. These protections include the privacy of phone calls, truth-in-billing, and rules against carrier anti-customer practices such as slamming and cramming.

We now have to rely on regulations for protection. During and after the PSTN transition, consumers will need to be adequately protected, especially regarding recourse to the timely resolution of complaints. Consumer protection must continue to ensure that the rules governing communications providers respect the basic rights of consumers and prevent predatory practices.

Reliability
The PSTN has been called a gold-plated service. It appears to be always available, more so when compared to electrical power. Customers rely on communications networks to work predictively, consistently, and reliably. A successful transition from the PSTN means that phone numbers will work and calls will be connected with the same reliability as experienced today. Phone service, independent of the communication protocols used, should be able to survive emergency situations.

The current trends are leading to less redundancy and back-up power and increased reliance on the commercial power grid, which can present a single point of failure. This design weakness will need to be addressed through regulatory authority. The providers balance cost and profit and are attempting to maximize profit by, in the end, reducing reliability. Providers do not always voluntarily follow best practices and internal procedures. See my blog "Our Networks; Not Ready for a Disaster" for how poorly Verizon handled resiliency problems of 911 access that lasted days in Northern Virginia during and after a severe storm.

Public Safety
The FCC has begun to evaluate the future of public safety requirements with the Next Generation 9-1-1 transition. My recent blogs cover the changing world of 911 calling, "Impacts of NG911" , "NG911: On the Horizon", "Finally: Texting to 911". Public safety rules and policies must be updated to ensure that emergency services like 911 and geolocation technologies continue to support emergency first-responders independent of the network that the customer uses--wireless or wireline, copper or fiber. The evaluation should also include ensuring that alarm systems and alarm system standards that rely on access to a "telephone line" are supported during and after the transition.

I do not want to see the future IP-based phone network retrench and offer less service and quality than the PSTN offers today. Some are used to the poorer quality of cell calls. But I still want the quality of the wireline call and most of my broadband calls.