Introduction:
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.  3G and 4G wireless voice and data services are increasingly prevalent, empowering consumers to connect at the place and time of their choosing.

The FCC is the public’s representative in the ongoing network revolution and plans to pursue three main areas in this regard:

1. Promote and incent competition

2. Network Compact with the public, which has four key elements –universal accessibility, reliable interconnection, consumer protection, and public safety and security. 

3. Regulatory philosophy based on risk and economic growth.

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Wheeler said there were three steps the FCC can take to remove obstacles and to supply inputs, tangible and intangible, to enable innovators to spur growth.  These will be the FCC’s top policy initiatives in the coming months and years.

1.  Spectrum policy that eliminates risks stemming from the government-mandated misallocation of spectrum.  A key area here is the reworking (or repurposing) of analog/broadcast TV spectrum concepts to the new digital realities.

2.  Speeding the transition to all-IP networks by preserving the Network Compact.  That transition is important because it demonstrates that the Commission will adapt its regulatory approach to the networks and markets of the 21st century.  Communications protocols are moving from circuit-switched Time-division Multiplexing (or TDM) to IP.  3G and 4G wireless voice and data services are increasingly prevalent, empowering consumers to connect at the place and time of their choosing.

3.  Through the protection of the “Open Internet” that is, today, our largest, global channel of commerce.  Unfortunately, the Open Internet and Net Neutrality are now in jeopardy, based on a federal district court ruling.  Read the scoop, comment and analysis at: http://viodi.com/2014/01/17/net-neutrality-ruling-the-beginning-of-the-end-or-the-end-of-the-beginning/

 
Transitioning to an “all-IP” Network:

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 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 (VoIP) network must support 911 calls in a consistent manner.  It doesn’t now.

It appears the all-IP network transition will be the number one agenda item at the FCC’s January 30th Open Commission Meeting.  The agenda and live streaming info is at: http://www.fcc.gov/events/open-commission-meeting-january-2014

Advancing Technology Transitions While Protecting Network Values is the first agenda item.  It’s 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 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). http://www.att.com/Common/about_us/files/pdf/fcc_filing.pdf
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.”9 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.  The event summary can be read at:  Telco Tours & Seminars Top ComSoc-SCV Activities http://www.comsoc.org/files/Publications/Magazines/gcn/pdf/gcn1213.pdf

The FCC’s new “Technology Transitions Policy Task Force” was asked 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 aforementioned FCC task force has proposed the following trials related to the all-IP network transition:
http://www.fcc.gov/document/technology-transitions-policy-task-force-see…
-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 at:  

http://www.ustelecom.org/sites/default/files/documents/USTelecom-IP-Tran…

Important Unanswered Issues for an all-IP network (i.e. retiring the PSTN/TDM/Digital Circuit Switched Network):

 Transition to an “all-IP” network implies retiring the PSTN, TDM/Digital Circuit Switched and all Wireless networks other than 4G with VoIP over LTE.  In our opinion, that is a huge undertaking that will be incredibly disruptive and take many years, if not decades.  Here are just a few point to ponder:

-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!

-What happens to faxes/fax machines, which are still overwhelmingly based on analog PSTN access? The death of fax has been predicted for over a decade, yet it is still alive and kicking!

-Battery backup is required for an all-IP network to make emergency phone calls when power is lost.  There is a substantial montly 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. 

http://www.att.com/esupport/article.jsp?sid=KB407650&cv=803#fbid=qLQu26G…

-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 functionalities 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 temporarilty reaching IP endpoints.

-Interconnection and Interoperability between IP and TDM networks is a work in progress. 

-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.

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Closing Comment:

Surely, there are more questions and issues in decommissioning PSTN/TDM/non-4G wireless networks and replacing them with an all-IP network.  BT tried to do that over a decade ago with it’s 21st Century Global IP Network, which is a very long way from being realized today.  BT hoped to have over 50% of its customers transferred by 2008. Capital expenditure was put at £10 billion over five years, this being 75% of BT’s total capital spending plans in that period.  But it didn’t happen and there seems to be no progress reports from BT on 21CN for years!  Instead, it appears to have been renamed Next Generation Broadband Network which is described at:  http://www.bt-ngb.com/home

This should be a lesson in reality or at least a wake-up call for the FCC, AT&T, US Telecom Association and others who believe that a rapid transition to an all-IP Network is feasible.

 
References:

http://www.infoworld.com/d/networking/fcc-chief-pushes-open-internet-rob…

http://www.broadcastingcable.com/news/washington/wheeler-fcc-will-look-d…

http://www.mercurynews.com/business/ci_24885303/mountain-view-anti-wirel…

https://www.youtube.com/watch?v=rn_1GjpbLnA

http://www.washingtonpost.com/blogs/the-switch/wp/2014/01/09/fcc-chairman-offers-his-strongest-endorsement-yet-of-net-neutrality/
http://www.networkworld.com/news/2014/010914-fcc-chief-wheeler-pushes-op…

http://www.pcworld.com/article/2086600/fcc-chief-wheeler-pushes-open-int…

http://www.fcc.gov/document/fcc-chairman-tom-wheeler-remarks-computer-hi…

http://www.fcc.gov/blog/ip-transition-starting-now

http://viodi.com/2013/09/25/tc3-part-2-likely-strategic-goals-for-next-f…

http://viodi.com/2013/12/09/fcc-delays-reverse-auction-till-2015-spectru…

http://viodi.com/2013/10/30/new-fcc-chair-tom-wheeler-faces-challenges-i…