I made a passing reference to the rural call completion problem in a post about 2 months ago. I’ve now written a much longer piece explaining the problem of rural call completion, and the nature of the problem, for the Daily Yonder. You can find the article, and the very nice illustrations they added, over here.
To give a very brief recap for why y’all should click through to learn the details of rural call completion — rural call completion is an unexpected side effect of the transition of the Public Switched Telephone Network (PSTN) to an all-IP based network. Using IP-packets gives you greater flexibility to pick how you route calls. To avoid very expensive rural termination fees (which subsidize rural systems and keep them operating), Least Call Router systems can send calls through lots of hops, creating latency or even trapping the call in a perpetual loop. As a result, calls to some rural systems don’t go through, or quality degrades to where rural areas may not be able to have reliable phone service or reliably reach 9-1-1. The FCC has issued a Notice of Proposed Rulemaking to address the problem, and every Commissioner has emphasized that making sure the phone netwok remains reliable is a core mission of the FCC.
I and my Public Knowledge colleagues have emphasized both network reliability and service to all Americans as part of our “Five Fundamentals Framework” to guide the transition of the PSTN to all-IP. The rural call completion problem demonstrates precisely why we need a framework to guide us, rather than jumping right away into the “deregulation v. regulation” fight so many people want to have instead of focusing on the real issues.
It is also an example of a phenomenon I call “network neuropathy,” how problems in networks may first manifest themselves in failures of service around the extremities.
More below . . . .
I’ve been sorting through the various filings at the FCC in the Phone Network to IP transition docket. I single out the 7-page filing by Comcast as the filing that scares the absolute bejeebers out of me.
Why? Because everyone else – no matter what their financial interest or political alignment – at least paid lip service to the idea that we ought to have some kind of regulation. Whether it’s a general nod to a “minimal and light touch regulatory regime” or a specific shopping list, the vast majority of commenters recognized then when you have something as big, complicated and utterly essential to people’s lives as the phone system, you need some kind of basic backstop for people to feel comfortable and to address problems that will invariably come up. Even AT&T has made it utterly clear that it does not see the future of phone service as a regulation-free zone.” Even staunch free market conservatives such as TechFreedom and Free State Foundation acknowledge that, as a practical matter, there is going to need to be some set of rules – even if they hope to keep these rules to what they regard as the barest minimum necessary.
Comcast, and Comcast alone, suggests otherwise. Comcast alone thinks we can manage the phone system as the Libertarian Nirvana. This smacks either of unbelievable hubris (“we’re so big everyone will have to deal with us – what could go wrong?”) or an incredible sense of market power (“we’re so big everyone will have to deal with us – heh heh heh”). Either way, this sends chills down my spine, because the filing signals loud and clear that Comcast – one of the largest providers of residential phone service in the United States, the largest residential broadband provider, and the single most powerful entity in U.S. telecom policy – simply doesn’t get it when it comes to the future of the phone system.
As I explain below, Comcast needs to understand that “With Great Market Share Comes Great Responsibility.” Because when you are this big, even what you don’t say can have huge consequences. Comcast is beyond “too big to fail.” It is now officially in its own regulatory category called “too big to be allowed to screw up.” Because Comcast is now so big, and so central to communications in the United States, that it could single-handedly crash the phone system by stupidly trying to manage it as if it were the cable world. Unless Comcast gets with the program and acknowledges the need for some kind of ongoing oversight of the phone system, this transition is guaranteed to become an utter disaster.