[governance] [Dewayne-Net] Shutting Down The Phone System Gets Real: The Regulatory Implications of AT&T Upgrading To An All IP Network

Thu Nov 15 16:44:10 EST 2012

Michael:

I think there is a significant difference between national regulations and
regulation by a body such as the ITU. National regulations anticipate
national needs, and in the case of the US (and I suspect many other
countries) happens within processes that hold the regulator accountable to
the public. While the regulator may not always act in the public interest,
there are mechanisms in place that would hold the regulator to account.

In contrast, international regulations need to be much more high level
because they cannot anticipate particular local needs. I think a high level
statement of principle at the ITU that calls for universal access to
broadband is good.

Another cause for discomfort with detailed ITU regulations stems from its
closed processes.

Best,

Rashmi

On Thu, Nov 15, 2012 at 12:46 PM, michael gurstein <gurstein at gmail.com>wrote:

> I'm sure this is naïve of me, but I'm wondering what the difference (at the
> level of principle) might be between arguing as below, for regulation (in
> support of the public interest) for an IP based network through the FCC and
> arguing for regulation of "the Internet" (in support of the public
> interest)
> at the WCIT/the ITU (as per for example
>
> http://gurstein.wordpress.com/2012/10/11/the-ituwcit-thinking-about-internet
> -regulatory-policy-from-an-ldc-perspective/
>
> (and please could we discuss this at the level of theory/principle while
> avoiding US "exceptionalism"...
>
> M
>
> -----Original Message-----
> From: dewayne-net at warpspeed.com [mailto:dewayne-net at warpspeed.com] On
> Behalf
> Of Dewayne Hendricks
> Sent: Wednesday, November 14, 2012 2:46 PM
> To: Multiple recipients of Dewayne-Net
> Subject: [Dewayne-Net] Shutting Down The Phone System Gets Real: The
> Implications of AT&T Upgrading To An All IP Network
>
> Shutting Down The Phone System Gets Real: The Implications of AT&T
> Upgrading
> To An All IP Network.
> By Harold Feld
> November 13, 2012
> <
> http://www.publicknowledge.org/blog/shutting-down-phone-system-gets-real-im
> plicat>
>
> I believe AT&T’s announcement last week about its plans to upgrade its
> network and replace its rural copper lines with wireless is the single most
> important development in telecom since passage of the Telecommunications
> Act
> of 1996. It impacts just about every aspect of wireline and wireless
> policy.
>
> For those who missed it in the morning-after blur of the election results,
> AT&T announced that it will invest an additional $14 billion to upgrade its
> wireline and wireless networks, so that it projects investing $22 billion a
> year for the next several years in capital expenditures (“CAPEX” as they
> say
> on “The Street”). At the end of the three year time frame, AT&T expects to
> have converted its existing “time division multiplexing” (TDM) phone
> network
> entirely to an IP-based network which will seamlessly mix its wireless,
> remaining souped-up copper, and fiber (but not fiber-to-the-home). Since
> all
> existing phone regulation governing universal service, consumer protection,
> and competition rest entirely on the existing TDM/copper network, AT&T
> simultaneously filed a petition with the FCC to “begin a dialog” on how to
> address the regulatory issues raised by this shift and proposing some
> entirely deregulated “pilot programs” to determine what regulations are
> “really” necessary.
>
> Setting aside my skepticism that these pilot programs offer anything of
> value, I thank AT&T for beginning with an offer to talk. At the same time,
> I’m mindful we need to get the key elements of the new framework down over
> the next year or two – which is practically nothing given the complexity of
> the issues and the number of stakeholders involved. It puts a premium on
> communities working quickly to come to internal consensus and on trying to
> bring as many allies to the table as possible. Ideally, we would set
> universal rules for all IP networks, but this would meet fierce resistance
> from existing IP-providers. Nevertheless, AT&T raises a valid point of
> concern if the rules for the TDM to IP apply only to it and other Local
> Exchange Carriers (LECs) upgrading their networks. The FCC must balance
> these concerns about competition and fairness with the broader questions of
> what happens when our 100-year-old copper safety net gets replaced by an
> essentially unregulated IP-based networks.
>
> What’s At Stake? Everything In Telecom Policy.
>
> To list just the headline questions:
>
>         • What happens to the concept of universal service, particularly in
> rural areas? AT&T itself says in its announcement that its new combined 4G
> LTE and wireline IP footprint will cover "Ninety-nine percent of existing
> customer locations." That loss of 1%, while small in absolute terms,
> potentially means many thousands of people losing access to basic phone
> service.
>
>         • Even if AT&T’s wireless footprint precisely overlapped its rural
> copper footprint, there would still be significant questions about
> reliability and price.  Traditional phone service has minimum standards of
> quality enforceable at the local level, and in most states a requirement to
> offer basic voice service at a regulated price. This combination of a
> requirement to serve everyone in the service territory, at a minimum
> standard and to offer a basic, affordable voice option is generally thought
> of as “Carrier of Last Resort” (CoLR) regulations. If AT&T transition to
> IP-based networks and eliminates its CoLR obligations associated with its
> traditional telephone service, what happens? In rural areas, wireless
> signal
> might not have the same quality as existing copper, or it might become
> unaffordable for poor subscribers in rural and urban neighborhoods where
> low-income families rely on a low-cost basic voice service.
>
> [MG>] (Snipped... Lot's of important stuff on regulatory/deregulatory
> telecom/IP issues in the US
> ....
>
> Conclusion:
>
> Every stakeholder community needs to carefully consider its position and
> come ready for some hard bargaining. The traditional battle lines and
> positions need to be carefully reexamined. The world is changing, and it
> will make a radical change like this only once. This is not the time to
> repeat the rote responses of the past. This is not going to be some
> Libertarian nirvana where the regulatory state withers away and we shall
> move from each according to his need to each according to his ability to
> pay. Neither is traditional regulation going to remain unchanged. Anyone
> taking either position is effectively removing him or herself from the real
> conversation that must take place.
>
> What we need to do, individually and collectively, is figure out how to
> take
> the values of the 100-year old social contract in telecom that has served
> us
> so well as a nation and decide how to express those values in concrete
> terms
> for the next generation of networks. That won’t be easy. But stuff that
> matters never is.
>
> Dewayne-Net RSS Feed: <http://www.warpspeed.com/wordpress>
>
>
>
>
>
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-- 
Rashmi Rangnath
Director, Global Knowledge Initiative and Staff Attorney
Public Knowledge
1818 N Street NW
Suite 410
Washington, D.C. 20036
202 861 0020
rrangnath at publicknowledge.org
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