Pure VoIP Won't Be Regulated, Phone-Like VoIP Might Be

["Stastny Richard" <]

I commented on the FCC decision, on the FICORA decision and 
also related to the dicussion here on the EC Workshop on IP voice and
convergence 
on the FWD List as follows:

-----Original Message-----
From: Stastny Richard 
Sent: Friday, February 13, 2004 1:36 PM
To: 'Free World Dialup - The Future of Dialing'
Cc: 'Jeff Pulver'
Subject: Pure VoIP Won't Be Regulated, Phone-Like VoIP Might Be


First of all, Congratulations to Jeff and FWD on this ruling.

BUT: I have thought about this decision and wrote something into my
Blog: http://voipandenum.blogspot.com There you have also some
references to additional activities regarding these issues:

Comment from Richard:

I have some problems with this decision (see below), although I
congratulate Jeff to his personal sucess. But considering all the recent
developments, and seeing it in context, especially the decision by
FICORA on Sonera's Puhekaista Service:
http://www.ficora.fi/englanti/document/SoneraPuhekaista.pdf
I am not very happy with this development. 

In principle I have no problem that Phone-like VoIP might be regulated,
the only question is to which extent. I understand that there is some
regulations required if VoIP is interworking with the PSTN (e.g. using
E.164 numbers, access to emergency services, an fixed lines, etc.). I
also understand that if a VoIP is replacing an existing primary line
service or PATS , it should have similar regulations then the original
service beacuse of customer expectations.

What I do not understand is the extreme position (and simplistic) of
FICORA simply stating if you use E.164 numbers in- and outbound, you are
PATS, period. Any therefore you have to comply to ALL Universal Service
Directives. I understand that the FCC is currently not going down this
way, stating that Phone-like Services Might Be regulated, but one never
knows. There is also the danger that very different regulations crop up
in different countries, and VoIP is from the beginning international or
global (and NOT NATIONAL, Alan).

So even if VoIP services originating on geographic fixed lines replacing
primary line services are regulated as PATS, all nomadic or mobile VoIP
services are not PATS, IN THE SAME WAY ALL MOBILE SERVICES ARE NOT PATS.

I consider it very strange that existing mobile services are explicitely
not PATS, but VoIP should be (ok, laws are also a question of lobbying)

I see the following possible developments, which IMHO are dangerous:

1. We may have two phone services, one as IP telephony and one on the
PSTN (including carrier VoIP (NGN+3GPP)) 2. The PSTN continues using
E.164, the other Internet addressing or an own new dialling plan, which
would take years to develop consistently 3. The two services are not
interworking with each other, or even worse, only by (illegal?)
"private" interconnections. 4. All this would lead primarily to endless
customer confusion. 5. Customer confusion leads primarily reluctance of
customers to invest (see other "standard" wars)

In effect, this development would hurt both sides: 
1. VoIP deployment would be delayed, and there is also the danger that
competing numbering plans and implementations would confuse customers
even further. We should not forget that all VoIP and IP Communications
are still tiny islands in the large PSTN see. But if IPC finally wants
to replace the PSTN, IPC need to be an ubiquitous service, therefore
cooperation and interworking is necessary. The E.164 numbering plan and
ENUM could provide the glue to achieve this goal early. 

2. But also the PSTN will be hurt: If the barriers are to high, Telcos
will continue to be reluctant to invest in IP technology, even some or
parts within the Telcos will like the delay, but this is short sighted.

The customers and especially the business customers will finally go to
all-IP (not only because of the price, but also because of superior
features) and so VoIP and IP Communications will finally succeed, and
the breakdown of the PSTN will come EARLIER then now expected, because
there is NO interworking.

Do not forget, IPC can always interwork with the PSTN, but the PSTN can
only interwork with the Internet via E.164 and ENUM (that why some
poeple in the Internet Community are against ENUM).

Consider a time in the future when 50% of users are on VoIP and 90%
already on BB-IP anyway and 50% are on the PSTN. The IP guys then have
the global service (there are always ways to reach the PSTN from IP),
but the guys on the PSTN are LEFT BEHIND.

First all on both sides will drop the PSTN like a hot potato (see whats
going on with the fixed network with 80% mobile) and there will be a
rush to move over, especially the grannies to reach their grandchilds
living on all-IP since years, and the PSTN will crash.

Conclusion: a decision to strongly regulate all IPC services touching
the PSTN will hurt both VoIP and the PSTN, and it also will cause in the
short term a serious delay in investment of innovative products.

One way out may be found in the excellent report from Analysys to the
European Commission and 
at the workshop to be held in Brussels on March 15th. See:

http://europa.eu.int/information_society/topics/ecomm/index_en.htm: 


best regards
Richard

> -----Original Message-----
> From: Carsten Schiefner [
	    
	    
] 
> Sent: Thursday, February 12, 2004 3:43 PM
> To: Michael Haberler; Gordon.Lennox@localhost
> Subject: Re: EC Workshop on IP voice and convergence
> 
> 
> Michael, Gordon -
> 
> related, but from another region:
> 
> CHILE
> The Challenges of IP Telephony
> 
> http://www.thelink.lu/live/newsletters/The%20l.i.n.k.%20-%20Is
sue%2024.htm#1033
> 
> Regards,
> 
> 	-C.
> 
> Michael Haberler wrote:
> > this looks very relevant, timely and - at first reading - 
> addressing 
> > the
> > relevant issues.
> > 
> > The Ficora decision on Sonera VoIP *really* is a disaster 
> and has the
> > ability to stop VoIP, but als other converged services 
> based on ENUM in 
> > its tracks because of the narrow interpretation of "e164 number use 
> > makes it publically available telephone service".
> > 
> > And that makes me very wary in my role of getting +43 ENUM 
> out of the
> > gates. But if the Finnish model becomes the model of reference, the 
> > whole industry has a major problem within the EC footprint. That is 
> > totally aligned with the fact that some telcos try to throw 
> sand into 
> > the gearbox. Combined with the nature of the Internet this 
> will just 
> > foster offshore services as a consequence, and that cant be the 
> > direction we're heading.
> > 
> > If regulators would have taken a stance like that during 
> GSM rollout a
> > decade ago regarding CALEA, emergency call location, speech 
> qualitiy and 
> > coverage, we definitely would not have todays cellular 
> service market. 
> > It seems appropriate to me to give the IP communications industry a 
> > similar time window to develop services and address those 
> issues over time.
> > 
> > BTW it is also time to review at the justification of asymmetric
> > termination of mobile operators - it isnt required for 
> growth of the 
> > mobile industry anymore and it barrs resources from the 
> PSTN operators 
> > towards broadband rollout.
> > 
> > I would be interested in what the intended process of commenting,
> > collecting inputs and trickling it down to the member 
> states is - will 
> > there be a discussion, consultation?
> > 
> > -Michael
> > 
> >At 10:44 11.02.2004, Carsten Schiefner wrote:
> >> Colleagues,
> >>
> >> not _totally!_ ENUM related but still close enough, I 
> believe. Please 
> >> distribute as widely as possible.
> >>
> >> Thanks & best,
> >>
> >>         Carsten Schiefner
> 
> 
>