The FCC Can Relax

Forgive me for taking the opportunity to throw in my two cents on a topic that has seemingly been beaten to death over the course of the last few days. But I feel the need to line up in VON/xchange Editor-in-Chief Richard Martin’s court and further temper the knee-jerk reaction that followed last week’s ruling by a federal appeals court against the FCC regarding the Comcast traffic-throttling issue.

The discussions regarding the options that the FCC has at its disposal to keep on pressing the Net neutrality issue were very enlightening and quite to the point. However, I am not quite sure that the FCC itself needs to initiate any immediate action to achieve its goals regarding Net neutrality.

The reasoning behind this particular thinking is actually rooted in the topic of this blog — namely, telecom convergence.

Looking at the three basic service types – conversational, entertainment, and data services – the FCC has traditionally wielded the least authority over the data services that were at the core of the development of the Internet. Entertainment services, meanwhile, can be separated into traditional broadcast services and upcoming Web-based services. Along with voice calling, these traditional broadcast services are where the government’s authority was applied successfully in the past.

As they grew, data services over the Internet were pretty much left to find their own way with minimal government interference. In the current telecom climate, though, NSPs and MSOs alike are looking at converging these services into a single framework in order to reduce their capex and opxx and offset the current traffic/revenue divergence. The approach of choice, so far, for the NSPs, has been to port conversational services and broadcast-entertainment services, using emulation, onto their lesser-regulated infrastructure initially deployed to support their bandwidth-intensive data services. The cable distribution networks of the MSOs themselves, despite having originated from a different paradigm, are evolving toward a similar end-point.

The result is a blurring of the lines separating these three basic services enumerated above.

VoIP, IPTV and data services are thrown into one big pipe with no fundamental transport type differentiation. The thinking is to have just IP-based data, with various SLAs enforced via traffic management to validate the outcome of the emulations, when needed.

To ensure the success of this grand master plan, however, traditional voice networks can not remain in parallel with this new all-IP, statistically-multiplexed network. Besides, causing a dislocation within the unified services, this would reduce the opex savings that are one of the primary motivations behind the whole scheme. So, we need to eliminate these networks, primarily embodied by the PSTN, and merge these voice services into our data-transport facilities. Sounds straightforward enough, doesn’t it?

Unfortunately not. Integrating these voice services into the data-transport framework constitutes a de facto invitation to the FCC, which currently has well-established regulation authority over these very same voice services. That is, VoIP can no longer be passed of as a data service when there are no more traditional voice services over a circuit-switched network. This means that VoIP will likely fall under the regulations originally applied to the PSTN only.

Given the extraordinary success of mobile telephony and the decline in numbers in wireline customers, the net may be cast even wider and snag cellular voice as well.

Finally, now that we are here, how can we tell what is voice and what is data? After all, it is now all just IP packets, with various classes of services. How can you single out voice, and treat it differently, within the big pipe?

Any reliability and availability rules applied to voice services, in particular, emergency services such as 911, are most likely to impact the other services sharing the same framework. Not all the characteristics of the Layer 1 (physical layer) and of Layer 2 can be offset in Layer 3 or higher via a clever management of the bandwidth resources. Bandwidth resources appear pretty sparse for the near future, both in the wireless area, due to spectrum availability and service usage, and in the wireline area, given the slow progress and high costs of 40G and 100G technologies. Similarly, packet-based OA&M, needed to ensure the said reliability and availability, keeps on sent back to the kitchen.

What it all means is that the FCC does not really have to initiate anything at the present time to pursue its goals toward Net neutrality. All the FCC has to do is wait, because telecom convergence itself is bringing the ball into its side of the court.

Serge Fourcand is a principal engineer with Huawei Technologies USA. He is an accomplished product manager and system architect with extensive multimedia experience in both consumer and telecom industry segments, including advanced multimedia distribution, digital signal processing, Ethernet Layer 2 transport and switching, and end-to-end telecommunications technology.