Entries in PSTN (3)


The PSTN: Sunset, Transition, Rebirth, or Just Leave it Alone?

“Sunset the Phrase ‘Sunset the PSTN’”

The first thing you should probably know about the FCC’s second “The PSTN in Transition” workshop, held on December 14, is that it was long—I’m talking 8 hours of economic, technical, legal and regulatory perspectives, debates, statistics and countless questions along the way. More importantly, it was extremely engaging and interesting. I was glued to my computer the entire day, opting not to sit in the FCC Open Meeting room in a suit with a short-lived laptop battery for 8 hours. Keeping this in mind, it was quite challenging to narrow down the key take-aways from the day, but there were certainly several important underlying themes as well as particular questions that rural providers might want to think about, including:

  • Regulatory lag is a notorious problem, so would an FCC mandate for a PSTN sunset cause more harm than good considering how far along we are in the transition already?
  • Are we assuming that IP is the end-all-be-all for communications networks, and we won’t possibly evolve beyond IP in the next decade or so?
  • What minimum speed, capacity, and quality of broadband will be good enough for a ubiquitous, non-discriminatory, affordable IP network? What basic services and applications should it support—Facebook? Over-the-top video?
  • What are the consequences for locking-in a particular technology, or “picking winners and losers?”
  • How will we manage the conversion to IP and the coexistence of technologies during the transition?
  • Should the end-date for the PSTN be targeted toward the early adopters or the hold-outs?
  • Does there need to be a “termination fund” to support the transition? If so, how on earth will that be funded? How would you convince Congress—and taxpayers—to support a fund that essentially kills the network that the very same taxpayers (as well as the industry) have spent billions of dollars building? Personally, I think this could be the greatest challenge.

Now that you have some food for thought, let’s look at some stand-out points by specific speakers.

In the first panel, “Impact of the Transition on the Technology and Economics of the PSTN,” Richard Shockey (SIP Forum) and Joe Gillan (Gillan Associations) both expressed frustration with the term “sunset the PSTN.” Shockey noted that the term is confusing, and should instead be a “renewal of our communications systems.” He also added, “We are not taking away grandma’s phone.” Gillan recommended that we “sunset the phrase ‘sunset the PSTN,’” and rather think of it like a “rebirth.” Dale Hatfield (University of Colorado) and William Lehr (MIT) continued the theme of the first workshop by stating that the definition of the PSTN in this context is really unclear. Hatfield asked if the PSTN was a service, a network, a regulatory construct, or a social contract; and he recommended creating multi-stakeholder groups to rely on the industry as much as possible to come up with solutions. He also warned against picking technology winners or losers.  

The third panel, “Implementing the Transition to New Networks,” brought thought-provoking comments from participants from Verizon, Comcast, Carnegie Mellon and XO Communications. David Young (Verizon) pointed out that even if companies, technologies and markets are in transition, regulations and laws do not usually transition very rapidly or easily. Marvin Subu (Carnegie Mellon) argued that transitions take time, for example the IPv4 to IPv6 transition will likely take decades. Therefore, it is important to manage technical aspects like conversion and coexistence, but also let market forces determine the pace of the transition. Young later added that some remnants of the PSTN will likely hang around for a long time, but there is no real reason to pick an artificial date to kill them—they will probably just go away on their own once they become too costly to maintain.

There was a very creative and apropos analogy in the fourth panel, “Expectations, Emerging Technologies and the Public Good.” Kevin Werbach (University of Pennsylvania – Wharton) applied transitioning the PSTN (“the death of an old friend") to the Kübler-Ross Five Stages of Grief, broken down as follows:

  1. Denial: We can’t plan for things we don’t anticipate. Werbach recommended that the FCC initiate a proceeding to identify conflicts, opportunities, ambiguities, and what should be preserved.
  2. Anger: Werbach predicted that there would be indeed losers in the process, and some “will throw themselves across the tracks.” Objections should be addressed sooner, rather than later.
  3. Bargaining: Werbach warned that “those who can game the regulatory process will do just that.” It is important to know upfront what should be mandatory and what is up for negotiation.
  4. Depression: Knowing something is going to happen doesn’t necessarily mean it will happen. We should have “energy and enthusiasm” and a “bias for action.”
  5. Acceptance: Werbach recommended developing a common visulaization for ending the PSTN, which will help the goals become more tangible.

The final panel, on economic issues, brought a forceful perspective from Lee McNight (Syracuse University)—he recommended a rapid “graceful exit,” from PSTN regulations as soon as 2015. He argued that creative destruction is driving the transition, and there is no point in delaying the obvious. Regarding the PSTN, McNight provided a short eulogy: “It’s been a nice run. It’s over…Thanks for the memories. It’s been nice. Let’s have a big party.”

Should we celebrate the swift demise of the PSTN or allow it to gradually shrivel to insignificance, and then yank out the cord to the respirator? Will the PSTN end with a whimper or a bang? I’m not sure these workshops helped answer the fundamental questions of when, why and how this needs to happen, but they certainly provided plenty of fodder for the coming months while the industry and regulators try to figure out the path forward.

If you have 8 hours to spare, it is well worth the time to watch the full workshop, available here.


The PSTN is Already in Transition… What is the PSTN, Anyway? 

Panelists Discuss Challenges for Public Safety, Disabled Individuals and Rural Networks

The FCC held two informative public workshops on December 6 and 14 to help itself and the industry better understand the recommendation that the PSTN ultimately be transitioned to an all-IP network. The FCC gathered around 50 experts to share insight on the transition from the perspective of ILECs, RLECs, mobile and fixed wireless, cable, consumer electronics, numbering, public safety, disability services, consumer protection, home security, VoIP, economics, engineering, academia, backhaul, and many more. If you think this sounds complicated with so many stakeholders—it was. But, it is necessary to understand how transitioning the PSTN will impact all of these industry sectors, because each one is deeply involved.

The first workshop, on December 6, included four sessions. The first two covered public safety and disability access issues, the third discussed rural network challenges, and the final session was focused on edge device functionality. This workshop set the stage for some of the broader, high-level issues that carriers and consumers will face if the PSTN is transitioned at a specific date—2018 was the popular target initially. Many of the panelists stated what their respective companies or organizations provide, what their customers or constituents need in terms of communications, and how their customers or constituents would be impacted if access to the PSTN vanished.

The public safety panelists seemed to agree that although many public safety networks are already transitioning to IP, many are still deeply entrenched on the PSTN. Allan Sadowski (North Carolina State Highway Patrol) explained that public safety is not necessarily about having the newest communication technology, it is about first response. Networks and communications equipment must be extremely reliable in every possible emergency situation, and public safety entities also face budget constraints as well as technical staff constraints. Challenges aside, the public safety panelists seemed excited about and interested in dynamic IP communications technologies that will benefit the public safety community. Brian Fontes (National Emergency Number Association) added that he approves of the 2018 PSTN sunset, but 911 services must continue to be available and reliable.

The disability services panelists were generally more concerned about how transitioning the PSTN to all-IP would impact their constituents—individuals who are blind, hearing impaired, physically challenged, elderly, etc., who might not willing or capable of adopting new technologies by a specific date.  Jenifer Simpson (Coalition of Organizations for Accessible Technology) explained that there are 15 million people who rely on disability communications services, and “most don’t know what the PSTN is.” There seemed to be some fear that the individuals in the disability community would be left behind in a PSTN-to-IP transition without proper consumer education coupled with easily available and affordable IP technologies. However, it was also acknowledged that there will be numerous new technologies for disability communications that are much better than today’s PSTN technology.

The third panel, “Technical Capacity, Capabilities and Challenges Facing Rural Networks” included representatives from ViaSat, Rural Cellular Association, Wireless Internet Service Providers Association, Vantage Point Solutions, Midcontinent Communications and OPASTCO; and it was moderated by Commissioner Anne Boyle from the Nebraska Public Service Commission. Although the panelists covered a wide range of rural communications perspectives, a few did not dig very deep into the issue at hand—transitioning the PSTN to IP networks. Rather, some focused more on promoting their respective services. Steven Berry (Rural Cellular Association) discussed the importance of ensuring basic interconnection “regardless of technology.” Berry added that “The PSTN as we know it is probably going away;” and “The future is coming faster than we otherwise may think.” He is also concerned about how such a transition would impact competition, because “some may view this as an opportunity…to essentially eliminate competition.”

Larry Thompson (Vantage Point Solutions) provided some interesting input about the engineering challenges and opportunities for small rural providers. He asserted that the transition will not work if narrowband POTS service is still the only option in some areas, and broadband IP networks must be completely deployed end-to-end. Tom Simmons from northern midwest rural cable provider Midcontinent also added that broadband adoption is “a big part of the equation,” especially in very rural areas that have a high population of low-income and Native American households.

John McHugh (OPASTCO) argued that it is not really important to set a “date certain” to end the PSTN because the transition of technology is natural and “occurs on an orderly fashion.” He described how many rural carriers already have softswitches and extensive fiber networks, over 90% of OPASTCO’s members provide broadband, and RLECs “have gone above and beyond the call of duty to provide their customers with the latest technologies.” McHugh noted that some challenges in the transition include public safety, ensuring all consumer devices are IP-enabled, and converting the customers who simply don’t want broadband. He also added that it is financially and strategically challenging for RLECs to build broadband to everyone and then the consumer decides to get VoIP service from a 3rd party instead of the traditional telephone company.

The final panel focused on transitioning edge functionalities and consumer devices.  One question that was asked repeatedly throughout both workshops—and was never fully answered—was “What is the definition of the PSTN?” Brian Daly (AT&T) insisted that this is a fundamental question that must be addressed before the transition can occur. Once this is determined, we can look at all of the other aspects on the user end, like devices. Daly explained that many alarm systems, ATM machines, faxes, credit card transactions, pay phones, and other devices still rely on the PSTN and will continue to do so for many years, even if their numbers are low. Harold Feld (Public Knowledge) argued, “There will always be surprises” and “you have to design any transition mechanism to handle surprises,” such as the wireless microphone debacle in the digital TV transition.

Overall, this first workshop was a good introduction to the myriad issues at hand, and an insightful look at where certain industry sectors stand on the debate over whether or not the PSTN should be transitioned at a specific date. At an industry workshop I attended back in July, I got the impression that most of the participants were in favor of sunsetting the PSTN in 2018. However, I got a slightly different impression from both of the FCC’s workshops (the second workshop will be recapped tomorrow). The bottom line is that there needs to be a specific definition of the PSTN before the PSTN can be killed, and the longer this fundamental question goes unanswered, the longer the transition will take. On the other hand, if the transition to IP is indeed well underway already, do we really need a specific end date? What do you think? How do you define the PSTN?

You can watch this FCC workshop here.


It's 2018: Where’s the PSTN?

Telecom Experts Argue PSTN Could be Dead by 2018

On June 29, 2011, the Technical Advisory Council (TAC) presented a newsworthy and controversial recommendation to the FCC: “The FCC should take steps to prepare for the inevitable transition from the PSTN,” and they should do it as fast as possible by establishing a specific end date. TAC referenced a National Center for Health Statistics report that determined only 6% of the U.S. population will use the PSTN in 2018; therefore 2018 seems like a reasonable year to put the PSTN to bed forever. There is no denying that landline PSTN customers are bailing at a rapid pace, but is 2018 too soon to expect 100% broadband and wireless adoption, such that no Americans are without at least one reliable communications connection?

Tom Evslin (a member of TAC, a telecom expert and author of the blog Fractals of Change) noted in a blog post last week that “People are making a free-market decision to abandon the PSTN for cellular or VoIP service.  People are chatting and texting and emailing and tweeting instead of talking.” Free market momentum aside, Evslin argues that the government needs to be involved in the transition so that people are not stranded without any form of communication, which raises special concerns for public safety. Regarding the phase-out, Evslin argues, “The date, in my opinion, should be the earliest possible time we can assure that alternatives to the PSTN are universally available, so long as we spend less public money in providing these alternatives than it would cost us to keep the PSTN alive past the date certain.”

Several of TAC’s recommendations have specific consequences for RLECs and rural Americans, because Universal Service is currently married to the PSTN. Although the FCC is hoping to reform USF to support broadband networks, we haven’t quite gotten to that point yet. TAC recommends that the FCC “change USF funding and spending to support universal coverage and other social goals;” and “assure that mobile and/or broadband replacements are available everywhere PSTN is currently provided. The need will be greatest in rural areas.” Although I agree that the PSTN is well on the road to dying a slow death, I feel that it might be a bit hasty to start looking at ways to expedite the death of the PSTN before the ink is dry on rules for reforming USF. Furthermore, I also think it is necessary to reform USF contributions, which currently come from PSTN services, before moving towards a PSTN-less nation.  

I think the real controversy comes in when deciding how to end funding for the PSTN in rural areas. Evslin asks, “Why continue to subsidize the most expensive and least effective way of keeping people in touch?” I feel that this question really gets at the core of the USF reform debate, as many believe that it has clearly become wasteful and inefficient for consumers to foot the bill for slow adopters to continue using landline phones. However, I think this issue needs to be looked at from the perspective of telecom providers who use the PSTN to provide DSL and other services in addition to telephone services. For many providers, telephone service is becoming the least important source of revenue and is basically just an add-on for broadband. As a result, consumers can utilize the PSTN foundation for landline calls or for VoIP calls using Skype or other over-the-top applications, and they can tweet and e-mail and Facebook all they want. Many consumers also like the security and reliability that a landline provides, even if they don’t use it very often, and this is especially true for households that have poor wireless coverage. Evslin also notes, “What about leaving great grandma with no 911 and no way to call her daughters?” How will the FCC ensure that all the grandmas are willing and capable of using wireless or VoIP before the PSTN is phased out? I know how much trouble it was teaching my own grandma how to use a cellular phone, so this seems like a fairly daunting challenge that must be addressed with great care and consideration for all types of consumers.

A blog post on Telecompetitor by Bernie Arnason also commented on the difficulty of defining the PSTN. He asks, “Are the fiber connections to the wireless towers which carry wireless traffic and eventually interconnect with the PSTN, part of the PSTN? Are copper local loops that provide DSL service no longer part of the PSTN?” I believe that these are definitely some of the most important questions—where do we draw the line between the PSTN that should be phased out and the PSTN that is an integral component of broadband and wireless communications networks? I wonder if there is really a point to ending the PSTN if USF subsidies are eventually going to be entirely for broadband anyway—if there is still a consumer demand for landline service, why not just continue to offer it at the company’s full expense? I personally liked Hargray Telephone Company’s Broadband Incentive Plan for USF because it allowed for ongoing landline cost recovery as long as there were landline customers, but increased the subsidies for broadband depending on the broadband speeds that customers subscribed to. So, a company could in theory only have 10 landline customers in 2018 and therefore only get support for those 10 customers based on their 2011 support level. Meanwhile, the real cost recovery would come from the 10, 20, 100 Mbps broadband customers, where the company would get the 2011 landline recovery amount times a weighting factor based on the speed.

The discussion on ending the PSTN is definitely in the early stages, so it is hard to tell if TAC’s exact recommendations will come to fruition or not. TAC also recommends updating the National Broadband Plan to include the PSTN phase-out, but I think that the USF reform rules should be published before this step can be considered more seriously, else the FCC may end up creating even more anxiety-inducing regulatory uncertainty. Meanwhile, it wouldn’t be a bad idea for RLECs to start thinking about 2018, and start estimating their cord-cutting rates for the next few years. It also might not be a bad idea for RLECs to start teaching the local grandmas how to use cell phones and Skype.

Learn more about TAC’s PSTN recommendations here. Tom Evslin’s blog post is available here, and Bernie Arnason’s is here.