Entries in Telecom 2018 (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‚Ķ 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.


Are You in "Club 2018?"

Telecom 2018 Workshop Participants Debate the End of the PSTN

About a month ago, the Technical Advisory Council (TAC) made a bold recommendation to the FCC: set a specific end date for the PSTN. This recommendation was largely based on a National Center for Health Statistics study that estimated only 6% of Americans would use landlines by 2018. This recommendation set off a flurry of debate, and it also brought the Telecom 2018 Workshop to Washington DC on July 28, 2011. This workshop was the first of probably many events dedicated to discussing issues related to phasing out the PSTN, and I was happy to have had the opportunity to attend. As one of the hosts said at the end of the conference, I will one day be able to tell my children that “I was there” when the industry started planning the end of the 130+ year telephone network.

The workshop really tested the waters to see what different stakeholder groups thought about setting a specific end date for the PSTN—the perspectives ranged across the board from reluctant to highly optimistic. The panelists and presenters came from all corners of the industry too—some of the companies represented were AT&T, Public Knowledge, John Staurulakis, Inc., Google, Acme Packet, Verizon, CEA, Telecordia and TIA. There were individuals from a variety of legal and consulting firms, and there was even surprise appearance by National Broadband Plan Director Blair Levin. The event was organized by Daniel Berninger, president of GoCiper Software, and co-moderated by John Abel from Team Lightbulb.

Two industry leaders gave opening remarks at the day-long event: Richard Wiley, partner at Wily Rein, former FCC Commissioner and leader in the lengthy transition to digital TV; and Tom Evslin, a member of TAC and a leading voice in the 2018 end-date recommendation. Wiley talked about the decades of efforts and evolution to finally accomplish the DTV transition, which he considered a success. According to Wiley, the elements of success in the DTV transition included reliance on the engineering community, open and transparent peer review, rigorous testing, opportunities for all participants to come together, the efforts of the Grand Alliance, and that the evolution was not dictated by the government. I considered all of these elements to be especially insightful for the road ahead in the telecom industry, especially reliance on the engineering community and not expecting or allowing the government to dictate the entire transition.

Wiley also explained that it is important to develop clear objectives, and it is especially important for consumers to understand what is going on by providing information with limited potential for misunderstanding. Wiley made an interesting comment that the eventual transition to an all-IP communications network may result in greater competition and choice, which will create “less need for pervasive government oversight,” and possibly eliminate the “demarcation lines” that currently segment the telecom industry.

Evslin discussed the lifecycle of the PSTN, noting that it peaked during the dial-up Internet era when people were rapidly adding second lines, but then it started to decline when DSL became popular. He strongly believes that the PSTN is nearing the end of its useful life, and he also stated that the more valuable POTS consumers have largely abandoned the service already. Evslin touched on the intertwined issues of reforming USF and ending the PSTN, and he argued that the PSTN is basically being kept alive by government programs. He said that USF was a good program but it has now failed, and the PSTN subsidies are hogging resources that should be going for broadband deployment. Evslin believes that January 1, 2018 should be the official end-date for the PSTN—he thinks that 6 years is a sufficient transition period and each extra year will just diverts resources that should go to IP networks. Evslin envisions an all-IP future where “all phones can be smart,” and the every-day office desk phone could have some really interesting capabilities, like the wireless smartphones we all use now.

The first panel of the workshop, moderated by Harold Feld of Public Knowledge was called “Deconstructing the PSTN: What Does it Mean to Turn it Off?” Valerie Wimer from John Staurulakis, Inc. presented the RLEC perspective in this panel, and she emphasized that RLECs utilize the same facilities for broadband as they do for traditional telephony. She also argued that rural carriers have unique challenges in terms of distance and population density, and Title II regulations are—and will continue to be—important for these companies. Representing the CLEC perspective, Thomas Jones from Willkie, Farr & Gallagher argued that we should think of Telecom 2018 as a transition, not as a retirement of the PSTN. He added that forcing the transition to a new technology will not necessarily solve some of the market failures that exist now, and an abrupt end to the PSTN could have negative consequences for price, choice and competition. Colleen Boothby from Levin, Blaszak, Block & Boothby agreed that technical evolution alone does not always change the market structure, and regulations will still be needed even in an all-IP ecosystem. Overall, this panel was fairly skeptical about the benefits of setting an end-date for the PSTN. Feld asked what would happen if we shut off the PSTN tomorrow; Wimer replied that networks would stop and RLECs would default on RUS loans.

The second panel, “Embracing Innovation Across the Ecosystem,” really brought up a lot of questions that must be addressed in the process of transitioning from PSTN to all-IP: interconnection obligations, non-discrimination principles, network neutrality principles (soon-to-be laws, presumably), device markets, privacy, the role of state utility commissions, open standards, and USF/ICC reform are all areas that must be analyzed closely. I was pleased that this panel discussed the importance of reforming USF and ICC in advance of setting an end-date for the PSTN. Panelists Barlow Keener (Keener Law Group) and Rick Whitt (Google) both agreed that there is a clear need to reform USF from “a world that is less and less relevant” to a world where USF subsidizes IP network build-out and network upgrades.

The rest of the day consisted of individual presentations from industry experts on transition solutions and deployment models.  Here are a few of the points that stood out to me:

  • Mark Uncapher from TIA provided data analysis to illustrate that the decline in business voice lines has been much less dramatic than the decline in residential voice lines, which leads to the question:  How will the transition accommodate PSTN-reliant business customers?
  • Don Troshynski from Acme Packet argued that there is “no one solution to fit all” in delivering IP networks, but successful networks will provide a superior user experience, service flexibility, and be secure, trusted and scalable.
  • Link Howeing from Verizon explained that monopolies are not realistic in an all-IP ecosystem because there are multiple facilities-based competitors and different business models, unlike in a monopoly marketplace. He believes that there are real benefits to setting a firm date for ending the PSTN, but the industry should not get too caught up on a deadline and the corresponding regulatory aspects.
  • Jesse Oxman from CEA talked about the success of the DTV transition and the consumer coupon program for converter boxes. He added that the last deadline push-back during the DTV transition was unnecessary and ended up causing panic and confusion. He thinks most of the lessons from DTV will carry over to the transition to all-IP.
  • Bob Frankston from Frankston Innovating made some interesting observations about how bits are not consumable—they are like the alphabet and you cannot say “you used up the letter B, so you can’t use it anymore.” He used an analogy to compare the PSTN to IP networks, where PSTN users are like tenants with monthly fees and rules to follow, but IP users are like owners because bits can be used in any way, by any device, with no marginal costs.
  • William Manning from Booz Allen Hamilton commented on the challenges for rural areas, saying “if you aren’t in an urban or suburban area, you’re toast,” referring to the apparent capacity challenges for rural ISPs.

At the end of the conference, Berninger went around the room and asked everyone if they were in “Club 2018” or not, and what they thought the next moves should be. I responded that I was indeed in “Club 2018,” but only if USF and ICC are reformed in such a way that rural telecom providers are able to continue investing in IP networks.

I believe that the next step in the Telecom 2018 process will be to get the engineering community involved, and continue bringing together diverse stakeholders to hash out the different perspectives. Generally, most of the attendees were in “Club 2018,” and several others also commented that it will be important to get regulatory issues like USF, ICC and net neutrality figured out before we can move forward. One 2018 skeptic argued that broadband adoption must be increased significantly before we can take away a viable means of communication. Overall, this workshop left me with a lot of things to think about regarding the future of communications, the role of rural telecom providers in an all-IP ecosystem, and how an end date for the PSTN may impact USF and ICC reform (and vise versa).

So, are you in Club 2018?