Special VoIP Phone Numbers: A Quick Regulatory Fix
Dr. Jerry Lucas
09/01/2004
It should come as no surprise that the FCC, in a "preliminary" but unanimous vote, moved to require CALEA compliance for VoIP providers. "Unanimous," because the commissioners can't afford to be soft on national security issues during this election year. "Preliminary," because Chairman Michael K. Powell has an infatuation with VoIP, and the other commissioners don't want to make it appear as though he is not dealing with reality, which is that VoIP is a telecommunications technology that delivers telecom services.
In its notice of proposed rulemaking, the commission has requested comments on how VoIP service providers can deal with CALEA, in terms of issues such as feasibility of trusted third parties, standards for lawful interception and so on. But CALEA is only one issue; taxation, E-911, security and a host of others still need to be addressed. (See July 2004 Editorial.)
Taking Stock of VoIP
Before getting into quick regulatory fixes, where does VoIP stand today? First, the only reason for VoIP regulatory attention in the near term is that it's the only wireline technology that enables local competition.
In theory, consumers can get DSL from their ILECs and local service from AT&T, a CLEC, Vonage or others. In practice, however, many ILECs don't offer DSL unless you also subscribe to their local service.
Cable companies offering Internet access via cable modems don't have this problem and, with their VoIP service, can compete one-on-one against the ILECs. Alternatively, a consumer with Internet access can go with a VoIP-over-broadband service provider.
Note: the current vehicle for local service competition, utilizing ILEC UNE-P or local resale, will no longer be an economically viable option because ILEC rates will skyrocket after the November election. VoIP is the only competitive game in town for non-facilities based CLECs and IXCs.
So, what's the problem? In the long run, nothing. The residential consumer will have three sure options for local service: an ILEC, a cable company, and a wireless provider. However, in the short term, the regulators have to create opportunities for today's IXCs, CLECs and VoIP-over-broadband providers, or admit to the fact that the Telecom Act of 1996 was a total failure.
But what about all of these vibrant new VoIP services that Chairman Powell and VoIP upstarts keep talking about? Today, these services barely exist (from a service provider perspective), and unless the industry moves to create a carrier-grade, multi-carrier operated VoIP network, these new services will remain nascent.
And what about those lower local costs that regulators are talking about and consumers are seeing? The only reason prices are low is that access charges, the Universal Service Fund (USF), E-911 provisioning and CALEA aren't being addressed. Furthermore, the consumer is paying for access, not the VoIP provider, and the service is "best-effort" (meaning poor).
If It Ain't Broke, Don't Fix It
At this point, the VoIP zealots say that you have to look beyond voice services and see VoIP as a totally new way of communicating: integrated voice and data, new addressing (IP addresses instead of phone numbers), new CPE or devices, and so on.
OK, regulators should consider these visionary points—but in the process they shouldn't break what's already working. Consider that by this day's end, 10 million wireline and wireless phones and/or devices will be purchased around the world. None of these devices create or receive an IP packet carrying voice directly into the phone. When will you see the 10 millionth VoIP phone reach the hand of a residential consumer? The answer: Years.
What about the business market for VoIP? Not relevant here, because business VoIP phones are not causing regulatory problems. There are solutions in place for E-911, CALEA doesn't apply to CPE, and business customers pay access charges through their carriers. The regulatory issues surround residential consumers, period.
Phone Numbers!
So what can VoIP break if the regulators let it? The strength of our phone numbering systems, if we let it. Here's why: Location.
Until VoIP over broadband came along, the beauty of our numbering system was that phone numbers were based geographically. (OK, wireless is changing this a bit.) When you get a phone number from the ILEC, people know where you live based on your area code. With VoIP, it can appear as though you live in New York City, or you can get a number that lets your relatives reach you for free because it processes as a local call. VoIP providers are helping you carry out deception. Not that this is morally wrong.
But geographically based phone numbers are good. When you dial 911, the police or ambulance can find you. As for taxes, service providers know what to levy based on your location. With VoIP, due to the loss of location information, E-911, CALEA and taxation are problematic.
And a final point: When you want to call someone with your wireline or cell phone, you simply enter a phone number. Sorry, but you can't enter an IP address into these telephony relics. As for connectivity, isn't it great that you can have service between the 1.3 billion wireless and 1 billion-plus wireline phones?
What About the 'One Number' Theory?
VoIP zealots claim that with VoIP you can have one number for all of your phones—wireless, wireline and business. The service would be integrated seamlessly with voice mail, e-mail, PDAs and Wi-Fi devices, and it would use one authentication code for access. Ironically, these are the same folks who take issue with government actions regarding privacy, such as CALEA and the Patriot Act.
What's wrong with having one number that makes it easier to be reached anywhere, anytime, on any device that you happen to have with you? Based on a survey sample of one (me), I don't want to make it any easier to be reached. Today, vacation time is a meaningless term when everyone knows that you can check your e-mail at practically every hotel in the world. Even campgrounds have Wi-Fi hot spot cyber cafes. Soon, with WiMAX, you will be reachable even when you are deep in the woods.
The Quick Fix: Special VoIP Phone Numbers
Back to numbers. Sticking with our rigid numbering policy, the FCC can fix many of the problems VoIP is creating.
Here's how: Assign a special block of telephone numbers to VoIP service providers, say 500-NXX-XXXX for starters. With a VoIP phone number, everyone will know when they are calling someone who has VoIP phone service, or when someone who has VoIP service is calling you. Here are the benefits.
1. Access charges: If you are a VoIP customer and place a call via your VoIP service provider, the terminating carrier can charge your provider interstate access charges. Note: regulators have already ruled that Internet traffic is automatically considered interstate. If you receive a call, your carrier can collect reciprocal compensation.
2. E-911: If you call 911 from a VoIP phone, the PSAP will recognize that and be able to blast a short recording telling you "please be prepared to give your location." It's better than the PSAP operator interrupting to explore the issue.
3. CALEA: This would simplify lawful interception in two ways. First, if law enforcement agents know the target is using or calling a VoIP phone, they know they are dealing with IP traffic. Second, it gives criminals no incentive to use a VoIP phone as a way to elude surveillance, because they know the lines can be tapped just as with a circuit-switched connection.
4. QoS: If you know this call is VoIP transport, carriers have a better chance of improving quality by not routing the call to another VoIP carrier via a PSTN-type gateway connection.
5. VoIP devices: It's true that not all VoIP traffic will come from phones. Various gaming and other devices will also generate traffic. By assigning a number associated with a type of device, the class of VoIP service can be assigned accordingly. With a higher grade of service, service providers could charge more. Rating can be based on the calling or called party's type of service, plus billing can be performed via legacy voice billing systems.
6. Differentiated services: The service provider could differentiate VoIP packets delivering information from those delivering telecom services.
7. Taxation: Lastly, a service provider can gather accurate accounting data for taxation purposes. Is this session supporting a voice call where taxes apply, or is this a session supporting an interactive game that requires voice channel support, where taxes may not apply? The phone number can be used to differentiate such services.
Of course, today's VoIP service providers will likely reject this concept of special phone numbers. They will most likely argue that they wouldn't want their customers being labeled as penny pinchers when others see a 500 number appear on the caller ID. On this, they may have a point.
If you are charged with building or supporting a carrier-grade VoIP network and must deal with real-world issues associated with transitioning to an all-VoIP PSTN, OSS/BSSs for new IP-based services or VoIP taxation, plan to attend TeleStrategies' VoIP World on November 10–12, 2004, in Washington D.C. For an updated conference agenda or to register, go to www.telestrategies.com.
Email this article
Add a comment
Printer version
Order reprints
RSS Feed
Bookmark article