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Goldberg: How to Regulate VoIP

Now that the CRTC has been giving the task of figuring out a regulatory regime for VoIP once again, some of the leading voices in that debate the last time are speaking up once more.  In How to Regulate VoIP, Mark Goldberg points to a paper he authored a year ago titled Regulating Voice over IP, in which he argues the issues of market power, the role of the regulator, and that voice is just an application on the network.  He writes:

A proper decomposition of a voice call reveals that users are being provided with an access element over a copper loop (or more often, a hybrid copper / fibre access network) combined with a switching element, that can be considered to be the voice application element. Since the introduction of common control switching machines in the 1950’s, the voice switch has had a form of central processor with an associated user database. Modern digital switches are primarily a software system with voice services defined through various application software programs. The voice switch examines a database containing a user service profile that determines the features defined for each subscriber. The dial tone application is integrated into the switching machine operated by the local exchange carrier providing conventional phone service. The functionality of a switch has been to provide the voice services application,including the interpretation of dialed digits and proper routing based on these dialing instructions.


Indeed!  Furthermore, as open source solutions like SER, Asterisk, and SIPx make their way into the market, the fundamental voice application, switching, is becoming a commodity.  There simply is no need any longer to regulate it.

So what of emergency services — the argument put forward by carriers time and time again, and the one element that strikes fear into the public. 

Emergency service is composed of two unrelated, but important elements:

  1. Today’s telephone networks provide power to the phone.  In the event of a hydro outage, phones still work.  VoIP phones don’t do that, because they and the IP network rely on power from hydro. 
  2. 911 services rely on telephone company databases to locate the caller.  Because VoIP disassociates the physical network from the logical IP network, it is claimed that this is impossible.

Neither of these are within the purvue of the application provider.  Both are access network issues.  At best, the application provider could be expected to take location information from the access provider, and relay that to a 911 operator.  And you know what?  Those same databases that are used to provision your phone number today, know the address of your DSL line, and so on… the CRTC should mandate that access providers provide this information.

The emergency services argument is strawman advance by incumbents to maintain their position in the market.

{ 4 comments… add one }

  • Mark Goldberg May 9, 2006, 8:02 am

    Thanks for helping solicit input on this. VoIP 911 is a continuing challenge and one of the biggest issues, as I wrote on Sunday, is 'who pays'. [see: http://mhgoldberg.com/blog/2006/05/who-pays.html%5D

    Emergency service bureaus are notoriously underfunded for capital improvements… why is it that governments can't distinguish between capital and expense dollars for budgeting?

  • Alec May 9, 2006, 4:33 pm

    I don't know Mark :) But thanks for the feedback.

  • Aswath May 13, 2006, 3:23 am

    As VoIP proponents, we are falling into the trap by saying that E911 is a voice service. A more correct way to look at E911 in telephony is that it is a service that is part of telephone network access service – after all, if you get a data line or a fax line you get E911. Then, analogously E911 must be part of Internet access service and not an application. I strongly maintain that even in PSTN voice is an application!

  • Alec May 13, 2006, 1:20 pm

    Absolutely, Aswath. It's a network service, as you say.

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