Yabut On Net Neutrality

Yes, I signed the petition urging the Federal Communications Commission (FCC) to regulate the Internet as a communications service.  I favor "net neutrality" for basic reasons of fairness, to minimize conflicts of interest, and to give the public the most options for the best services.  I support the Federal Court decision that upheld the right of the FCC to regulate the Internet.  

But, I'm also interested in the migration of voice calling from the Public Switched Telephone Network (PSTN), our long-familiar circuit-switched service, to packet-based networks including the Internet. Packet voice starts at a lower quality level than users experience on the PSTN.  The industry must be careful with this migration to avoid a 'quality crash' in voice service. 

My main concern is for voice quality, expressed as Mean Opinion Score (MOS).  On a good day the PSTN delivers a MOS of up to 4.5 out of a possible 5 (face-to-face conversation).  Packet voice typically tops out at 3.5.  QoS declines rapidly if voice packet loss exceeds a few percent or one-way latency gets much above 100 ms.  Any further degradation can make understanding more difficult--not good for business or 911 calls.  

In an enthusiasm for fairness and equal access, the idea of every Internet Service Provider (ISP) treating every packet the same has tremendous appeal.  This case seems to be a common interpretation of "net neutrality."  It ensures every user has the same experience--but it imposes equality across applications.  The closer I look, the more nuanced "openness" becomes.

In an enterprise network that supports voice and data, every equipment vendor insists on router configurations that give voice packets priority over data packets.  Priority is needed to hold down latency and packet loss.  Total equality is not good for voice. 

For decades I've believed companies that provide the wired (and wireless) access services should be Common Carriers (CCs).  Remember that concept?  Used to be that many services offered to the public were regulated so that, for example, shippers of the same commodity between the same points paid the same rates (or at least off the same tariff if rates depended on volume).  The idea of a CC fell out of favor as "The Market" replaced regulation in shaping competition.  After roll-ups and mergers The Market failed to regulate much at all.  In place of fixed rates on a published tariff, today we have "surge pricing" and "revenue optimization" that sticks it to the inattentive, the unwary, and all last-minute buyers. 

Introducing voice to the Internet makes it harder to contend that every packet deserves the same treatment or "rate."  The CC regulations didn't guarantee every package a ride on the same kind of truck or the same train.  For some customers, for example those who shipped full truck loads, the delivery was faster and cheaper.  But any customer could get that service if shipping the same quantity of the same goods.

It is the customers who should get equal treatment under CC regulation.  Who then are the customers on the Internet?  It's not the packets;  they're the boxes shipped.  The true customers are the users--and their telephones and voice applications.

How's this for a Net Neutrality policy:

For example, voice connections could be assigned to low-latency virtual circuits while web browsing is handled as a best effort.  All users within a category--VoIP provider, movie streamer, on-line gamer, storage site, web site, etc.--would see the same service and performance parameters for the same price.  Defining the classes should be an industry effort, with the FCC having the final approval.  

Recognize that some users would attempt to classify all their packets to receive top priority.  ISPs will need to filter packets to prevent abuse.  The FCC may choose to penalize such efforts.  If carriers offer "private voice" networks, separate from the Internet, all users and providers should have access to those networks.  

Ensuring equal treatment of users may require separation of common carrier services from added-value services (like VoIP) into separate corporate entities.  When trucking was a CC service, trucking companies weren't also manufactures that shipped their own products on the same trucks offered in a CC service.

In particular, effective Net Neutrality regulation will ensure that carriers and ISPs who provide VoIP services cannot charge other providers more than they charge themselves or related entities.  Cloud-based providers need regulation to have any chance of competing against the incumbent carriers who own the wired and wireless access. 

Net Neutrality is a great policy.  If the PSTN disappears and voice traffic moves to the Internet, voice packets will need some priority advantage to prevent a collapse in the Quality of Service.  A class of packet service reserved for voice could be the answer.  Or should there be a separate (virtual) network for voice to replace the PSTN?