Dear Congress; A Phone Number does not a Service Make

In the last thirty years, the computing world has changed so much, that it is hard to remember the logic of roles and rules that existed and still drive the basis of law and leadership when it comes to telecommunication.  Telecom has always been a service that has made a distinction between service and use.  Telecom services were deliberately limited to enable the maximum amount of people to use the services for whatever activities they choose. 

Enabling the network to be ubiquitous was accomplished by aggregating the costs of service between local services and long distance services.  The cost of providing the connection (the local loop) was harmonized as much as possible with statewide loop costs and subsidization from the long distance market.  However with the ubiquity achieved the opportunity to support specialized services enabled for the early focus of the Internet to be about the signaling on top of the phone network and not inside it.

A primary reason why the issues of the phone network were of no concern was that IP was distance insensitive, and connecting at the closest point on the phone network through dial up or private line was pretty efficient. 

Now the technology and cost models of access are intertwined and efficiency in the network is not represented in any particular type of fee structure.  Nor is there a clear distinction between accessing a service via the phone network, or an "Internet" service that replaces the phone network.

However, certain principles of the phone service have been considered primary and certain have been considered secondary.  Primary services are your origination point for phone calls and have the responsibility for delivering calls to the 911 network. 

Until the Internet, the primary way to innovate on the phone network was to use the network for secondary services; the phone company did this themselves with solutions such as Wide Area Telephone Services [WATS] and 800 numbers. However the place where people were doing more than just talking was with computer networks, ring back services, and call centers. These connections all managed the call after the handoff from the phone network and continued routing the call for innovative services.

With the Internet's inter networking ability to support connectivity on the network without a usage charge these solutions rapidly to advantage to stay connected to provide unique synergies that added value without being a primary service. 

Today with many people using wireless as their primary service, and the ability to provide smart computing devices to the user we again stand at a point where the basis of the regulation of the past no longer matches to the realities of technology.  Today a smart phone can have an application as a result of being part of the Internet or an app store, before there was an app store many companies provided services via these secondary lines.

If you treat all phone numbers as a primary service solution, the result is that the innovation fostered by the ability to connect via the telecom network will never be offered to the telecom network.  On the Internet side the ability to innovate will not be associated with the network connectivity when accessing the Internet but only to the applications. 

Services that do not support primary line functions of origination, or are "free" services should not be driven by the same rules as primary line solutions.

Many people speak about the issues of Net Neutrality without real market drivers behind their rationale.  The principles discussed by FCC Chairman Genachowski assume a controlling factor by the access provider. 

However at the core of the discussion should be relationship of ubiquity and usage.  Service levels and performance

Viewing any service with a phone number from the perspective of telephonic service is as antiquated as the term, which was used to distinguish telephones from telegraphs.

The goal should not be on extending the regulation that tried to curtail monopolies, but to encourage the innovation, which will bring new types of services even to the plain old telephone services.

GoogleVoice is one such service as are many other innovative companies. Via GoogleVoice you can route calls you can initiate signals to originate calls to your primary service number.  It combines the web, video and phone services.

Tags: ATT, FCC, Genachowski, GoogleVoice

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