Re: cr> *BULLETIN*: FCC Sets Comment Date for Internet Phone Comments


The following notes are the rough basis for a potential comment to the
FCC on the ACTA Internet Phone Petition.

The issue: several companies and free software offerings allow users
to talk to each other in real-time over the Internet.  This is often
called a kind of long-distance telephone.  A coalition of
long-distance providers called ACTA have petitioned the FCC to
temporarily stop and then to regulate "telephone calls" made in this
manner.  The rationale stated in the petition is that conventional
long-distance carriers have to pay extra fees for interconnection to
wide-area telephone networks (fees that go toward the network's
creation and maintenance); thus it is not fair for Internet users to
forego the fees.



Viewed superficially, the use of real-time audio transmissions to
carry on bidirectional voice conversations on the Internet is simply
another way to provide telephone service.  This view is the basis for
the ACTA petition.  Our contribution here is to look more closely at
the technology of real-time audio and to draw long-term conclusions
about the effect that regulation or an injunction would have at this


Essentially, we view real-time audio on the Internet as just one
representative of the many useful applications being developed.
Attempts to single it out and regulate it could prove harmful to
technological progress in digital networking.  It would also be
technically difficult to administer.

Emerging Internet Technologies

Increasingly, digital electronic networks are being used to carry
images, audio signals, and video signals.  Once they are sampled and
represented in numerical form, audio and video become just another
form of digital data and can thus be carried over a digital network
like any other traffic.

A large number of organizations are working hard to make the Internet
more than a text-only medium.  Many people see the availability of
graphics, audio, and video as key to the broadening of digital
networks as valuable media for education and other social goals.
Voice transmission has been used for such experiments as Internet Talk
Radio (in which files of audio data can be downloaded and played
off-line) and more recent experiments in real-time radio transmission.
CU-Seeme has been available for several years to provide audio and
video links between individuals on the Internet.  While the ACTA
petition considers Internet telephone a "new technology," we recognize
it as a convergence of many existing techniques that grow naturally
from Internet applications and audio sampling.

While Internet telephone is beginning to find commercial use, most
real-time applications remain experimental because sound and image
quality remain low for the vast majority of Internet users.  If
allowed to proceed, however, these experiments can lead to
improvements in service through either physical upgrades or new
protocols.  The use of the Internet for telephone calls could then
conceivably become ubiquitous.

The Integration of Audio with Other Internet Technologies

One of the most exciting trends in Internet technology is the
combination of text, audio, and video in real-time collaborative work.
Here, all data is transmitted as a single stream and then divided into
constituent channels at the receiving end.

Collaborative multi-media applications are cited here as an
illustration of the seamlessness of digital technologies.  There is no
technical basis for distinguishing between audio and other media.  In
all the digital networking technologies currently envisioned for the
near future (such as Asynchronous Transfer Mode) transmissions are
still divided into packets, and many kinds of data can be combined and

Implications of Singling Out Real-Time Audio for Regulation

Given that audio becomes just another form of packet data on the
Internet, an attempt to halt or regulate its use leads to technical
dilemmas and unintended effects on technological progress.

1. Real-time audio transmissions on the Internet cannot be banned.

Several free products are already available, so the technology is in
the field.  Furthermore, a ban would fly in the face of the basic
principles that drive technological development: the promotion of
competition, the desire for improved technology, and the goal of
serving end-users better.

2. Metering presents technological challenges.

Internet telephone is a product that runs on individual computer
systems at the users' endpoints, so there is no service that can
measure traffic.  To determine where connections are made and how long
they last, each provider would have to install special metering
software.  This form of metering could probably be defeated by actions
on the user's side, or by the availability on non-metering free

3. Special treatment of audio data, even if it were feasible, would
place barriers in the way of technological development.

A central premise of digital network research is that all data can be
treated as fungible.  The protocols assume that all data will be
reduced to a lowest common denominator and be freely combined with
other forms of data.  The most advanced and promising technologies, as
stated earlier, mix several media.  The technical challenges of trying
to measure and price one of these data streams may render the
technologies unusable.  It is crucial, therefore, to the development
of this technological frontier that audio be treated equally and not be
subject to special regulation.

Regulation of the Internet

We do not argue that the FCC has no jurisdiction over the Internet.
This area is already an important part of the world's information
infrastructure and is likely to become a major arena for competing
offerings among telecommunications companies.  Therefore, the FCC may
well find itself issuing orders that affect use of the Internet.  The
important criterion for establishing rules is to preserve the
viability and robustness of the medium.  The ACTA petition, as we show
in this comment, cannot be granted without imposing serious burdens on
this promising area of development.

Equity in Pricing

We certainly subscribe to the principles that funding of the telephone
infrastructure must be assured, and that pricing of services should be
equitable.  But the use of the Internet for audio conversations is
still an emerging technology, and due to the many changes may take
place technically and financially, it is inadvisable to set up
regulations now.

Current quality is hampered by bandwidth that is slightly too low for
most users and unreliable delivery of packets.  If the market for
Internet telephony is encouraged to grow, these problems may be
remedied by the installation of new hardware or the use of protocols
that promise a higher quality of service.  When the market adjusts in
this manner, it may be accompanied by new pricing structures.

Future Potential

Telecommunications industries should, in our view, encourage and
improve the conditions for promising technologies that could reduce
costs or provide new functions.  Real-time audio transmission over
digital networks offers intriguing potential benefits: lower costs,
user options such as storing and filtering, and integration into
collaborative multimedia.  The ACTA position goes precisely in the
wrong direction.  Instead of furthering the potential of new
technology, it puts barriers in the way.

For the reasons stated in this comment, we recommends that the
petition be rejected and that the FCC take no action related to
Internet telephone at this time.

These notes were written by Andrew Oram, a member of CPSR and
moderator of its Cyber Rights working group, with help from the input
of Craig Johnson and Steve Miller.

 Posted by Andrew Oram  - •••@••.••• - Moderator: CYBER-RIGHTS (CPSR)
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