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. Andy ---------------------------------------------------------------------- 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 time. Summary 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 intermingled. 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 software. 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) Cyber-Rights: http://www.cpsr.org/cpsr/nii/cyber-rights/ ftp://www.cpsr.org/cpsr/nii/cyber-rights/Library/ CyberJournal: (WWW or FTP) --> ftp://ftp.iol.ie/users/rkmoore Materials may be reposted in their _entirety_ for non-commercial use. ~=-=-=-=-=-=-=-=~=-=-=-=-=-=-=-=-=~-~=-=-=-=-=-=-=-=~=-=-=-=-=-=-=-=-=~