The Nation Telecommunications Cooperative Association (NTCA) recently posted a “lightning round” recap of their activities. Many rural areas are served by NTCA members. So it’s interesting to see what is on their radar. One note that caught my eye was on the IP Evolution.

Last month the NTCA posted a petition to the FCC that asks them to think about how to support and promote the transition from TDM (Time Division Multiplexing) technology to all-IP (Internet Protocol) infrastructure.

The petition uses an interesting analogy – comparing the current regulatory system to a building foundation…

The challenge facing industry and policy-makers concerns the development of a proper path by which to promote and, more importantly, sustain the already-ongoing IP evolution in a manner consistent with the core statutory objectives of protecting consumers, promoting competition, and ensuring universal services. In considering this challenge, it is useful to analogize the current regulatory construct to a foundation that is suspected of having some cracks. Within the range of ways by which to consider whether such cracks exist and how to address them, one can plot three fundamental approaches: 1) tear the foundation down; 20 examine the bricks and repair or replace then as needed; or 3) leave the foundation standing without change and hope that it holds.

The first option would effectively take a “sledgehammer” to the regulatory foundation, using (re)classification, forbearance, and/or preemption to discard, or depart almost entirely from , the statutory framework and the regulatory framework developed thereunder. It is unclear, however, whether such an experimental and sweeping “sledgehammer” approach can satisfy the statutory cornerstones of consumer protection, competition and universal services. Moreover, if one proposes that regulatory oversight stifles investment, the uncertainty of a regulatory vacuum and a lack of clear “ground rules” are likely to stifle investment even more.

On the other end of the range regulators could simply hope the foundation will hold and continue to mechanically apply every current regulation “as is” in an IP-enabled world. But such an approach would fail to assess whether the regulatory foundation is built in the right way to fulfill the core statutory objectives in an evolving environment.

This petition therefore recommends a more balanced approach of “smart regulation” that examines what has worked (or not) in protecting consumers, promoting competition, and ensuring universal service. After this review, the Commission can consider what from that framework should be kept, discarded, or modified as the IP migration continues. In other words, the Commission should maintain certainty by retaining and reasserting the clear regulatory foundation, while coordinating with state counterparts to examine each brick for potential replacement, repair, or removal…

The specifics they want are…

– Developing a specific process for thoughtful and targeted examination of current regulations in light of the statutory cornerstones of protecting consumers, promoting competition and ensuring universal service.

– Introducing new near-term economic incentives to promote the IP evolution, including policies that: (1) encourage IP interconnection by allowing carriers to recover the cost of carrying traffic on their networks; and (2) provide sufficient and predictable universal service support for broadband-capable, IP-enabled networks.

– Coordinating closely on such regulatory initiatives with state regulators to tailor solutions at the local level in order to achieve the core statutory objectives of protecting consumers, promoting competition, and ensuring universal service.

I think this is one of those policy issues that is wonky, seems only to be of interested to those steeped in the details – but will have a great impact on consumers in the short term. Eventually everyone will more to IP – it’s just the way things are going. But we’re not there yet – and we’re seeing the impact of TDM and IP combining in real world with issue such as dropped calls (which is a policy-related issue, not a technical issue).

An article from Telecom Engine (from Aug 2011) outlines the magnitude of the issue…

According to a whitepaper put out by IP networking company Sonus (Westford, Mass., U.S.A.) and HeavyReading, 80% of fixed lines worldwide still use TDM as of 2011. In the same whitepaper it states that TDM will be used on 64% of fixed lines in 2015.

The main resistance to transition to IP is the cost involved. The article in Telecom Engine predicts that it could take at least another decade before TDM is gone completely. It seems to make sense to find a way to speed up that process in such a way that doesn’t leave rural areas behind.