Enterprise Mobile Security


Archive for the ‘FCC’ Category

The Post PSTN Telco Cloud

Thursday, December 1st, 2011

I will be moderating a panel on this topic at ITExpo East 2012 in Miami at 3:00pm on Thursday, February 2nd.

The panelists are Brian Donaghy of Appcore, LLC, Jan Lindén of Google, Hugh Goldstein of Voxbone and Danielle Morrill of Twilio.

The pitch for the panel is:

The FCC has proposed a date of 2018 to sunset the Public Service Telephone Network (PSTN) and move the nation to an all IP network for voice services. This session will explore the emerging trends in the Telco Cloud with case studies. Learn how traditional telephone companies are adapting to compete, and new opportunities for service providers, including leveraging cloud computing and Infrastructure as a Service (IaaS) systems that are being deployed with scalable commodity hardware to deliver voice and video services including IVR, IVVR, conferencing plus Video on Demand and local CDNs.

In related news, a group of industry experts is collaborating on a plan for this transition. The draft can be found here. I volunteered as the editor for one of the chapters, so the current outline roughs out some of my opinions on this topic. This is a collaborative project, so please contact me if you can help to write it.

FCC to address White Spaces at September 23rd Meeting

Monday, September 13th, 2010

The agenda for the September 23rd FCC Commission Meeting lists:

TV White Spaces Second MO&O: A Second Memorandum Opinion and Order that will create opportunities for investment and innovation in advanced Wi-Fi technologies and a variety of broadband services by finalizing provisions for unlicensed wireless devices to operate in unused parts of TV spectrum.

Early discussion of White Spaces proposed that client devices would be responsible for finding vacant spectrum to use. This “spectrum sensing” or “detect and avoid” technology was sufficiently controversial that a consensus grew to supplement it with a geolocation database, where the client devices determine their location using GPS or other technologies, then consult a coverage database showing which frequencies are available at that location.

Among the Internet companies this consensus now appears to have evolved to eliminate the spectrum-sensing requirement for geolocation-enabled devices.

The Register says that this is because spectrum sensing doesn’t work.

The Associated Press predicts that the Order will go along with the Internet companies, and ditch the spectrum sensing requirement.

Some of the technology companies behind the white spaces are fighting a rearguard action, saying there are good reasons to retain spectrum sensing as an alternative to geolocation. The broadcasting industry (represented by the NAB and MSTV) want to require both. It will be interesting to see if the FCC leaves any spectrum sensing provisions in the Order.

Net Neutrality heating up

Wednesday, August 4th, 2010

I got an email from Credo this morning asking me to call Julius Genachowski to ask him to stand firm on net neutrality.

The nice man who answered told me that the best way to make my voice heard on this issue is to file a comment at the FCC website, referencing proceeding number 09-191.

So that my comment would be a little less ignorant, I carefully read an article on the Huffington Post by Marvin Ammori before filing it.

My opinion on this is that ISPs deserve to be fairly compensated for their service, but that they should not be permitted to double-charge for a consumer’s Internet access. If some service like video on demand requires prioritization or some other differential treatment, the ISP should only be allowed to charge the consumer for this, not the content provider. In other words, every bit traversing the subscriber’s access link should be treated equally by the ISP unless the consumer requests otherwise, and the ISP should not be permitted to take payments from third parties like content providers to preempt other traffic. If such discrimination is allowed, the ISP will be motivated to keep last-mile bandwidth scarce.

Internet access in the US is effectively a duopoly (cable or DSL) in each neighborhood. This absence of competition has caused the US to become a global laggard in consumer Internet bandwidth. With weak competition and ineffective regulation, a rational ISP will forego the expense of network upgrades.

ISPs like AT&T view the Internet as a collection of pipes connecting content providers to content consumers. This is the thinking behind Ed Whitacre’s famous comment, “to expect to use these pipes for free is nuts!” Ed was thinking that Google, or Yahoo or Vonage are using his pipes to his subscribers for free. The “Internet community” on the other hand views the Internet as a collection of pipes connecting people to people. From this other point of view, the consumer pays AT&T for access to the Internet, and Google, Yahoo and Vonage each pay their respective ISPs for access to the Internet. Nobody is getting anything for free. It makes no more sense for Google to pay AT&T for a subscriber’s Internet access than it would for an AT&T subscriber to pay Google’s connectivity providers for Google’s Internet access.

Test your broadband connection at the FCC

Friday, March 12th, 2010

The FCC has launched a broadband speed and quality test presumably to gather information about the real state of broadband in the US. This is a great initiative and I encourage you to go and run the test.

I tried it myself, and it wouldn’t let me take the test because I put in an English zip code, because that is where I happen to be this week. So I put in my Dallas zip code instead and it ran the test. I hope that there is some check in there that compares the zip code to the geographical location of my IP address, and discards the ones that don’t match, or the results will presumably be worthless.

[Update:]Lauren Weinstein mentions this issue, as well as several others…

Network Neutrality – FCC issues NPRM

Thursday, October 22nd, 2009

I wrote earlier about FCC chairman Julius Genachowski’s plans for regulations aimed at network neutrality. The FCC today came through with a Notice of Proposed Rule Making. Here are the relevant documents from the FCC website:

Summary Presentation: Acrobat
NPRM: Word | Acrobat
News Release: Word | Acrobat
Genachowski Statement: Word | Acrobat
Copps Statement: Word | Acrobat
McDowell Statement: Word | Acrobat
Clyburn Statement: Word | Acrobat
Baker Statement: Word | Acrobat

The NPRM itself is a hefty document, 107 pages long; if you just want the bottom line, the Summary Presentation is short and a little more readable than the press release. The comment period closes in mid-January, and the FCC will respond to the comments in March. I hesitate to guess when the rules will actually be released – this is hugely controversial: 40,000 comments filed to date. Here is a link to a pro-neutrality advocate. Here is a link to a pro-competition advocate. I believe that the FCC is doing a necessary thing here, and that the proposals properly address the legitimate concerns of the ISPs.

Here is the story from Reuters, and from AP.

AT&T to open wireless data channel to VoIP

Wednesday, October 7th, 2009

In an earlier post, I discussed a comment AT&T made contemplating allowing VoIP on the cellular data channel. Today AT&T wrote a letter to the FCC saying that they have decided to go ahead with it.

This will make international calls much cheaper for people who are willing to put up with the latency issues of the data channel.

Femtocell pricing chutzpah

Tuesday, September 22nd, 2009

It’s like buying an airplane ticket then getting charged extra to get on the plane.

The cellular companies want you to buy cellular service then pay extra to get signal coverage. Gizmodo has a coolly reasoned analysis.

AT&T Wireless is doing the standard telco thing here, conflating pricing for different services. It is sweetening the monthly charge option for femtocells by offering unlimited calling. A more honest pricing scheme would be to provide femtocells free to anybody who has coverage problem, and to offer the femtocell/unlimited calling option as a separate product. Come to think of it, this is probably how AT&T really plans for it to work: if a customer calls to cancel service because of poor coverage, I expect AT&T will offer a free femtocell as a retention incentive.

It is ironic that this issue is coming up at the same time as the wireless carriers are up in arms about the FCC’s new network neutrality initiative. Now that smartphones all have Wi-Fi, if the handsets were truly open we could use our home Wi-Fi signal to get data and voice services from alternative providers when we were at home. No need for femtocells. (T-Mobile@Home is a closed-network version of this.)

Presumably something like this is on the roadmap for Google Voice, which is one of the scenarios that causes the MNOs to fight network neutrality tooth and nail.

FCC to issue Net Neutrality rules

Monday, September 21st, 2009

In a speech to the Brookings Institution today, FCC Chairman Julius Genachowski announced that the FCC is initiating a public process to formulate net neutrality rules for broadband network operators based on six principles:

  1. Open access to Content
  2. Open access to Applications
  3. Open access to Services
  4. Freedom for users to attach devices to the network
  5. Non-discrimination for content and applications
  6. Transparency of network management practices

The first four of these principles were initially articulated by former FCC Chairman Michael Powell in 2004 as the “Four Freedoms.” Numbers 5 and 6 are new. The forthcoming rules will apply these six principles to all broadband access technologies, including wireless.

Genachowski made the case that Internet openness is essential and that it is threatened. He acknowledged that network providers need to manage their networks, and said that they can control spam and help to maintain intellectual property integrity without compromising these principles.

The threats to Internet openness come from reduced competition among ISPs and conflicts of interest within the ISPs, because they are also trying to be content providers.

Genachowski rightly sees these threats as serious:

This is not about protecting the internet against imaginary dangers. We’re seeing the breaks and cracks emerge, and they threaten to change the Internet’s fundamental architecture of openness. This would shrink opportunities for innovators, content creators and small businesses around the country, and limit the full and free expression the internet promises. This is about preserving and maintaining something profoundly successful and ensuring that it’s not distorted or undermined.

These rules will be very tough to enforce. The fundamental structure of the business works against them. A more effective approach may be to break up the ISPs into multiple independent companies, for example: Internet access operations, wide area network operations, and service/content/application operations. The neutrality problem is in the access networks – the WANs and the services are healthier. With only the telcos (DSL and fiber) and the MSOs (cable) there is not enough competition for a free market to develop. This is why Intel pushed so hard for WiMAX as a third mode of broadband access, though it hasn’t panned out that way. It is also why municipal dark fiber makes sense, following the model of roads, water and sewers.

Apple’s App-roval process

Friday, August 28th, 2009

I wrote earlier about AT&T’s responses to FCC’s questions concerning the iPhone App Store and Google Voice.

Now Apple has posted its responses to the same questions, which are basically the same as AT&T’s. Among the differences are that Apple’s responses contain some hard numbers on its controversial App Store approval process:

  • 80% of applications are approved as originally submitted.
  • 95% of applications are approved within 14 days of submission.
  • 65,000 applications have been approved.
  • 200,000 submissions and re-submissions have been made.
  • 8,500 submissions are coming in each week.
  • Each submission is reviewed by two reviewers.
  • There are 40 reviewers.

These numbers don’t really add up. So what Apple probably means is that 95% of the applications that have been approved were approved within 14 days of their final submission. Even so, each reviewer must look at an average of 425 submissions per week (8,500*2/40), which is 10 per hour per reviewer – an average of 12 minutes of reviewer time per submission, which doesn’t seem to justify the terms “comprehensive” and “rigorous” used in Apple’s description of the process:

Apple developed a comprehensive review process that looks at every iPhone application that is submitted to Apple. Applications and marketing text are submitted through a web interface. Submitted applications undergo a rigorous review process that tests for vulnerabilities such as software bugs, instability on the iPhone platform, and the use of unauthorized protocols. Applications are also reviewed to try to prevent privacy issues, safeguard children from exposure to inappropriate content, and avoid applications that degrade the core experience of the iPhone. There are more than 40 full-time trained reviewers, and at least two different reviewers study each application so that the review process is applied uniformly. Apple also established an App Store executive review board that determines procedures and sets policy for the review process, as well as reviews applications that are escalated to the board because they raise new or complex issues. The review board meets weekly and is comprised of senior management with responsibilities for the App Store. 95% of applications are approved within 14 days of being submitted.

Of course much of this might be automated, which would explain both the superhuman productivity of the reviewers and the alleged mindlessness of the decision-making.

AT&T, Apple and VoIP on the iPhone

Wednesday, August 26th, 2009

The phone OEMs are customer-driven, and I mean that in a bad way. They view service providers rather than consumers as their customers, and therefore have historically tended to be relatively uninterested in ease of use or performance, concentrating on packing in long checklists of features, many of which went unused by baffled consumers. Nokia seemed to have factions that were more user-oriented, but it took the chutzpah of Steve Jobs to really change the game.

A recent FCC inquiry has provoked a fascinating letter from AT&T on the background of the iPhone and AT&T’s relationship with Apple, including Voice over IP on the iPhone. On the topic of VoIP, the letter says that AT&T bound Apple to not create a VoIP capability for the iPhone, but Apple did not commit to prevent third parties from doing so. AT&T says that it never had any objection to iPhone VoIP applications that run over Wi-Fi, and that it is currently reconsidering its opposition to VoIP applications that run over the 3G data connection. Since the argument that AT&T presents in the letter in favor of restrictions on VoIP is weak, such a reconsideration seems in order.

The argument goes as follows: the explosion of the mobile Internet led by the iPhone was catalyzed by cheap iPhones. iPhones are cheap because of massive subsidies. The subsidies are paid for by the voice services. Therefore, AT&T is justified in protecting its voice service revenues because the subsidies they allow had such a great result: the flourishing of the mobile Internet. The reason this argument is weak is that voice service revenues are not the only way to recoup subsidies. AT&T has discovered that it can charge for the mobile Internet directly, and recoup its subsidies that way. It will not sell a subsidized iPhone without an unlimited data plan, and it increased the price of that mandatory plan by 50% last year. Even with this price increase iPhone sales continued to burgeon. In other words, AT&T may be able to recoup lost voice revenues by charging more for its data services.

This is exactly what the “dumb pipes” crowd has been advocating for over a decade now: connectivity providers should charge a realistic price for connectivity, and not try to subsidize it with unrealistic charges for other services.