Rural Phone Calls and “Network Neuropathy”

April 2, 2013

made a passing reference to the rural call completion problem in a post about 2 months ago. I’ve now written a much longer
piece explaining the problem of rural call completion, and the nature of the
problem, for the Daily Yonder. You can find the article, and the
very nice illustrations they added, over here.

Public Knowledge colleagues and I have emphasized both network reliability and service to all Americans as part of our “Five Fundamentals Framework” to guide the transition of the
telephone network from traditional technology to an internet-based one.

The rural call completion problem demonstrates precisely why we
need a framework to guide us, rather than jumping right away into the
“deregulation v. regulation” fight so many people want to have instead of focusing on the
real issues.

is also an example of a phenomenon I call “network neuropathy,” how problems in networks may first manifest themselves
in failures of service around the extremities.

An Unexpected Bug In The Transition

one anticipated the rural call completion problem. It didn’t happen because
anyone misused their market power or tried to do anything bad. It happened
because IP-based voice service gives companies a way to save money by selecting
from a choice of possible routes. For the vast majority of IP-based services,
this kind of flexibility works fine. But for services that are not tolerant of
latency, like voice, problems come up unexpectedly.

because the problem — at least initially — impacts a relatively small number
of calls as measured against the overall number of calls completed every day,
it takes a long time for the problem to get noticed, properly diagnosed, and
hopefully corrected. During that time, the problem keeps getting worse.

We Need To Get The Framework Right

is only the first of many hiccups that will come up as we convert something as
enormous and complicated as the phone system to an all-IP system. Yes, things
have worked very reliably until now, because everyone operated in an
environment where everyone understood the rules (both explicit from agencies
and the unwritten rules of conduct that always emerge in a long-standing stable
system), knew what was expected of them, what they could get away with, and
what not to try. As the old way of doing things falls away, everyone is groping
to find the new way of doing things. That process of discovery – for all of its
positives – also means that you get new and unexpected problems that the market
does not work out, like rural call completion.

that happens, we need the FCC (and the states) to step in and diagnose the
problem and determine what (if anything) needs to be done. Because, as the
rural call completion problem illustrates, “the market” isn’t automatically going
to work everything out. We need someone who can step in when the market doesn’t
work, and we need a framework based on values to guide the analysis and

could approach rural call completion in two ways. We could say: “This impacts a
relatively small number of calls in a system that handles millions of phone
calls every hour. It impacts a tiny fraction of the population, and a minute
number of actual calls. How can that possibly justify imposing expensive and
intrusive reporting requirements on the market as a whole – especially when no
one has deliberately done anything wrong?”

we could say: “It is a foundational principle that we keep the telephone system
functioning reliably for all Americans. That means that when we have a systemic
problem that is making the phone system behave unreliably for a portion of the
population, we treat that as a Big Deal and we take it seriously. We look into
it, and if necessary we do something about it to make sure that calls get reliably

tells you which way to respond is whether you actually have a framework and a
set of principles and what they say. If you don’t have any framework at all,
you have no way to judge which answer is the right answer. If the focus is just
“regulate or deregulate” without any guidelines for what we care about, what
needs we’re trying to address, or what problems we want to avoid, then you end
up with no one with the ability or authority to diagnose the problem or
prescribe the right solution.

For the Future: Network Neuropathy

medical science, there is a condition called “neuropathy.” Problems in the
central nervous system manifest themselves initially as a loss of sensation in
the extremities. People with Parkinson’s or Hansen’s or diabetes lose sensation
in their hands and feet, or constantly get the “pins and needles” sensation of
the hands and feet. Peripheral neuropathy can lead people to injure their
extremities without realizing it, and can also be the first warning sign of a
deeper problem that, if left unattended, will work its way into the central
nervous system not just the periphery.

call completion is an example of what I like to call “network neuropathy.” It
is a loss of functionality at the edges, an unraveling at the extremities of
the network. It is also a warning sign, that no matter what the benefits of the
IP transition, it can also produce unanticipated problems.

glad the FCC is acting on the rural call completion problem. We need to have
the tools to deal with these problems as they emerge. We need to have an FCC
(and state regulators) with a set of guiding principles that tells how to
evaluate these issues, and has the authority to address them as they emerge. If
we focus on our fundamental framework, on getting the core values and goals,
then we will be able to do that.

About Harold Feld

Harold Feld is Public Knowledge’s Senior Vice President and author of “The Case for the Digital Platform Act,” (Public Knowledge & Roosevelt Institute 2019) a guide on what government can do to preserve competition and empower individual users in the huge swath of our economy now referred to as “Big Tech.” Former FCC Chairman Tom Wheeler described this book as, “[...] a tour de force of the issues raised by the digital economy and internet capitalism.” For more than 20 years, Feld has practiced law at the intersection of technology, broadband, and media policy in both the private sector and in the public interest community. Feld has an undergraduate degree from Princeton University, a law degree from Boston University, and clerked for the D.C. Circuit Court of Appeals. Feld also writes “Tales of the Sausage Factory,” a progressive blog on media and telecom policy. In 2007, Illinois Senator Dick Durbin praised him and his blog for “[doing] a lot of great work helping people understand how FCC decisions affect people and communities on the ground.”