What We Mean When We Say “Things Should Still Work” After the PSTN TransitionOctober 4, 2013
First, Some Background
At the start of blog posts like this it’s always a good idea to remind readers what the heck we’re talking about. In this case it’s the “PSTN” again–the “public switched telecommunications network” that voice calls usually go over (but which is not limited to voice). You know, that thing with the phone numbers.
We’re in the middle of a debate in this country about the “transitioning” of the PSTN. That means that a some technologies are being switched over to cool new technologies. Just as electronics replaced electromechanical switches, which replaced human operators, news kinds of networking technology (packet-switched) are replacing older kinds of networking technology (circuit-switched).
A lot of people have framed this as the PSTN’s “sunset,” but that’s misleading, since most people want the functional characteristics of the PSTN to stick around. 911 calls should still work, any endpoint (whether it’s a physical phone or a software application) with a phone number should be able to call any other endpoint, there should be a guaranteed level of quality, and universal service remains an ideal. The “switched” part of the network might go away as we move to Internet protocol-based technology (which may or may not involve most calls traveling over the Internet, as there are many non-Internet IP-based networks today), but that just means we should retrofit “PSTN” to stand for “Packet-Switched Telecommunications Network,” which I hope would be more successful than Kentucky Fried Chicken trying for “Kitchen Fresh Chicken” before just settling on KFC.
Avoiding “Telecom Lawyer’s Disease”
PK’s engagement with this issue has been broad. We’ve said that certain fundamental principles of the PSTN should continue to apply, regardless of the technology. The more technology-focused discussions are fun, but as long as the principles are met, shouldn’t matter from a public interest standpoint.
Similarly, we’ve tried to avoid “telecom lawyer’s disease,” where endless digressions on legal authority and minutia of administrative law replace actual policy discussions. The FCC almost certainly has the authority it needs to manage the transition successfully, but even if it doesn’t, that just means we’ll need the amend the statutes. There’s no point in getting wrapped up in issues like this when, from some of the largest telecommunications companies, there is still dispute as to whether they should be required to even interconnect with other telecommunications companies, as they do now. These issues about what the shape of the PSTN should be, post-transition, are more basic than and need to be resolved before we start discussing the exact mechanism by which the FCC or Congress can bring them into effect.
Here Is One of the Things That Needs to Work Post-Transition
One of the things that needs to still work–or maybe even work better–after the transition is caller ID. Many IP-based voice systems allow callers to easily spoof their caller ID–it’s similar to how, in the 1990s and before, it was very easy to anyone with rudimentary typing and instruction-following skills to spoof her email “from” address. While this led to many hilarious pranks, and while email is still far from a secure and un-spoofable communications medium, mail servers for the most part don’t just allow anyone to send email to anyone “from” anyone nowadays.
Reading through a recent FCC filing by Richard Shockey, though, you begin to see how the problem of caller ID spoofing is growing, and how the PSTN, thus far, is not transitioning as smoothly as one would hope. (As an side, one of my favorite facts, which Shockey mentions, is how carriers exchange important records using Excel spreadsheets of all things. I’m not saying there’s necessarily a better way, but Excel?)
As Shockey writes, spoofing “is a complex problem that will need multifaceted solutions that include both regulatory, legislative and technical solutions,” but the problems are clear. The failure thus far to adapt the network to changing technology has led to “massive violations of the Do Not Call List, robocalling, vishing, swatting, reports of serious crime and Telephony Denial of Service attacks that have devastated individuals, businesses and even Public Safety Answering Points.” (If you don’t know what “vishing” or “swatting” or any of those other things are, I suggest you look them up in your favorite search engine, and then have a nice drink of water. Jerks adapt to changing technology at a much faster pace than telephone carriers or the FCC.)
So, when we at PK say things like “This stuff has to work,” we’re not just talking about the saga of Fire Island. And we don’t think we should keep the PSTN concept around just because we love good old-fashioned telecom regulation for its own sake. Our point is that a lack of coordinated attention to important, but technical issues like caller ID spoofing shouldn’t be allowed to erode people’s trust in the concept of making a “phone call.” A lack of forethought on the issue of interconnection should not lead to “network neuropathy” where the current problems with rural call completion are magnified a thousandfold. The PSTN transition is happening, and it’s important that things don’t get screwed up. There are already hints of how things might look if they do.
About John Bergmayer
John Bergmayer is Legal Director at Public Knowledge, specializing in telecommunications, media, internet, and intellectual property issues. He advocates for the public interest before courts and policymakers, and works to make sure that all stakeholders — including ordinary citizens, artists, and technological innovators — have a say in shaping emerging digital policies.