Regulating by layer

Back from my speech this morning. I had a great conversation with Steve Kelley about the “layer cake” problem that VoIP regulation presents. After scribbling a few things on a pad of paper, it was time to give my talk but I thought it would be a Good Thing to get the scribbles into this blog. Read on for the details…

Suppose you decided to approach regulating VoIP (or any other telecommunications thingy) from the standpoint of regulating differently depending on what layer that thingy was. Here’s a picture of the layers;

The bottom layer is the physical link between you and your provider. It could be copper wire to the phone company, coax cable to the cable company, fiber optic cable, a microwave radio link, a laser link, etc. It’s the physicall stuff that makes the connection. Very expensive to put in, very unlikely that you’re going to have these connections to more than one place. Aka a natural monopoly.

The middle layers make the connection between your physical stuff and the physical stuff at the destination. Phone switching (SS7), TCP/IP, routers, switches, all fall into this layer. It’s where ISPs and CLECs sit, and it’s much easier to have competition at this layer — witness all the ISPs and CLECs that popped up in the mid-90’s.

The top layer is the application that you actually use to get things done. An email browser, a web browser, a database, or a VoIP software/hardware package all fall in this top layer and there are virtually no barriers to competition at this layer. There are lots and lots of web pages, VoIP phone companies, email providers and so forth and the problems of monopoly are virtually non-existant. So one view would be to say — “hey, there’s no need to regulate VoIP at all, it’s just an application.”

But wait, what if we added the notion of a “service” to the mix. We might say, let’s regulate similar things in similar ways. Here’s another picture;

Now, in addition to thinking about layers, we think about the “service” that is running across those layers. Perhaps we should regulate all TV the same, all phone-calls the same, etc. If you deliver TV pictures over cable or the Internet, what’s the difference? They’re TV pictures and it’s silly to have completely different regulation for each — they’re doing the same thing. If it walks like a duck, quacks like a duck, it’s a duck. In the case of VoIP, the argument would be — “either regulate VoIP like POTS, or remove the regulation from POTS” and put them on a level playing field.

But wait… What about the technology that’s being used? Doesn’t that enter into the discussion as well? Here’s a picture;

This is a tricky thing — especially in light of the current enthusiasm for protecting “The Internet” from regulation. If you make regulatory decisions based on technology, perhaps the baby goes out with the bathwater. Depending on where I wanted the outcome to wind up, I could pick my argument to use the technology dimension to trump all the other dimensions.

There are more dimensions, but I don’t know how to draw pictures with any more dimensions than 3, so I’ll stop here. I think the point of this ramble is that the regulatory picture around VoIP can be “segmented” a lot of different ways. If I were trying to push an argument, I would put this segmentation into my bag of tricks and use it to push things into a configuration that favored my outcome.

Handy info about blogging

I'm finding myself sending the same links and email message to people over and over, so here's a blog entry that covers the waterfront. Old hat for you experienced blog type people, this entry is for us newbies.

Bloglines is a great place to start subscribing to and managing blog/RSS feeds.

This page is where I've put some basic info about what RSS feeds are all about, and is also where you can find the link you need in order to subscribe to this blog.

RSS feeds are the Rosetta Stone that unlocked blogging for me and transmogrified them into something useful/powerful. I wrote this entry describing RSS feeds for PR folks to puzzle through some of the implications.

For the technical people, Xoops is the freeware that this blog is built in. It sits on top of two other powerful pieces of freeware — MySQL a very powerful database (competes nicely with the likes of ORACLE or Microsoft SQL Server) and PHP a nifty cross-platform programming language. That mySQL/PHP plumbing environment is a bubbling hotbed of great innovative software development.

Regulatory Issues — Speech

I'm off to give a speech to the assembled regional telecommunications lawyers gang this morning — my topic is the regulatory issues in VoIP. Good thing there are folks like Jeff Pulver out there doing a great job of blogging this issue — there's an amazing amount of stuff going on in this arena with new twists every day. Read his stuff to stay up to date.

Here's the outline of my speech.

How should we classify VoIP?

– A voice service?
– A mobile service?
– A data service?

Which way should we be consistent as regulators?

– By technology?
– By service?
– By layer?

Which things do we want to break?

– Universal Service?
– Access charges?
– Long-distance rates?
– LATAs?
– The Internet?
– Numbering?
– Disability access?
– 911?

Whose ox do we want to gore?

– LECs and CLECs?
– LD Carriers?
– VoIP over Internet providers (eg. Vonage)?
– ISPs?

What is our goal?

– Promote new technology adoption and investment?
– Preserve existing investments/infrastructure?
– Assure quality and standardization?
– Level the playing field?
– Assure non-discrimination and access?
– Promote competition and lower prices?

Who does the regulating?

– International – ITU?
– National – FCC?
– State – PUC?
– City – Cable Commissions?
– Nobody?

New Groove on the way

I'm a huge fan, and long time user of, Groove — one of the “Internet aware” sequels to Lotus Notes. I use it on projects when I come across fellow-addicts although I've never been very good at evangelizing new users into the fold. This is one of those things that you have to come to at your own speed, I guess.

Anyway, the new version (3.0) is due to come out next week and looks pretty darn nifty to me. One of the big complaints that many of us have had is that it's dang slow, both launching and switching between workspaces, which really gets annoying. All the Groovies are saying that this new version fixes that, which may go a long way towards bringing more converts into the fold.

Not freeware, but a very good value. It's got some pretty nifty “always on” encryption built in and I like the way copies of the shared workspaces reside on every members' computer. That saved my bacon one time when a computer crash wiped out the work on one team-member's computer and we could get them right back up to speed by pushing the workspace over to their backup machine.

Ah lahk et…

National community-networking summit

For you history buffs; Lorenzo Milam, Bill Thomas and I organized the first national community-radio-organizer gathering back in 1975. Held in Madison, WI, we called it NARC (national alternative radio convention). I, living in Madison, was responsible for the actual logistics of the conference and overlooked a few things. Like, places for people to stay… But it didn't matter because we all just sat around and talked to each other for 72 hours straight and then headed home.

This conference — the 2004 National Summit for Community Wireless Networks looks to be the same kind of “ignition” event for the community wireless folks.

Check out the “sponsor” links if you're interested in finding out who the movers and shakers are around the country. Looks like a pretty energetic bunch. I hope they have as much fun, and get as much started, as we did way back in Madison.

Virtual teams — community folks could use this technology too

Here’s an article in CIO that talks about the improved productivity of virtual teams. They are grumpy about video conferencing, but like the “shared workspace” systems that are coming into use.

I’ve been following (and using) those systems for a while now, and think that there are some good ones (like Groove) that have finally gotten to the point of being really nifty. But I’m getting even more excited about all the open-source activity in this area. Check out this very cool matrix of open-source “content management systems” and be amazed at the capability that’s available for really cheap.

Which brings me around to Community Computing. Read on…

I’m thinking that these systems could be put to great use by organizers who are trying to move the ball forward for their causes. I’m reminded of the early days of the Internet when Jon Pratt was working on this sort of thing over at the Minnesota Council of NonProfits and how much cheaper/easier these new systems would be.

So while I’m fiddling these systems into use in the private sector, I’m also going to be looking for ways that nonprofits could take advantage of all that virtual-team stuff that the CIO piece is talking about.

Spoofing caller ID

Ooo, now this one’s interesting… Here’s a writup in The Register talking about how some clever folks have figured out how to fiddle with caller-ID strings in the VOIP world — in both directions (inbound and outbound). Here’s a link to the article.

Hardly a “harmless prank” this could have some pretty nasty implications for stalking and identity-theft reasons. Read on for a few thought-provoking quotes…


Callers with life-or-death anonymity concerns might consider spoofing just to get a little privacy. For now, Lucky says pranks among friends are the most common use that he’s seen of VoIP spoofing, but he believes that identity thieves and other swindlers could have a field day. “I’ve used it myself to activate my own credit cards, because I never give credit card companies my real number,” he says. “One simple spoof, and it’s like saying, if you have the guy’s phone number, that piece of information is more important than his mother’s maiden name and date of birth. If you have the phone number, you don’t need anything else.”

How ’bout them apples? This could cause the financial-services crowd a fair amount of heartburn. But what about the implications for people who are tangled up with a stalker? Here’s another quote:

Privacy advocates, who had reservations about Caller ID when it was introduced in the 90s, aren’t happy that it’s becoming easier to subvert. “A worse case scenario is if you have a blocked number, and you’re a victim of stalking, and you’re duped into calling a number the stalker set up that was routed through a VoIP line,” says Jordana Beebe of the San Diego-based Privacy Right’s Clearinghouse. “It could put their life in danger.”

I’m also really interested in the regulatory impacts of VOIP, and this promises to generate a lot of pain on that front as well. Once again, here’s what The Register has to say:

This arrangement relies on telephone equipment at both ends of the call being trusted: the phone switch providing you with dial tone promises not to lie about your number to other switches, and the switch on the receiving end promises not to reveal your number if you’ve asked that it be blocked. In the U.S. that trust is backed by FCC regulations that dictate precisely how telephone carriers handle CPNs, Caller ID and blocking. Most subscribers have come to take Caller ID for granted, and some financial institutions even use Caller ID to authenticate customers over the phone.

Stay tuned, this will be coming up again. Fersure…

VOIP — topic introduction

Ralph Jenson and I built us a pretty-darn-close-to-perfect copy of Vonage back a couple years ago and were within a whisker of kicking it off here in the Twin Cities. Unfortunately, Vonage came to town a year earlier than we thought they would and blew us out of the water. But I've been tracking VOIP stuff ever since.

These days the most interesting thing to me is the regulatory rasslin' that's going to be going on, so this will mostly be policy-wonk stuff. Heck, I've got to give a speech about VOIP regulatory impacts in a few weeks. That research alone should fill up several good blog entries.

Markle Foundation — longstanding heros

I had lunch with Sheldon Mains today and he reminded me of another topic area I want to cover in this blog — community technology.

This evening brought this article about the Markle Foundation my way from the Fast Company site.

The Markle folks have been supporting all kinds of community access technology stuff for ages. I ran into them back in the ’70’s when I was part of the community radio crowd. They were hip back then, and they’re hip now too. Hats off to the Markle gang, glad to see they’re still at it. Read on for a quote from the article that gives a sense of the kind of outside-the-box thinking they’re doing these days…


Just listen to Hammond wax rhapsodic on the potential of the MP3 player as a force for social change: “This basically was invented for a market of rich teenagers to download music and walk around with it,” he says, digging unsuccessfully through a sheaf of papers for his own device. “The current model costs $150 and carries an hour’s worth of music. So let’s envision a world just a year away where we’re going to have $50 devices that can store eight hours’ worth of speech. Well, poor villages can afford $50. So suppose a village bought one of these things and then went to their local NGO to download compressed speech files that provide AIDS information, agricultural information, and so on. Listeners share the player with their neighbors, and then six months later, the village takes it back and downloads a whole new set of files. You would have an affordable information-transmission system that is under the control of the users.”

Pretty nifty, eh? Check out the Markle website if you’re feeling like getting smarter about community technology.

RSS feeds for PR folks

Ok, I’ve been one of the ones who took a long time to “get” blogging, so I’m probably going to preach with the enthusiasm of the recently-converted. But it seems to me that there is a tasty middle ground between the monsto-blogs (for example the New York Times front page) and the pipsqueak-blogs (like this one) in which lots of interesting things could happen. One that comes to mind is switching the PR industry away from “pushing” out their stuff (with web pages, email or gawd-forbid fax) towards publishing RSS feeds so that journalists can “subscribe” to their press-release stream and gain all the productivity gains that would arise if reporters could “cover their beat” by watching RSS feeds rather than slogging through the daily deluge…

Nope, not a new idea by a long-shot — Mark Jones has exactly the same idea in

this piece

that ran in


last November. But it’s worth amplifying, and explains why I’m starting to “get” blogging as a useful gizmo for the mainstream business type person.

*My* revelation came while talking to the PR person at a large local outfit and asked him what his day was like. The story he told got me to thinking… He spends his day mostly rasslin’ with the logistics of getting his stuff *out* rather than actually writing. He’s held captive by Joe, The Webmaster From Hell to get the stuff out on their web site. He waits for the fax machine. He juggles a huge list of email addresses.

If our hero had an RSS-capable blog at his disposal, he could push his own content to the web page, and reporters who cover his beat (of which there are many, this is a pretty important outfit he works for) would be able to peruse his stuff the way we watch RSS feeds. You know, “boring” “I don’t care” “yawn” “OH! Now *that’s* interesting…”

I think both sides of the equation would be better off. The PR person would do more writing, the audience would do more reading and a lot of awful middle-stuff would be gone.

I also think there are a lot of projects out there for blog-builders who want to get paid for their efforts. Package this up as the answer to the PR-maven’s problem and go to town.