A layered United States Universal Service Fund for an everything-over-IP world
Telecommunications Policy
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Traditionally, specific telecommunications serviceswere essentially confined to certain types of networks;e.g., television over broadcast networks or cable andvoice service over wireline or wireless networks.Regulations were built around the underlyinginfrastructure. The regulations imposed on theseproviders were as stratified as the networks and theservices they carried. Convergence of services ontonon-traditional platforms creates a dilemma where therules no longer conform to the infrastructure. Thiscreates inconsistencies and gives rise to problems suchas: market, investment, and interconnectiondistortions, as well as universal service, accessibility(for the disabled) and public safety concerns.One of the most relevant of these services is voice,specifically voice over the internet protocols. Whileseveral authors have suggested alternative regulatorymodels to deal with these changes, these models tend toignore important aspects of market power, networkdesign and technology evolution. One proposed solutionto this problem is based on a layered model similar tothat used in the development of technicalcommunications protocols. The consistency andmodularity of such an approach may be a workablealternative to the current title-based policy. However, alayered model in and of itself is insufficient. A layeredmodel solution must reflect the reality of network designand business arrangements, and, to be viable, itrequires a transition policy to get there from theexisting policy regime. Emerging policy must addressthe diversity of existing access technologies (e.g., cablenetworks versus common carrier wireline networks), thedisparity within industry segments (e.g., ILEC vs. CLECuse of last mile) and the strong influence of presentpolicy on these various segments when implementing a transition to new policy. It is important to realize thatinterconnection will remain at the core of anycompetitive telecommunications policy. There is alwayssome physical or logical interconnection that must beresolved and this involves pricing. Without the correctincentives or obligations in place, providers will not bemotivated to interconnect.The theory behind our model is to separate policy issuesalong what we see as logical boundaries; ones thatmake sense in terms of such issues as cost, technologyand network design. The method we apply is simply toconsider the problems of the existing policy and showhow a layered model might be used to resolve them. Aswe move toward more fully converged networks, we willneed to understand how best to revise policy. A generaldirection should be to simplify the rules and to minimizeregulation where necessary. We believe that a layeredmodel could provide this simplification.In previous work, the author described the generalnotion of a layered model for telecommunicationspolicy. In this paper, we examine the application of thismodel for voice over internet protocols. We begin bydescribing the existing policy environment. Next, werationalize why a layered model makes sense in aconverged environment. We then consider thetransition into such a model and a number of associatedissues. Finally, we apply this layered model to a fewvexing policy problems. Specifically, we look at how alayered model allows us to frame the issue of Voiceover IP and the closely related issue of UniversalService in a consistent and logical manner.