VOICE OVER INTERNET PROTOCOL SERVICES

Approved by the IEEE-USA
Board of Directors (11 Nov. 2005)

The migration of voice communications from historically circuit-switched networks to Internet Protocol (IP) based-packet networks is accelerating. These services are often called Voice Over Internet Protocol (VoIP). The increase in the use of VoIP services is fueling debates over whether (and if so, to what extent) VoIP should be subject to the regulatory framework traditionally applied to telephone services within the United States.

IEEE-USA supports the migration to and growth of VoIP services as a key step in the evolution of the Internet and the beginning of broadly accessible Internet Protocol (IP) based services. Throughout the world, VoIP services are becoming a major application for, driver to and service of the Internet. IEEE-USA believes that VoIP presents substantial new opportunities for user-driven innovation in both hardware and software, and that such innovation will likely result in efficiency-driven reductions in the cost of ordinary voice communications and, at the same time provide consumers with a rich variety of new services and features, including video telephony and enhanced communication management features. IEEE-USA recognizes that the integration of VoIP services into the legacy Public Switched Telephone Network (PSTN) poses significant technical challenges to incumbent carriers who must manage the migration of their circuit-switched legacy networks to a packet-switched architecture. This same network migration offers new opportunities for the incumbent carriers to broaden their portfolio of services and make more efficient use of network resources.

Federal and state legislators and regulators also face substantial challenges as they seek to create conditions that will allow for an orderly and efficient migration of voice communications from a hierarchical circuit-switched network to a decentralized packet-switched “network of networks.” Legislators and regulators must make decisions on policy issues that include, but are not limited to the following:

The extent to which VoIP services should be classified for regulatory and tax purposes as a traditional common carrier telecommunications service, as an information service, or as some new type of service
Whether all providers of VoIP (e.g., incumbents as well as new entrants; network-based providers, as well as providers of “application layer” services over third-party networks) should be subject to the same degree of regulation/deregulation
How best to ensure that VoIP callers have access to emergency services (police, fire and ambulance) via the universal emergency service number 911, with all of the features that the callers have come to expect when they dial 911 from a conventional wired or wireless phone
The extent to which VoIP providers should be required to provide funding for, and be eligible to receive funding from, various universal service programs designed to ensure that basic and affordable telecommunication services are available in rural and high-cost areas and to persons with limited income
How best to ensure that VoIP callers have access to emergency services (police, fire and ambulance) via the universal emergency service number 911, with all of the features that the callers have come to expect when they dial 911 from a conventional wired or wireless phone
How best to ensure access by law enforcement agencies with the appropriate levels of legal authority to the VoIP equivalents of “call identifying information” and “call content” under the Communications Assistance for Law Enforcement Act or other appropriate legislation

Decisions on these issues are complicated by the existence of several types of VoIP, ranging from PSTN-to-PSTN through VoIP-to-PSTN to VoIP-to-VoIP or P2P (peer to peer) “calls” that never touch the PSTN. They are further complicated by the deployment of VoIP applications in a wide variety of settings, including corporate and institutional wide-area and local-area networks; in IP-based, private branch exchange gear serving a small-to-medium-sized business; and even in game consoles connected to the public Internet, which allow for one-to-one voice communications during multiplayer game sessions. Finally, decisions on such issues as emergency calling and lawful intercept are complicated by the fact that many VoIP-enabled devices and services are "nomadic."

IEEE-USA recommends that the Chair and the Commissioners of the Federal Communications Commission use all mechanisms at their disposal to gain a better understanding of the capabilities and limitations of VoIP technologies. The development of a fuller understanding of VoIP technology requires more than a request that interested parties submit written comments and reply comments, supplemented by ex-parte meetings with advocates for particular positions.

At a minimum:

The Chair should fill the long-vacant post of Chief Technologist
The Commission should ask its Technological Advisory Council to prepare a series of reports or briefings on particular aspects of the VoIP-PSTN coverage

Additionally, the Commission may consider holding a series of public hearings, possibly through the Federal-State Joint Board and Federal-State Joint Conference provisions of the Communications Act, to provide additional opportunities for parties to present and defend opposing views on various issues.

IEEE-USA members stand ready to assist the Members of Congress, congressional staff, the Federal Communications Commission and other policymakers in understanding both the enormous potential and the very real technological limits of VoIP.

This statement was developed by the IEEE-USA Committee on Communications Policy and represents the considered judgment of a group of IEEE-USA members with expertise in the subject field. IEEE-USA is an organizational unit of the Institute of Electrical and Electronics Engineers, Inc., created in 1973 to advance the public good and promote the careers and public policy interests of the more than 220,000 electrical, electronics, and computer engineers who are U.S. members of the IEEE. The positions taken by IEEE-USA do not necessarily reflect the views of IEEE or its other organizational units.

1 A nomadic VoIP device can be unplugged from a broadband connection and reconnected to any other broadband connection virtually anywhere in the world. But unless the device user registers the new location with the service provider, when the caller dials 911, emergency service personnel may be dispatched to the original location. Although various potential methods for automatic position updates exist, ranging from IP geolocation to embedding GPS chips in VoIP devices through triangulation of DTV signals, it does not appear that any of these methods can deliver automatic position updates with the degree of reliability and accuracy that emergency services personnel need.

The Institute of Electrical and Electronics Engineers, Inc.--United States of America
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Last Update: 28 Nov. 2005
Staff Contact: Deborah Rudolph