RE: More on Vonage service disruptions...

Those are good points. Someone last week mentioned what I thought was a
great list of priorities for an ISP:
1. Keep the network running
2. Remove those violating policies
3. Route packets
(or something along those lines)

  A 30/50/90 kbps unicast stream isn't going to affect #1. I
don't think any policies involved in #2 would cover a VoIP service
either. That should leave #3 as the default for this traffic. I can
picture a DDOS where infected Windows machines could send bogus SIP
traffic to Vonage servers; in this case temporary blocking might be
needed/justified. But until that happens, blocking SIP is just wrong.
Another thing for an ISP considering blocking VoIP is the fact that
you're cutting off people's access to 911. That alone has got to have
some tough legal ramifications. I can tell you that if my ISP started
blocking my Vonage, my next cell phone call would be my attorney...

Chuck Church
Lead Design Engineer
CCIE #8776, MCNE, MCSE
Netco Government Services - Design & Implementation Team
1210 N. Parker Rd.
Greenville, SC 29609
Home office: 864-335-9473
Cell: 703-819-3495
cchurch@netcogov.com
PGP key: http://pgp.mit.edu:11371/pks/lookup?op=get&search=0x4371A48D

Church, Chuck wrote:

Another thing for an ISP considering blocking VoIP is the fact that
you're cutting off people's access to 911. That alone has got to have
some tough legal ramifications. I can tell you that if my ISP started
blocking my Vonage, my next cell phone call would be my attorney...

Vonage is not supposed to be a Primary Line Service. IIRC, I got a big
flyer with my welcome kit that basically said this is a Communications
service, not a Telephone service, and it outlined the differences.

What is more stable where you are, your broadband connection or your
telephone line to your LEC? (if you still have one). I know in my case
at home, the phone line was much more reliable, then my cable modem. I
can count the times on 1 hand that I had been without Dial tone in the
last 3 years (And I live in a rural area), but my cable modem connection
goes out at least once a month. So if My cable modem goes out, I would
be effectively without 911 also. As my ISP @ home is not a regulated
entity, the only person I can complain to is them, or else take my
business elsewhere.

Even if the ISP in question is a LEC, normally the ISP side of the house
is unregulated. The LEC providesthe circuit, and the ISP provides the
bandwidth / services on that circuit.

If you ISP decided to block VOIP, your cell phone call should be to
their competition to order service from them, and vote with your
dollars. Or at least to your ISP to call up and complain.

Just my opinion, IANAL (I don't even play one on TV), etc...

-Patrick

Why? Do you have a binding legal agreement with your ISP that requires
them to pass all traffic? Do you really think you can make a
persuasive case that you have an implicit agreement to that effect?

(Note that I am not expressing an opinion about whether you _should_
or _might like to_ have such an agreement, just my skepticism that
you actually _do_ have such an agreement, and can enforce it)

The 911 issue is a tremendous red herring. In fact, it's more of a
red halibut, or perhaps a red whale. Vonage fought tooth-and-nail
to *not* be considered a local exchange carrier precisely *so that*
they could avoid the quality of service requirements associated with
911 service. One of their major arguments in that dispute was that
they provided a service accessible by dialing 911 that was "like"
real 911 service but that was "not actually 911 service".

As I and others noted at the time, that very much violates the
principle of least surprise, and is quite possibly more dangerous
than not providing any 911 service at all: in New York City, for
example, the number to which Vonage sends 911 calls is not equipped
to dispatch emergency services and often advises callers to "hang
up and dial 911": this _decreases_ public safety by causing people
to waste time instead of dealing with emergencies in some constructive
way.

But Vonage persisted nonethess in insisting that they should not be
held to real 911 service standards, and they prevailed, basically by
convincing a compliant federal regulatory body with little or no
understanding of the underlying technical and human-factors issues
to force the state regulators to see it Vonage's way. To turn around
now and use 911 reliability (of their service that is "like 911 but
not 911" and thus should not _have_ any reliability standards enforced
upon it) as a reason why other carriers should be enjoined from
filtering Vonage's packets is not just wrong, it's absurd.

Of course, like much of Vonage's other rhetoric, it will probably
be effective. Ultimately, Vonage will succeed in the marketplace
and, in the process of controlling its own costs, manage to wipe
away almost all of the traditional regime of regulation of service
quality, telco accountability, etc. even in realms like contact to
emergency service in which the public good is generally considered
to in fact be well served by those regulations.

We will have cheaper voice telephone service when all is said and
done but will we, eventually, be forced to turn around, after
Vonage uses cheaper costs from differential regulation to wipe out
all the old wireline carriers, to painfully reinstate a large part
of the old regulatory regime to ensure that telecom services that
we believe essential to the public good are not (or do not remain)
wiped out as well?

Thor

Patrick Muldoon wrote:

What is more stable where you are, your broadband connection or your
telephone line to your LEC? (if you still have one). I know in my case
at home, the phone line was much more reliable, then my cable modem. I
can count the times on 1 hand that I had been without Dial tone in the
last 3 years (And I live in a rural area), but my cable modem connection
goes out at least once a month.

You are starting with a faulty assumption - that you *know* when your phone service has been interrupted. Unless you have some sort of special dialtone test going 24x7x365, you have no way of knowing when your phone service was unavailable except if that unavailability coincided with a time when you tried to place a call. If it coincided with a time when someone tried to dial into you, they most likely didn't realize that their inability to reach you was due to a service interruption and probably didn't notify you about the problem if/when they were able to reach you at a later time.

Where I am (in the geographic center of Silicon Valley) we have had power interruptions significant enough to reset digital clocks at least 5 times in the past 12 months. I suspect that POTS has been similarly interrupted even if I don't have any direct evidence of those interruptions.

jc

The problem is that, as more people take up VOIP service, it cannot be
long before some of those people start dropping wireline. Examples of
possible places are apartment blocks, with DSL on the janitor's phone
line, and each apartment having VOIP service off that DSL.

When that happens, if VOIP access to 911/112 is still problematic, we
can expect standards for it to be mandated by governments - and they
WILL do it - there is nothing politicians hate more than an avoidable
fatality where the blame can be attributed to their failure to act.

Far better that "we" get this right in advance, so that nothing needs
to be made mandatory anyway.

Some of my responsibilities involve work protecting telecommunications
for deaf people, where emergency calls may have to be made by means
of text messages. Some very similar issues seem to be arising there!

When that happens, if VOIP access to 911/112 is still problematic, we
can expect standards for it to be mandated by governments - and they
WILL do it - there is nothing politicians hate more than an avoidable
fatality where the blame can be attributed to their failure to act.

So what is legislation going to do short of banning VoIP applications that
connect to the PSTN? So who's going to stand trial if fatalities occur
because the 911 operator was unreachable? The ISP for having insufficient
bandwidth, the janitor for sharing the DSL line, the phone owner for
dropping legacy PSTN service...?

Who would in their right mind rely on MSN Messenger for 911 access? Today
residential VoIP service offered by Vonage or like companies is nothing
more or less than your instant messenging gizmo. Perhaps it is more useful
but by no means more reliable.

Adi

* tls@netbsd.org (Thor Lancelot Simon) [Thu 03 Mar 2005, 23:01 CET]:

Another thing for an ISP considering blocking VoIP is the fact that
you're cutting off people's access to 911. That alone has got to have
some tough legal ramifications. I can tell you that if my ISP started
blocking my Vonage, my next cell phone call would be my attorney...

Why? Do you have a binding legal agreement with your ISP that requires
them to pass all traffic? Do you really think you can make a
persuasive case that you have an implicit agreement to that effect?

Why, yes, an agreement for Internet access. The end-to-end principle is
considered an integral part of the design (and power) of the Internet.

Kindergarten ISPs exist but I do not buy from them. And the verbiage in
the contract is that the ISP doesn't guarantee access but will do its
best to provide and keep offering such.

The 911 issue is a tremendous red herring. In fact, it's more of a
red halibut, or perhaps a red whale. Vonage fought tooth-and-nail

... and then you spend two entire pages derailing the debate towards
emergency services. Thanks!

Any provider intentionally causing deterioration of network performance
towards a competitor's service offering is engaging in anticompetitive
behaviour. This may be merely bad or legally suicidal.

  -- Niels.