Subject: The US Federal Communications Commission just sent the IETF RAI/SIP community an early Christmas present...

From: "Richard Shockey" <[email-masked]>
Date: Wed, 2 Nov 2011 19:06:59 -0400

Folks it was suggested that I resend this message from the RAI list to the
Full Dispatch list but what the heck ...  the IETF community needs to see
this. 

What you see here is a very significant policy direction from the US Federal
Communications Commission to the IETF/SIP/RAI community.

Mandatory IP interconnection between carriers for E.164 named Voice. In
addition there are clauses that mandate non modification of the calling
parties E.164 number in the headers. 

This should come as no surprise to anyone.  Our international carrier
partners at  i3Forum.org have been preaching this for some time. 

>From the FCC executive summary of the Report and Order.   

26. IP-to-IP Interconnection. We recognize the importance of interconnection
to

competition and the associated consumer benefits. We anticipate that the
reforms we adopt will

further promote the deployment and use of IP networks, and seek comment in
the accompanying

FNPRM regarding the policy framework for IP-to-IP interconnection. We also
make clear that

even while our FNPRM is pending, we expect all carriers to negotiate in good
faith in response to

requests for IP-to-IP interconnection for the exchange of voice traffic.

http://transition.fcc.gov/Daily_Releases/Daily_Business/2011/db1027/DOC-3106
92A1.pdf

http://www.snrdenton.com/news__insights/alerts/2011-10-28_overhaul.aspx

http://www.dwt.com/LearningCenter/Advisories?find=441777

I wish to make it clear that I'm personally willing to privately discuss
with the technical community how we can transition our industry to the all
SIP network. 

If you want to speculate on how you translate a E.164 number to a point of
interconnection ..you can,  but RFC 6116 is not a bad starting point though
Global SPID identifiers would work.  ( I gladly gave up my blue dot
recently) 

We won! 

Richard Shockey
Shockey Consulting
Chairman of the Board of Directors SIP Forum
PSTN Mobile: +1 703.593.2683
<mailto:richard(at)shockey.us>
skype-linkedin-facebook: rshockey101
http//www.sipforum.org

---

From: "George Willingmyre" <[email-masked]>
Date: Wed, 2 Nov 2011 23:00:58 -0400

Thanks for sharing this important development Richard.

I do not know what  is the meaning of the sentence, 

"we expect all carriers to negotiate in good faith in response to requests for IP-to-IP interconnection for the exchange of voice traffic."

Does anyone have insight?

George T. Willingmyre, P.E.
President, GTW Associates
Spencerville, MD USA 20868
301.421.4138
www.gtwassociates.com
  ----- Original Message ----- 
  From: Richard Shockey 
  To: 'IETF-Discussion list' 
  Sent: Wednesday, November 02, 2011 7:06 PM
  Subject: The US Federal Communications Commission just sent the IETF RAI/SIPcommunity an early Christmas present...

  Folks it was suggested that I resend this message from the RAI list to the Full Dispatch list but what the heck ...  the IETF community needs to see this. 

  What you see here is a very significant policy direction from the US Federal Communications Commission to the IETF/SIP/RAI community.

  Mandatory IP interconnection between carriers for E.164 named Voice. In addition there are clauses that mandate non modification of the calling parties E.164 number in the headers. 

  This should come as no surprise to anyone.  Our international carrier partners at  i3Forum.org have been preaching this for some time. 

  26. IP-to-IP Interconnection. We recognize the importance of interconnection to

  competition and the associated consumer benefits. We anticipate that the reforms we adopt will

  further promote the deployment and use of IP networks, and seek comment in the accompanying

  FNPRM regarding the policy framework for IP-to-IP interconnection. We also make clear that

  even while our FNPRM is pending, we expect all carriers to negotiate in good faith in response to

   

  http://transition.fcc.gov/Daily_Releases/Daily_Business/2011/db1027/DOC-310692A1.pdf

   

   

  I wish to make it clear that I'm personally willing to privately discuss with the technical community how we can transition our industry to the all SIP network. 

  If you want to speculate on how you translate a E.164 number to a point of interconnection ..you can,  but RFC 6116 is not a bad starting point though Global SPID identifiers would work.  ( I gladly gave up my blue dot recently) 

  We won! 

  Richard Shockey
  Shockey Consulting

------------------------------------------------------------------------------

  _______________________________________________
  Ietf mailing list
  [email-masked]
  https://www.ietf.org/mailman/listinfo/ietf

---

From: "Richard Shockey" <[email-masked]>
Date: Thu, 3 Nov 2011 19:15:44 -0400

I read it  "If you don't play nice .. we're going to make you."  You are
going to eat your Broccoli and like it and no whining ..

From: George Willingmyre [mailto:[email-masked]] 
Sent: Wednesday, November 02, 2011 11:01 PM
To: Richard Shockey; 'IETF-Discussion list'
Subject: Re: The US Federal Communications Commission just sent the IETF
RAI/SIPcommunity an early Christmas present...

"we expect all carriers to negotiate in good faith in response to requests
for IP-to-IP interconnection for the exchange of voice traffic."

----- Original Message ----- 

From: Richard Shockey <mailto:[email-masked]>  

To: 'IETF-Discussion list' <mailto:[email-masked]>  

Subject: The US Federal Communications Commission just sent the IETF
RAI/SIPcommunity an early Christmas present...

 

 

 

 

We won! 

Richard Shockey
Shockey Consulting

  _____

---

From: John Leslie <[email-masked]>
Date: Thu, 3 Nov 2011 20:29:25 -0400

> going to eat your Broccoli and like it and no whining ..

   Hopefully someone better informed than I will respond, but I have
dealt in FCC-speak... :^(

   IMHO, they're talking "obligation to interconnect" between "carriers"
as required by actual law.

   "interconnect" in FCC-speak means exchange voice traffic at a
"feasible" point. "Carriers" means a regulated voice provider.

   Thus, they mean to "expect" these regulated entities to negotiate
a point of interconnection where they speak IP instead of e.g. SONET.

   And, yes, they will (eventually) force them to interconnect (using
IP) whether or not the "negotiations" succeed.

   Speaking only for myself, I don't read it to impose anything except
on regulated "carriers", and they're opening up themselves to forcing
a particular mechanism and point of connection when negotiation fails.
This, of course, creates an opportunity to educate FCC folks on the
actual technical issues of voice interchange at IP level...

--
John Leslie <[email-masked]>

---

From: "Richard Shockey" <[email-masked]>
Date: Thu, 3 Nov 2011 22:14:11 -0400

IMHO, they're talking "obligation to interconnect" between "carriers"
as required by actual law.
[RS> ] In FCC terms this is Section 251 of the US Communications Act which
"the call must go through" mandatory interconnection.

[RS> ] Yea now we need to find out what is "feasible" IP interconnection.
Welcome to DC! 

[RS> ] SIP-I IMHO but that has yet to be determined and will be the subject
of lots of proceedings. 

[RS> ] E.164 named traffic is the clear focus. The FCC Pulver order for OTT
voice seems to be excluded. We'll see when the final Order is published but
it's pretty clear that this is not just a US issue but will ultimately
resonate in Canada and EC as well.

[RS> ] I'm happy to point out how you all can file ex parte statements to
the Commission. I'm sure they would be delighted to hear from the technical
community. 

http://www.fcc.gov/topic/ex-parte

When the final Order is released ..have a ball. Its easy its fun ..

---

From: "Michel Py" <[email-masked]>
Date: Thu, 3 Nov 2011 19:53:38 -0700

> Richard Shockey wrote:
> IMHO, they're talking "obligation to interconnect" between
> "carriers" as required by actual law.

Please forgive a probably naive question;

Does this mean that a "carrier" that recently jumped in the voice market
(it could be either an ISP now providing VOIP to their customers along
with a data bundle that -or- a VOIP-specialized carrier that leverages
the IP bandwidth provided to the customer by another ISP) now has some
leverage to go to the FCC to "require" (note the quotes) another
"carrier" that historically has been in the traditional business of
copper/TDM to connect primarily using IP/SIP?

There is a good potential of conflict in the appreciation of the
"negotiate in good faith" thing, as the carrier with a majority of SIP
clients would not want to invest in the TDM hardware to connect, while
the carrier with a majority of TDM clients would not want to invest in
the SIP gateways.

Michel.

---

From: "Worley, Dale R (Dale)" <[email-masked]>
Date: Fri, 4 Nov 2011 16:38:15 -0400

> From: Michel Py [[email-masked]]
> 

Given that the FCC has said

    We anticipate that the reforms we adopt will further promote the
    deployment and use of IP networks, and seek comment in the
    accompanying FNPRM regarding the policy framework for IP-to-IP
    interconnection. [...]  we expect all carriers to negotiate in
    good faith in response to requests for IP-to-IP interconnection
    for the exchange of voice traffic.

it appears that their intention is to require IP-to-IP
interconnection.  The "carrier with a majority of TDM clients" will
probably have to provide IP interconnection.

Dale

---

From: "Michel Py" <[email-masked]>
Date: Fri, 4 Nov 2011 21:05:14 -0700

> Worley, Dale R (Dale) wrote:
> interconnection.  The "carrier with a majority of TDM clients"
> will probably have to provide IP interconnection.

Being an outsider, I wonder how big the stick is. But nevertheless I
would say well played, as it indeed appears that the "TDM heavy"
carriers will have little or no choice but to pay top dollar for an IP
upgrade from the TDM vendors who provided them with their gear.

Would you like gravy on your Christmas turkey?

Michel.

---

From: "Richard Shockey" <[email-masked]>
Date: Mon, 7 Nov 2011 15:50:08 -0500

-----Original Message-----
From: [email-masked] [mailto:[email-masked]] On Behalf Of
Michel Py
Sent: Saturday, November 05, 2011 12:05 AM
To: Worley, Dale R (Dale); Richard Shockey; John Leslie; IETF-Discussion
list
Subject: RE: The US Federal Communications Commission just sent
theIETFRAI/SIPcommunity an early Christmas present...

> will probably have to provide IP interconnection.

Being an outsider, I wonder how big the stick is. 
[RS> ] Its pretty big baseball or cricket bat. E.164 voice traffic is a
fully regulated service with lots and lots of obligations associated with it
and a very very large contingent of lawyers in DC to either enforce it the
Act or find loopholes.

But nevertheless I
would say well played, as it indeed appears that the "TDM heavy"
carriers will have little or no choice but to pay top dollar for an IP
upgrade from the TDM vendors who provided them with their gear.
[RS> ] Well the other argument is the carriers have little or no choice at
this point since the classic Class 5 SS7/TDM gear (DMS-5ESS) is well beyond
its 25 year life cycle and is literally cracking up.  The cost differential
between a  Class 5 and a IMS/CSCF running SIP is not even close .. plus the
5E, for instance use 400 amps to service, I believe only 100,000 customers.
Plus the people operating these switches are retiring by the bushel full. 

Michel.

---

From: "Richard Shockey" <[email-masked]>
Date: Mon, 7 Nov 2011 15:53:43 -0500

-----Original Message-----
From: [email-masked] [mailto:[email-masked]] On Behalf Of
Michel Py
Sent: Thursday, November 03, 2011 10:54 PM
To: Richard Shockey; John Leslie; IETF-Discussion list
Subject: RE: The US Federal Communications Commission just sent theIETF
RAI/SIPcommunity an early Christmas present...

[RS> ] Yep that's the idea! 

There is a good potential of conflict in the appreciation of the
"negotiate in good faith" thing, as the carrier with a majority of SIP
clients would not want to invest in the TDM hardware to connect, while
the carrier with a majority of TDM clients would not want to invest in
the SIP gateways.
[RS> ] Well that's why there are communications lawyers.  Actually this has
been going on for some time.  Cable Operators in the US and the Netherlands
as well as some CLEC's have been interconnecting among themselves via SIP/IP
for years now as have US mobile operators. It's the "copperhead" land line
operators that have resisted the move. 

Michel.

---

From: "Richard Shockey" <[email-masked]>
Date: Thu, 10 Nov 2011 17:37:31 -0500

Santa came early this year....

http://transition.fcc.gov/Daily_Releases/Daily_Business/2011/db1110/DA-11-18
82A1.pdf

---

From: Dan York <[email-masked]>
Date: Fri, 11 Nov 2011 14:46:10 -0500

Richard,

Thanks for passing this along!

Dan

On Nov 10, 2011, at 5:37 PM, Richard Shockey wrote:

> http://transition.fcc.gov/Daily_Releases/Daily_Business/2011/db1110/DA-11-1882A1.pdf
> 
> 

-- 
Dan York  [email-masked]
http://www.danyork.com/   skype:danyork
Phone: +1-802-735-1624
Twitter - http://twitter.com/danyork
--------------------------------------------------------
All comments and opinions are entirely my own and have no connection whatsoever to any employer, past or present. Indeed, by tomorrow even I might be disavowing these comments.
--------------------------------------------------------

---

From: "Richard Shockey" <[email-masked]>
Date: Sat, 19 Nov 2011 14:55:02 -0500

<pun intended>

Just in case you don't have anything interesting to read on the plane back
from Tiawan. 

http://transition.fcc.gov/Daily_Releases/Daily_Business/2011/db1118/FCC-11-1
61A1.pdf

Selected passages of possible interest to the IETF RAI/SIP community are

Pages
29-32
210-240
268-292
380-383
459-458

Negotiations are to be in "good faith" of course. No I have no idea what
that means.