Comments on article found at: connectedplanetonline.com/residential_services/commentary/att-ends-pots-0104/

Like most ILECs and dominant carriers (as defined by the FCC), AT&T is politically forced to be all things to everyone.

An ILEC (AT&T is also an ILEC) is expected to be all things to everyone. That is not a perception it is a regulatory reality. That is what you get when you are the dominant carrier in a state or region.

AT&T’s comments are understandably self-serving. In the 1980s, ILECs were testing out the idea of dropping the PSTN insofar as being held accountable for maintaining it. Back then, carriers like NYNEX were actively promoting the concept of competitive local exchange carriers. We called them CAPs back then. ILECs supporting competition expected the market to open up for them as well. Guess what it worked in some fashion. The reality is that regulation is an evolving exercise.

VoIP has been a discussion in telecom for about 25 years as well. Technology takes time to implement, especially when you consider the fact that this is about changing the telecom infrastructure of the country. Well its now 2010, AT&T’s position needs to be considered. The whole point of maintaining the PSTN back in the 1980s and 1990s was to ensure that communications be maintained for local, state, and federal emergencies, calling that there were no alternative telecom technologies or network deployed. Remember the major network disasters of the early 1970s and mid-1980s. Well that is all different now; we have wireless networks and we have widely deployed IP-based landline networks. In other words the consumer has choices. Further, why maintain a TDM-based network when it appears to be no longer needed?

I am a little curious why AT&T is pushing for the elimination of POTS. The carrier has been phasing in IP-based networking for the last 15 years. My concern is the comment AT&T made in its filing: "If broadband and IP-based services represent the future of telecommunications, the PSTN and POTS are now relics of an earlier era. The business model that sustained circuit-switched voice service over the last century is dying."

Guess what “voice is not dying”. The regulated business/cost model that supported the PSTN is no longer working correctly but that does not mean voice service is finished.

Therein lays my concern. AT&T seems to be linking the PSTN and POTS together. The acronym PSTN stands for Public Switched Telephone Network. The acronym POTS stands for Plain Old Telephone Service. Back before 1983 and even today, POTS has typically referred to plain old voice service. In the 1980s and 1990s, the Bell System had drawn a distinction between conventional POTS and the then emerging intelligent networking-based POTS. The PSTN supported POTS but bear in mind POTS is not the PSTN.

Therefore, assuming AT&T is still defining POTS the old Bell System way then VoIP is now IP-Based POTS. Then again, if AT&T is using POTS the way some do today, POTS is PSTN, then we could be looking at AT&T (and other ILECs) trying to skip out on its obligation to ensure even the most areas of the nation have basic voice service.

I say “fine get rid of the PSTN but not the responsibility for maintaining basic voice service in all areas the ILEC operates.”  Don't use TDM-based switching, IP-based networking.

The problem for the FCC is that it must ensure the nation’s telecom infrastructure is maintained during a time when it seems some carriers do not want the responsibility. Then again, I might be totally wrong.