The Federal Communications Commission’s called for proposals of “voluntary experiments” by communications service providers to examine what happens when traditional analog phone service is replaced by digital service might – might – be problematic.

As a practical matter, the FCC is talking to phone companies. But since the issue is going from plain old telephone service (POTS) to VoIP, it might have some ramifications for MSOs that got into the voice market with VoIP, and those cable operators who also operate POTS networks.

New FCC Commissioner Tom Wheeler overtly wants to encourage the transition of the country’s communications networks to all-IP. What Wheeler is doing is merely giving the IP bandwagon that he’s jumping on a little tiny push, negligible but symbolically potent. This is the way things are going anyway. Verizon notably can’t rip out copper and replace it with fiber fast enough – albeit only in its most lucrative markets, pretty much where FiOS is already deployed.

If there’s a problem, it is the notion that phone service is a lifeline service – it has to remain on. Indeed, the FCC called the following considerations fundamental:

  • Public safety communications must be available no matter the technology
  • All Americans must have access to affordable communications services
  • Competition in the marketplace provides choice for consumers and businesses
  • Consumer protection is paramount    

Analog phone service is powered. If the power grid goes down, analog phones still work. This is not entirely true of VoIP. VoIP phones typically have battery backup for several hours, which covers the average power outage, but tends to be utterly inadequate during the increasing number of natural disasters that last for days.

Oh – the phone companies say – everybody has a mobile phone; during a disaster people just use those. Which ignores the fact that during natural disasters, cell towers often get taken out, whether through outright physical damage, power outage, or being overwhelmed by traffic (in which case emergency communications services frequently get prioritized).

And yes, analog phone lines can be severed during many natural disasters. But not all, not always uniformly, and the lines that remain working? They remain working.

You could say that the adoption rates for VoIP service indicate pretty clearly that consumers don’t care anymore about phone service that continues to work as long as the lines aren’t severed.

It would be interesting to find out if even 10 percent of VoIP customers are aware that this is so. The VoIP sales pitch has always been price, and the industry tends to elide the lifeline issue entirely.

It’s possible that consumers might not care if they did know. Maybe that’s one of the things the FCC wants to find out.

But if it turns out that the public decides that VoIP phone service from telephone companies should be powered or in some way always-on, any regulations the FCC imposes that covers telephone company VoIP are likely to cover cable VoIP as well.

The FCC said it is looking to hear about tests in the following areas:

Service-based experiments: Providers are invited to submit proposals to initiate tests of providing IP-based alternatives to existing services in discrete geographic areas or situations.  Proposals are due by Feb. 20, followed by a public comment and reply period ending on March 31, and final decision on the proposals made at the FCC’s May meeting

Targeted experiments and cooperative research:  These experimentswill explore the impact on specific values, including universal access and competition.

Rural America: experiments will focus on ways to deliver robust broadband to rural areas

People with disabilities: development and funding of interagency research on IP-based technologies for people with disabilities

Telephone numbering in all-IP world: a numbering testbed will address concerns raised about number assignment and databases in an all-IP world, without disrupting current systems

Wheeler said, “I believe that such voluntary experiments, through the use of carefully-constructed control groups, can tell us how IP networks impact users – and this is the only purpose of these experiments. How will households reach 911, which they must? How will small businesses continue to reach their customers, which they must? Will competition be maintained? How will people with medical monitoring devices or home alarms know that they will always be connected to a reliable network, which they also must be able to do?”

With today’s prevailing free-market philosophy, the issue of competition will be a ancillary at best. Even if Wheeler and the other FCC Commissioners are legitimately interested in protecting consumers, the phone companies will fight them tooth and nail, and there won’t be enough consumers who care, which means the rest of the U.S. Government won’t back them either.

The Internet Innovation Alliance, for example, cheered the FCC’s announcement. The IIA, which has a membership sprinkled with consumer groups, didn’t even mention the service issues.