Roaming is not Interconnection

There was a some very unusual action at the Senate’s “State of Wireline Communication” hearing on Thursday. The prepared statements weren’t remarkable: subsidized carriers want more subsidies, independent carriers want better access to bottlenecks, free market folks want to end subsidies, and the public interest folks want to maintain the status quo. As expected, Gigi Sohn of Public Knowledge slammed Verizon’s Voice Link and praised the legacy copper-wire telephone network for its extreme reliability. She glossed over the fact that Voice Link is simply a temporary stop-gap for areas where the legacy network was totally destroyed by Sandy and has nothing to do with transitioning basic communications service from narrow band to broadband.

The question and answer phase included some of the most unusual dialog I’ve heard on tech policy and served as a reminder for why this blog exists. The issue was interconnection, something that takes a very different form in the Internet world than in the telecom world, as I explained in the previous post. In telecom, interconnection moves both calls and money, but in the Internet world it generally moves nothing but bits. There’s a technical side to this that is surprisingly poorly understood, as we’ll see shortly. What High Tech Forum strives to do is explain the technical side of tech policy. That kind of understanding was sorely lacking in the Senate hearing.

So here’s what happened: Sen. Wicker asked Larry Downes (at 1:25:06) whether we need to take a heavily regulatory route to the post-PSTN world or a light-touch approach. Downes explained that the Internet’s “interconnection agreements” are generally handshake deals for settlement free peering (where networks exchange bits but not money.) The Internet mainly runs as well as it does because its multiple stakeholders want it run well so mandates aren’t counter-productive.  At 1:28:46, Gigi Sohn jumps onto the question to Downes with what she terms an example of the failure of interconnection.

According to Sohn, AT&T discontinued a wireless roaming agreement with Verizon in Montana, because of their market power, and as a result police have to drive 30 miles outside the city (she didn’t say which one) to get connectivity. She then built this roaming situation into a general problem affecting the ability of AT&T customers to call their mothers on the Comcast network. Finally, she said “Interconnection has been a value and a mandate for 100 years…and I don’t understand why we should retreat from that.”

The problem here, of course, is that Sohn is mixing up two entirely different things. Roaming agreements allow customers of one network to use the facilities of another network (towers and spectrum) in areas where their network doesn’t have towers or coverage. AT&T, Verizon, and all the other mobile carriers have a variety of roaming agreements with each other, primarily of two types:

  1. Large national carriers have roaming agreements with each other or with regional carriers that allow them to serve customers in remote areas where they don’t have their own towers; and
  2. Small regional carriers have roaming agreements with large carriers to use their towers and spectrum outside their regional coverage areas.

Roaming agreements address a problem that doesn’t exist in traditional telephony: that’s what “roaming” means. My wireline home phone is always attached to my carrier’s network and doesn’t roam. But my carrier still interconnects with all the other telephone networks in the world anyway. So roaming and interconnection are two different things.

Sohn alleges that AT&T is using “market power” to disadvantage Verizon customers, but the facts don’t support this view. What’s really happening in the parts of rural Montana affected by this particular roaming agreement reflects on a set of merger conditions imposed by the FCC on Verizon’s takeover of the Alltel network. It’s a problem created by the fear of market power, not by the reality of it, and it has nothing to do with interconnection.

When Verizon bought Alltel three years ago, the FCC required Verizon to divest (sell) some of the Alltel towers to AT&T. As that sale left Verizon without towers in the towns of Lincoln (population 1100,) Virginia City (pop. 190,) Lima (pop. 221,) Broadview (pop. 192,) Absarokee (pop. 1234,) and Columbus (pop. 1893) in Stillwater County, the two firms signed a three year roaming agreement for Verizon to continue to use the towers they had bought and been required to sell until they could replace them with towers of their own or a more durable agreement. AT&T and Verizon don’t use the same technologies, so roaming between their two networks is extremely rare.

The end of the roaming agreement left Verizon a bit short: They have new towers scheduled to go on-line in late August, which is probably later than was originally planned (Ed: I wonder if Sandy had anything to do with delaying this?) They believed that their coverage was good enough to bridge the gap of a month or two, and evidently they were wrong.

But there’s more: the “police” Sohn cited are the Montana Highway Patrol, which has a contract with Verizon across the state. They have a special problem at the moment, a gathering of the Rainbow Family that has created a temporary community in the Beaverhead-Deerlodge National Forest that needs policing.  Regardless of who owns the Stillwater County towers and what kind of roaming agreements they have, police would still need temporary towers to cover the gathering site; consequently, Verizon has brought in Cell Towers on Wheels (COWs) to extend coverage.

Some customers are reacting to the loss of Verizon coverage in Stillwater County by moving to the AT&T network. I won’t say they’re moving in droves since there aren’t droves in that part of the world, but they’re moving. Verizon is not standing in the way with termination fees or anything of the like:

Additionally, Verizon is offering customers who choose to stay with the carrier billing and/or equipment discounts.  These discounts will also apply to a Verizon Network Extender, which enhances indoor coverage and provides more reliable service.  For customers who choose to switch carriers, Verizon has agreed to waive any applicable early termination fees, which range from $175 — $350.  To pursue either option, pre-paid consumers should call Verizon Customer Service at 1-888-294-6804; all others should call 1-800-922-0204.

So what we have here is the fear of market power creating a service disruption with a little help from over-optimistic planning on the part of one carrier along with an odd little public event that creates a temporary city. This is not an interconnection problem: AT&T and Verizon still send calls to each other, and anyone who can get a signal can use it the same way they’ve always been able to use it.

If there’s a case to be made for mandatory interconnection according to rules set by the FCC, this isn’t it.

The most amusing part of Sohn’s passionate commentary was the complete lack of any response from the committee or the panel on the fact that she mixed apples and oranges. Even though the details of the Stillwater County roaming agreement aren’t headline news, the fact that roaming agreements are not in any way related to interconnection mandates should be simple to understand.