Hi Ron,
One-way, or two-way (simplex or duplex), it matters not,
IMO.
There are architectural and other efficiency-related
and demand differences between VoIP and FoIP. The
determining issue however, remains largely the same. As
with VoIP, the criterion is whether the FoIP call session
uses a fax machine to dial a LEC central office switch over
a POTS line which connects the user to a POP gateway in
the ISP's POP, or not, as the vehicle for dialing the end
point at the remote location.
Clearly, some forms of Fax over IP use this model, and I
think that they would fall into the same category that the
FCC is targeting.
On the other hand, if the Fax over IP application is using a
client/server model, and connected to the Internet via a PPP
access link to the ISP, say, as opposed to a fax machine
looking for an ISP POP gateway through a POTS
connection, then I would think that it constitutes Internet
traffic, pure and simple, just like PC-to-PC voice would be,
and therefore exempt, as things stand now.
Fax services present a different profile in certain ways,
because they demand a different grade of service with
regard to time sensitivities, and they are, by and large,
proprietary adaptations, and tend to cross-over from one
model (POTS) to the other (client server) frequently, using
attributes of both.
For example, such a cross-over would take place when you
send a fax file to a gateway locally over a POTS
connection, and have it delivered via the Internet to a 'fax
server' on the remote end (as opposed to a fax machine
over a POTS line) and vice versa. Of course, this could be
the case with certain voice designs as well, but unless I am
mistaken, it will not be as common in the early going.
Possibly later on, when servers begin to replace PBXs.
While we are discussing fax, it should be noted that fax
makes up close to half of all international traffic and a
good chunk of the domestic, therefore it will not go
unnoticed.
Many Gateway designs regard fax messages and modem
signals as 'exceptions,' through autosensing techniques,
and re-route (euphemism for 'bumping') them to regular
POTS lines. The reason for this is that fax is already
compressed, and cannot traverse, much less take advantage
of, the G.72x vocoders/codecs common in VoIP gateways.
More sophisticated gateways (we're beginning to talk about
the router variants now) will route the fax and modem calls
to appropriate Internet links, depending on the network
administrator's policy dictates.
But let's not get ahead of ourselves here. Don't draw any
overly general conclusions from this, because there are
more ways to design and customize a fax application than
there are service providers for same.
You've raised a very good issue, and I'm glad you asked. I
think that this one will be thornier than that of voice. There
are many other thorny questions, a ton of them, that I think
the FCC itself will be hard pressed to answer once they are
asked.
For example, if an ITSP is not using SS7, then how does
the LEC, and through extension, the FCC, know whether
the call is long distance or not? After all, Ingress/Egress
charges apply only to LD. Right? Who's to say that the
calls aren't local by the neophytes not using SS7?
EXPLANATION:
SS7, which will be used by the more sophisticated ITSPs,
early on, will provide pointers to remote end offices, and
look-ahead call setup procedures, and calling- and
called-party directory number information which are
_auditable_ . Indeed, necessary for billing purposes.
Less sophisticated nets which don't use SS7 and rely
instead on TCP/IP routing techniques to get to a limited set
of end points where there are similar gateways, are far
more limited in their reach potential. At the same time,
however, they don't leave a magnetic trail. Some of these
will not need to use traditional billing practices if
they offer prepaid and flat rate plans per minute,
regardless of where the calls are placed to, hence,
there is no audit trail, even on paper.
I suppose that there will be some form of compliance in
accounting ruling on this, but as it stands now, I haven't
even heard the question raised.
All of which raises the question of accountability in
reporting. Very Interesting, wouldn't you say?
Regards, Frank Coluccio |
