Summary Presentation: Acrobat
NPRM: Word | Acrobat
News Release: Word | Acrobat
Genachowski Statement: Word | Acrobat
Copps Statement: Word | Acrobat
McDowell Statement: Word | Acrobat
Clyburn Statement: Word | Acrobat
Baker Statement: Word | Acrobat

The NPRM itself is a hefty document, 107 pages long; if you just want the bottom line, the Summary Presentation is short and a little more readable than the press release. The comment period closes in mid-January, and the FCC will respond to the comments in March. I hesitate to guess when the rules will actually be released - this is hugely controversial: 40,000 comments filed to date. Here is a link to a pro-neutrality advocate. Here is a link to a pro-competition advocate. I believe that the FCC is doing a necessary thing here, and that the proposals properly address the legitimate concerns of the ISPs.

Here is the story from Reuters, and from AP.

This will make international calls much cheaper for people who are willing to put up with the latency issues of the data channel.

Here’s what has happened since, through the first three quarters of 2009:

There are still no certifications for 802.11 draft n, and almost none for 802.11a.

Here’s another breakdown, by manufacturer and year. Click on the chart to get a bigger image. This shows that the Wi-Fi enthusiasts have been pretty constant over the years: Nokia, HTC, Motorola and Samsung. Then more recently SonyEricsson and LG. Note that the 2009 figures are only through Q3, so the growth is even more impressive than it seems from this chart.

The all-time champion is Samsung, with a total of 84 phone models certified for Wi-Fi, followed by Nokia with 68, then HTC with 54. This changes if you look just at smartphones, where Nokia has 61 total certifications to HTC’s 34 and Samsung’s 29.

1. 3G (UMTS) download speeds average about a megabit per second; 2.5G (EDGE) speeds average about 160 kbps and 2G (GPRS) speeds average about 50 kbps.
2. For VoIP, latency is a critical measure. The average on 3G networks was 336 ms, with a variation between carriers and countries ranging from 200 ms to over a second. The ITU reckons latency becomes a serious problem above 170 ms. I discussed the latency issue on 3G networks in an earlier post.
3. According to these tests, Blackberries are on average only half as fast for both download and upload on the same networks as iPhones and Android phones. The Blackberry situation is complicated because they claim to compress data-streams, and because all data normally goes through Blackberry servers. The ARCchart report looks into the reasons for Blackberry’s poor showing:

The BlackBerry download average across all carriers is 515 kbps versus 1,025 kbps for the iPhone and Android - a difference of half. Difference in the upload average is even greater – 62 kbps for BlackBerry compared with 155 kbps for the other devices.
Source: ARCchart, September 2009.

The cellular companies want you to buy cellular service then pay extra to get signal coverage. Gizmodo has a coolly reasoned analysis.

AT&T Wireless is doing the standard telco thing here, conflating pricing for different services. It is sweetening the monthly charge option for femtocells by offering unlimited calling. A more honest pricing scheme would be to provide femtocells free to anybody who has coverage problem, and to offer the femtocell/unlimited calling option as a separate product. Come to think of it, this is probably how AT&T really plans for it to work: if a customer calls to cancel service because of poor coverage, I expect AT&T will offer a free femtocell as a retention incentive.

It is ironic that this issue is coming up at the same time as the wireless carriers are up in arms about the FCC’s new network neutrality initiative. Now that smartphones all have Wi-Fi, if the handsets were truly open we could use our home Wi-Fi signal to get data and voice services from alternative providers when we were at home. No need for femtocells. (T-Mobile@Home is a closed-network version of this.)

Presumably something like this is on the roadmap for Google Voice, which is one of the scenarios that causes the MNOs to fight network neutrality tooth and nail.

1. Open access to Content
2. Open access to Applications
3. Open access to Services
4. Freedom for users to attach devices to the network
5. Non-discrimination for content and applications
6. Transparency of network management practices

The first four of these principles were initially articulated by former FCC Chairman Michael Powell in 2004 as the “Four Freedoms.” Numbers 5 and 6 are new. The forthcoming rules will apply these six principles to all broadband access technologies, including wireless.

Genachowski made the case that Internet openness is essential and that it is threatened. He acknowledged that network providers need to manage their networks, and said that they can control spam and help to maintain intellectual property integrity without compromising these principles.

The threats to Internet openness come from reduced competition among ISPs and conflicts of interest within the ISPs, because they are also trying to be content providers.

Genachowski rightly sees these threats as serious:

This is not about protecting the internet against imaginary dangers. We’re seeing the breaks and cracks emerge, and they threaten to change the Internet’s fundamental architecture of openness. This would shrink opportunities for innovators, content creators and small businesses around the country, and limit the full and free expression the internet promises. This is about preserving and maintaining something profoundly successful and ensuring that it’s not distorted or undermined.

These rules will be very tough to enforce. The fundamental structure of the business works against them. A more effective approach may be to break up the ISPs into multiple independent companies, for example: Internet access operations, wide area network operations, and service/content/application operations. The neutrality problem is in the access networks - the WANs and the services are healthier. With only the telcos (DSL and fiber) and the MSOs (cable) there is not enough competition for a free market to develop. This is why Intel pushed so hard for WiMAX as a third mode of broadband access, though it hasn’t panned out that way. It is also why municipal dark fiber makes sense, following the model of roads, water and sewers.

Consistent with this approach, we plan to take a fresh look at possibly authorizing VoIP capabilities on the iPhone for use on AT&T’s 3G network.

So why would anybody want to do VoIP on the cellular data channel, when there is a cellular voice channel already? Wouldn’t voice on the data channel cost more? And since the voice channel is optimized for voice and the data channel isn’t, wouldn’t voice on the data channel sound even worse than cellular voice already does?

Let’s look at the “why bother?” question first. There are actually at least four reasons you might want to do voice on the cellular data channel:

1. To save money. If your voice plan has some expensive types of call (for example international calls) you may want to use VoIP on the data channel for toll by-pass. The alternative to this is to use the voice channel to call a local access number for an international toll by-pass service (like RebTel.)
2. To get better sound quality: the cellular voice codecs are very low bandwidth and sound horrible. You can choose which codec to run over the data network and even go wideband. At IT Expo West a couple of weeks ago David Frankel of ZipDX demoed a wideband voice call on his laptop going through a Sprint Wireless Data Card. The audio quality was excellent.
3. To get additional service features: companies like DiVitas offer roaming between the cellular and Wi-Fi networks that makes your cell phone act as an extension behind your corporate PBX. All these solutions currently use the cellular voice channel when out of Wi-Fi range, but if they were to go to the data channel they could offer wideband codecs and other differentiating features.
4. For cases where there is no voice channel. In the example of David Frankel’s demo, the wireless data card doesn’t offer a voice channel, so VoIP on the data channel is the only option for a voice connection.

Moving on to the issue of cost, an iPhone unlimited data plan is $30 per month. “Unlimited” is AT&T’s euphemism for “limited to 5GB per month,” but translated to voice that’s a lot of minutes: even with IP packet overhead the bit-rate of compressed HD voice is going to be around 50K bits per second, which works out to about 13,000 minutes in 5GB. So using it for voice is unlikely to increase your bill. On the other hand, many voice plans are already effectively unlimited, what with rollover minutes, friend and family minutes, night and weekend minutes and whatnot, and you can’t get a phone without a voice plan. So for normal (non-international) use voice on the data channel is not going to reduce your bill, but it is unlikely to increase it, either.

Finally we come to the issue of whether voice sounds better on the voice channel or the data channel. The answer is, it depends on several factors, primarily the codec and the network QoS. With VoIP you can radically improve the sound quality of a call by using a wideband codec, but do impairments on the data channel nullify this benefit?

Technically, the answer is yes. The cellular data channel is not engineered for low latency. Variable delays are introduced by network routing decisions and by router queuing decisions. Latencies in the hundreds of milliseconds are not unusual. This will change with the advent of LTE, where the latencies will be of the order of 10 milliseconds. The available bandwidth is also highly variable, in contrast to the fixed bandwidth allocation of the voice channel. It can sometimes drop below what is needed for voice with even an aggressive variable rate codec.

In practice VoIP on the cellular data channel can sometimes sound much better than regular cellular voice. I mentioned above David Frankel’s demo at IT Expo West. I performed a similar experiment this morning with Michael Graves, with similarly good results. I was on a Polycom desk phone, Michael used Eyebeam on a laptop, and the codec was G.722. The latency on this call was appreciable – I estimated it at around 1 second round trip. There was also some packet loss – not bad for me, but it caused a sub-par experience for Michael. Earlier this week at Jeff Pulver’s HD Connect conference in New York, researchers from Qualcomm demoed a handset running on the Verizon network using EVRC-WB, transcoding to G.722 on Polycom and Gigaset phones in their lab in San Diego. The sound quality was excellent, but the latency was very high – I estimated it at around two seconds round trip.

The ITU addresses latency (delay) in Recommendation G.114. Delay is a problem because normal conversation depends on turn taking. Most people insert pauses of up to about 400 ms as they talk. If nobody else speaks during a pause, they continue. This means that if the one-way delay on a phone conversation is greater than 200 ms, the talker doesn’t hear an interruption within the 400 ms break, and starts talking again, causing frustrating collisions.
The ITU E-Model for call quality identifies a threshold at about 170 ms one-way at which latency becomes a problem. The E-Model also tells us that increasing latency amplifies other impairments – notably echo, which can be severe at low latencies without being a problem, but at high latencies even relatively quiet echo can severely disrupt a talker.

Some people may be able to handle long latencies better than others. Michael observed that he can get used to high latency echo after a few minutes of conversation.

Now Apple has posted its responses to the same questions, which are basically the same as AT&T’s. Among the differences are that Apple’s responses contain some hard numbers on its controversial App Store approval process:

• 80% of applications are approved as originally submitted.
• 95% of applications are approved within 14 days of submission.
• 65,000 applications have been approved.
• 200,000 submissions and re-submissions have been made.
• 8,500 submissions are coming in each week.
• Each submission is reviewed by two reviewers.
• There are 40 reviewers.

These numbers don’t really add up. So what Apple probably means is that 95% of the applications that have been approved were approved within 14 days of their final submission. Even so, each reviewer must look at an average of 425 submissions per week (8,500*2/40), which is 10 per hour per reviewer - an average of 12 minutes of reviewer time per submission, which doesn’t seem to justify the terms “comprehensive” and “rigorous” used in Apple’s description of the process:

Apple developed a comprehensive review process that looks at every iPhone application that is submitted to Apple. Applications and marketing text are submitted through a web interface. Submitted applications undergo a rigorous review process that tests for vulnerabilities such as software bugs, instability on the iPhone platform, and the use of unauthorized protocols. Applications are also reviewed to try to prevent privacy issues, safeguard children from exposure to inappropriate content, and avoid applications that degrade the core experience of the iPhone. There are more than 40 full-time trained reviewers, and at least two different reviewers study each application so that the review process is applied uniformly. Apple also established an App Store executive review board that determines procedures and sets policy for the review process, as well as reviews applications that are escalated to the board because they raise new or complex issues. The review board meets weekly and is comprised of senior management with responsibilities for the App Store. 95% of applications are approved within 14 days of being submitted.

Of course much of this might be automated, which would explain both the superhuman productivity of the reviewers and the alleged mindlessness of the decision-making.

Rethink’s Matt Lewis cites improved performance and usability as driving forces, plus a change in the attitudes of carriers towards hot-spots. Wireless network operators now often have captive Wi-Fi networks and can use them to offload their cellular networks.

The upshot is a prediction of 300 million dual mode handsets to ship in 2011: 100% of the smartphone market plus high end feature phones.

The attach rate of Wi-Fi will continue to grow. By 2011 the effects of Bluetooth 3.0 will be kicking in, pushing Wi-Fi attachment towards 100% in camera phones and music phones in ensuing years.