Comcast: Our Voice Service Doesn't Hit The Internet

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Comcast told the Federal Communications Commission last Friday that the MSO's new bandwidth-management techniques have no bearing on its own voice service because that service does not actually traverse the public Internet.

The FCC launched a probe on Sunday, Jan. 18 -- two days prior to Kevin Martin's resignation as agency chairman -- asking Comcast to explain an "apparent discrepancy" between its disclosure that the updated network-management practices could affect voice-over-Internet services and a section of its site that says Comcast Digital Voice is unaffected.

"There is, in fact, no discrepancy," Comcast vice president of regulatory and state legislative affairs Kathryn Zachem wrote in the letter, dated Jan. 30. (The PDF of the letter is available here.)

That's because Comcast Digital Voice is a separate service that does not run over the operator's high-speed Internet service, she said. CDV customers do not even need to be broadband subscribers.

"The network management techniques at issue in this proceeding affected solely traffic that is delivered to and from our subscribers as part of our HSI service," Zachem said. "CDV, like Vonage or Skype, is an IP-enabled voice service (i.e., it uses voice-over-Internet-Protocol to deliver the service). However, unlike Vonage, Skype, or several other VoIP services, CDV is not an application that is used ‘over-the-top' of a high-speed Internet access service purchased by a consumer."

As of the end of 2008, Comcast moved to a "protocol-agnostic" network management approach across its entire footprint, after negative publicity and a previous FCC probe into whether the MSO was violating the agency's Internet fairness principles. The new approach inhibits the bandwidth available to individual users who consume excessive capacity, whereas Comcast previously singled out individual applications or protocols.

Comcast has acknowledged in its disclosures about the new approach that subscribers potentially could experience disruptions with voice-over-Internet services, which "would in all likelihood affect only a subscriber who has temporarily triggered congestion management thresholds due to his or her own bandwidth consumption," the company said.

However, Comcast claimed, its network-management policies have been developed with particular sensitivity to time-sensitive applications such as VoIP. For example, last July, Comcast and Vonage said they would work together ensure that congestion-management techniques will balance the need to avoid network congestion with the need to ensure that over-the-top VoIP applications work well for consumers.

Meanwhile, Cox Communications this month plans to begin testing a bandwidth-management system that the MSO said may "momentarily" delay non-time-sensitive Internet applications, such as peer-to-peer file swapping. The plan has already drawn fire from a self-appointed consumer watchdog group. 

The inquiry into how Comcast's new bandwidth-management system affects VoIP was one of the last actions initiated by Martin's FCC.

President Barack Obama last month appointed Michael Copps interim chairman of the FCC. Obama reportedly has picked Julius Genachowski, a longtime friend and technology adviser, as his permanent FCC chairman but the administration has made no formal announcement.