GCI Digital Telephone Service (VoIP)

Around January, 2007, GCI Communications began offering to convert customers in Juneau, Alaska to 'digital phone service'. There is no increase in the monthly bill. In fact, they have offered some customers incentives, such as Alaska Airlines mileage or some free long distance, as a reward for converting. What exactly is going on here?

They're actually offering to replace the state-regulated private line connecting you to the telephone exchange with a FCC-regulated Voice over Internet Protocol (VoIP) modem that connects to the exchange via a shared cable line instead. Phone and cable companies loathe the term 'VoIP' and instead use euphemisms such as 'digital telephone service', 'digital voice', and 'digital local' phone or telephone service. But it isn't digital phone service, a type of service found in offices and hotels that uses special phones and can zap modems. It really is VoIP. That may mean enhanced services for less cost. But it also means that you have no meaningful consumer protection and significantly degraded quality and reliability of service.

If you agree to switch to any cable or phone company's VoIP, including GCI's digital phone service, you are agreeing to forfeit state consumer protection. This is because the Federal Communication Commission (FCC) has, under a dubious reading of their power to regulate interstate commerce, preempted state regulation of any VoIP-based phone service -- even service delivered entirely over local lines wholly contained within one state. I have personal experience with this. I had run into some trouble with a line on the new VoIP system. The phone company was nonresponsive. So I filed an informal complaint with the Regulatory Commission of Alaska (RCA). The response from the RCA was that they could take no action because of the FCC preemption, and to give me the address of the FCC. I refiled there, but the FCC gets so many complaints that there is little they can do but forward it back to the phone company for reconsideration. In this particular case, following the FCC complaint, months after the original problems, the company apologized for the trouble in service and gave a 3 month credit on the bill. But the FCC took no action to prevent such problems in the future. State regulators, by contrast, actually consider the merits of individual consumer complaints and often compel individual phone companies to take corrective action. In Alaska that has included ordering refunds to entire communities on more than one occasion. Giving up state consumer protection is a big deal.

Getting local dial tone via packet switched VoIP is fundamentally different than getting it via a dedicated private line and may cause severe problems for dial-up modems, including faxes, burglar alarms, and credit card machines. Both systems are analog from your phones to the company's analog to digital codec (coder-decoder). Under the old system, you have a dedicated line -- a copper wire loop -- connecting your telephone to the phone company codec. This is generally at the local exchange, where the codec produces Pulse Code Modulation (PCM) for handling via the circuit switched phone system. You effectively get a continuous connection to the called party at the PCM sampling rate. Under the new system, your inside wiring connects to a codec inside a modem in the house, which uses packet switched VoIP to connect your call via a shared cable to the exchange. The VoIP portion interpolates everyone's speech packets over the same cable, so it doesn't actually provide a continuous connection; it only sounds that way. During breaks in the speech, VoIP often repeats the immediately preceeding audio, so the ear doesn't hear any break. Dialup modems weren't designed to cope with interruptions or repeats of audio. This is an engineering problem inherent in VoIP technology. It has nothing to do with the quality of your telephone wiring. There is a readable engineering overview by www.telchemy.com online: Data and Fax modem performance on VoIP services (Nov. 2005). (This is a 484 kilobyte Adobe portable document format (PDF) file. You need the Adobe Acrobat Reader from www.adobe.com or Ghostscript from www.cs.wisc.edu/~ghost/ to read it. Most systems already have one of these installed.)

• Under circuit switched PCM, the central office allocates a fixed digital circuit to any completed call. During a call, speech syllables are tranmitted live, as spoken; arrive at their destination with a constant delay; and there is never a break in the audio. Each call gets a dedicated 64 kilobit per second (kbs) path, of which 8 kbps is used for telephone system signaling and 56 kbps for end-to-end transmission. Dial-up 56 kbps modems take advantage of this. If the telephone wiring inside the house is modern 'twisted pair', a connect rate of 49 kbps and an end-to-end transmission of 46 kbps can easily be achieved if you are within a couple of miles of the central office. In homes wired with old-fashioned parallel wire 'quad' cable, line errors often slash the end-to-end transmission rate to 30 kbps, but even here, if secret modem commands to limit connect speed are used to reduce the rate to 42 kbps, the error rate can be reduced enough to get 37 kbps of end-to-end tranmission. Such speeds are sufficient to listen to Shoutcast 32 kbps radio streams for hours on end with never a break in the audio. Faxing with traditional fax machines, which need at most 14.4 kbps, is a snap.
• Under the new packet switched VoIP system, no fixed digital circuit is allocated to any completed call. During a call, speech syllables (packets) are transmitted when there is room on the network, resulting in slightly variable delays, and if there is network congestion, there may be gaps in the speech, which the VoIP system covers up by inserting noise or repeating previous audio. Dial-up modems were not designed to cope with this and may disconnect when these effects are encountered. In some cases, the same effects may cause computers to enter an unstable state such that reboot is required before reconnection is possible. In short, dialup modem service may be possible, but it will almost certainly be unreliable. Many companies offering VoIP local service advise customers who need dialup modem service to keep a traditional line for that purpose. Our results indicate that this is sound advice.
  • At first, I found it nearly impossible to connect over the VoIP cable digital phone, with as many at 15-20 redials necessary to handshake. Although the modem would show 'connect 45333', the error rate was so high that throughput was only 19 kbps. Using secret modem commands to limit connect speed, I found that when the maximum was reduced sufficiently, a bare majority of dial-in attempts would succeed, but this was at 'connect 33333'. At this rate, throughput was only 28 kbps, insufficient to listen to 32 kbps Shoutcast streams. And the line dropped unpredictably, from as little as five minutes into a call to a maximum of around 1-1/2 hours into a call. Sustained overnight connections for long downloads or clock synchronization were not possible.
  • I decided to upgrade modem firmware and/or drivers to try to improve connection success. After that, I found a sweet spot at 'connect 40000' where handshaking would sometimes succeed, and when it did, 33 kbps throughput was achieved -- just sufficient to listen to 32 kbps Shoutcast streams. But staying connected more than a couple of hours remained essentially impossible.
  • Faxing may also be a trial over VoIP. It may be impossible to receive a fax unless the sender reduces their speed to 4.8 kbps, and even then, it is often the case that multi-page faxes cannot be received. We found that even on local calls, the line would often drop by the end of the 2nd page. Oddly, we were able to receive a multipage long distance fax from the phone company. The unpredictability of the system makes it really undesirable for anything relying on dialup modems, in my opinion.

It is inadvisable to rely on digital VoIP-based digital local telephone service for any device using a dial-up modem. Dialup remains widely used for credit card point-of-sale approvals, for sending and receiving faxes, for home appliances such as TiVo TV time shifters and burglar alarm monitoring, and even today for dial-up internet service. It is simply not the case that nearly everyone has broadband internet at home. As of June 2007, only 53% of U.S. households had subscribed to broadband internet service, according to a websiteoptimization.com report on a Leichtman Research Group study. FCC broadband internet statistics for June 2006 (1.1 megabyte PDF) indicated that only about 46.4% of U.S. households (50.3 million household lines vs 100.3 households) had high speed internet access. And the FCC fudged the broadband statistics by such things as including seldom-used cell phone capability.

It's not particularly surprising that only about half of U.S. households subscribe to broadband, given the high price and limited availability. Consider GCI's cable modem offerings. As of July 2008, their cheapest broadband providing unlimited downloads is a bundled service providing phone, TV, and internet. It runs $136 a month plus taxes. This kind of economic hurdle may explain why the Leichtman study also found that 45% of households with incomes under $30,000 had no internet service at all. If $136 a month was instead invested in an employer's thrift saving plan, matched, and grew at 5%, it would be worth $226,374 after a thirty year career. Giving away nearly a quarter of million dollars for TV and internet over the life of a mortgage is perhaps just a bit steep. In fairness, GCI offers a cheaper cable modem package meeting the FCC's definition of broadband (at least 768kbps): XTREME internet, for $40 a month plus taxes, assuming you never exceed your free allowance. And they offer speeds down to 64kbps: LiteSpeed, for $25 a month. But even at that rate, if you spend $25 a month over 30 years instead of saving it in an employer matched saving plan, you reduce your nest egg by at least $41,613. And these cable modem packages aren't available everywhere. Dialup internet service, by contrast, is ubiquitous and in some cases free, which can never hurt. GCI actually offers FreeNet, free dialup internet, provided you subscribe to a $6 a month long distance discount plan.

Still, a lot of people do use cable modems for internet access, and if they don't use home faxes or have other special appliances, and can tolerate erratic phone service, they might find local VoIP satisfactory. People making light use of dial-up internet access who don't listen to streaming audio, don't download large files, don't use home faxes, and don't care about missing features like dial tone or, when appropriate, the busy signal might also find local VoIP satisfactory. Those who never receive faxes at home, may only rarely send a one or two page fax, and don't care if 911 service is always available may also find it tolerable. But heavy dial-up and fax users, particularly those who rent a second line expressly for such devices, will likely find VoIP entirely unsatisfactory for that line -- if they associate the problems that occur with the switch to VoIP service.

Who benefits from the conversion to digital VoIP, and who loses?

Who benefits?

The cable company benefits, and subscribers who enjoy the special services and discount plans the conversion makes possible also benefit. The conversion to VoIP allows the cable company to provide dial tone via their own cable modem and cable plant. This allows them to stop renting 'twisted pair' copper wire from the traditional phone company. It should convert providing local phone service from a low-profit operation to a high-profit operation. And it should make it possible to offer better deals to customers. For example, GCI already offers a long distance plan to their 'digital' subscribers that offers 2 cents/minute interstate calling, for $20 a month.

Who loses?

Unknowledgeable residential customers who rely on devices using dial-up modems may lose. Upon converting to VoIP, such customers may notice that their dial-up services no longer connect reliably, may not work as well when connected, and in some cases may be unusable. But they may not associate the degradation of service with the switch to VoIP. That's particularly true if they are only occasional users of such devices. For example, people who rely on their fax machine being able to send or receive time-critical multi-page faxes, but do so only rarely, may be shocked when they do try to use it and find that what used to work 100% is now nearly unusable. People who used to use nearly flawless dial-up internet service may eventually notice that it is now too hard to connect, too slow, and too prone to disconnect. But they are unlikely to associate this with the switch to VoIP and are more likely to simply switch to additional cost cable modem service because the dialup is so badly degraded.

There are also other problems, as might be expected from new technology. For some people, the problems are not an issue, and the VoIP service may be satisfactory. For others, they are major issues and will preclude use of VoIP. This is very well documented at VoIP Mechanic (voipmechanic.com). Most of what is discussed there has been observed on the GCI VoIP service.

1. People calling you may occasionally get a dead line followed by a fast busy signal. Some may interpret this to mean your line was disconnected for nonpayment. But if they keep trying, after two or three tries, the call may go through. A VoIP customer might not be aware of how many calls they don't get because the caller got a dead line followed by a fast busy signal and never tried again. Customers may not associate the problem with the switch of some lines to VoIP. See VoIPMechanic.com: Dropped Calls.

   A customer on ACS trying to call a customer on GCI VoIP received a dead line followed by a fast busy signal in two consecutive attempts. The third call went through. I personally witnessed this.

2. When you are calling people you may occasionally get a recording that a line is not in service when you know that this is not true. Keep trying, and the call may may go through. A VoIP customer may not associate this will the switch to VoIP. See VoIPMechanic.com: Dropped Calls.

   A customer on GCI VoIP trying to call known good numbers was getting recordings indicating that they were not in service. She knew this was not the case, and reported to me that "the phone are all screwed up'. At the time, neither of us associated it with the switch of her line to VoIP.

3. Local callers may hear a distracting echo on the line when they talk to you. This one is also a problem inherent in VoIP technology. It increases the local network delay from around 5 milliseconds to around 95 milliseconds, changing what is normally perceived as normal 'sidetone' to an annoying echo. A readable engineering overview is available from www.telchemey.com online: Echo in Voice over IP Systems (Jan. 2006) (568k PDF). One suggested cure for this is that you should always keep the volume control on your telephones turned all the way down. Another is to stop using cordless phones and switch to corded (i.e., unamplified) phones. But that isn't very practical in an era in which, thanks to live music and headphones, an entire generation of young people is more hard of hearing than their elders, and virtually every phone sold includes an amplified handset to compensate. An unamplified phone? Perhaps you could find one of those old fashioned big, bulky black phones with a rotary dial in the base. See VoIPMechanic.com: Phone and Voice Quality.

   A customer on ACS calling a hard of hearing customer on GCI VoIP who uses an amplified cordless phone receives a very significant and somewhat distracting echo during almost every call. It really is an echo. When his dog barks, a phantom dog barks back!

4. Your fax and dial-up internet calls may be summarily disconnected in a very unpredictable way, from five minutes into a call to half way through a 1-1/2 hour download. This is apparently because during a call, the audio may occasionally be interrupted for a moment. That may be tolerable for voice, but if you are faxing or using a dial-up modem connection, it will disconnect you every time. Breaks in audio are a common problem on VoIP. See VoIPMechanic.com: Phone and Voice Quality and VoIPMechanic.com: Dropped Calls.

   A customer on GCI VoIP who uses dial-up internet gets disconnected unpredictably. On one occasion it was possible to listen to a Shoutcast radio stream for 1-1/2 hours without a disconnect. But in four attempts to stay online overnight for time synchronization, every time the call was disconnected within 50 minutes. And disconnects often happen as early as 5 minutes into a call. There is no way to predict whether the connection will last long enough to complete a financial aid form, a credit card application, a banking transaction, a Ghostscript or Mozilla download, or just about anything else. Previously, this customer could stay connected continuously, overnight, without a disconnect.

5. Your fax machine may be unable to receive even a one page fax from a computer unless the sender slows their line speed manually. Having to slow fax speed is a common problem on VoIP. See VoIPMechanic.com: Setting Baud Rates.

   A customer on GCI VoIP who has a stand-alone fax machine could not receive a fax from a PC on a traditional phone until the PC sending speed was reduced. Speeds from 14400 to 9600 were not usable at all. At 7200, fewer than half of the one page faxes went through. At 4800, more than half went through.

6. Your fax machine may be unable to send or receive more than a single page at a time, with multi-page faxes always getting disconnected. Sending can sometimes be improved by tinkering with secret fax settings, but you can hardly expect to convince an insurance company or the government to tinker with *their* settings so that they can send you a fax. But this is a common problem for VoIP. See VoIPMechanic.com: Prevent Common Mistakes at "VoIP is far from the ideal medium for faxing"; VoIPMechanic.com: Faxing Issues & Other Devices; VoIPMechanic.com: Slowing the speed makes for better Faxing; and VoIPMechanic.com: About ECM & Baud Rates.

   A customer on GCI VoIP who has a stand-alone fax machine can often not receive more than a single fax page at a time. A one page fax may go through and the session complete normally. Any multi-page fax sent to him is almost always interrupted by the end of the 2nd page. Tested sending from a PC. Confirmed sending from a stand-alone business fax machine. Both senders were on traditional phone service. But when the phone company was present, a 4 page fax went through successfully. The unpredictability of the service is a huge problem for faxing.

7. You may have difficulty establishing a dial-up connection to your internet service provider. You may be able to restore the ability to connect to an average of 1 in 2 dialin attempts by using secret modem commands to slow down your modem's maximum connect speed to 40kbps, or in the worst case, as little as 32 kbps. But that can hardly be considered 'as good or better' than copper wire phone service, which can theoretically support 56kbps. Dial-in modem connection problems are not unusual for VoIP. See VoIPMechanic.com: Prevent Common Mistakes at "Most credit card machines fail when sending."

   A customer newly on GCI VoIP was at first able to dial in and get connected, but the line would drop in a few minutes. Within a couple of hours, the situation deteriorated, and he could not connect at all. The top-quality U.S. Robotics 56 kbps dial-in hardware modem had to be instructed to not try to connect at a speed faster than 34 kbps simply to be able to connect. (The U.S. Robotics command is AT&N22.) Even then, the dial-in failed 4 out of every 10 times. Previously, it almost always connected the first time.

   Because the speed had to be slowed to 34 kbps to establish a connection, the customer's data throughput fell to 31 kbps from the former 45 kbps. Formerly, the customer could play Shoutcast radio 32 kbps streams without ever a break in the audio even while browsing the internet. Under VoIP, with the speed reduction needed to connect, it is not possible to play Shoutcast radio 32 kbps streams while browsing, and even when doing nothing else, the streams are interrupted typically after 5 minutes to 1-1/2 hours. Previously, the streams would basically play indefinitely.

   It is worth noting that even when the PC was plugged directly into the analog telephone adapter (ATA), it was just as difficult to establish connections. Left unadjusted, when a connection was established, the 'connect' speed was 49kbps, but the data throughput was terrible, ranging from 8kbps to 24kbps at best. (You can Estimate dialup modem throughput (w-gregg.juneau.ak.us/ 2003/ text/ 2003k00-dialup-throughput) by visiting pages set up for that purpose. To get a true reading, it is important to use a test that times the transfer of noncompressible data, such as already-compressed JPG, MPG, or random data, and you need to run the test a few times because results can be somewhat variable, particularly for VoIP.) Using secret modem commands so that the modem would not try to connect at any speed faster than 40kbps (the U.S. Robotics command is AT&N26) made an enormous difference, raising throughput to 36-37kbps. But handshaking at this reduced speed remained very difficult, in one case, nearly 20 calls had to be made before the modems successfully linked up. It is difficult to choose between an acceptable connect speed of 40kbps with 36-37kbps of throughput but fewer than 50% of dial-in attempts succeeding, or a degraded connect speed of 34kbps with 31kbps of throughput that only improves the reliability of connecting to just over 50% of calls.

   After many complaints, including written complaints to the RCA and the FCC, the customer received a letter advising that a problem had been uncovered in the GCI switch and providing a small credit (around $20). Additionally, the modem firmware has been updated. A retest in June 2008 found that connections over the VoIP could finally be made reasonably reliably at 40kbps, delivering an acceptable throughput, though one significantly less than copper wire service. Whether the random disconnects remain a problem was not tested.

Better than cellphones for emergencies, but worse than traditional phones

"We don't think you should use VoIP as your only phone service...." That is what Consumer Reports said in February 2005. They didn't think the VoIP service could be counted on to reach 911 reliably, because it connects to the 911 system in a non-standard way. And they thought the inability of the technology to work in an extended power outage was a major drawback. At first, that may seem a bit picky. But there is something in what they say, if for a slightly different reason: if the network goes down, it's not just your phone, but everyone who is on the network who loses service. We've had a startling number of outages in Juneau during 2007.

• Tue. Mar. 13, 2007, no service from 11:45 a.m. to 9:00 p.m. My sister called me on a cell phone at about 11:45 a.m. to advise her listed line was out. KINY Radio reports about 500 customers were affected and service not restored until 9:00 p.m.
• Tue. Apr. 24, 2007, no service from 6:00 p.m. to 2:00 a.m. KINY Radio reports 2,500 customers affected.
• Sun. May 20, 2007, no service from 2:00 p.m. to 4:16 p.m. KINY Radio reports 500 customers affected.
• Tue. Nov. 11, 2007, no service from 10:15 p.m. or earlier to at least 11:00 p.m. I discovered the outage when Dad failed to call me back, so around 10:15 p.m. I walked over to his house. It turned out that he had lost dial tone. Dad tells me it had also happened earlier in the day. I visited until 11:00 p.m. and dial tone still had not been restored. A recording on 611 informed me that GCI already knew about the problem and no repair call was needed. But I held for repair and the repair person knew nothing about it. Dad's data line, which is now loop start copper, was not affected.
• Tue, Nov. 27, no service from about 6:00 p.m. or earlier to about 6:45 p.m. I was at Dad's. My sister called on the radio to advise that she couldn't get through on the phone. I tried to call her. There was no dial tone for several seconds, then dial tone arrived but was nonresponsive: dialing her number resulted in dead air. I hung up and tried again, and there was no dial tone. I walked over to her house. She had dial tone, but when she tried calling people, she was getting receiver off hook signal, fast busy signal, dead air, and the like. She also has GCI VoIP digital service. By about 6:45 p.m., the phones started working again.
• Thu Dec. 6. Around 7:30-8:30pm, From home (loop start copper) I called my sister (VoIP digital). It was busy. A bit later, I called again. It was still busy. Because of so many false busy signals when calling lines that are on the new VoIP digital system, I was suspicious. I almost called my sister on the radio to check. Then I called my Dad (VoIP digital). It was also busy. So I figured maybe they were on the horn to each other and it might be a long wait. I went to the store. After I got back, I called my sister (VoIP digital) again. The line was still busy. Now I was pretty sure it was another false busy signal. I called my Dad (VoIP digital). We visited a bit. I called my sister (VoIP digital). She answered. She informed me that they had not been on the phone except for having encountered a four-way cross connect.
• Sat Dec. 8. Around 10:15pm, from my Dad's (VoIP digital) I called my sister (VoIP digital). There was no answer. But they have an answering machine. Thinking I might have misdialed, I dialed again. There was still no answer. So I walked over. My sister was watching TV. The phone had not rung.
• Sun Dec. 10. Around 9:30-10:00 p.m., from home (loop start copper), I tried to call my Dad (VoIP digital). It was busy. And near 10:00 p.m., I concluded that it was pretty unlikely they were on the phone. I could not call them on their data line (loop start copper), as we have to leave the bell off to prevent GCI telemarketers from tricking them into converting it back to VoIP digital. Not wanting to worry about 80 year olds all night, I walked over to do a welfare check. They were not on the phone and had not been, and when I picked up the voice line (Voip Digital) there was no dial tone. I went into the office where there is a two line phone and started to call 611 gci repair. I heard faint receiver off hook signal and noticed the light blink on line 1 (voice, VoIP digital). So I checked it. It had dial tone. Dad walked in, and on rechecking, the dial tone was gone again. So I used line 2 (loop start copper) to call 611 gci repair. They asked if the light was blinking on the modem. They all were. They thought it might mean a receiver is off hook somewhere, but I just unplugged the phone cable from the back and it made no difference. All modem lights were blinking. Repair had me press a reset button in a hole on the back. After a bit, a more ordinary light pattern appeared and line 1 (voice, VoIP digital) had dial tone again.

A number of customers found the reliability problems intolerable and switched back to copper wire phone service for service reasons, from need for reliable internet dialup to reliable faxing to a mother needing reliable service when her children became ill.

Another problem, which we had through the end of 2007, was rather comical: the four way cross connect. This problem, new with the VoIP local service, also infected copper wire service. Jane calls John at the same time that Mary calls Tom. Jane is connected to Tom and discovers she got a wrong number. The comical part is that John's and Mary's phones both ring. If they both answer, they can't figure out why they are speaking, since neither one placed a call. If one isn't home and their answering machine picks up, the other party is really nonplussed. And if neither are home, the two answering machines take a message from each other. It's really bizzare. And copper wire customers can be on the receiving end of this nonsense.

Problems continue in 2008

Starting the weekend of November 1, 2008, the busy signal went on strike. I was about to write that the GCI VoIP cable digital local phone service in Juneau seemed to have improved sufficiently this year to be tolerable for voice. But at about this time, I started getting rather irritating communications from my father. He would call and complain that he was really worried about me because he'd not been able to get through. He is in his in 80's, and I kind of tersely told him that I've not a little kid any more and if my line is busy, it simply means I'm busy and he shouldn't bug me about it. But I should have known -- it wasn't my Dad's fault, it was his digital GCI service acting up again. It turned out that no matter who he called locally, if they are already on the phone, he just got a dead line. So we called repair. Every day. For a week. The repairman came by and after probably over an hour finally gave up on fixing the busy signal, putting in an order to switch Dad's line back to loop start copper wire service instead. That was evidently the only way to fix the problem. Meantime, I learned from my niece, who was also back on the digital service, that when she called people who were on the phone, she too was getting a dead line instead of a busy signal. Evidently, then, this started happening to everyone on the digital service. I'm sorry, but I think the provision of busy tone when you call a busy line is a pretty basic part of phone service, and I think it is pretty shocking that after a week of daily calls the phone company didn't yet know that they had a system problem. It would be nice to tell the Regulatory Commission of Alaska to jack up the phone company, but they have no jurisdiction, and it's basically pointless to tell the FCC. While looking up this problem on the web, I was startled to discover that at least one manufacturer of VoIP equipment is actually selling ATA's (Analog Telephone Adapters) that have a variant of this problem:

Description: Customer A calls X. Customer B simultaneously calls X. As a result, customer B does not get any tone, indicating a seemingly "dead line." Customer B should get the busy tone. Workaround: None. Thompson, Customer Release Note ST780 (WL) R6.2.T (Aug. 2007) (E-DOC-CRN-20070712-0009) (available Nov. 2008 from speedtouch forum (www.speedtouchforum.de/ Daten/ FW/ 780i/ E-DOC-CRN-20070712-0009_V1.0_public.pdf) (1M PDF),

Unbelievable. Some companies are actually selling VoIP hardware that is known to be defective. If you are a small business, this is a disaster. If a customer calls and gets a dead line, s/he will certainly call a different company and you will certainly lose sales.

To reiterate, it took multiple calls, but we got a repairman to come to Dad's house to fix the missing busy signal problem. He swapped out the ATA. This didn't fix the problem. He called the GCI central office. They said there was no problem on their end. Yet even with his butt set plugged in directly to the ATA, so that inside wiring could not be involved, calling a number known to be busy resulted in at most one beep of busy tone followed by dead silence. After repeated calls to GCI, the repairman, actually from Jeffus & Williams under contract to GCI, put in an order to put the line back to copper wire service. It was evidently the only way to restore real telephone service that actually provides a busy signal when you call a busy number.

It took another week, but by November 14, Dad's voice line was converted back to good old loop start copper wire service and busy tone was again working when appropriate. Dad and I had to take the ATA back to GCI. A representative indicated that they had been having trouble with their system. No shit.

My major concern after this was that GCI's telemarketers would start calling Dad and my stepmother to ask them to 'upgrade' from the copper wire service to their digital service.

It happened Wednesday December 10. I happened to be visiting. Around dinner time, my stepmom answered the phone. She said it was GCI. She handed me the phone. I explained that we had already tried the digital service, found it unsatisfactory, and switched back to copper wire. The representative made some comment about cable TV and then launched into her script about wanting to offer us an 'upgrade' to their digital telephone service. I cut her off, said we'd had the service, it was totally unsatisfactory, we had filed complaints with the FCC and the Regulatory Commission about it, and please don't call us again. But they will. And my over-80 year old folks are liable to fall for it. I'm now wondering what the best way is to handle this. Here are some potential options:

• File a lawsuit in Juneau Superior Court to ask for a restraining order prohibiting GCI from contacting my dad and stepmom again. But it usually costs at least about $20,000 to go to court. I'm not making that up. Dad is an attorney who practiced until around 2001, and I worked for him for a few years. It is very expensive to go to court. Still, we do have the money. It is an option.
• Write to the Attorney General of Alaska to ask them to prosecute GCI for false and misleading advertising and fraudulent marketing, since there is no technical sense whatsoever in which this digital service can properly be described as an 'upgrade'.
• Have the phone numbers changed to be in my name, and buy a listing for Dad and Anne, so that they aren't on the account and have no legal power to accidently 'agree' to 'upgrade'.
• Switch to ACS and pay perhaps $300 a year extra to get internet service.

Are there other options? Is there some way to stop GCI from calling? Can we cut off their telemarketer's phone service if they call again? Email me if you have a found an answer. Please. I'm beginning to wonder if God could ressurect Ma Bell to put a stop to this nonsense. I'm a big believer in competition, but I believe in regulated competition. The FCC preemption of state regulation of local phone service via local VoIP is arguably unconstitutional and ought to be struck down. But getting that done is beyond my pay grade.

What else could cause your VoIP to fail?

• Someone unplugs the interface box. This in fact happened at my Dad's house. Someone vacuumed and forgot to plug the box back in. Eight hours later, the phones went dead. Unlikely? I used to be an Electronics Technician for the USDA Forest Service. One of the most common service calls was to fly to other cities to fix the base station, only to find that the janitor had unplugged it and not plugged it back in. Before you traveled, you could call and get assurances that yes, yes, we have checked, and the base station is plugged in. Upon arrival, it was common to find that it was in fact not plugged in and that nothing else was wrong. And you're not the only one who might unplug it. It could be your spouse, your grandfather who lives with you and has dementia, your 2 year old, your siblings, a maid, a tradesman, or even a dog or cat. It doesn't matter how it happens: eight hours later, your phones go dead. Unplugging of important equipment is a really common failure mode.
• Someone plugs in a space heater. It trips the circuit breaker. But no one notices that the branch circuit is out. Eight hours later, your phones go dead.
• A windstorm takes the power out and in an unusual circumstance, AEL&P is unable to restore power to your neighborhood within eight hours. So your phones go dead. And neighborhoods in Juneau do indeed occasionally suffer power outages longer than eight hours in duration. It's unlikely in the downtown, but can and does happen in outlying areas, such as past Auke Bay. And it is likely that a time of an extended neighborhood outage is the very last time you would want your phone, your lifeline to the outside world, to fail.
• GCI's cable system goes down. When was the last time that the entire neighborhood's phone system was down for scheduled maintenance or unscheduled problems for a few hours? Perhaps not in memory, since the regular telephone system is designed to the "five 9's:" 99.999% reliability. When the last time that the entire neighborhood's cable TV and modem system was down for a few hours? That happens often enough that GCI has a place on their web site where they report system status. They even make you sign a disclaimer acknowledging that you will not have 911 service when their network (think: cable TV) is down. Of course, you don't have 911 service when the traditional phone network is down either -- but it happens so seldom that they don't make you sign in advance that you understand that.
• You are trying to call 911, but the system is having one of those transient glitches in which calls to known good number are rewarded by a dead line, a fast busy signal, or a recording that the line is not in service. Unlikely? In February 2005, Consumer Reports said one of their panelists trying to call home had to try six times before the call went through. There is no reason to believe that calls to 911 could not experience this: in the same article, Consumer Reports indicated that calls to 911 do not have the "kind of fail-safe connection available with regular land-line service."
• You are speaking to the 911 operator, and the system summarily drops your call. Occasional dropped calls are a known problem of VoIP systems. Ordinarily that might merely be an inconvenience, but in a 911 situation, it could be catastrophic.
• You move across town and take your cable and phone modems with you. Now the 911 operator gets a readout telling them the wrong street address. Think it can't happen? A toddler in Calgary recently died because of VoIP service. The family had VoIP service and had taken it with them when they moved. But the address information in the VoIP providers database had not been updated. The ambulance was dispatched to the wrong city, and as a result the child died. Even the U.S. FCC warns that VoIP is not reliable for 911.

There is a real public policy issue with any lifeline system that can fail so easily. But the FCC, under its dubious reading of the interstate commerce clause, has preempted states from dealing with the issue. The FCC's solution is to have people sign a form indicating that they understand that 911 may fail if they move, unplug the box, the power fails, etc. In my view, it's doubtful whether anyone under the age of 30 or over the age of 65 is competent to sign such a form. And even if the person who signs is competent, what about the other people who rely on the phone? The issue of the box being unplugged or moved to another address by someone who doesn't understand the consequences because of inexperience or cognitive issues is really troubling. The power issue might be resolved by requiring local VoIP to be line-powered, or to have a UPS like alarm signaling lack of power. The 911 issue might be resolved by requiring a monthly test to verify that the reported address is still current. The FCC's solution -- disclaimer forms -- is really grossly negligent in terms of protecting public safety.

The conclusion seems clear: ideally, for emergency service, for faxing, and for dial-up modem service, everyone should have at least one regular, 'old fashioned' copper wire telephone line. On the other hand, many people currently only have a cell phone, and no land-line at all. And cell phones complete calls even less reliably and don't even provide a street address to the 911 operator. VoIP service is certainly better than that. But it does not measure up to traditional phone service in a number of important respects, and where possible, in my opinion, it is unquestionably better to keep at least one regular phone line available.

Can you switch back?

According to Consumer Reports for Feb. 2005, the FCC determined in November 2004 that VoIP is largely exempt from state regulation. But GCI remains certified as a regulated telephone company, so a customer who wants the regulated service should be entitled to it. I checked with the Regulatory Commission of Alaska (RCA) and the consumer protection people indicated that there shouldn't be a problem in switching back to traditional regulated phone service. So if you have already switched a line to VoIP, and have found that it is not satisfactory, for example, because you use a fax and it is no longer usable, a simple call to GCI customer service (800-800-4800) should get back traditional phone service. If it doesn't, write to GCI, P.O. Box 99016, Anchorage, Alaska 99509 by certified mail, return receipt requested, and request a resolution. If nothing satisfactory is forthcoming, you can file a complaint with the Regulatory Commission of Alaska. They take complaints by phone, by email, by fax, and by mail. Another option, and one that nearly always get results, is to switch to ACS (or call 800-808-8083). They offer grade A telephone service, dial-up internet, high speed internet, and more. That approach lets the marketplace take enforcement action. Either way, you can get standard, regulated, copper wire telephone service back. But it may take some time.

• One customer's dial-up modem/fax data line was inadvisably converted by February 22 to the VoIP service. The customer remembers receiving a call from the GCI telemarketer and stating that they would need to check before agreeing to any change. GCI responded to an email inquiry and indicated that the service should be 'at least as good' but could not confirm that anyone had tested it with dial-up internet. The customer has no recollection of agreeing to switch. But one day the customer said GCI was coming by to work on the lines, and it was too late to stop the conversion. Since then, we have learned that one approach used by some GCI telemarketers is to state that they are upgrading to digital and need to make an appointment for the switch. It is not, in this instance, presented as optional. But when the consumer in good faith ordered local phone service from a state certified utility, and reasonably expected that the service would be the state regulated tariffed service, it seems false and misleading to actually install service that is actually so fundamentally different that it is exempt from state regulation.
• The dial-up line, after conversion, presented severe problems with fax and moderate problems with dial-up internet. When discussing the issue with a telephone repairman on a Friday night, I indicated that the fax really has to work, and unless they had a magic fix it would have to be switched back. He indicated that he would call ACS and initiate the switch, and it should be done in 48 hours. But it wasn't done by late on Monday, so I called telephone repair to check. No such order had been placed. They explained that the repairman was mistaken, that only customer service can place the order with ACS, and that it can take 6 to 7 business days to get done. They connected me with customer service, who took, the order, and suggested calling Thursday for a date by which it might be done.
• That request for conversion back was processed. But a repairman came out and tried to fix the problem with inside wiring fixes. The request to convert back to copper was to be put on hold until the customer could could test. It was just as unsatisfactory. And the customer tested with a 100 foot twisted pair extension cord connected directly to the box, to eliminate inside wiring, and had exactly the same issues. So a call was made to go back to copper. There was not going to be a problem, but it was later learned that the request had actually been canceled.
• The next request, of course, involved yet another 7 day delay. It was to be implemented March 14 between 1 and 3 p.m. No one showed. A call was rewarded with the news that the appointment was between 3 and 5 p.m. Apparently, it was changed without customer notification. It was also a no show. A call said to wait a while, they might be running late. No luck. Another call to inquire of when we can reschedule advised we don't reschedule until 7:00 p.m. A call at 7:00 p.m. was rewarded with the information that they can't reschedule because the department that handles that closes at 6:00 p.m.
• On Thursday afternoon, a repairman called and announced he was coming by. At first, he found ACS had not restored dial tone via copper wire, but that was resolved almost immediately. He wondered why we were converting back and after hearing about the data problems started in on the inside wiring. It is true that it is an old house with poor inside wiring and wire nuts instead of proper telephone connectors. But it had already been verified by (1) it having worked fine before the switch; (2) another technician having tried the inside wiring ruse; and (3) the customer directly plugging the PC into the interface box, that inside wiring was not the issue. The customer's BS quotient was exceeded, and the repairman was told he only needed to provide dial tone to the ACS demarcation box and the customer would get the dial tone to the computer. In short, the customer ran the phone company off the premises.
• Results: the customer got dial tone to the computer. Connect speed: 49.333 kbps. Throughput: 46 kbps. Dial-in attempts: 6 of 6 succeeded. Disconnects in the first hour: none. Compare this to Voip: Connect speed: reduced to 40 kbps to get tolerable throughput. Throughput: 36-37 kbps. Dial-in attempts: 1 in 2 fail. Disconnects in the first hour: nearly 100%. Clearly, for dial-up modems, copper wire runs circles around VoIP.

Fraudulent Telemarketing?

I have learned that GCI's telemarketers are calling saying that GCI is converting to digital and they need to make an appointment to upgrade the service. I've received the calls personally. It is not presented as optional, but as a mandatory change. Because the Regulatory Commission of Alaska has told me that in fact people are entitled to the state-regulated tariff service, I think that is misleading. I also thing it is misleading to sell the service as an upgrade. It has a lower signal to noise ratio than the copper wire service. Internet connections are unreliable and much lower speed. Fax connections are more difficult. Callers may receive slight echo not present on the analog service. Dial tone and busy signal both seem to disappear from time to time, rather inexplicably. Long power outages disrupt service. Even 911 service is less reliable. Thus, I am at a loss to understand how it can legally be sold as an upgrade. It may indeed be acceptable for many people, but technologically, it's unquestionably inferior.

Conclusion

Bottom line? Don't let them convert a phone line used for dial-up modems of any kind to the VoIP system, and don't let it be your sole phone. For data and fax, at best, it is marginally commercial -- usable only by operators and experienced subscribers. And for some data applications, where getting disconnected unpredictably is intolerable, it is definitely not commercial. If you have a superspeed cable modem, the most expensive cable TV package, don't use those old-fashioned fax machines, don't care if your callers hear echo, all trunks busy, or get a dead line instead of busy signal, can live without dial tone periodically, wouldn't call 911 even if you were dying, and think $136 a month is a good deal, you will probably be happy downgrading your phone to digital VoIP service in exchange for all that fancy stuff. Otherwise, stick with plain old telephone service -- the kind that's been working reliably since 1949.