Repealing De-Regulation: How Not to Build a Roadmap Towards an All-IP World

[Commentary] The Federal Communications Commission has circulated an order that would undo more than 12 years of Clinton-era, deregulatory pricing policy on legacy non-packet services. The services in question are called “special access” services – 95% of which are slow 1.5 megabits per second (Mbps) TDM (think POTS) services.

That is not a misprint. We are not talking about 100 Mbps connections – services we should actually be figuring out how to get to more people in more places. We are not even talking about fiber. We are talking about legacy, copper-based services that are so slow the services would not qualify for a single dollar of Universal Service Fund (USF) support if they were deployed to homes throughout rural America under the FCC’s recent USF order. We are concerned about the impact the proposed action is going to have for the overall transition to IP technology that the FCC had begun in that USF order. The transition to IP cannot happen fast enough. The industry needs to move to a more cost-effective, all-IP infrastructure if we are going to remain a globally competitive economic force. In regulatory time, that transition must occur with incredible speed. Once subsidies are removed from TDM/POTS infrastructure, carriers will need to nimbly move to retire that infrastructure to make way for an all-IP world. In the USF order, the FCC took a great step in that direction by declaring the obsolescence of TDM/POTS. To make those investments work, however, there must also be a path away from the costs of the legacy infrastructure.