By Dave Talbott, AT&T Assistant Vice President of Federal Regulatory

It was back in 2012 when AT&T first proposed to the FCC a path for consumers, businesses, government and telecom providers to transition from last century’s telephone services to this century’s broadband services relying on wireless and Internet Protocol (IP) technology.  As part of that discussion, AT&T, and other companies that offered traditional phone service, began the search for transition solutions that would maximize investment in broadband networks while managing the sunset of outmoded infrastructure and services.

As the FCC’s proposal makes clear, “Every dollar an incumbent LEC must put towards maintaining its aging copper facilities is a dollar it cannot spend on something else, such as fiber deployment.” Thus, moving quickly to replace obsolete networks and services minimizes the investment necessary to maintain them, and frees up investment that can be redirected to building next-generation networks and the more capable services they support.

Since 2012, consumers have doubled down on wireless and IP-based services, largely abandoning plain old telephone services (POTS) in favor of these newer services.  Today, fewer than 10% of households subscribe to POTS in the states where AT&T is the traditional phone provider, demonstrating that consumers are already making their technology transition.  Businesses also have moved on.  When businesses grow, they are faced with a choice of how to meet their expanding communications needs. More and more, they are choosing IP-based services that can carry both voice and large amounts of data as opposed to extending older, archaic services.

With so many consumers and businesses voluntarily transitioning to the newer IP-based and wireless services, the FCC, under the prior Administration, began a series of proceedings to examine what, if any, changes needed to be made to its regulations to facilitate the transition and allow incumbent providers the ability to quickly modernize their legacy networks and services.  As these proceedings concluded in 2015 and 2016, the results in many ways did not facilitate, much less accelerate, the transition to these newer, more capable services.  Indeed, in many ways the orders made the transition more cumbersome. 

For example, in 2015, the FCC adopted copper retirement regulations  doubling the notice period and vastly increasing the paper work required to upgrade copper cables.  As a result, Verizon said it was required to print and mail nearly 200,000 pages of paper notices to 1,650 entities in a single month.  These 2015 rules were followed in 2016 with yet more new regulations to “streamline” the process for discontinuing services that are delivered over obsolescing copper technology. This effort to “streamline” the process instead accomplished the opposite – instead of promoting modern networks and infrastructure that customers want, these new rules increased the complexity, adding more regulations to the transition process.

With the item set for a vote tomorrow, the FCC moves in a different direction. As the NPRM explains, “High-speed broadband is an increasingly important gateway to jobs, healthcare, education, and information. Access to high speed broadband is essential to creating economic opportunity for all Americans. Streamlining rules, accelerating approvals, and removing other barriers, where possible, will better enable broadband providers to build, maintain, and upgrade their networks, which in turn will lead to more affordable and accessible Internet access and other broadband services for consumers and businesses alike.”  We couldn’t agree more.

This NPRM demonstrates that Chairman Pai not only recognizes the importance of the technology transition that is already underway, but that he is willing to tackle the issue head on early in his leadership.  Not only will the proposed rules foster and accelerate broadband investment in unserved areas, they should make telcos more formidable competitors to cable broadband companies. AT&T looks forward to participating in the forthcoming proceeding and supports its goal of providing access to broadband services for all Americans.

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