Yesterday, we filed comments on the 25th public notice released by the FCC on the national broadband plan. (Not including the original notice of inquiry.)  At this point, we’re all suffering from a bit of comment fatigue, and I’m sure that includes the people at the FCC who are writing the plan. But this particular public notice is a big enough deal that I hope it draws the best ideas out there.

This time the FCC asked about the transition from legacy networks and services to broadband IP networks. While it may seem like this transition is both inevitable and well underway,  there are some significant regulatory barriers to its completion. In particular, legacy universal service and intercarrier compensation policies stand in the way of completing this transition in a timely or efficient manner. In our filing, we propose a firm deadline for the transition from the POTS business model to an IP-based broadband environment, as one of the most significant actions the FCC can take to achieve the goal of ubiquitous, affordable broadband for all Americans:

Due to technological advances, changes in consumer preference, and market forces, the question is when, not if, POTS service and the PSTN over which it is provided will become  obsolete.…the single most important feature of Commission action at this time is the establishment of a firm deadline at which point the transition will be complete, and we advise the Commission to seek comment on when that deadline should be, taking into account Commission experience in managing the transition to digital broadcasting as well as the retirement of analog cellular networks.

We think the most important thing the FCC can do is to put a stake in the ground and declare an end point to the public switched telephone network. Think of it as a DTV transition for voice communications. Once a date is set, everyone will know how long we have to eliminate the legacy programs and make the country 100% broadband.

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