It should come as no surprise that AT&T believes the Federal Communications Commission should substantially deregulate many important elements of its fixed network framework as the public switched telephone network is shut down and replaced by an Internet Protocol driven replacement.

Though some might bristle at the notion, the FCC itself has concluded that universal service itself should focus on broadband access, not voice service. The corollary is that all applications and services in the future will be IP based, and should use frameworks that have proven to work in all IP application businesses.

Given that about 4.5 dollars are earned in the global telecom business for every one dollar of fixed network revenue, some might argue that regulators should be careful about applying onerous regulations on a business that already has been eclipsed by wireless, and might arguably be described as a declining business.

Among the steps seen as “critical” is a definite and firm deadline for ending all requirements related to the old PSTN, a step that would encourage investment in the new network and also encourage customers to switch.

AT&T also prefers that all carrier services be regulated using the IP-enabled services framework, which would make telco-provided applications “information services” subject to minimal regulation only at the federal level.  

The Commission could permit service providers to offer DSL or other broadband transmission services on a common carrier basis if the carriers so choose, but in no event should a provider be required to do so.

Section 214 rules should be dropped or modified in ways that encourage retirement of TDM-based networks and services, again to encourage adoption of IP network services.

“Eligible telecommunications carrier” status, which allows a carrier to receive universal service support, should be an optional decision any carrier can make. In other words, carriers that don’t take the money also are free of the obligations USF imposes.

Interconnection rules also should make clear that after the PSTN sunset, no carrier is required to interconnect using TDM. AT&T also argues that a market-based, regulation-free interconnection regime that has applied to IP-based interconnection for decades should be established for new IP network services as well.

To the extent that the TDM network continues to operate, all networks that wish to connect using TDM should pay the actual costs of such interconnection to the legacy network.