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The IP transition does not eliminate the public...

The IP transition does not eliminate the public policy objectives of state regulators to provide affordable rates, high quality services, 911 access or broadband deployment, said a National Association of State Utility Consumer Advocates paper Friday in response to an…

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Internet Innovation Alliance paper from Anna-Maria Kovacs, visiting scholar at Georgetown University’s Center for Business and Public Policy. Kovacs’ paper (http://bit.ly/16vzCTf) argues that ILECs are not investing in broadband because of “alleged regulatory obligations that require wasteful investment in ‘duplicate’ copper-based circuit switched network,” said the NASUCA paper. She said the small volume of voice traffic, compared to all IP traffic, negates the importance of policy oversight of the IP transition, and competition gives consumers a “plethora of choices over various platforms” which undermines the need for regulatory oversight, said the NASUCA paper. Kovacs’ arguments on ILEC investment are based on the 2011 Atkinson study, and she misinterprets the study, said NASUCA. The study by Bob Atkinson, Columbia Institute for Tele-Information director-public policy research, came from a report on the state of broadband in the U.S. It shows that ILECs are targeting two-thirds of investment in next-generation technologies rather than the 47 percent identified in Kovacs’ paper, which ignored “substantial portions” of ILEC legacy facilities and investments shared by ILEC broadband facilities. The NASUCA paper said ILECs will operate on a single network during the IP-broadband transition rather than the duplicate networks needed to support broadband that Kovacs argues. Kovacs’ argument is that there are “so many non-voice bits circulating on IP networks” that the relevance of voice is diminished, which NASUCA thinks is unreasonable because the flood of IP-based video traffic does not diminish the importance of high-quality voice services. Kovacs’ assumption that consumers are capable of addressing issues of network reliability and access to emergency services on their own through the purchase of “multiple infrastructures” is unreasonable to NASUCA because not all consumers can afford multiple infrastructures, and wireless and next-generation IP-based technologies are not immune from simultaneous failure. Kovacs’ conclusion that “liberating” ILECs from regulatory oversight will produce additional investment and result in the optimal outcome is not reasonably supported, said NASUCA. Comptel also came out against Kovacs’ paper last month, saying the paper’s claims about ILECs were not supported by the underlying data (CD Oct 22 p6).