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GN 14-126: USTelecom Comments on 2015 Broadband Progress Report


USTelecom respectfully submits these comments in response to the Commission’s request for input on additional steps the Commission should take to facilitate broadband deployment by removing “barriers to infrastructure investment” and promoting “competition.” USTelecom is the nation’s oldest and largest association for providers of wired communications, and the overwhelming majority of its members offer broadband in rural and urban areas across the United States. USTelecom and its members strongly support policies that promote continued broadband deployment so that broadband services are accessible to all Americans. In deploying broadband in rural and urban areas across the country, USTelecom’s members have experienced firsthand barriers to infrastructure investment. These barriers include: (1) outdated legacy regulations that apply only to a subset of wireline telecommunications providers that divert substantial resources away from next generation networks; (2) restrictive local rules and regulations that hamper the roll-out of broadband services; (3) the inability to deploy fiber facilities to multi-dwelling units (“MDUs”) due to uncooperative building owners; and (4) the lack of financial support necessary to subsidize broadband deployment in high-cost areas that are otherwise uneconomic to serve. The Commission can and should take at least four steps to eliminate these barriers, which would help ensure that “advanced telecommunications capability is being deployed to all Americans in a reasonable and timely fashion.” 47 U.S.C. § 1302(b). First, the Commission should grant the petition that USTelecom filed in October 2014 that seeks forbearance from various outdated regulatory requirements applicable only to incumbent local exchange carriers (“ILECs”). As USTelecom explained in its Forbearance Petition, unlike most broadband providers – including cable, wireless, and competitive fiber providers – ILECs are not free to focus their expenditures on next-generation networks designed to deliver the higher-speed broadband services customers increasingly crave; instead they “must direct a substantial portion of their expenditures to maintaining legacy networks and fulfilling regulatory mandates whose costs far exceed any benefits.”