NTIA Question

NTIA Question	Verizon Reference Section(s)
A. What should be the primary policy considerations in formulating broadband policy for the country? Please discuss the relative importance of the following: access for all; facilities-based competition; minimal regulation; technological neutrality; intra-modal competition; inter-modal competition; and any other policy consideration.	III. - New National Broadband Policy Should Remove Regulatory Obstacles to Investment and Deployment
B. How should broadband services be defined? Please discuss (1) what criteria should be used to determine whether a facility or service has sufficient transmission capacity to be classified as “broadband;” (2) how the definition should evolve over time; and (3) the policy implications of how the term is defined.	I.B. - The Broadband Market Is Distinct from the Narrowband Market and is Characterized by Robust Competition
C. Several studies indicate that the rate of deployment of broadband services is equal to or greater than the deployment rates for other technologies. What is the current status of (1) supply and (2) demand of broadband services in the United States? When addressing supply, please discuss current deployment rates and any regulatory policies impeding supply. When addressing demand, please discuss both actual take rates and any evidence of unserved demand. Please also address potential underlying causes of low subscribership rates, such as current economic conditions, price, cost-structure, impediments to the development of broadband content, or any other factor. To what extent has the growth in competition for broadband and other services been slowed by the existing rates and rate structures for regulated telecommunications services?	I.C. - Regardless of Whether Growth is Supply-Constrained or Demand-Constrained, Government Should Let Market Work To Bring Better Services to More Customers II. - The Current Regulatory Environment Discourages the Needed Investments
D. Should government adopt as a goal “access for all” to broadband service? What would be the costs of such a goal? What policy initiatives, if any, should be considered to achieve that goal? Are there areas or persons that are unlikely to be served through marketplace forces?	III. - New National Broadband Policy Should Remove Regulatory Obstacles to Investment and Deployment
E. Do the interconnection, unbundling, and resale requirements of the Telecommunications Act of 1996 reduce incumbent local exchange carriers’ (ILECs’) incentives to invest in broadband facilities and services?	II.A. - Regulations Designed for Traditional Voice Services Have Been Uncritically Extended to Broadband
1. Are there investment disincentives attributable to the regulated rates for interconnection, unbundled network elements, and resold services?	II.B. - Unbundling and Other Wholesale and Retail Requirements Deter Critical ILEC Investments in Broadband Facilities
2. To what extent are those disincentives due to ILECs’ uncertainties about their ability to recover the added network costs needed to accommodate potential requests from competitors? What are the magnitude of those additional costs? What mechanisms could be used to share the risks of those costs efficiently and equitably among ILECs, competitors, or users?	II.B. - Unbundling and Other Wholesale and Retail Requirements Deter Critical ILEC Investments in Broadband Facilities Generally covered in II.B. - Unbundling and Other Wholesale and Retail Requirements Deter Critical ILEC Investments in Broadband Facilities
3. To what extent are the returns on ILECs’ investments in new infrastructure uncertain? Is the uncertainty of gaining an adequate return on each infrastructure improvement (attributable in part to other firms’ ability to use those facilities to offer competing services) significant enough to deter investment?	II.B. - Unbundling and Other Wholesale and Retail Requirements Deter Critical ILEC Investments in Broadband Facilities
4. What are the principal strengths and weaknesses of the FCC’s total element long run incremental cost (TELRIC) methodology? What changes could be made to render TELRIC an effective deterrent to the exercise of market power and conducive to efficient infrastructure investment? Would it be possible to construct an alternative methodology that would not depend on cost information controlled by regulated firms?	II.B. - Unbundling and Other Wholesale and Retail Requirements Deter Critical ILEC Investments in Broadband Facilities
F. Some have suggested that a regulatory dividing line should be drawn between legacy “non-broadband” facilities and/or services and new “broadband” facilities and/or services. Is this a feasible approach? If so, how would it work?	III. - New National Broadband Policy Should Remove Regulatory Obstacles to Investment and Deployment
1. What effects would changes in the regulatory structure for broadband services and facilities have on regulation and competition with respect to voice telephone and other non-broadband services?	III. - New National Broadband Policy Should Remove Regulatory Obstacles to Investment and Deployment III.A. - Broadband Should Be Regulated Under Title I of the Communications Act
2. If ILECs deploy broadband services using a mixture of new and old facilities, will competitors be able to use the older shared facilities that they previously had access to?	II.B.3.b - Deployment of Fiber
3. If ILECs deploy broadband facilities to replace portions of their existing copper plant, will the displaced copper plant give competitors a viable opportunity to offer alternative services? What would be the annual costs to the ILEC (or to a purchaser of the displaced copper plant) of a continuing obligation to maintain that plant?	II.B.3.b - Deployment of Fiber
4. What regulations, if any, should apply to new broadband facilities and/or services to ensure a competitive marketplace?	III.A. - Broadband Should Be Regulated Under Title I of the Communications Act
G. To what extent have competitive firms deployed their own (a) transport, (b) switching, and (c) loop facilities? Are those investments limited to particular areas of the country or to particular portions of communities and metropolitan areas? What market characteristics must exist for competitors to make facilities-based investments? Do competitors have the ability to deploy their facilities in ways that minimize costs and facilitate efficient network design?	I.B.2. - Robust Competition Within and Between Delivery Technologies
H. What cable companies are currently conducting trials to evaluate giving multiple Internet service providers access to broadband cable modem services? Describe the terms and conditions of ISP access in such trials. What technical, administrative, and operational considerations must be addressed to accommodate multiple ISP access? How can cable firms manage the increased traffic load on their shared distribution systems caused by multiple ISPs?	Not Addressed
I. What problems have companies experienced in deploying broadband services via wireless and satellite? What regulatory changes would facilitate further growth in such services? Is available spectrum adequate or inadequate? What additional spectrum allocations, if any, are needed?	Not Addressed
J. How should the broadband product market be defined? What policy initiatives would best promote intra-modal and inter-modal broadband competition?	I.B. - The Broadband Market Is Distinct from the Narrowband Market and Is Characterized by Robust Competition
K. Would it be appropriate to establish a single regulatory regime for all broadband services? Are there differences in particular broadband network architectures (e.g., differences between cable television networks and traditional telephone networks) that warrant regulatory differences? What would be the essential elements of a unified broadband regulatory regime?	III. - New National Broadband Policy Should Remove Regulatory Obstacles to Investment and Deployment
L. Are there local issues affecting broadband deployment that should be addressed by federal policies? Please provide specific information or examples regarding these problems. Should fees for rights of way and street access reflect costs in addition to the direct administrative costs to the municipalities affected? To what extent do state laws and regulations limit municipalities’ ability to establish nondiscriminatory charges for carriers’ use of public rights-of-way? Please discuss the most appropriate relationship between federal, state, and local governments to ensure minimal regulation while removing disincentives or barriers to broadband deployment.	III.C - The Nation Needs a Truly National Broadband Policy
M. Are there impediments to federal lands and buildings that thwart broadband deployment? Please provide specific data. What changes, if any, may be necessary to give service providers greater access to federal property?	Not Addressed
N. With respect to any proposed regulatory changes suggested in response to the above questions, can those changes be made under existing authority or is legislation required?	III.D - Prior Successful Examples of Deregulation Show The Advantages of a Uniform National Policy

NTIA Question

Verizon Reference Section(s)

A. What should be the primary policy considerations in formulating broadband policy for the country? Please discuss the relative importance of the following: access for all; facilities-based competition; minimal regulation; technological neutrality; intra-modal competition; inter-modal competition; and any other policy consideration.

III. - New National Broadband Policy Should Remove Regulatory Obstacles to Investment and Deployment

B. How should broadband services be defined? Please discuss (1) what criteria should be used to determine whether a facility or service has sufficient transmission capacity to be classified as “broadband;” (2) how the definition should evolve over time; and (3) the policy implications of how the term is defined.

I.B. - The Broadband Market Is Distinct from the Narrowband Market and is Characterized by Robust Competition

C. Several studies indicate that the rate of deployment of broadband services is equal to or greater than the deployment rates for other technologies. What is the current status of (1) supply and (2) demand of broadband services in the United States? When addressing supply, please discuss current deployment rates and any regulatory policies impeding supply. When addressing demand, please discuss both actual take rates and any evidence of unserved demand. Please also address potential underlying causes of low subscribership rates, such as current economic conditions, price, cost-structure, impediments to the development of broadband content, or any other factor. To what extent has the growth in competition for broadband and other services been slowed by the existing rates and rate structures for regulated telecommunications services?

I.C. - Regardless of Whether Growth is Supply-Constrained or Demand-Constrained, Government Should Let Market Work To Bring Better Services to More Customers

II. - The Current Regulatory Environment Discourages the Needed Investments

D. Should government adopt as a goal “access for all” to broadband service? What would be the costs of such a goal? What policy initiatives, if any, should be considered to achieve that goal? Are there areas or persons that are unlikely to be served through marketplace forces?

III. - New National Broadband Policy Should Remove Regulatory Obstacles to Investment and Deployment

E. Do the interconnection, unbundling, and resale requirements of the Telecommunications Act of 1996 reduce incumbent local exchange carriers’ (ILECs’) incentives to invest in broadband facilities and services?

II.A. - Regulations Designed for Traditional Voice Services Have Been Uncritically Extended to Broadband

1. Are there investment disincentives attributable to the regulated rates for interconnection, unbundled network elements, and resold services?

II.B. - Unbundling and Other Wholesale and Retail Requirements Deter Critical ILEC Investments in Broadband Facilities

2. To what extent are those disincentives due to ILECs’ uncertainties about their ability to recover the added network costs needed to accommodate potential requests from competitors?

What are the magnitude of those additional costs? What mechanisms could be used to share the risks of those costs efficiently and equitably among ILECs, competitors, or users?

II.B. - Unbundling and Other Wholesale and Retail Requirements Deter Critical ILEC Investments in Broadband Facilities

Generally covered in II.B. - Unbundling and Other Wholesale and Retail Requirements Deter Critical ILEC Investments in Broadband Facilities

3. To what extent are the returns on ILECs’ investments in new infrastructure uncertain? Is the uncertainty of gaining an adequate return on each infrastructure improvement (attributable in part to other firms’ ability to use those facilities to offer competing services) significant enough to deter investment?

II.B. - Unbundling and Other Wholesale and Retail Requirements Deter Critical ILEC Investments in Broadband Facilities

4. What are the principal strengths and weaknesses of the FCC’s total element long run incremental cost (TELRIC) methodology? What changes could be made to render TELRIC an effective deterrent to the exercise of market power and conducive to efficient infrastructure investment? Would it be possible to construct an alternative methodology that would not depend on cost information controlled by regulated firms?

II.B. - Unbundling and Other Wholesale and Retail Requirements Deter Critical ILEC Investments in Broadband Facilities

F. Some have suggested that a regulatory dividing line should be drawn between legacy “non-broadband” facilities and/or services and new “broadband” facilities and/or services. Is this a feasible approach? If so, how would it work?

III. - New National Broadband Policy Should Remove Regulatory Obstacles to Investment and Deployment

1. What effects would changes in the regulatory structure for broadband services and facilities have on regulation and competition with respect to voice telephone and other non-broadband services?

III. - New National Broadband Policy Should Remove Regulatory Obstacles to Investment and Deployment

III.A. - Broadband Should Be Regulated Under Title I of the Communications Act

2. If ILECs deploy broadband services using a mixture of new and old facilities, will competitors be able to use the older shared facilities that they previously had access to?

II.B.3.b - Deployment of Fiber

3. If ILECs deploy broadband facilities to replace portions of their existing copper plant, will the displaced copper plant give competitors a viable opportunity to offer alternative services? What would be the annual costs to the ILEC (or to a purchaser of the displaced copper plant) of a continuing obligation to maintain that plant?

II.B.3.b - Deployment of Fiber

4. What regulations, if any, should apply to new broadband facilities and/or services to ensure a competitive marketplace?

III.A. - Broadband Should Be Regulated Under Title I of the Communications Act

G. To what extent have competitive firms deployed their own (a) transport, (b) switching, and (c) loop facilities? Are those investments limited to particular areas of the country or to particular portions of communities and metropolitan areas? What market characteristics must exist for competitors to make facilities-based investments? Do competitors have the ability to deploy their facilities in ways that minimize costs and facilitate efficient network design?

I.B.2. - Robust Competition Within and Between Delivery Technologies

H. What cable companies are currently conducting trials to evaluate giving multiple Internet service providers access to broadband cable modem services? Describe the terms and conditions of ISP access in such trials. What technical, administrative, and operational considerations must be addressed to accommodate multiple ISP access? How can cable firms manage the increased traffic load on their shared distribution systems caused by multiple ISPs?

Not Addressed

I. What problems have companies experienced in deploying broadband services via wireless and satellite? What regulatory changes would facilitate further growth in such services? Is available spectrum adequate or inadequate? What additional spectrum allocations, if any, are needed?

Not Addressed

J. How should the broadband product market be defined? What policy initiatives would best promote intra-modal and inter-modal broadband competition?

I.B. - The Broadband Market Is Distinct from the Narrowband Market and Is Characterized by Robust Competition

K. Would it be appropriate to establish a single regulatory regime for all broadband services? Are there differences in particular broadband network architectures (e.g., differences between cable television networks and traditional telephone networks) that warrant regulatory differences? What would be the essential elements of a unified broadband regulatory regime?

III. - New National Broadband Policy Should Remove Regulatory Obstacles to Investment and Deployment

L. Are there local issues affecting broadband deployment that should be addressed by federal policies? Please provide specific information or examples regarding these problems. Should fees for rights of way and street access reflect costs in addition to the direct administrative costs to the municipalities affected? To what extent do state laws and regulations limit municipalities’ ability to establish nondiscriminatory charges for carriers’ use of public rights-of-way? Please discuss the most appropriate relationship between federal, state, and local governments to ensure minimal regulation while removing disincentives or barriers to broadband deployment.

III.C - The Nation Needs a Truly National Broadband Policy

M. Are there impediments to federal lands and buildings that thwart broadband deployment? Please provide specific data. What changes, if any, may be necessary to give service providers greater access to federal property?

Not Addressed

N. With respect to any proposed regulatory changes suggested in response to the above questions, can those changes be made under existing authority or is legislation required?

III.D - Prior Successful Examples of Deregulation Show The Advantages of a Uniform National Policy