special access

Statement On Public Knowledge’s Call To Delay BDS Proceeding

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Washington, DC, April 18, 2017 – Fred Campbell, director of Tech Knowledge, issued the following statement regarding Public Knowledge’s demand that the Federal Communications Commission (FCC) delay a decision in its Business Data Service (BDS) proceeding:

“Public Knowledge’s call to delay the FCC from acting is Washington hypocrisy at its worst. Just six months ago Public Knowledge ‘urged the [FCC] to proceed quickly to reform the business data service.’ Public Knowledge asked the FCC to act quickly ‘given the fact’ that the agency ‘has been aware of … conditions in the BDS market for over a decade.’ Public Knowledge’s sudden reversal is pure election politics, not data-driven analysis in the public interest.

The latest FCC data shows there is stiff competition in the vast majority of BDS markets and that competition is growing. No single BDS provider controls more than 20% market share, cable BDS services are growing 20% annually, and competitive carriers’ BDS revenue is higher than the BDS revenue of all incumbent telephone and cable providers put together. In short, Public Knowledge should stop calling ‘wolf’.”

Bang Saphan Tech Knowledge promotes market-oriented technology policies on behalf of the public interest. Additional information about Tech Knowledge can be found on our website, techknowledge.center.

Tech Knowledge Statement on FCC’s Business Data Services Proposal

Posted by | Broadband Internet, Regulatory State | No Comments

Haymarket, VA, October 7, 2016 – Fred Campbell, director of Tech Knowledge, issued the following statement regarding the FCC’s proposal to impose new price regulations and classify packet-based business data services as a common carrier service:

“The FCC’s proposal to subject packet-based business data connections to its Title II jurisdiction reveals the terrible truth about Wheeler’s approach to net neutrality — the alleged need to protect edge providers using Title II was merely an excuse for the FCC to regulate the internet from end-to-end just like it once regulated the plain old telephone network.

There is no edge provider justification for the FCC to dictate terms in commercial disputes involving data connections for big businesses. The proposal is nothing more than 1930’s style government intervention for the sake of helping businesses the current administration favors at the expense of those it doesn’t. The other commissioners should reject Wheeler’s latest attempt at government economic planning 2.0 and let all carriers compete on an equal footing.”

Nakhon Pathom Tech Knowledge promotes market-oriented technology policies on behalf of the public interest. Additional information about Tech Knowledge can be found on our website, techknowledge.center.

Tech Knowledge Reply Comments In BDS Proceeding

Posted by | Broadband Internet, Wireless | No Comments

Today, Tech Knowledge filed the following comments at the Federal Communications Commission in its proceeding to regulate business data services (BDS). The complete comments as filed can be downloaded in PDF format HERE. (Note, the HTLM version of the comments printed below does not contain the footnotes provided in the PDF version available at the link above and filed at the FCC.)


Tech Knowledge submits these comments to emphasize a single point: the data does not support arguments that prospective 5G deployments require price regulation of fiber-based wireless backhaul in any market. Read More

Georgetown Analysis Shows FCC Special Access Regulation Intended To Give CLECs Even Higher Profits

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The FCC is examining whether AT&T, Verizon, CenturyLink and other incumbent telephone companies have market power in the market for business data services (also known as “special access”). To hear their competitors like Level 3 and Windstream tell it, incumbent telcos have “locked up” the business broadband market and exercise “overwhelming control … to dictate terms and conditions” in that market. According to a recent study by Anna-Maria Kovacs at Georgetown University, however, these competitors’ services “are far more profitable” than services provided by incumbent telephone companies.

If incumbent telcos could actually exercise market power, they could unilaterally increase their profitability by either (1) charging monopoly prices (i.e., prices that are higher than would occur in a competitive market) or (2) lowering the quality of their services (e.g., by forgoing maintenance or investment in new network capabilities). These results of market power — artificially high prices or lower quality services — are what competition laws are intended to avoid.

Yet the evidence presented in the Georgetown report and the recent, sworn testimony of FCC Chairman Tom Wheeler show that the way incumbent telcos are behaving in the broadband marketplace is the exact opposite of how firms with market power are expected to behave. Read More

Event: Special Access Re-Regulation at TIA Spring Policy Summit 2016

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The FCC appears poised to extend antiquated special access regulations using the pretext that additional asymmetric regulation of new broadband investment would enhance competition.

reshuffling Join Tech Knowledge and IIA on March 9 in Washington, DC for for a timely discussion about the state of competition in the market for business communications services and the FCC’s pending special access proceedings at the Telecommunications Industry Association’s  Spring Policy Summit 2016.

An eminent panel of experts from both sides of the aisle will discuss the issues at stake in the special access debate, including:

  • Bruce Mehlman, Co-Chairman of the Internet Innovation Alliance and former Assistant Secretary of Commerce for Technology Policy
  • Fred Campbell, Director, Tech Knowledge and former FCC Wireless Bureau Chief
  • Hal Singer, Senior Fellow, Progressive Policy Institute and adjunct professor at Georgetown University’s McDonough School of Business
  • Patrick Brogan, Vice President – Industry Analysis, USTelecom
  • Berge Ayvazian, Principle Consultant, Wireless 20/20

Cam Ranh Register: Click HERE.

Where: Hotel Monaco 700 F Street, NW, Washington, DC 20004

When: Wednesday, March 9, 2016, from 1:15 to 2:05 pm

Tell The FCC That Competition And A Monopoly Aren’t The Same Thing

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Fred Campbell’s latest article in Forbes explains why forcing phony competition on fiber investments will only slow the deployment of fiber Internet to businesses and put our global competitiveness at risk. The complete article is available HERE.

Tell The FCC That Competition And A Monopoly Aren’t The Same Thing

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Don’t believe it when the Federal Communications Commission (FCC) says it wants to regulate wholesale access to business fiber connections in order to promote “competition.” The FCC’s plan to impose monopoly regulation on new fiber deployments to businesses indicates the agency has forgotten what “competition” actually means. The plan makes sense only if the word “competition” is replaced by “monopoly.”

Consider this example from a post on the official FCC blog: “Traditional copper network infrastructure has also been a mainstay of competitive (read: monopoly) service purchased wholesale from the incumbent telcos by competitive providers and retailed to businesses, schools, health-care facilities, and other small- and medium-sized institutions.” Read More

CBIT Statement: Federal Communications Commission Embraces Investment Slacker Culture

Posted by | Broadband Internet, Regulatory State | No Comments

Haymarket, VA, August 6, 2015 – Fred Campbell, Director of the Center for Boundless Innovation in Technology, released the following statement with respect to the Federal Communications Commission order forcing Verizon, AT&T and other incumbent telephone companies to sell their new fiber infrastructure to their competitors at regulated rates that are based on outdated copper infrastructure:

“The FCC took two huge steps backward today when it voted to give America’s investment slackers a free ride on the backs of the country’s biggest investment heroes, AT&T and Verizon. When Congress adopted the Telecommunications Act nearly 20 years ago, it hoped that allowing global companies like Level 3 — known as CLECs — to piggyback on incumbent telephone company networks would prod CLECs to compete by investing in their own network infrastructure. The FCC implemented Congress’s desire to give CLECs a hand while maintaining investment incentives by permitting CLECs to use incumbent telcos legacy copper networks, but not their new fiber infrastructure. The happy result was massive investment in the new fiber facilities that power the Verizon FIOS and AT&T U-verse services.

Today’s FCC order upset this successful balance by forcing Verizon and AT&T to sell their new fiber facilities to their CLEC competitors at legacy copper network prices. The FCC’s change in course is a government handout of the worst sort — one that rewards the sloth of investment slackers while punishing the industriousness of the companies who are betting the most on America’s future. The FCC’s new approach is sure to help CLECs make more money at the expense of consumers, but will do nothing to promote sustainable competition or the deployment of new fiber networks. What a sad day for innovation, investment, and competition in America.”

FCC Tariff Decision Is Not Consistent with the IP Transition, the National Broadband Plan, or the Law

Posted by | Broadband Internet | No Comments

Yesterday’s decision requiring AT&T to continue offering seven-year term discounts on POTS lines while the FCC conducts a meritless investigation is more than a drag – it is a government shackle on the deployment of modern IP-based infrastructure to rural and low-income consumers.

In early 2010, the Federal Communications Commission (FCC) issued the National Broadband Plan (Plan) to ensure that all people of the United States have access to broadband Internet communications. The Plan concluded that “broadband is a foundation for economic growth, job creation, global competitiveness and a better way of life” and urged that everyone “must now act and rise to our era’s infrastructure challenge.” (Plan at XI, XV) Yesterday the FCC threatened to turn its back on this call to action when it suspended revisions to AT&T tariffs that sought to stop offering term discount plans of five to seven years for 1960s era “Plain Old Telephone Service” (POTS) technology using circuit switched “special access” lines. The FCC suspended the tariff revisions for five months to investigate their “lawfulness” (even though the remaining tariff rates have already been conclusively presumed to be just and reasonable).

Ironically, at the open Commission meeting on Thursday, the Technology Transitions Policy Task Force will provide a status update on the National Broadband Plan’s recommendation that the FCC eliminate—within the next five to seven years—the requirement that AT&T and other carriers offer POTS technologies using circuit-switched networks (known as the “IP transition”).

Why would the FCC open a five-month investigation on Monday to determine whether it is “lawful” for AT&T to stop providing long-term discounts for services using outdated technologies the FCC will discuss eliminating altogether at its meeting on Thursday? Read More

The Telecommunications Act of 1996 Turns Seventeen with No Future Plans

Posted by | Broadband Internet, Regulatory State | 2 Comments

Today marks the seventeenth birthday of the Telecommunications Act of 1996. Since it became law nearly two decades ago, the 1996 Act has largely succeeded in meeting its principal goals. Ironically, its success is becoming its potential failure.

By the time most teenagers turn seventeen, they have already begun planning their future after high school. Their primary school achievements are only a beginning in a lifetime of future possibilities. For most legislation, however, there is no future after the initial goals of Congress are achieved. Fortunately, the seventeen year-old 1996 Act isn’t like most legislation.

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