Sunday, June 29, 2003
By Jeff Pulver
I received the following email from David Young at Verzion with regard to the Verizon comments on the FWD Petition. A copy of the Verizon filing has been posted to: ( http://pulver.com/fwd/vzfwd.pdf ).
---------- Forwarded message ----------
Date: Mon, 17 Mar 2003 07:59:06 -0500
From: david.e.young@verizon.com
To: jeff@pulver.com
Subject: Verizon Comments
Jeff,
FYI - Just wanted to share our comments with you. In the end, we agreed
with your petition - FWD should not be regulated under Title II as a 'telecommunications service', although we do not believe the FCC should make their determination until they have completed their work on the regulatory framework for broadband services and associated applications. They have 3 proceedings underway right now that address this issue in both the DSL and Cable Modem environments. Hopefully these will be completed some time this summer.
Regarding the particulars of our comments, we agree, as Bruce said in your petition, that FWD dial-up is not an information service. We did disagree regarding 'telecommunications' and do believe that the end-to-end voice transmission capability created by FWD does constitute 'telecommunications'. However, just because a service is or has some 'telecommunications' components, there is no need to require that the service be offered as a common carrier service under Title II. Instead, the FCC can classify it under Title I and deregulate it, just like they
did with CPE. We think this is what should be done after the broadband
proceedings are finished
Best regards,
-David
I received the following email from David Young at Verzion with regard to the Verizon comments on the FWD Petition. A copy of the Verizon filing has been posted to: ( http://pulver.com/fwd/vzfwd.pdf ).
---------- Forwarded message ----------
Date: Mon, 17 Mar 2003 07:59:06 -0500
From: david.e.young@verizon.com
To: jeff@pulver.com
Subject: Verizon Comments
Jeff,
FYI - Just wanted to share our comments with you. In the end, we agreed
with your petition - FWD should not be regulated under Title II as a 'telecommunications service', although we do not believe the FCC should make their determination until they have completed their work on the regulatory framework for broadband services and associated applications. They have 3 proceedings underway right now that address this issue in both the DSL and Cable Modem environments. Hopefully these will be completed some time this summer.
Regarding the particulars of our comments, we agree, as Bruce said in your petition, that FWD dial-up is not an information service. We did disagree regarding 'telecommunications' and do believe that the end-to-end voice transmission capability created by FWD does constitute 'telecommunications'. However, just because a service is or has some 'telecommunications' components, there is no need to require that the service be offered as a common carrier service under Title II. Instead, the FCC can classify it under Title I and deregulate it, just like they
did with CPE. We think this is what should be done after the broadband
proceedings are finished
Best regards,
-David
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