USTelecom is an organization made up of ILEC's. The org has filed for forbearance at the FCC on behalf of its members. Not certain THAT is legal.

The petition [pdf] comes from the ILEC executives "essentially telling the FCC that it's time to wake up and smell the coffee--"many rules were adopted in a different era, long before the advent of broadband networks or the creation of the public Internet."," as JSI describes it. JSI continues with, "it might be time for a new regulatory regime as even the 96 Act is becoming less and less relevant with each new cord cutter and cross-platform conglomerate. The petition is also in line with the White House and Congress' push to get the FCC to clean house, and "the Commission's commitment to eliminate unnecessary regulatory requirements.""

The petition states, "Forbearance is warranted because the rules have been rendered obsolete by technological and market changes. From a technological standpoint, the Commission's legacy telecommunications regulations are ill-suited to facilitating, and in fact hamper, broadband deployment." I'm not sure that's true. It hasn't hampered DSL; the LEC's have by not deploying, switching to fiber and, quite frankly, arrogantly thinking that they were still a Monopoly. In every respect, the trouble with ILEC's is NOT the federal (or dwindling state) regulations. The trouble with the ILEC's is a Monopoly Mindset.

They don't choose the best technology nor do the deploy technology well. Mismanaged spectrum just being a symptom.

FiOS failed because the numbers forecast was wrong. Basing it on 50% penetration was a mistake. Not considering that it would take 2 techs all day (or longer) to install triple-play FiOS. Thinking that the CPE - all 4 pieces of equipment - would be cheap to install.

Let's also look at three bigger problems for ILEC's Pensions, Unions, and USF. By shifting to a cellular and entertainment companies, the RBOCs - AT&T and Verizon - are moving toward a non-union shop. AT&T is dealing with CWA union contracts right now - and VZ had to deal with them last year (along with a strike). They want to eliminate the union. Cellular, entertainment, cloud and outsourced services mean less Union liability - and less pension liability. The ILEC's - Embarq, VZ, ATT, Qwest - are sitting on a chunk of pension payments. It's just another example of bad planning by the executives running these corporations. I know in my life time I will see one of these companies file BK papers. With all the debt they have - $109B just for the Big 2 - mixed with declining revenues, pension payments, probably healthcare costs, union troubles and hyper-competition, the C-Suites at the ILEC's - all of them - are as ill-suited to run them as Hesse is to turn Sprint around.

A Forbearance petition is nice, but it won't solve any of their problems.

With USF Reform, the RLEC's - and even some ILEC's (FFW+C) - will be in even more trouble. Not just competition and dwindling access lines, but decreasing government subsidies for those access lines PLUS a requirement to build out broadband, which means CAPEX! It is not a pretty horizon.

As I read this paragraph all I can think is: Monopoly MIndset is the problem, not FCC regulations. And claiming that it is regs that have created the current quagmire is sticking your head in the sand.

"Indeed, the most recent survey by the Center for Disease Control (which has been relied upon previously by the Commission) has found that more than 32 percent of households have completely "cut the cord" and have abandoned their wireline phone altogether. .... At the same time, incumbent carriers compete against a host of providers, including cable companies that offer service to at least 93 percent of American households, already serve approximately 20 percent of the residential voice market, and are the primary provider of residential broadband. Under these competitive circumstances, the current outdated regulatory regime imposes unnecessary costs on a limited subset of competitors to the detriment of these competitors and consumers alike." Plus it's a Duopoly. There isn't much competition in the Broadband space. It's DSL, cable or 3G.

Comments or Oppositions Due: April 9, 2012 TODAY>

And of course COMPTEL has filed opposition.

Category 10 (Service Discontinuance Approval Requirements); Category 9 (Rules Governing Notices of Network Changes); and Category 2: (Open Network Architecture and Comparably Efficient Interconnection Requirements, All-Carrier Computer Inquiry Rules and the Structural Separation Rule) would really make CLEC life miserable.

Think about this when thinking about regulations being the issue: "According to the Telecommunications Industry Association, wireless has become the preferred voice-services option. Wireless revenue in 2012 is forecast at $335 billion, while all other forms of fixed network voice revenue will only total $176 billion ($132 billion for wireline, $38 billion for broadband access and $6 billion in cable/television revenue)." Is it regulations doing this or our mobile culture? De-regulating ILECs will mostly hurt SMB who are the profit center of ITSP and CLEC businesses.

One last point: voice is being replaced by Skype, G+, Facebook, IM, chat, SMS, and other types of communications. These innovations were NOT brought to you by the telcos NOR will any innovation because they have a Monopoly Mindset. And that mindset screams: "We want to make more money off our old plumbing without having to morph, change or innovate!"

There's no fixing that.

I learned a few things at the EarthLink training today in Tampa. EarthLink has 175K business customers and about 3 Million consumers, most of them dial-up customers, providing $20M in free cash flow per month. So of the $1.3B in annual revenue, about $500M is dial-up. ELNK has 4 data centers - Columbia, SC; Rochester, NY; Marlborough, MA; and 55 Marietta.)

The first (or 70+ slides) shows that Pipe is the foundation for Managed Security and other services. However, despite having 28,000 miles of fiber, they don't want to sell transport on it. Even On-Net gets the response that "This is not our sweet spot".

What is the Sweet Spot? As I wrote here, Multi-Location Multi-Access type across LEC's or cablecos.

The partner portal is in development. The customer portal, called myLink, seems cool they way that you can drill done on customer locations in Google Earth and open a trouble ticket.

Agents in the room, called T1 Slingers, asked about DSL, since EarthLink resells ADSL out of 10K end offices through 12 providers. As a resell service, a 1FB is required. And since neither RBOC is really supporting their copper plant and especially not DSL, it leaves the business DSL customer hanging for days when there is an outage. [See my post about Is DSL Done?] 3G/4G wireless backup is my answer for that. There are cool routers that even do it automatically.

The other question centered around T1. "You just are not going to make a living slinging T1's at $400 any more."  PRI's are available east of the Mississippi still, which actually IS an advantage for ELNK. TDM PRI's are still the preferred reliable way to deliver voice to a PBX, especially with alarms, faxes, and elevators.

It was an hour on MPLS. I still find it amazing that almost 9 years after my first MPLS class, we are still presenting the Fundamentals of MPLS. For Agents, it will be about layering on services to the MPLS network. The sticky stuff is value added services.

Retail needs a voice line, some Internet, credit card processing, payroll and data backup. That should actually be a bundle that someone offers. ELNK has the old New Edge AX platform that connects payroll and cc processing to the MPLS Network. Add on a VoIP line and some data backup and there's a bundle. Want to make it stickier? Add network DVR to the service so that those IP surveillance cameras can be viewed from anywhere (and can't be erased locally). Bingo!  (Do you have an opening in Product Management? My resume is here.)

The team mentioned POS, Inventory, HR and Loyalty programs. Do you have those on the AX platform? Those would make some excellent sticky add-ons.

"So we have an Internet T1 service that connects you securely to one of 4 data centers, Mr. Prospect. Do you currently have a payroll service? Are you looking to upgrade your POS? Are you worried about security on your credit card data (PCI compliance)?"

That's where the conversation has to go. Even though the customers just want the access - as cheap as possible - Agents will have to steer the conversation to: applications on top of that access (AOTTA).

So back to MPLS with Type II access. Ethernet is delivered over a Type II DS3 from the LEC. T1 is delivered over the ILEC copper pair. DSL is a resell of the ILEC product offering. Then for outliers to attach to the MPLS network, there is an IPSec GRE tunnel with BYOB (bring your own broadband). Blended Access.

EarthLink is a Sprint MVNO, but it is more for 3G access where there isn't DSL to attached to the MPLS. Also, for the MPLS customers that want to have one bill that included cellular.

Something else I learned: ELNK bought STS because Rolla knew the Mark Amarant, CEO of STS, and STS had a reputation for best practices in on-boarding customers in the Hosted PBX realm. That's smart, because Hosted PBX (like VDI, another product that ELNK is rolling out), requires a detailed on-boarding process from pre-sales through post-sale, including mapping extensions to desktops, extension attributes, handset type, employee training and some on-site installation. EarthLink is not selling Hosted PBX as a stand-alone. You have to buy access from ELNK.

So in summary word of the day: "Blended Access".

Key association: Multi-location multi-access MPLS.