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.

Agents have a similar worry. One reason agents worry is because selling Managed Services in Consultative Selling is very different than selling a PRI or T1. Very Different!

It's transition time - time to take some sales training (Call RAD-INFO!)

For value-added resellers who sell IT services, the Cloud is still an opportunity. Here's 3 ways VAR's can profit from the Cloud:

One: partner with SAAS providers to get residual commissions from customers you bring to them. It isn't much money, but every stream of income counts. (I'd rather have 25 small streams of income than 1 big one).

Two: someone has to the integration and migration. Migrating databases to SAAS requires labor. IT shops can get paid for that. Integration with the SAAS provider and the client company employees is another space that needs to be filled. (VAR's could just re-bill the SAAS with a support or management fee).

Finally, the management piece. Remember, that not every application and certainly not all data will be moving to the cloud. Some of it will be a hybrid solution of private cloud and public cloud. You know what becomes important? Access, security and backup.

By Access, I mean ways to access the data in the cloud: Internet Access, MPLS or VPN. With Redundancy and reliability, too.

By security, I mean that private clouds coupled with lots of government regulations mean that security on the WAN as well as the LAN will be important - and likely too complicated for any in-house tech department. Access to the Access, if you will.

Lastly, data backup, email archiving and storage will be even more important as we move to the cloud. Someone has to manage that. It could be you.

In the Agent World, we have TEM and TAM. VAR's will need something similar.

TEM is telecom expense management (and sold as software-as-a-service, btw). Even circuits that I did not sell to the customer can be checked and inventoried on a TEM platform. Bill reconciliation is one piece of it, but also as offices open and close, employees leave and join, connections will need to be moved, changed, added or terminated. TEM helps to watch all that.

Close to that is TAM, telecom asset management. Laptops, EVDO cards, cellphones, data cards, routers, switches, IP phones - all these hardware assets that an employee or very small office may have - need inventory management. When the employee leaves, don't you want his hardware back? Don't you want to know how many data cards and data plans are in service? TAM.

VAR's could do something similar. In the security realm, companies would like to know that when they fire Al, he can be locked out of all data, systems and networks. That's your job!

Seth Godin says a Linchpin manages chaos, makes the complex simple. That's the Value.