Introduction and Summary

The Information Technology and Innovation Foundation (ITIF) appreciates the opportunity to comment on accelerating the transition of communications networks in the United States to all Internet Protocol (IP) Technology.[1] ITIF supports the Commission’s suggested approach to “forbear from incumbent LEC-specific interconnection and related obligations in sections 251(c)(2) and (c)(6) of the Communications Act of 1934.”[2] Doing so will align regulations with today’s market realities, ensure that more Americans enjoy the benefits of IP-based networks, and spur the transition to next-generation broadband.

Application of Sections 251(C)(2) and (6) Is Unnecessary in Today’s Broadband Market and Consistent with the Public Interest

These rules were established at a time when a regulated monopoly dominated the broadband market. Today’s market is entirely different, as technologies such as fiber, fixed wireless, coax cable, and low-earth-orbit satellite now offer substitutable broadband services. This technological convergence creates greater competition in the broadband market and improved outcomes for consumers, like lower service prices and bundle options.[3]

Today, over 94% of broadband serviceable locations have at least two providers to choose from, meaning these outdated regulations are no longer relevant and should be eliminated.[4] The application of these outdated provisions is thus illogical and creates inconsistency across the market. Consumers have benefited from more modern technologies, so requirements that cling to outdated mandates are manifestly unnecessary and, in the long run, harmful to consumers.

IP-Based Networks Have Better Security for Protecting Consumers

Transitioning networks to all IP technology will better protect consumers at a time when bad actors are frequently trying to defraud Americans via robocall scams. From January to September of 2025, Americans received an average of 2.56 billion robocalls every month. [5] Victims of these scams lost an average of $3,700 in the first half of 2025.[6]

IP-based networks protect consumers from these scams better than TDM networks because they use the STIR/SHAKEN security framework for Caller ID.[7] Wide implementation of STIR/SHAKEN will “reduce the effectiveness of illegal call spoofing, allow law enforcement to identify bad actors more easily, and help phone companies identify calls with illegally spoofed caller ID information before those calls reach their subscribers,” necessitating the transition to everyone using IP networks.[8] Using industry-leading technologies like STIR/SHAKEN across all communications networks will be increasingly important as deep fake technologies, like voice cloning, become more advanced.[9]

Any Resource Spent Maintaining Legacy TDM Networks Could Have Gone to Deploying Next-Generation Networks Instead

Outdated rules, like interconnection requirements under section 251(c)(2) and (6), harm consumers by standing in the way of timely network upgrades and are no longer necessary for creating a competitive market. Forbearance from these rules will prevent unnecessary slowdowns in the pace of progress and will allow incumbent local exchange carriers to upgrade their networks to become stronger competitors and benefit consumers.

Money, workers, and equipment cannot be used on modern high-capacity networks if they are instead being used for upkeep on obsolete ones. [10] Meanwhile, the tools, components, and know-how needed to maintain TDM systems are becoming increasingly rare because they are no longer widely used. That means longer outages and slower repairs for anyone still using TDM.

Conclusion

Now is the time for the Commission to remove unnecessary regulations that stand in the way of next-generation network deployment. Careful, strategic regulatory reform will create a future where every American has a high-speed broadband connection provided by the fastest, most secure technologies available.

Thank you for your consideration.

Endnotes