# Presentation: 742253

## The Internet and the Deregulator’s Dilemma

- Stagg Newman
- Chief Technologist
- Federal Communications Commission
- Columbia University
- October 4, 1999

## Purpose

- To analyze:
- What is different about the Internet from a technology and business perspective that account for its success
- The  two key regulatory issues arising from convergence and the Internet
- A proposed new deregulatory framework for the communications industry
*To provoke and challenge your thinking*

## Disclaimer

-     The opinions expressed in this talk are those of the speaker and do not represent official FCC policy or the views of the Commissioners.
- Acknowledgement
- 	The author thanks Dale Hatfield, Chief of the Office of Engineering and Technology, and Bob Pepper, Chief of the Office of Policy and Plans who supplied material for this talk.

## Riddle for the Audience

- Suppose the Internet existed and the telephone  and television didn’t.
- Now suppose A. G. Bell, IV, invented the telephone and television.
*Would voice be an information service?*
*Would broadcast services be information services?*
*Would cable TV be an information service?*

## Outline

- Introduction - Public Policy Issues
- Disruptive Technologies and Virtuous Cycles
- Mass Market Access to the Internet
- What’s Different About the Internet
- Info Services, Telco Services, B/C Services?
- A New Deregulatory Framework

## The Telecommunications Act of 1996A Mandate for Competition and Deregulation

- “AN ACT To promote competition and reduce regulation in order to secure lower prices and higher quality services for American telecommunications consumers and encourage the rapid deployment of new telecommunications technologies.”

## 1996 Telecommunications Act

- Signed February 8, 1996
- Goals:
- Dismantle barriers to entry
- Give new entrants a chance
- Give incumbent telcos access to long distance market
- Give consumers the benefits of competition (choice, lower prices, new services)
- Let Congress, not the courts, set policy

## Where the FCC Fits In

- Focus on infrastructure to ensure
- incentives for higher bandwidth
- competition among suppliers of bandwidth (aka telcos, broadcasters, cable, wireless, satellite)
- connectivity is available to all Americans & to serve education, and by extension US competitiveness
- Advocate competition for new technology
- convince other governments that traditional monopoly regulation should not be applied to new technologies

## ‘96 Telecom Act - Section 706Advanced Telecommunications Incentives

- Encourage the deployment of  Advanced Telecommunications to
- All Americans
- Particularly to elementary and secondary schools
- FCC and State Commissions shall
- conduct regular inquiries as to deployment
- remove barriers and promote competition
- High speed switched broadband for voice, data, graphics, and video using any technology

## Two Critical Public Policy Issues

- Mass Market High Speed Access to the Internet
- The breakdown of the Information Services, Telecommunications Services, Broadcast Services, Cable TV Services distinction

## Outline

- Introduction - Public Policy Issues
- Disruptive Technologies and Virtuous Cycles
- Mass Market Access to the Internet
- What’s Different About the Internet
- Info Services, Telco Services, B/C Services?
- A New Deregulatory Framework

## Virtuous Cycle

- Applications
- Growing

**Processor**
**and Memory**
**Costs Dropping**

**Speed **
**and Capacity**
**Increasing**

- The Computer Industry

## NETWORK DEMANDParallels with the Computer Industry

**“****Free” MIPS is to the  Computer Industry**
**as**
**“****Free” B/W will be to the  Communications Industry**

- The desperate search for bandwidth is generating billions of
- investment in the latest technology that will destabilize the industry.

## Growth of Internet Users

**Number of molecules in the universe**

**Number of humans on the planet**

**55 million users today**

**9 million users in 1995**

## NETWORK DEMANDThe Explosion in Traffic Demand

- NETWORK DEMANDThe Explosion in Traffic Demand

- 0

- 100

- 200

- 300

- 400

- 500

- 600

- 700

- 1995

- 96

- 97

- 98

- 99

- 0

- 1

- 2

- 3

- 4

- 2005

- 800

**Today’s**
**Traffic**

**Tomorrow’s**
**Traffic**

## UNDERLYING TECHNOLOGYEnablers Are Here

- UNDERLYING TECHNOLOGYEnablers Are Here

**Network **
**Technology**
**& **
**Architectures**

**Optical Networking**

**Wireless**

**Market Forces**

**New Services**

**Technology**

**Digitization**

**Deregulation**

**Exploding Demand**

**Internet**

**New**
**Products**

**Service **
**Providers**

## Virtuous Cycle

- Applications
- Growing

**Optoelectronics,**
**Radio, Processing **
**Costs Dropping**

**Affordable**
**Bandwidth**
**Increasing**

- The Communications Industry

## Performance Improvements

- Optical Technology - Doubling every year
- Wireless - 10x to 100x improvement in 2-5 yrs
- Chip Technology - Moore’s Law (2X in 18 mo)

## Reality Check

- Infrastructure Costs and Build
- First Telegraph - Baltimore to Washington
- 10s Bps, crew of 5-10, 1 mile per day, 1 regulator- 45 days
- First major long haul fiber - NE Corridor system
- 100s Mps, crew of 5-10, 1 mile per day, 100s regulators, 4 yrs
- Operations and customer acquisition

## Convergence????Digital Destabilization - Yes!!!

- Technology Outpacing Regulation is not new, but
- The pace of change is accelerating
- All boundaries are being destroyed
- Competition is accelerating
- Intelligent Networks and Smart boxes obsolete regulation

## Regulatory Perspective:  Circa 1980Service, Franchise, Technology, & Price Regulation

- Customers

- Cable

- Computers - The World of Bits - No regulations

- Broadcast

- Telephone

- Electricity

- ?

- Franchises
- Spectrum Rules
- Advertising Rules (min/hr)
- Etc.

- Franchises
- Rate of Return
- Tariffs
- Etc.

- Franchises
- Rate of Retrun
- Tariffs
- Etc.

## Digitization Hypotheses

- The introduction of digital technology into a market creates competition and obsoletes regulation because of:
- Exponential destabilization of Price/performance
- Reduced costs of entry
- Enhanced feature differentiation
- Power of microelectronics, S/W, radio, and photonics come together
*Regulated Communications Regimes Are All Going Digital*

## Digital TechnologyCreator of market chaos

- Expands markets, fragments markets, obsoletes regulation

**Market Size**

**AT&T**
**POTS**
**Private lines**
**Data Modems**
**Business Nets**

**Market **
**Share**

**1965**

**1984**

**PBXs**

**Private Data Networks**

**Private Voice Networks**

**Other IECs**

**Celllular**

**RBOCs**

**ATT**

**1996**

**CAPs**

**ISPs**

**Other**

## Intelligent Boxes and Intelligent People Can Know Much About

- Exploit Regulatory Cracks
- Arbitrage
- Circumvent Geography
- Abuse Tariffs
- Hide Content

**Using Digital Bit Streams to**

## Digitization Destroys Compartmentalization

- A Bit does not know if its Broadcast, Cable, Telephony, Computer Networking, or Electronic Print
- Bits can be transmitted over cable, satellite, terrestrial radio, power line carrier, copper or fiber
- Bits can be readily stored
- Bits can be processed anywhere
- Customer devices can readily manipulate bits

## Regulatory view: circa 1997Digitization Blurs all Boundaries

- Regulatory view: circa 1997Digitization Blurs all Boundaries

**Customers**

**World of Digital Content**

**Broadcast**

**Telco**

**Cable**

**Elco**

**Facility**
**Based ISP**

## The Paradigm Shift

- Moving from circuit-switched voice to packet-switched open internetworks
- Decoupling network software from hardware
- Users benefit immediately from rapid innovation in software, rather than waiting for extensive switch upgrades
- Ability to take advantage of scale economies at the edge of the network
- Voice as one form of data, rather than struggling to transmit data through networks optimized for voice
- Traditional regulatory, policy, and business models no longer work

## The Foreseeable Future

- All applications -- voice, data, image, video, multimedia -- carried by
-  digital,
-  packet switched,
- broadband,
-  low latency networks
- 	networks
- Those networks will be based on the Internet Protocol -- IP.

## Outline

- Introduction - Public Policy Issues
- Disruptive Technologies and Virtuous Cycles
- Mass Market Access to the Internet
- What’s Different About the Internet
- Info Services, Telco Services, B/C Services?
- A New Deregulatory Framework

## ACCESSING THE INTERNET

***Today’s Options***

**Internet**
**Access**
**Points **
**(IAP)**

**Internet**
**Backbone**

**Private Lines**
**Fast Packet**

**Cable TV**

**xDSL**

**Wireless**

## MASS MARKET ACCESS

- Customer Requirements - A Hypothesis
- Flat rate or very predictable pricing
- User friendly
- Customer installable
- Telephony-like ease of use
- Non-disruptive with Telephone, TV
- LAN-like thruput
- 128 kbs now
- Mbs soon

## xDSL SolutionsIt’s more than Pairs from a Wiring Closet

***xDSL Solutions******It’s more than Pairs from a Wiring Closet***

**Existing**
**Fast Packet**
**Network**

**Internet **
**Backbone**

**ADSL**
**line**
**.**
**.**
**.**

**ADSL**

**ADSL**

**Central Office**

**T1, T3, OC-x**

**Fast packet**
**statistical**
**multiplexer**

**IAP**

**.**
**.**
**.**

**10 BT/**
**ADSL**

## CABLE MODEMSEarly lead but growing pains

**O/E**

**Video**

**Head End**

**O/E**

**fiber node**

**optoelectronics**

**O/E**

**Internet **
**Backbone**

**IAP**

**Cable Modem**

**Network**
**Controller**

**10 BT**

**set top**

**T**

## WIRELESS 

***WIRELESS ***
***Wireless - will it be competitive?***

**Telephone**
**Line**

**Telephony**
**Net**

**Internet Backbone**

***RJ***
***11***

**PC**

**Low Speed**
**Modem**

**Digital****Signal****Processing**

**Hybrid**
**mux**

**Telephone**
**I/W**

**10 BT**

**set top**

## HIGH-SPEED ACCESS COMPARISONSCost Elements per SubscriberA SWAGActual costs are very location dependent

- HIGH-SPEED ACCESS COMPARISONSCost Elements per SubscriberA SWAGActual costs are very location dependent

**CPE**

**Network**

**Installation**

**xDSL**

**$400**
**$100**
**$200**

**$400**
**$400**
**$50**

**$600**
**$100**
**$200**

**Cable ****Modems**

**Hybrid**
**Wireless**

## Outline

- Introduction - Public Policy Issues
- Disruptive Technologies and Virtuous Cycles
- Mass Market Access to the Internet
- What’s Different About the Internet
- Info Services, Telco Services, B/C Services?
- A New Deregulatory Framework

## Architecture Perspective: POTS

_**APPLICATION**_

_**NETWORK**_

- Financial Services

- Info Browsing

- Video Server

**Voice**

- ATM

- Frame Relay

- DBS

- Wireless

- LANs

- SMDS

**PSTN**

- Electronic Mail

- Analog
- not packet
- not broadband
- not correct separation
- not driven by competition

## Architecture Perspective: ISDN

_**APPLICATION**_

- Financial Services

- Info Browsing

- Video Services

**ISDN**

- Electronic Mail

- ATM

- Frame Relay

- DBS

- Wireless

- LANs

- SMDS

_**NETWORK**_

_**BEARER SERVICE**_

**Voice**

- Digital
- barely packet
- not broadband
- not correct separation
- not driven by competition

## Advantages of Packet Switching

- Users only consume network resources when they actually generating information
- Captures the benefits of statistical multiplexing
- Allows multiple, simultaneous applications to be supported in a suitably equipped end user computer using a single hardware port

## Advantages of Packet Switching

- Provides bandwidth on demand
- Facilitates the simultaneous carriage of different types of signals -- voice, data, image and video -- and supports multimedia applications

## Architecture Perspective: BISDN

_**DATA APPLICATIONS**_

- Financial Services

- Web
- Browsing

- Video Services

**Voice**

- Electronic Mail

**ATM**

**SONET**

**DWDM**

**Non- IP Data**

- IP

- Digital
- Packet
- Broadband
- Not correct separation
- Not driven by competition

## Advantages of Packet Switching

- Advantages of packet switching alone do not fully account for the success of the Internet
- Other packet networks preceded the Internet and the Internet protocols
- The Internet versus earlier packet switched networks
- Philosophies or policies regarding overall network designs -- network architectures

## Advanced Internet Architecture

_**APPLICATION**_

- Web
- Browsing

- Video Server

- Voice

**Dial-up**

- Electronic Mail

- Financial Services

**ATM**

**Frame Relay**

**Satellite**

**Wireless**

**LANs**

**SMDS**

**IP**

**Cable** **Modem Access**

**Private Lines**

- ADSL

**DWDM**

**SONET**

- Digital
- Packet
- Broadband
- Correct separation
- Driven by competition

## Lessons

- For IP based networks adding new technology  and services is  easier and costs less
- Internet approach will always reach more customers than any other network
- Internet approach will attract more developers, leading to more rapid service evolution

***Voice and Video over the Internet are becoming real!***
***Convergence is happening.  It’s the Internet!!***

## Advantages of the Internet -- Openness

- Openness
- Standards and specifications are open, not closed or proprietary
- Standards/specifications are freely available without restrictions on use
- Standards/specifications are developed in open meetings

## Advantages of the Internet -- Openness

- Advantages of Openness
- Facilitates access by end users
- Facilitates the Interconnection of private and public networks of which the Internet is composed

## Advantages of the Internet -- Openness

- How the Internet differed from other attempts to develop open, packet-based networks (including the OSI model)
- Emphasis on developing running code and then proceeding with standardization rather than the other way around; penalties of the latter include delay and complexity
- Running code and then standardization coupled with the open architecture facilitates change and encourages the development of new services and applications

## Advantages of the Internet -- Modularity and Protocol Layering

- The Internet protocols are arranged in essentially independent, unbundled layers with the Internet Protocol (IP) itself at the “waist” of the stack
- The protocol stack broadens above the waist to support a wide range of transport and applications layers including email, the Worldwide Web, file transfer protocols, remote login, etc.

## Advantages of the Internet -- Modularity and Protocol Layering

- The protocol stack broadens below the waist to ride on a wide range of underlying networks using a variety of technologies including frame relay, ATM, ADSL, radio links, fiber optic systems, etc.

## Advantages of the Internet -- Modularity and Protocol Layering

- Modularity promotes fair and open competition between and among providers of the different layers
- This modularity/stratification coupled with openness facilitates the introduction of new transmission technologies and new applications thereby stimulating innovation

## Advantages of the Internet -- Control at the Edge of the Network

- In the Internet architecture, the routers internal to the network perform what is basically a “dumb” function of forwarding packets according to routing tables that are created on a largely decentralized, dynamic basis.

## Advantages of the Internet -- Control at the Edge of the Network

-  In the Internet architecture, the control is shifted to increasingly powerful computers that reside at the edge of the network (e.g., on the customers premises)
- Because these powerful computers reside at the edge of the network, they are under the control of the end users and content providers

## Advantages of the Internet -- Control at the Edge of the Network

- Because of the control exerted at the edge of the network, services – including content – can be created without the cooperation or even knowledge of the underlying network provider

## Advantages of the Internet -- Control at the Edge of the Network

- Note that this model of service creation is very different from the model used in the Public Switched Telephone Network; in the PSTN, service creation occurs within a much more centralized, tightly controlled process

## Other Factors

- The “network effect” or “network externality” -- the value of a network tends to increase more than proportionally as its connectivity increases (Metcalfe’s Law
- Latent or derived demand for a ubiquitous, mass-market data communications network for applications such as chat groups and email

## Question

- 	Why did the Internet succeed while other open packet networks, particularly those developed by PTTs and regulated common carriers fail?

## Possible Answers

- Worldwide deregulation/unregulation
- inexpensive private lines in U.S.
- flat rate dial access in U.S.
- World Wide Web fueled demand
- open access to the world of content
- greatly reduced cost of S/W development
- Growth of data compared to voice
- Technology that rides Moore’s Law
- Driven by hyper-competitive industry

## Outline

- Introduction - Public Policy Issues
- Disruptive Technologies and Virtuous Cycles
- Mass Market Access to the Internet
- What’s Different About the Internet
- Info Services, Telco Services, B/C Services?
- A New Deregulatory Framework

## Regulation of Standalone Industries (Silos)The regulatory regimes in countries circa 1995.

- Customers

- Cable

- Computers - The World of Bits - No regulations

- Broadcast

- Telephone

- Power

- ?

- Franchises
- Spectrum Rules
- Advertising Rules (min/hr)
- Etc.

- Franchises
- Rate of Return
- Tariffs
- Etc.

- Franchises
- Rate of Return
- Tariffs
- Etc.

## Old Rules and New Realities

- Old Rules based upon industry/regulatory silos
- Telecom services distinct from enhanced (info) services
- Old Rules based upon non-competitive model
- Assumed natural monopolies or regulated oligopolies
- Protecting incumbents
- Barriers to entry
- Defined industry and service boundaries
- Consumer protection through rate regulation
- Government decides winners and losers

## Regulatory Treatment of Communications Services

- Basic service:
- Pure transmission capability
- Includes circuit- and packet-switching transmission services
- Subject to regulation as telecommunications
- Information (Enhanced) service:
- Involves computer processing, interaction with customer-supplied information, interaction with stored information
- Includes voice mail, e-mail, and Internet access
- Not subject to regulation
**The Internet is blurring this distinction!!!**

## Difficult Questions Regulators Worldwide Struggle for Answers

- What is a telecom service, what's not?
- If point-to-point data transmission is a telecom service,
- then is a wavelength in a DWDM net a telecom service;
- but then is ATM transport a Telecom service;
-  but then is transport of IP packets a Telecom service;
-  but what if the ISP caches, multicasts, .....
- What if different industries offer the same service?
- ISP access using IP  directly on top of DWDM on fiber as a **CLEC**
- ISP access using ATM on top of ADSL as an **ILEC**
- ISP access using ATM with cable modem as a **Cable Operator**
- ISP access using modified ATM via **Satellite Operator**
- ISP access using private lines as a **Private Operator**
- How do universal service and competition coexist?

## Regulatory Treatment of the Internet WorldwideIncreasingly Controversial

- In most countries Internet access treated as an "info service”
- But what about IP Telephony
**Incumbent telcos**:  "IP telephony is functional equivalent of traditional telecom.  Providers of IP telephony should be subject to telecom regulation"
**Internet community**: "Do not impose archaic regulatory framework on emerging technology."
- More questions w/ Fax, streaming audio/video, ......
- What’s at stake - $Bs, $Bs, $Bs!!!

## The FCC Universal Service Report

- Issued April 10, 1998
- Required by US Congress
- FCC  to evaluate interpretations of definitions in the Telecommunications Act of 1996
- Available online at <http://www.fcc.gov>
- The Issues
- Concern about migration of traffic to the Net
- Fears about undercutting universal service
- “Telecom services” subject to FCC regulation and universal service contribution,  “info services” are not
- How to ensure affordable access, while opening competition and promoting technological innovation?

## The Report to Congress on Universal Service The Internet Sections ( a struggle with convergence) 

**No Intent to Regulate the Internet**
- Telecom Services & Info Services
- Mutually Exclusive
- Enhanced Services = Info Services
- Internet Access Providers are ESPs
- Provision of Transmission for Internet
- Underlying transmission is Telecommunications
- Purchase of Telecom Svcs  by ISP contributes to US Fund
- Contribution by Self Providing ISPs not *currently* required
- Status of IP Telephony

## The Report to Congress on Universal Service Status of IP Telephony

- Computer to Computer IP Telephony does not *appear *to be *providing *a telecom service
- Phone to Phone IP telephony services “appear to present a different case”
- holding out of voice telephony or fax svc
- works with ordinary CPE (touch-tone phone)
- calls use NANP and Int’l equivalent (E.164)
- transmits info w/o net change in form or content
- Not appropriate to make any definitive pronouncements w/o more complete record
- Bell South & USWest letters/USWest Petition

## The Regulators DilemmaThe business reality in most countries circa 1998.

**Customers**

**World of Digital Content**

**Broadcast**

**Telco**

**Cable**

**Elco**

**Facility**
**Based ISP**

- The Regulators Dilemma*The business reality in most countries circa 1998.*

## Convergence and Divergence

- Technology will enable
- (convergence)
- Many  different services (under different regulatory regimes) offered by one provider
- The same service offered by many different providers (under different regulatory regimes
- (divergence)
- Many different architectures with many possible different contentious points of interconnection and access
- The challenge:  Finding the best way to DEREGULATE

## Outline

- Introduction - Public Policy Issues
- Disruptive Technologies and Virtuous Cycles
- Mass Market Access to the Internet
- What’s Different About the Internet
- Info Services, Telco Services, B/C Services?
- A New Deregulatory Framework

## Advanced Internet Architecture

_**APPLICATION**_

- Web
- Browsing

- Video Server

- Voice

**Dial-up**

- Electronic Mail

- Financial Services

**ATM**

**Frame Relay**

**Satellite**

**Wireless**

**LANs**

**SMDS**

**IP**

**Cable** **Modem Access**

**Private Lines**

- ADSL

**DWDM**

**SONET**

- Digital
- Packet
- Broadband
- Correct separation
- Driven by competition

## (De) Regulator’s Dream

- IP separates Services Layer from Digital Access
- Services Layer is fully competitive
- Customers have many choices of ISP
- Customers have many choices of Digital Access

## Assumptions

- The Internet will supplant today’s PSTN.
- Email, WWW, and Broadcast radio are here
- Video and carrier class voice are coming
- A Virtuous Cycle will drive communications.
- Market forces will drive the proper Interconnection and open interfaces.
- Within a few years, most customers will have multiple choices of broadband pipes.

## Deregulator’s Dream: Circa 2002Freedom of Choice

- Customers

**World of Digital Content**

**Backbone Network Providers**

**POTS**

**B/C**

**IWU**

**Digital**
**Bit **
**Pipes**

**Cable**

- Legacy Regs

## ????(Re)regulator’s Dilemma: Circa 2002???Will There be a new Broadband Monopoly?

- Customers

**World of Digital Content**

**Backbone Network Providers**

- Cable TV

- PSTN

- For now:
***Let market***
***work!!!***
***& monitor***

## Bold Ideas for a Deregulatory Future 

- Interconnection through market determination
- Competitive Broadband access
- Universal access instead of Universal Service
- Sunset legacy regulation

## Interconnection 

*ISPs that either self-provide or privately obtain their telecommunications input will not be subject to common carrier regulation provided they follow a general policy of fair and open interconnection. The Commission will carefully monitor this.  ****Only if **** market forces fail to work for Internet interconnection, setup an "Interconnection Commission" as a tribunal of last resort to arbitrate any interconnection disputes  through a process of binding arbitration.*

## Competitive Broadband AccessFCC Actions 

- UNE Rulemakings
- Advances Services Rulemakings
- Collocation, Spectrum Mgmt, Line sharing, etc
- Wireless Spectrum Availability
- 2-Way MMDS, Auctions, Unlicensed Rules, satellite.
- Forbearance and monitoring of cable
- Competition rulemaking
- ROWs, roof rights, etc.
- Access to MDUs, inside wiring, etc.

## Broadband Wireless Internet Access

- Make enough spectrum available for competition and multiple solutions
- Permit flexible use of the spectrum
- Enable competing technologies
- Permit multiple, evolving standards
- Minimal number of rules
- to minimize interference
- to encourage interconnection
- to promote open interface standards

## Universal Access

- Universal access instead of universal service
- Base subsidy to people/institutions in need
- Fund from general revenues or fee on numbers
- All areas should have a least one evolable broadband access network
- Work with Joint Conference to develop national policy with local administration

## Sunset Legacy Regulation

- Challenge
- Develop a blueprint to sunset legacy regulation that encourages investment by incumbents while not permitting anti-competitive exploitation of today’s dominant market position.

## Chaos Isn't All That Bad

- Chaos theory: Complex systems can self-organize
- Benefits of decentralization
- great flexibility
- allows dynamic growth and evolution
- reduced need for (potentially cumbersome) central control
**Difficult or impossible for one firm to dominate**
- new, unexpected competitive alternatives
- With proper incentives, solutions will emerge to meet demand
- Chaos leads to opportunity for the nimble

## Summary

- The Internet has all of the advantages of packet switching in an increasingly data-centric world coupled with the benefits of openness, protocol layering, control at the edge of the network, and a market driven approach.

## Summary

- The Internet has become an open market driven platform upon which individual entrepreneurs and entrepreneurial firms can – and are – creating new businesses and revolutionizing old ones
- Convergence (aka the Internet) will obsolete old business models and old regulations.
- The challenge: developing new deregulatory  legal structures and business models
***To lead, to follow, or to get out of the way***

## Conclusion

- The bandwidth virtuous cycle will fuel the explosive growth of the Info Age.
- Convergence and the Internet will fundamentally reshape the industry.
- The chaos of the market is the best way to meet the thirst for bandwidth.
- The challenge:  Finding the best way to DEREGULATE

## Answer to the Riddle

*YES!*
*Homework Exercise:*
*Given above, rewrite Title II, III, VI of the Telecom Act of ‘96*
*For extra credit:*
*Rewrite the pertinent FCC regulations so that the Telecom Act of  ‘96 does not have to be rewritten*

## For More Information

**FCC Web Site**
- http:/www.fcc.gov