It is a niche offering that is used as an alternative to traditional telephone services. Comments of Level 3 Communications at 7. Because industry has recognized that the use of legacy assistive devices, such as TTYs, may be problematic in IP networks, it is working to resolve this issue. This is the result that disability advocates, industry, and the Commission seek. Because industry is already testing to ensure the compatibility of TTYs in IP networks, the Commission should not adopt rules requiring TTY compatibility or testing.
Regulation imposes costs.
Particularly when it mandates the use of specific technologies or solutions, it tends to stifle competition and innovation, thereby depriving consumers of product and service improvements. Because regulation constrains investment and growth opportunities, the costs of regulation are particularly burdensome to nascent industries such as IP telephony. The Commission should be reluctant to risk these adverse consequences in the absence of any demonstrated need to do so. The record demonstrates that an FCC mandate is not necessary to guarantee the accessibility of IP telephony. Nonetheless, if the Commission believes it is appropriate to consider the regulation of particular IP voice applications, then it should do so only in a separate 5 The V. 18 standard accommodates the five major non-proprietary text telephone systems that operate globally.