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Affordable access to telecommunications networks is extremely important to all Americans. The federal universal service policy is critical to ensuring affordable access for low income Americans and those living in rural and high cost areas, and on tribal lands. Consequently the nation’s commitment to preserving universal service has been longstanding and continues to this day.

While reform of the telecommunications universal service policy is clearly warranted, ignoring the impact of IP-enabled intermodal competition is counterproductive. In an era of IP-enabled convergence, ultimately, proposals and policies that solely focus on one technology platform will be less successful. Too often they will serve as an opportunity for regulatory arbitrage by firms seeking an advantage through exemption. The advent of IP-enabled broadband telecommunications, cable, and wireless platforms offering bundled voice, video, and data services provides a critical opportunity to harmonize a fundamental public interest goal across platforms. As the IP-enabled network platforms evolve and compete, how should the public goal of universal service be met?



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