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FCC Opposition to Petition for Declaratory Ruling regarding the Rate for Cable System Pole Attachments Used for VOIP Service

Submission Date: 
09/24/2009
I.   Introduction.
 
     The Commission should deny American Electric Power Service Corporation, Duke Energy Corporation, Southern Company, and Xcel Energy Services, Inc.’s (“Petitioners”) Petition for Declaratory Ruling (“Petition”)1 for the following reasons:

  • Applying the Telecom Rate to pole attachments used by cable operators to provide VoIP telephony services will raise costs to consumers and impede broadband deployment.
  • There is no valid statutory or policy basis for applying the Telecom Rate to pole attachments used for providing VoIP telephony services.
  • The Commission should seek to provide regulatory parity among cable operators and competitive telephone service providers.
  • Electric consumers are not subsidizing cable companies.

 For these reasons, the Commission must deny the Petition.

AttachmentSize
2009 09 24 ACA Comments Responding to Utilities re VoIP Dkt 09-154 FINAL as filed.pdf170.01 KB

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