AT&T seeks state sanction to exit residential premise service, transition customers to mobile wireless

Fellow blogger Steve Blum of Tellus Venture Associates calls bullshit on AT&T for sponsoring California legislation that would relieve it from its premise landline universal service obligations under Title II of the federal Communications Act. Blum has the same problem with the bill as I do. It's dressed up as enabling AT&T to transition from copper POTS service to Internet protocol-based service. As Blum points out, AT&T can do that without the need for enabling legislation. It has chosen not to make an orderly transition over the past two decades. That's a business issue, not one of regulatory policy.

The bill is essentially seeking state sanction to transition AT&T residential landline customers to its mobile wireless service. The thing is, that's not premise service under Title II's universal service obligation. However, with the U.S. Federal Communications Commission not enforcing its 2015 Open Internet rulemaking bringing IP-based services under Title II's universal service requirement, AT&T faces no regulatory consequence for "mobilizing the world" of its residential customers with service not engineered or priced for residential premise service.

Affordability only part of the solution to #homeworkgap; lifeline goes hand in hand with universal service

Boost the homework connection - Times Union: But more can be done. For starters, on Thursday, the FCC is expected to vote on a proposal to modernize a program called Lifeline. Lifeline began more than three decades ago, when President Ronald Reagan was in the White House and rotary phones were still in style. Then and now, this program provides a discount for basic phone service. But broadband is the essential technology of our time. So it's time for the FCC to take steps to make this program broadband-capable and use it to help close the homework gap.

It should be recalled that when lifeline was implemented in 1985, the United States had achieved universal or near universal access for telephone service. Unlike today when according to the FCC's figures released earlier this year, 34 million Americans are unable to obtain telecommunications service capable of delivering high-quality voice, data, graphics and video.

Universal service is an essential component and not separate and distinct from lifeline subsidies for low income households. Another difference from 1985 is telephone service rates were tightly regulated in order to keep them affordable, unlike Internet service today. Notwithstanding the fact the FCC classified Internet service as a common carrier telecommunications utility in 2015 with its Open Internet rulemaking. Prices will naturally tend to be unaffordable for low income households in a price unregulated natural monopoly market.

Local government Internet infrastructure efforts spurred by FCC's non-enforcement of Title II, encourgement of "competition"

EPB Lays Out Plans To Provide All Of Bradley County With High-Speed Internet, TV Service; Cost Is Up To $60 Million - Chattanoogan.com: State Rep. Dan Howell, the former executive assistant to the county mayor of Bradley County, was in attendance and called broadband a “necessity” as he offered his full support to helping EPB, as did Tennessee State Senator Todd Gardenhire. “We can finally get something done,” Senator Gardenhire said. “The major carriers, Charter, Comcast and AT&T, have an exclusive right to the area and they haven’t done anything about it.”

The "exclusive right" mentioned here isn't generally a government-granted or regulated license or franchise to offer Internet service. It's actually a de facto duopoly market of legacy telephone and cable companies. Title II of the federal Communications Act recognizes that telecommunications infrastructure due to its high cost of construction and operation tends to function as a natural monopoly. In accordance with this, the Federal Communications Commission classified Internet as a telecommunications utility under Title II by adopting its Open Internet rules in 2015. But the FCC is currently not enforcing the universal service and anti-redlining provisions of Title II.

It's therefore unsurprising that barring such enforcement, local governments will attempt to fill in the gaps in unserved or poorly served areas in response to their citizens' complaints. When those living and operating businesses in landline unserved areas attempt to order Internet service, without FCC enforcement of Title II the incumbent telephone and cable companies can summarily turn them down without consequence. That leaves them little recourse other than to demand their local elected officials do something to help. The FCC's non-enforcement of these Title II provisions correlates with its current policy position advocating local government "competition" with incumbent telcos and cablecos -- in conflict with its Open Internet rules predicated on a monopolistic and non-competitive market.

Why the “more competition” argument for better Internet service is misguided

Hardly a day goes by without calls for “more competition” as the elixir to make modern Internet-based telecommunications services more widely available and offering better value than those offered by the legacy incumbent telephone and cable companies. U.S. Federal Communications Commission Chairman Tom Wheeler has curiously joined the chorus calling for more competition -- even though his agency and its 2015 Open Internet rules are predicated on regulating Internet service as a natural monopoly common carrier utility.

The problem is telecom infrastructure by nature isn’t a competitive market defined as having many sellers and buyers. There are many buyers but there cannot be many sellers because it’s too costly and economically inefficient to have multiple providers building and owning infrastructure connecting homes and businesses. More competition isn’t a solution here. 

In the states, the legacy incumbents reinforce the notion of competition by blocking projects that would threaten their service territory monopolies. From their perspective, these projects represent competition because they would potentially steal away customers. Therefore, proponents reason, competition must be a good thing if the incumbents oppose it. This however illustrates the faulty reasoning of the “more competition” argument. 

The problem is the pro-competition proponents are buying into the incumbents’ concept of competition -- and not a consumer perspective. For the incumbents, any project that would build infrastructure in their service territories is competition. However, for consumers, having a choice among many sellers is competition. That’s not possible with telecommunications infrastructure. But it is possible if the infrastructure is publicly owned like roads and highways. That would open up Internet service to competition since multiple Internet service providers could offer their services over that infrastructure.

Google fights AT&T, Comcast over Bay Area Google Fiber service - San Jose Mercury News

Google fights AT&T, Comcast over Bay Area Google Fiber service - San Jose Mercury News: MOUNTAIN VIEW -- Google's plan to bring ultrahigh-speed Internet service to the Bay Area has run into a decidedly nontech hurdle: utility poles. To roll out Google Fiber in five Silicon Valley cities, the tech giant needs access to the poles for stringing up fiber cable. But in several cities a who's who of Google competitors are standing in the way. The outcome of the pole fight is likely to have a profound effect on which communities get Google Fiber and which don't. "The infrastructure needs to be mostly above ground," said MoffettNathanson Research analyst Craig Moffett. "You can't proceed ... if you don't have pole access." Similar battles have played out in other cities across the nation, slowing Google's multibillion-dollar program while competitors push forward with their own gigabit-speed offerings.

This illustrates the death by thousand cuts delaying strategy of the legacy incumbent telephone and cable companies to protect their service territory monopolies from interlopers offering telecommunications infrastructure far superior to their own. Those legacy dinosaurs have armies of attorneys prepped to spend years if not decades in the courts erecting legal speed bumps to slow the progress of new entrants like Google Fiber.

Some observers believe the U.S. Federal Communications Commission's promulgation of its Open Internet rules in 2015 deeming Internet service providers common carrier utilities would make pole access easier. But so did others when Congress amended the Communications Act in 1996 to allow competitive local exchange carriers (CLECs) the right to use incumbent telephone central offices and cable plant to offer competing telephone and DSL services that was just emerging in the late 1990s. The incumbent telcos took a decidedly uncooperative and litigious stance to hamstring those providers as well.

These incumbent delaying tactics deepen America's telecommunications infrastructure crisis because they push a nation that's already a generation behind where it should be in terms of replacing its legacy metal cable system with fiber to the premise (FTTP) even more behind the curve. The situation calls for aggressive federal intervention in the form of a crash program to modernize and build out this vital telecom infrastructure to serve the nation's needs in the 21st century.

Obama administration, FCC use incumbent "broadband adoption" talking point designed to shift attention from nation's telecom infrastructure deficiencies

Obama Seeks Broadband for 20 Million More Low-Income Subscribers - The New York Times: The White House also released a report outlining the economic effects of broadband adoption, focused on how families without broadband at home are at a disadvantage in finding jobs.

Once again, the Obama administration and the U.S. Federal Communications Commission conflate access to advanced telecommunications service with its use. They are two different things. The unfortunate use of the term "broadband adoption" parrots a favorite talking point of the legacy telephone and cable companies to take the focus off the nation's telecommunications infrastructure deficiencies that leave some 34 million Americans without access to landline premise service according to the FCC's most recent estimate released in January. After all, the incumbent argument goes, why should we build Internet telecom infrastructure when people aren't using computers at home and therefore not adopting "broadband?"

The term "broadband" dates back to the late 1990s when people were beginning to migrate from narrowband, dial up Internet service to faster "broadband" connections. The context there was personal computer connections to the Internet. Which is also outdated given that today, Internet connections also provide voice and video services that don't require a personal computer.

As long as policymakers insist upon living in 1999, it will be difficult for America to advance into the 21st century.

The Cord Empire Strikes Back - Bloomberg Gadfly

The Cord Empire Strikes Back - Bloomberg Gadfly: Like in the rule-making for set-top boxes, incumbents are showing they're good at putting up roadblocks. AT&T last week sued the city and county and said local officials don't have the authority to regulate attachments to its poles. The telecom company also said tinkering with its equipment might cause outages for its own customers.

As the scuffles show, breaking Big Cable won't be easy. And it is cringeworthy that Americans' best chance to end the cable-and-telecom monopoly may lie with Google, another monopolist. But if the status quo doesn't change, ambitions for more robust Internet connections and more compelling home entertainment options will be realized painfully slowly, or not at all.

Telecommunications infrastructure is a natural monopoly. As such, it warrants strong monopoly regulation such as Title II of the Communications Act (implementing regulations symbolically adopted but not being enforced by the U.S. Federal Communications Commission ) or government ownership. The United States currently has neither and is reaping the consequences in the form of widely disparate access and high prices. The legacy incumbent telephone and cable companies are only all too happy to take advantage.

Why the "last mile problem" is a national problem

In the United States, telecommunications infrastructure deficiencies tend to be defined as a local or "last mile" problem. Residents of homes, businesses and government buildings have orders for services refused by providers because no infrastructure exists to deliver them. Or the cost of service is exorbitant, offering very poor value.

Since the problem typically manifests in a specific neighborhood or at a particular address, it's naturally seen as local problem. Particularly when premises just down the road, around the block or elsewhere in the neighborhood are offered service, a broader selection of services or service at considerably higher value.

But while the problem manifests locally, it is not fundamentally a local problem nor is it confined to a single area with a local root cause or causes. It's a microeconomic issue that occurs throughout the nation due to a common cause: market failure on the sell side due to incumbent telephone and cable companies deeming a neighborhood, road, street or even address not sufficiently profitable to serve -- even if consumers request service. It's known as redlining.

Local problems with local causes naturally lend themselves to local solutions. However, telecommunications infrastructure market failure and redlining and price gouging are not local in origin. They are the national business policy of the dominant incumbent providers that while not legal under current U.S. Federal Communications Commission rules, nevertheless are a widespread pattern and practice affecting similarly situated consumers. The resulting market failure is a national problem because telecommunications infrastructure is essentially interstate. National problems require national solutions.

Wheeler talking through his hat on "cable competition"

Stop the Cap! FCC Chairman Tells Crowd He's "Not Done Enough" to Bring More Cable Competition: FCC Chairman Thomas Wheeler confessed he “has not done enough” to bring consumers more competition to Comcast, Time Warner Cable, Charter, and other cable operators.

This is complete nonsense from Wheeler. Cable is not a competitive market. It exists in a natural monopoly/duopoly market. The chairman can't make it more competitive any more than he could interstate highways if were were head of the U.S. Department of Transportation.

Wheeler's view of the cable market as a competitive one is also at odds with the FCC's adoption one year ago of its Open Internet rulemaking deeming Internet service provided by cable, telephone and other ISPs a common carrier telecommunications utility under Title II of the Communications Act. That title is predicated on a monopoly -- and not a competitive -- market.

FCC declines to forbear universal service requirement; AT&T complains

The FCC’s Half-Shoveled Sidewalk | AT&T Public Policy Blog

This blog post by AT&T notes that it wants the U.S. Federal Communications Commission to relieve it from the obligation to provide landline voice service to all premises in its service territory requesting it, even those in areas not eligible for subsidization through the FCC's universal service subsidy program, the Connect America Fund (CAF). While the subject of the requested relief is voice telephone service, it also extends to Internet service now that the FCC reclassified it as a common carrier telecommunications service subject to the Communication Act's universal service obligations under its 2015 Open Internet Order. 

Although not mentioned in AT&T's blog post, that's the real issue here. AT&T does not want to invest in upgrading and building out its infrastructure to bring landline Internet service to all premises in its service territory -- service that would also be capable of delivering voice service.

Germane to AT&T's complaint are those communities where the cost of deployment is relatively high, but not high enough to justify universal service fund subsidies intended for high cost rural regions. There are a lot of these neighborhoods in its vast service territory because AT&T continues to rely on limited range, obsolete (in its own words) DSL technology to deliver Internet service over aging copper plant that cannot reliably serve premises more than a couple of miles from its central offices or field distribution nodes.

The question going forward is whether the FCC pursuant to its Open Internet order will enforce the universal service obligation on AT&T when a consumer living in one of these unserved areas beyond the range of DSL technology requests Internet service. So far, the FCC has shown no inclination of doing so as AT&T allows its legacy copper plant to rot on the poles. Consumers in these redlined neighborhoods will continue to face the worst of all worlds: no service from their nominal ISP, nor meaningful regulatory action to remedy their plight.

At start of new year, U.S. faces worst of all worlds on federal telecom modernization policy

As 2016 dawns, the United States faces the worst of all worlds when it comes to federal policy on telecommunications infrastructure modernization to ensure all American homes and small businesses have access to landline Internet connections.

In early 2015, the nation adopted policy classifying Internet service as a common carrier telecommunications service. Under the Federal Communications Commission’s Open Internet Order, Internet service is subject to the Communication Act’s universal service requirement, mandating service be provided upon request and barring neighborhood redlining by Internet service providers. Nevertheless, a year later, millions of U.S. premises that attempt to order service will -- as they have for more than a decade -- continue be turned away by ISPs because the FCC is not enforcing these provisions.

Absent regulatory action ensuring compliance with these requirements and frustrated by technologically outmoded, spotty and overpriced Internet telecommunications service, state and local governments are naturally concerned over the adverse economic impacts. Consequently, they’re looking to build their own modern infrastructure. But given the billions of dollars needed to build it, they’ll need substantial financial backing from the federal government. Since none exists or appears to be forthcoming, pressure for strong policy action at the federal level will grow this year.

Internet service franchises offer local governments potential work around to incumbent-sponsored state video franchises

Mediacom questions Iowa City deal with ImOn | The Gazette: Jeff Janssen, vice president of sales and marketing with ImOn Communications, said Tuesday he had not seen the Mediacom letter, but said ImOn has lease agreements similar those with Iowa City in other communities like Hiawatha and Marion.

Janssen also noted a franchise agreement only becomes required when cable TV is added to the list of service offerings. ImOn’s current plans for Iowa City are strictly for telephone and Internet services, he said.

“Franchise agreements are all around cable TV,” he said. “Once we decide, or if we decided to offer cable TV in Iowa City, we would get that franchise agreement, we are required to.”

This issue was bound to emerge sooner or later. In the early 2000s, legacy incumbent telephone and cable companies realized that with the emergence of the Internet and its capability to deliver TV programming, local governments would come under intense pressure from their constituents to require ISPs offering video services to provide Internet connections to all premises under municipal franchise agreements. That would have required substantial capital investment incompatible with the incumbents' business models based on milking their existing wireline "footprints" -- and not modernizing and expanding them to reach every doorstep.

To head off this prospect, the legacy incumbent cable and telephone company lobbies went into high gear to get state laws enacted putting states in charge of so-called "video franchises" and usurping local government authority over video services.

But that left a potential loophole for local governments to franchise Internet services other than video -- what's at issue in this Iowa case. Watch for this gambit to take off elsewhere, especially in states where there are also laws barring local governments from building and/or operating their own Internet services. Local governments could get around both restrictions by creating Internet service franchises and partnering with private ISPs as their franchisees. (Also referred to as "telecommunications franchises" in this item on a recent Brookings Institution panel discussion). They could also pressure the legacy incumbent telephone and cable companies by requiring them to obtain an Internet service franchise serving all premises if they wish to offer Internet services other than video within their jurisdictions.

With interest in wireline-delivered video declining among "cord cutting" consumers and incumbents relying more on Internet service for revenue, that pressure could be quite intense. It would also give localities a powerful tool to bring service to all of their residents and businesses given the U.S. Federal Communications Commission's lack of interest in enforcing its recently adopted rulemaking reclassifying Internet as a common carrier telecommunications service subject to the universal service and anti-redlining provisions of Title II of the Communications Act.

Redlined in Bradley County, Tennessee

Broadband providers battle over service in Bradley County | Times Free Press: Dr. Terry Forshee, president of Cherokee Pharmacy stores in Cleveland and Dalton, is eager for that growth. He said he can't get broadband at his South Bradley County home near Red Clay State Park.

"Charter Communications has had 27 years to bring cable down to me, but I'm still three miles away from service," he said. "I'm waiting, and I call every month to both Charter and AT&T, but I can't get anyone to come to my residence."

Forshee said he is trying to build his obesity education business, Take Charge, into a national company. But that's hard to do when he can't get high-speed Internet service at home.

Sandy Wallis lives in northern Bradley County, less than a quarter-mile from where Charter Communications and AT&T lines end.

"I've lived in my house for 30 years waiting on Charter and AT&T, and I've had to send my kids into town to do their homework (where broadband is available)," she told the Chamber gathering. "We need better service."

The U.S. Federal Communications Commission's Open Internet rules adopted earlier this year require Internet Service Providers fulfill requests for service under universal service and non-discrimination provisions of the Communications Act. Internet service is treated as a common carrier telecommunications utility under the rules. So far, however, there are no indications the FCC is enforcing these requirements in response to reports of ISP redlining such as these.

Telco business model -- not regulation -- curtails infrastructure investment

FCC Forbearance Vote a Welcome First Step | USTelecom: “While more remains to be done to update communications regulation to reflect the realities of today and to level the playing field among wireline, wireless and cable competitors, we applaud Chairman Wheeler for recognizing the importance of giving wireline companies greater freedom to compete, innovate and invest their capital efficiently in modern networks. We urge the full commission to adopt the reforms proposed, and to continue to eliminate antiquated requirements that distort the market, ultimately to the detriment of consumers.”

The legacy telephone company lobby oddly continues to blame regulation for chilling its investment in landline telecommunications infrastructure. The real reason is telcos simply lack a business model that can support extensive, long term capital investment. Regulation or the lack thereof doesn't fundamentally alter the equation.

Transition from copper to fiber plant? Show me the fiber.

From a Communications Workers of America (CWA) Nov. 29, 2015 blog post:

The Communications Workers of America (CWA) filed reply comments at the Federal Communications Commission (FCC) in support of an FCC proposal to adopt clear criteria to evaluate a telecom carrier’s request to discontinue, reduce, or impair legacy service. As communications infrastructure changes from copper to fiber, the fundamental goals of communications policy remain the same: universal service, consumer protection, public safety and national security, and competition.

Note the emphasized text on the transition from copper to fiber. Reading further leads to some major cognitive dissonance that suggests telcos aren't in fact transitioning from copper to fiber but instead retiring their landline outside plant and sending residential and small business customers to satellite and their mobile wireless offerings:

CWA urged the FCC to add an additional criteria: affordability. If an alternative service is more expensive -- such as wireless with data caps or satellite service for Internet access -- then it is not an adequate substitute to legacy wireline service.

Lifeline Internet access first requires universal service -- and FCC not enforcing

L.A. County backs plan to ensure Internet access for seniors and the poor - LA Times: Undergirding the county leaders' support for expanding the lifeline programs is the increasing prevalence of digital technology in the economy and social programs.

"Technology is a key component of our economy, and it is unconscionable that so many county residents lack access to broadband," said Supervisor Hilda Solis, who co-wrote the motion passed Tuesday by the board. "These individuals are being marginalized and ignored."

The policy expressed here is Internet service is now as vital as telephone service was before it. Hence per the position adopted by the county, it too requires a "lifeline" rate subsidy for lower income households to ensure universal access. However, before there can be universal access, there must be universal service.

Early this year, the U.S. Federal Communications Commission adopted its Open Internet rulemaking classifying Internet service as a common carrier telecommunications utility service like telephone service. That legal classification under the Communications Act includes a universal service obligation on providers to offer Internet service to any household requesting it. But thus far, the FCC has shown no inclination to enforce the rule, which became effective in June.

Fiber to the premise can't accurately be described as "on fire" in U.S.

Fiber to the Home Council : Blogs : Survey Says: Speedy Fiber Changing the Way We Use the Internet: Washington, DC (November 16, 2015) – The Fiber to the Home (FTTH) Council Americas has released the results of a survey by RVA, LLC showing that fiber deployments in the United States grew 13 percent in 2015.

“From our survey of North American broadband providers, we’ve found that fiber to the home deployment has continued to grow steadily and 2015 marks the second biggest year for expansion since the technology became available,” said Michael Render, President of RVA, LLC. “The industry is poised for substantial growth over the next five years.”

“Fiber’s on fire in the U.S.,” said Heather Burnett Gold, President of the FTTH Council. “Now, nearly one fifth of the world’s fiber connections are here in the United States. Offering faster speeds and better reliability, fiber sells itself.”

Fiber to the premise (FTTP) Internet service could hardly be described as "on fire" in the United States with some 55 million Americans living in areas of the nation lacking infrastructure capable of supporting high-quality voice, data, graphics and video (i.e. FTTP service) according to a U.S. Federal Communications Commission assessment issued earlier this year. And with slim prospects of obtaining such service in the foreseeable, they would rightfully laugh ruefully at such outlandish claims as overstated hype.

Mobile wireless service won't solve America's telecommunications infrastructure crisis

Congress Seeks to Bolster Nation’s Broadband: (TNS) -- A draft bill making the rounds among Senate lawmakers would require selling even more airwaves than initially agreed to in the recent budget deal.

The language is part of a proposal that would move forward several bipartisan efforts aimed at boosting high-speed Internet access nationwide. The wide-ranging discussion draft bill in the Senate Commerce, Science and Transportation Committee comes after a series of hearings in recent weeks by the committee and its House counterpart where Republicans and Democrats have called for auctioning government-held airwaves to the private sector to increase the amount of wireless spectrum available to carry voice and data over the air. (Emphasis added)

"Boosting high-speed Internet access nationwide" isn't solely about mobile wireless as this story suggests. The biggest component of the United States' Internet access problem is landline-delivered premise -- and not mobile -- service. According to a U.S Federal Communications Commission estimate issued earlier this year, approximately 55 million Americans – about 17 percent of the population -- live in areas unserved for basic Internet service capable of supporting high-quality voice, data, graphics and video. Meeting this need requires fiber to the premise infrastructure. It can't be served by mobile wireless services alone because they can't offer adequate bandwidth to meet premise needs given the multiple connected devices used in the home.

Bath Twp. man battles for broadband connection | www.daytondailynews.com

Bath Twp. man battles for broadband connection | www.daytondailynews.com: Malogorski wants to be able to show photos and videos of his work to the world online, but he has been struggling to get reliable broadband internet service for himself and his neighbors for years.

“I can’t figure out why we’re living in this hub of technology for the Midwest — Wright-Patt is the most important employer around here, so it’s very technically oriented. It doesn’t make any sense that we don’t have it,” said Malogorski, who lives on Ohio 4 between Upper Valley Road and Bath Road.

“Wright-Patterson Air Force Base is right beyond the treeline across the four-lane highway,” he said as he stood in his front yard pointing to the base, then the utility pole on his property, with AT&T and Time Warner Cable lines clearly visible above him.

This is a common example of telecommunications infrastructure disparities in the United States. Oftentimes people are located close to existing infrastructure that doesn't extend to their neighborhoods, discrediting the notion that rural areas lack infrastructure. They do have infrastructure. It's just arrayed in an incomplete, vexing crazy quilt of small "footprints" of neighborhoods with landline service and those without. That situation remains unlikely to change given the U.S. Federal Communications Commission's lack of enforcement of its policy adopted in 2015 classifying Internet service as a common carrier utility and thus mandating providers fill in the unserved pockets.

Combining two flawed subsidy programs won’t build FTTP infrastructure

Fellow blogger Steve Blum of Tellus Venture Associates suggests coordinating the U.S Federal Communications Commission’s Connect America Fund (CAF) Internet telecom infrastructure construction subsidies with a state subsidy program administered by the California Public Utilities Commission to multiply the amount of money available for such projects. (See Blum's blog post here)

Combining two fundamentally flawed subsidy programs, however, won’t produce a beneficial result considering the underlying weakness of both. Each is primarily structured to subsidize bandwidth, not infrastructure. They do so by defining subsidy eligible areas based on existing low bandwidth levels supported and delivered by legacy infrastructure rather than subsidizing the construction of modern fiber to the premise (FTTP) infrastructure in high cost areas. If an incumbent provider is providing that minimum bandwidth level, the area is deemed ineligible. That furthers the goal of the legacy telephone and cable companies to preserve the status quo by making it more difficult for others to finance FTTP builds in their service territories.

This is a key shortcoming because the primary problem in California and the nation is outdated and inadequate telecom infrastructure that needs to be replaced with FTTP infrastructure. Also, incumbent local exchange carriers (ILECs) are not motivated to construct FTTP infrastructure in high cost areas regardless of the availability of subsidies. Their business strategy is to focus on more profitable mobile wireless services and on cherry picking high end private communities and parts of low cost, urbanized areas for very limited FTTP builds.