HomeMy WebLinkAboutTMobilecomments.pdfCOMMENTS to the Idaho Public Utilities Commission from T‐Mobile:
The bill proposes to remove the State of Idaho completely from all aspects
of IP networks. These networks are complex and include both
retail/consumer‐facing elements and wholesale/carrier‐facing elements.
T‐Mobile is not opposed to deregulation generally. Certainly, where
market competition justifies it, we would support a lighter regulatory touch
by the state and possibly deregulation entirely.
We’re concerned about only part of the deregulation proposal, the part
applicable to wholesale markets. Wholesale telecom markets—which
include such services as special access, interconnection, intercarrier
compensation—remain under monopoly control.
Competitive carriers such as T‐Mobile must still do wholesale business with
the legacy monopoly carriers in order to provide a full, competitive retail
service. Those wholesale relationships are at risk if important regulatory
protections are removed.
To the extent the proposal would remove regulatory protections in these
legacy monopoly wholesale markets, T‐Mobile objects. Because wholesale
markets remain under monopoly control, monopoly‐type protections and
regulation should remain in effect, under both federal and state law.
We can agree to apply deregulation to retail markets only. Any current
wholesale protections, under both federal and state law, should be
preserved.
The best way to preserve these protections is to draw a distinction between
retail markets and wholesale markets and apply the deregulatory language
only to retail. One could identify the specific elements of wholesale
markets—such as special access, interconnection and intercarrier
compensation, just to name a few—but in order to ensure that the
proposed bill all of the wholesale elements, the language should simply
apply to retail IP markets and not to wholesale IP markets.
We’re happy to draft those amendments.