VoIP is a telecom service ‘and should be regulated as such,’ the ...

rulemaking is wrong -- “IP by itself is neither a network nor a service; it is merely one of literally dozens of transmission protocols that may be employed to facilitate the transmission of information.” NCL said that since VoIP is a telecom service, it should contribute to the universal service fund, provide full E-911, provide all consumer protections and meet all disability access mandates; states shouldn’t be preempted from VoIP regulation; and VoIP shouldn’t be allowed to unfairly shift the cost of telecom services to non-VoIP customers. EarthLink said the near-ubiquity of VoIP “does nothing to change the fact that the use of IP… has absolutely no bearing on the proper regulatory treatment of such services.” EarthLink also said the FCC shouldn’t confuse 3 separate elements -- the protocol itself, networks that support IP transmissions, and services delivered over those networks. OPASTCO said the use of IP technology doesn’t reduce an ILEC’s cost of providing access to the network, so VoIP services “should provide equitable compensation.” It also said IP services that are functionally equivalent to traditional telephony should provide full E-911 functionality and access for the disabled… Classifying IP-enabled services as information services will provide incentives for electric utilities to use the technology to upgrade their own private networks and provide broadband services to consumers, the United Telecom Council (UTC) and the United Power Line Council (UPLC) said. While applauding the FCC for minimizing regulation of IP- enabled services, they cautioned the agency against assuming that “additional regulation of IP-enabled services is necessary to promote social policy objectives such as universal service and public safety and disability access services.” They opposed any regulations that would apply to private networks of critical infrastructure industries used primarily to support their core electric, gas and water services.