From: Dr. Ira Jacobs [ijacobs@vt.edu]
Sent: Sunday, December 14, 2003 2:52 PM
To: voipforum
Subject: Materials Submitted to the VoIP Forum

Name:
 Dr. Ira Jacobs

E-mail:
 ijacobs@vt.edu

Organization:
 Virginia Tech

Comments:
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The policy of not regulating the Internet has been beneficial to the growth of Internet usage and applications. However, unregulated enhanced communication services (ECS) sit atop and are provided over a highly regulated telecommunications infrastructure provided and operated by incumbent carriers. As the distinction between ECS and standard services is blurring, and data traffic exceeds voice traffic, the disparity of present regulatory policy is of increasing concern. In an excellent  paper, Jason Oxman (“The FCC and the Unregulation of the Internet,” OPP WP31, July 1999) indicated that “so long as the underlying telecommunications network, over which data services would ‘travel,’ remained healthy and robust, data services themselves should be free from regulation.” However, it is by no means clear that the health and robustness of the underlying telecommunications network will be assured under existing industry and government practices. Although it is not the function of the FCC to protect specific compan ies, I am concerned (as a former employee, as an educator, and as a citizen) over the increasing instability of the U.S. telecommunications industry. The challenge of regulation is to achieve a minimal set of consistent rules that encourage new entrants and services, and assures the health, robustness and stability of the telecommunications infrastructure, but neither promotes nor disadvantages incumbents. I agree with Commisioner Adelstein’s statement that “we cannot afford to let the rise of VoIP to undercut the very networks that carry it.”  
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