WASHINGTON, December 31, 2009 – A key component of formulating a National Broadband Plan should be an end to regulatory requirements that prolong the life of public switched telephone network and plain-old telephone service, AT&T said in comments it filed to the FCC on December 21.

“Any such forward-looking policy must enable a shift in investment from the legacy [public switched telephone network] to newly deployed broadband infrastructure. While broadband usage – and the importance of broadband to Americans’ lives – is growing every day, the business model for legacy phone services is in a death spiral,” wrote AT&T.

“Revenues from [plain-old telephone service] are plummeting as customers cut their landlines in favor of the convenience and advanced features of wireless and VoIP services,” wrote AT&T.

“At the same time, due to the high fixed costs of providing POTS, every customer who abandons this service raises the average cost-per-line to serve the remaining customers. With an outdated product, falling revenues, and rising costs, the POTS business is unsustainable for the long run. Yet a web of federal and state regulations has the cumulative effect of prolonging, unnecessarily, the life of POTS and the PSTN,” the company continued.

AT&T said that it is not clear if public switched telephone network and plain-old telephone service will survive.

WASHINGTON, December 31, 2009 – A key component of formulating a National Broadband Plan should be an end to regulatory requirements that prolong the life of public switched telephone network and plain-old telephone service, AT&T said in comments it filed to the FCC on December 21.

“Any such forward-looking policy must enable a shift in investment from the legacy [public switched telephone network] to newly deployed broadband infrastructure. While broadband usage – and the importance of broadband to Americans’ lives – is growing every day, the business model for legacy phone services is in a death spiral,” wrote AT&T.

“Revenues from [plain-old telephone service] are plummeting as customers cut their landlines in favor of the convenience and advanced features of wireless and VoIP services,” wrote AT&T.

“At the same time, due to the high fixed costs of providing POTS, every customer who abandons this service raises the average cost-per-line to serve the remaining customers. With an outdated product, falling revenues, and rising costs, the POTS business is unsustainable for the long run. Yet a web of federal and state regulations has the cumulative effect of prolonging, unnecessarily, the life of POTS and the PSTN,” the company continued.

AT&T said that it is not clear if public switched telephone network and plain-old telephone service will survive.

WASHINGTON, December 31, 2009 – A key component of formulating a National Broadband Plan should be an end to regulatory requirements that prolong the life of public switched telephone network and plain-old telephone service, AT&T said in comments it filed to the FCC on December 21.

“Any such forward-looking policy must enable a shift in investment from the legacy [public switched telephone network] to newly deployed broadband infrastructure. While broadband usage – and the importance of broadband to Americans’ lives – is growing every day, the business model for legacy phone services is in a death spiral,” wrote AT&T.

“Revenues from [plain-old telephone service] are plummeting as customers cut their landlines in favor of the convenience and advanced features of wireless and VoIP services,” wrote AT&T.

“At the same time, due to the high fixed costs of providing POTS, every customer who abandons this service raises the average cost-per-line to serve the remaining customers. With an outdated product, falling revenues, and rising costs, the POTS business is unsustainable for the long run. Yet a web of federal and state regulations has the cumulative effect of prolonging, unnecessarily, the life of POTS and the PSTN,” the company continued.

AT&T said that it is not clear if public switched telephone network and plain-old telephone service will survive.