TELUS Communications Company - Appendix C · THE EFFECTS OF MANDATED NETWORK UNBUNDLING ON FTTP...

THE EFFECTS OF MANDATED NETWORK UNBUNDLING ON FTTP

DEPLOYMENT

Robert W. Crandall

The Brookings Institution

Technology Policy Institute

Washington, DC

January 31, 2014

TELUS Communications Company December 21, 2015 Appendix C

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Summary

1. I have been asked by TELUS to provide an analysis of certain issues raised by the

Commission's Review of Wholesale Services and Associated Policies. I am a Non-

Resident Senior Fellow in Economic Studies at the Brookings Institution and an Adjunct

Senior Fellow at the Technology Policy Institute, both located in Washington, DC. I file

this testimony in my individual capacity and not on behalf of the Brookings Institution

or the Technology Policy Institute. My Curriculum Vitae is attached as an Appendix to

this testimony.

2. In this testimony, I explain why mandated wholesale access to new high-speed fiber-to-

the-premises (FTTP) networks is unnecessary and counterproductive. I draw upon a

body of applied empirical research on the regulation of wholesale access to incumbent

telecommunications carriers’ networks to analyze the prospective effects of mandating

access to new FTTP network deployments on investment and subscriber take-up of the

ultra-fast broadband services they provide.

3. This analysis is conditioned on the fact that deployment of FTTP networks is expensive

and risky, particularly where utilities must be buried or deployed outside major cities,

because of continuing technological change and the fact that these fiber investments are

irretrievably sunk. i.e., they cannot be redeployed if technologies or markets change in

the future.

4. I conclude that :

Any prospective mandate for mandatory sharing of new FTTP facilities with

competitors at regulated rates (“network unbundling”) necessarily reduces the

incentive to deploy such facilities, particularly in areas of modest or low density

and in high-cost areas.

In countries where regulators have pursued aggressive wholesale unbundling of

copper networks and have suggested a similar policy towards new fiber networks,

network investment has lagged severely, and FTTP has been rolled out much

more slowly than in countries with less wholesale regulation.

There is strong empirical evidence that mandated wholesale unbundling of

copper networks has not increased broadband subscriptions; there is no reason to

believe that such policies, if extended to fiber, would be more successful.

Moreover, any discussion of potential regulation of new FTTP networks must

take into account that such networks are not embedded “essential facilities.” Any

of a number of carriers could build such facilities to compete with existing DSL,

cable television, and satellite broadband and video services. In many countries,

non- incumbent carriers have built their own fiber networks. They have not relied

on access to regulated carriers’ fiber networks because, as in much of Canada,

such networks have not yet been built.


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Introduction

5. The continuing technological revolution in communications has spawned an ever-

expanding demand for bandwidth as households and businesses download more and

more data, photos, games, and video through a variety of devices. The

telecommunications networks of ten or twenty years ago, while sufficient for the

bandwidth demands of that period, are no longer sufficient to accommodate the demands

of today’s – and especially tomorrow’s -- users of smartphones, tablets, and high-

definition television receivers.

6. Canadian carriers are adapting to these expanding needs for bandwidth by investing

substantially in new technologies. Cable television companies have deployed DOCSIS

3.0 widely, allowing them to offer hundreds of video channels and super-fast broadband

Internet services. Wireless carriers have deployed 4-G technologies to allow the new

generations of tablets and smartphones to receive (and transmit) a variety of video

services, book-length manuscripts, and video games.

7. The traditional incumbent telecommunications companies have also responded by

extending fiber optics farther and farther into their networks, allowing them to offer

faster copper-based DSL services. But eventually extending fiber to subscriber premises

may be necessary for carriers to offer the ultrafast broadband services that can compete

in the modern communications marketplace and offer Canadians access to a wide variety

of new services.

8. Unfortunately, the extension of fiber to the premises is both costly and risky, particularly

in areas of moderate to low population density. As a result, in most countries, including

Canada, FTTP accounts for very little of current broadband penetration. The OECD

reported that at the end of 2012 only 15 percent of broadband subscribers in the most

developed (34) countries were connected directly by fiber-to-the-home or fiber-to-the-

building (also known as “Ethernet-to-the-suite” or “apartment LAN,” which is common

in densely-populated urban areas in Asia).1

9. In many countries, particularly in Europe, the incumbent telephone companies have

deployed very little FTTP. As I shall show below, a likely reason for their reticence in

this regard is a history of mandated wholesale access to traditional copper networks at

low, regulated rates. Without assurances that similar regulation will not be imposed on

new fiber networks, these carriers likely cannot justify the large investment required to

deploy FTTP.

10. A large share of the new FTTP facilities in OECD countries has been deployed by non-

regulated carriers. These include a variety of new entrants, electric utilities, non-

incumbent fixed-wire and wireless carriers, and municipal authorities. These entities

1 OECD, Broadband Portal, available at www.oecd.org


http://www.oecd.org/

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typically operate with fewer regulatory obligations than those faced by incumbent

carriers.

The Effect of Mandated Wholesale Access at Regulated Rates: Theory

11. The theory underlying mandated wholesale access to telecommunications platforms is

based on the deduction that some portion of an existing telecommunications network

cannot easily be replicated and is therefore a monopoly bottleneck. In earlier years,

when cable companies and wireless carriers were unable to compete in offering mass-

market subscribers data and voice services, the incumbent telecommunications carrier’s

“last-mile” copper wire connections to final subscribers were deemed to be such a

bottleneck. Regulators, therefore, attempted to facilitate competitive entry into such

service offerings by mandating network “unbundling” and the wholesale leasing of the

unbundled last-mile connections to entrants at regulated rates.

12. For this network-sharing policy to work properly, it was essential that regulators be able

to establish efficient wholesale prices for the leased network connections. Too high a

price would frustrate entry, and too low a price would lead to inefficiently low network

investment by incumbents and entrants alike. Moreover, regulators had to be cognizant

of the costs of executing this unbundling since existing networks had not been designed

to accommodate multiple carriers.

13. Although it is always difficult to establish the efficient wholesale price for unbundled

network connections over the traditional copper-wire network, at least the regulators

have had some idea of the cost of building such facilities since they had been setting

cost-based rates for traditional telephone services over these networks for decades.

Nevertheless, the appropriate rate, based on the forward-looking cost of such network

facilities and the option-value to the entrant of not having to invest was often difficult to

determine. 2

14. For prospective new network facilities, however, the task of establishing efficient

wholesale rates for competitor access is much more difficult for a number of reasons.

First, there are a variety of network architectures that may be used to deploy FTTP. Each

one presents different problems for establishing competitor connections and, therefore,

requires different assessments for establishing the appropriate wholesale rates.

15. Second, there are not likely to be any established networks that can be used to provide

“benchmarks” for wholesale rates. But if the rates under prospective wholesale

regulation are not known ex ante, the incumbent carrier may be reluctant to deploy the

FTTP network because of the added uncertainty in forecasting cash flows from such an

investment.

2

By not having to invest in sunk facilities that are subject to premature obsolescence, the entrant using the

incumbent’s facilities receives a “real option” to wait before making its own investments. See Avinash K. Dixit,

Investment under Uncertainty. Princeton University Press, 1994.


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16. Third, the regulator will not likely know how a given wholesale rate will affect

competitors still leasing the older copper network. Nor will the regulator likely be able

to forecast how any prospective wholesale rate for access to fiber will affect incumbent

investments in new technologies based on the existing copper network, such as VDSL.

17. It is certain, however, that any wholesale regulation of prospective FTTP networks will

affect the projected cash flows available to the carrier deploying the network. Since the

prospective returns on such investments decline as they are deployed into less densely

populated areas, any wholesale rate that results in competitors leasing access will likely

cause the carrier deploying the network to consider a reduction in the geographical scope

of its deployment.

18. Mandated wholesale access to incumbent facilities can also lead to a reduction in

investment by new entrants, especially if the regulated wholesale rates are set

inefficiently low. A theory advanced a decade ago held that mandated wholesale access

can facilitate new entry by companies that subsequently climb a “ladder of investment”

by building their own facilities.3

Eventually, according to this theory, the entrants may

climb to the top rung of this ladder, building their own customer connections, replacing

the network elements initially leased at regulated wholesale rates. However, the

accumulated empirical evidence has been unkind to this theory, as I demonstrate below.

Empirical Evidence of the Effects of Network Unbundling: Network Investment

19. Mandated unbundling of copper loops has been in existence for nearly two decades.

Copper loop unbundling began in Hong Kong in 1995. In 1996, the United States

became the first major developed country to require unbundling of incumbents’ copper

plant and competitors’ access to these unbundled facilities at low, regulated rates. Since

that time, the U.S. Federal Communications Commission (FCC) has reduced the scope

of these unbundling requirements and has importantly decided not to require the sharing

of new fiber networks.4

20. A common form of copper-loop unbundling is “line sharing” – allowing entrants to lease

only the upper frequencies on the loop for the distribution of broadband Internet

services. The United States initially imposed such line sharing on legacy copper

networks under the 1996 Telecommunications Act, but a court decision forced the FCC

to revoke this requirement in 2002.5

In its 2003 Triennial Review Order, the FCC

decided not to require unbundling of Next Generation Networks, i.e., new fiber networks

designed to offer ultra high-speed Internet and video services.6

The very next year,

3 Cave, M. (2006), “Encouraging infrastructure construction via the ladder of investment,: Telecommunications

Policy, Vol. 30, No. 3-4, pp. 223-37; 3

Cave, M. and Vogelsang, I. (2003), “How Access Pricing and Entry Interact.”

Telecommunications Policy, 27(10-11): pp.717–727. 4

FCC, Triennial Review Order, 18 FCC Rcd 16978 (2003). 5

United States Telecom Association v. FCC, 290 F.3d 415 (2002). 6

FCC, Triennial Review Order, 18 FCC Rcd 16978 (2003).


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Verizon began to deploy its FTTP service (FiOS) in Texas.7

Subsequently, the FCC

deregulated all broadband services, including cable modem service and DSL.8

21. The European Union, by contrast, has aggressively pursued network unbundling and

requires line sharing on traditional copper loops to promote competition in broadband

services. Moreover, the European Commission continues to advocate unbundling for

new FTTP deployments although it has not been able to reach a consensus on the

regulatory standards for accomplishing fiber unbundling. Thus, unlike the United States,

the European Union has not foresworn the use of mandated network sharing for new

fiber-based networks, and it continues to rely heavily on unbundling traditional copper

loops.

22. The difference in regulatory approaches between the U.S. and the EU is reflected in the

annual investment by (regulated) incumbent carriers on the two sides of the Atlantic. As

Figure 1 shows, over the decade 2002-11, U.S. and Canadian carriers consistently

invested more per communications path than their counterparts in the European Union.9

Figure 1

Incumbent Telecom Companies’ Capital Spending per Communications Path

United States, Canada, and EU-15

($000)

0.250

0.200

0.150

0.100

0.050

0.000

2002- 2011

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 Ave.

U.S. Canada EU-15

Source: OECD, Communications Outlook, 2013.

7 http://news.cnet.com/Verizons-fiber-race-is-on/2100-1034_3-5275171.html

8 FCC, Report and Order and Notice of Proposed Rulemaking, (FCC 05-150).

9 These data are available in the latest OECD, Communications Outlook (2013), Tables 3.8 and 4.1. Note that these

data reflect spending by all carriers, not just the incumbent telecommunications companies. There are similar

differences in capital spending by incumbent carriers among these three areas.


http://news.cnet.com/Verizons-fiber-race-is-on/2100-1034_3-5275171.html

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23. Moreover, the U.S. – having foresworn regulation of new fiber networks – has had far

more penetration of FTTP than either the EU or Canada as Figure 2 shows. The

difference in the extent of FTTP investment by EU and U.S. carriers suggests that the

more aggressive regulatory approach found in the European Union has suppressed

capital spending and the deployment of new FTTP networks.

Figure 2

Fiber Connections per Thousand Persons, 2012

Europe vs. North America

25

20

15

10

5

0

EU-15 Canada U.S.

Sources: OECD, Communications Outlook 2013 (fiber connections);

World Bank and U.S. Census Bureau (population)

24. The data in Figure 2 understate the difference between EU and U.S. incumbent-company

deployment of FTTP. In the EU-15, most of the deployment of FTTP has been

undertaken by non-incumbents who are not generally subject to wholesale access

regulation, as I demonstrate below. In the U.S., most of the FTTP has been deployed by

incumbents, particularly Verizon, who have been relieved of any unbundling

responsibility for all broadband services.

25. The difference in incumbents’ share of FTTP can be seen in Table 1, which shows the

relative shares of broadband subscribers by technology for major developed countries.


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Table 1

Broadband Penetration by Modality

(Percentage of broadband subscribers) Country (1)

FTTP Share† (2)

Incumbent FTTP

Telco Share

(3) DSL Share †

(4) Unbundled DSL

Share*

(5) Cable Share†

Japan 67% 48%a 16% 10%

a 17%

Korea 61% 30%b 12% 0% 27%

Sweden 34% <8%c 47% 17%

d 19%

Denmark 17% 0%e 55% 7%

f 28%

Portugal 15% 12%g 45% 8% 40%

U.S.A. 7% 6% 34% 8% 57%

Netherlands 6% 6%h

49% 11%f 45%

U. K. 0%i 0%

i 75% 37% 20%

Spain 3% 3%j 78% 25% 19%

Luxembourg 3% 3% 86% 9%f 10%

Italy 2% <1% 98% 37% 0%

Finland 2% 2%c 66% 1%

f 18%

Canada 2% 2% 43% 2% 55%

Austria 1% <0.1% 68% 13% 31%

France 1% 0.7% 92% 42% 6% Belgium <1% 0% 51% 3% 49%

Germany <1% <0.1%l 83% 12%

f 16%

Greece <1% 0%j 100% 14%

f 0%

Ireland <1% 0% 70% 2% 30%

† OECD. Broadband Portal, December 2012 estimates. * OECD Communications Outlook 2013, Table 2.8,

number of unbundled loops, 2011, where available.

a. NTT, 2013 Annual Report, p. 35.

b. Based on June 2011 data from http://www.slideshare.net/DigiWorldIDATE/montagne-10250348

c. TeliaSonera has less than 25% of FTTH homes passed in Sweden; 95% of FTTH homes passed in its

franchise area in Finland. SNL_Kagan, Marketing Fiber to the Global Consumer, November 20, 2012, p. 34.

d. OECD estimate unavailable. Estimate based on European Commission, Digital Agenda, “Broadband

Markets,” Fig. 44, available at http://ec.europa.eu/digital-agenda/en/digital-single-market-analysis-and-data.

e. Incumbent TDC owns a cable company deploying DOCSIS 3.0, no mention of FTTH subscribers in 2012

Annual Report.

f. Based on 2009 OECD data (the most recently available for these countries).

g. PT began deploying fiber in 2008 after favorable regulatory ruling. It appears to have about 80 percent of

the country’s FTTP subscribers.

h. The incumbent KPN has bought a controlling interest in the country’s largest FTTH supplier, Reggefiber.

i. BT will begin to launch FTTP in 2013. See http://www.ispreview.co.uk/index.php/2013/03/bt-confirm-

final-uk-isp-prices-and-launch-of-330mbps-fttp-on-demand.html. j. CMT, Geographical Analysis of Broadband Services and NGA Deployment in Spain, December 2012.

k. OTE is deploying only FTTC, not FTTP (2012 Annual Report, p.50.).

l. Deutsche Telekom, 2012 Annual Report, p. 107.

26. Table 1 shows that in very few countries have incumbents deployed FTTP to any

measurable extent. Moreover, as Figure 3 (based on the data in Table 1) clearly

demonstrates, the countries with the largest share of DSL delivered over unbundled

loops generally have little or no broadband service delivered over fiber.


http://www.slideshare.net/DigiWorldIDATE/montagne-10250348

http://ec.europa.eu/digital-agenda/en/digital-single-market-analysis-and-data

http://www.ispreview.co.uk/index.php/2013/03/bt-confirm-final-uk-isp-prices-and-launch-of-330mbps-fttp-on-demand.html



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Figure 3

FTTP, Incumbent FTTP, and DSL Unbundling

Shares of Broadband Subscriptions

80%

70%

60%

50%

40%

30%

20%

10%

0%

FTTP Incumbent FTTP Unbundled DSL Share

Source: Table 1

27. Of the European countries in Table 1, only Sweden, Denmark, Portugal and Netherlands

have substantial FTTP penetration. In Denmark, the incumbent carrier, TDK, has no

measurable FTTP subscribers. In Sweden, a very large share of FTTP subscriptions is

accounted for by municipal government networks. In Netherlands, the incumbent, KPN,

did not deploy fiber, but rather bought the largest independent FTTP provider after this

new carrier had deployed large amounts of fiber. And in Portugal, the incumbent

deployed FTTP only after the regulator guaranteed it freedom from wholesale

regulation. Thus, incumbents in the EU-15 – subject to copper unbundling mandates and

potentially subject to fiber unbundling – have generally avoided investing in new FTTP

networks.

28. The countries that OECD credits with having the greatest FTTP penetration are Japan

and Korea. Both have extremely high population density, high levels of Ethernet-to-the-

suite (or “apartment LAN”), as opposed to true FTTP, and high degrees of government

intervention in the form of planning and financial support for fibre deployment.10

Both also have substantial facilities-based competition in the delivery of broadband services

over fiber networks. In Korea, three major carriers –KT, SK-Hanaro, and LG Telecom –

compete actively using their own networks. KT, the incumbent carrier, has only about

one-half of the country’s FTTP subscribers. In Korea, there has been never been much

unbundling of copper loops, and today copper-loop unbundling is non-existent as

10

For details, see Robert D. Atkinson, Daniel K. Correa, Julie A. Hedlund, Explaining Broadband Leadership, The

Information, Technology, and Innovation Foundation, 2008, Appendices D and F.


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column (4) shows. Moreover, the regulator, MIC, has exempted KT from unbundling its

fiber facilities, as an OECD report explains:

“For fibre optics deployed before 2004, the MIC imposed obligations on Korea

Telecom (KT) to open its fibre optics to alternative operators, with regulated

wholesale charges set by the MIC. For KT fibre optics deployed after 2004, the

MIC did not impose any regulations on KT … Regulatory forbearance was also

applied for the fibre deployed by other operators.”11

29. In Japan, the incumbent, NTT, has a larger share of FTTP subscribers than its Korean

counterpart, but facilities-based competition is considerable in major urban areas.

Electric utilities, USEN Corporation, and KDDI have also deployed fiber networks

rather widely. By 2010, these competitors accounted for about 25 percent of Japanese

subscribers to FTTP.12

Softbank, once a prominent supplier of DSL over NTT’s

unbundled loops, has not ascended the ladder of investment to deploy fiber, choosing to

concentrate on mobile services instead.13

As a result, the share of broadband connections

over unbundled loops fell from nearly 37 percent in June 2006 to just 10 percent in

2011.14

30. In addition to these cross-country comparisons of FTTP deployment, there is a

substantial body of systematic empirical research that concludes that mandatory

unbundling discourages investment. Cambini and Jiang’s authoritative 2009 review of

the literature, which examined more than 20 empirical studies and concludes that while

additional research could be useful, ‘‘most of the evidence shows that local loop

unbundling discourages both ILECs and CLECs from investing in networks.” 15

31. More recent econometric studies, not covered by Cambini and Jiang, confirm these

findings. For example, a 2009 study of European telecommunications companies by

Grajek and Roller found that mandatory wholesale access at regulated prices reduced

investment. “We find access regulation to negatively affect both total industry and

individual carrier investment. Thus promoting market entry by means of regulated

access undermines incentives to invest in facilities-based competition.”16

11 OECD, Fibre Access - Network Developments in the OECD Area, 16 June, 2011, p. 11.

12 Akematsu, Yuji; Sobee Shinohara; and Masatsugu Tsuji (2012), “Factors of FTTH deployment in Japan: A panel

data analysis,” 23rd European Regional Conference of the International Telecommunication Society,

Vienna, Austria, 1-4 July. 13

In Japan, the regulator, MIC, has nominally required NTT to unbundle its GPON network, but there is no

evidence that rivals have been willing or able to use NTT’s facilities. As a result, competition in offering FTTP

services is almost entirely based on competing platforms, not network sharing. 14

OECD, Broadband Portal, June 2006; OECD, Communications Outlook, 2013. 15

Cambini, Carlo, and Yanyan Jiang,”Broadband Investment and Regulation: A literature Review,” Telecommunications Policy, Vol. 33 (2009), p. 569. 16

Grajek, Michał, and Lars-Hendrik Roller. 2012. “Regulation and Investment in Network

Industries: Evidence from European Telecoms.” Journal of Law and Economics 55 (1): pp.189 – 216.


10

32. A 2010 study by Bacache, Bourreau and Gaudin finds that European entrants that use

unbundled local loops do not ascend “the ladder of investment” and eventually build

their own infrastructure.17

Briglauer, Eckler, and Kugler studied the relationship

between copper unbundling and FTTP deployment in the EU-27 and found that

regulation has negatively affected NGA deployment.18

33. Earlier, Waverman et.al., used an econometric model to estimate the effect of low

regulated wholesale rates for unbundled loops on competitors’ investment. They found

that a 10 percent reduction in wholesale rates results in an 18 percent reduction in the

deployment of network infrastructure by competitors.19

Finally, the primary author of

the ladder of investment thesis, Dr. Martin Cave, now admits that his thesis “remains no

more than a hypothesis, as scientific testing of an imprecise proposition of this kind

remains problematic.”20

Empirical Evidence on the Effects of Network Unbundling: Broadband Penetration

34. It is possible that mandated network sharing of telecommunications networks, despite its

adverse effects on network investment, creates benefits in the short run by reducing

retail prices, particularly if the wholesale rates are set very low, and thereby increasing

subscriber penetration. However, the empirical evidence generally does not even find a

short-term benefit from mandated sharing.

35. The preponderance of the empirical evidence from studies of broadband penetration

shows that inter-platform competition (principally, between cable television and

telecommunications companies) increases broadband penetration, but intra-platform

competition (from entrants relying on access to incumbent facilities) based on forced

network sharing does not. Only one study using recent data finds a positive, but small

impact of intra-platform competition that is facilitated by local-loop unbundling, but this

effect erodes after three years.21

36. Crandall, Eisenach and Ingraham review the empirical evidence on the effect of copper-

loop unbundling on broadband penetration.22

In addition, they provide new evidence in

17 Bacache, M., Bourreau, M., & Gaudin, G. (2011). “Dynamic entry and investment in new infrastructures:

Empirical evidence from the telecoms industry.” Telecom ParisTech working paper EES-11-01. Retrieved from

http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1750217S. 18

Briglauer, W., Eckler, G., & Kugler, K. (2011). “Regulation and investment in next generation access networks:

Recent evidence from the European member states.” Working papers/Research Institute for Regulatory Economics, 4. Retrieved from http://www.wu.ac.at/regulation/research/wp/next_generation_access_eu. 19

Waverman, L., Meschi, M, Reillier, B., and Dasgupta, K. (2007), “Access Regulation and Infrastructure

Investment in the Telecommunications Sector: An Empirical Investigation,” LECG, London. 20

Cave, M. (2007). “Applying the ladder of investment in Australia.” Retrieved from

http://www.docstoc.com/docs/37098359/Applying-the-ladderof-investment-in-Australia. 21

Gruber, H and Koutroumpis, P. (2012), “Competition enhancing regulation and diffusion of innovation: the case of broadband networks,” Draft paper, available through [email protected]. 22

Crandall, R, Eisenach, J, and Ingraham, A (2013), “The long-run effects of copper-loop unbundling and the

implications for fiber,” Telecommunications Policy, 37, 262-81. For details, consult Section 3 of the paper.


http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1750217S

http://www.wu.ac.at/regulation/research/wp/next_generation_access_eu

http://www.docstoc.com/docs/37098359/Applying-the-ladderof-investment-in-Australia

mailto:[email protected]

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the form of a regression analysis of pooled annual time-series, cross-section data from

28 countries for 2001-10.

37. Crandall, Eisenach, and Ingraham’s empirical results show that broadband penetration

increases over time after a broadband network is deployed, but the advance of subscriber

penetration is not positively affected by the number of years that an unbundling regime

has been in place. Indeed, in one specification they find that unbundling may even be

associated with reduced levels of penetration over time, perhaps because of its effect on

network investment.

38. After more than a decade of empirical research, economists have not been able to

identify a systematic positive effect of mandated unbundling on subscriber penetration.

While it is possible that low regulated wholesale rates result in lower retail broadband

prices and some increase in subscriber penetration in the short run, the longer-run

adverse effect on network investment appears to offset any short-term positive effect on

subscriptions. At this juncture, there is simply little credible evidence that mandated

network sharing, in the form of leased unbundled copper loops, contributes to broadband

penetration in the long run.

New Fiber Networks Are Being Built by a Variety of Carriers

39. It is very difficult to argue that prospective FTTP networks are “essential facilities” that

can only be built by incumbent telecommunications companies. If and when deployment

of such networks is economically viable, they can deployed by a variety of different

business entities – other fixed-wire carriers (perhaps out-of-region), wireless carriers,

electric utilities, railroads, or even natural-gas distributors. Indeed, there is ample

evidence that incumbent telephone carriers face FTTP-based competition from other

carriers in many countries.

40. Recall that Table 1, above, showed that in countries with substantial FTTP penetration,

the incumbent carriers often have a small share of FTTP subscribers. In Sweden, Korea,

Denmark, and even Japan there is substantial platform competition, often from non-

traditional carriers. And new entrants have sprung up in a number of other developed

countries, as Table 2 demonstrates.


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Table 2

Non-Incumbent Companies with FTTP Networks in Major OECD Countries

Country Carrier Type of Business

Japan TEPCO Electric utility (Network sold to KDDI)

KDDI Non-incumbent carrier

Korea SK-Hanaro Non-incumbent telco and cable TV company

LG Telecom Non-incumbent carrier

Denmark Dong Energy Electric utility (purchased by TDC)

SEAS-NVE Electric utility

Tre-For Electric Utility

Parknet Non-profit association

France Iliad-Free Non-incumbent carrier

SFR Non-incumbent carrier

Bouygues Telecom New entrant (owned by large industrial company)

Italy Fastweb New entrant (purchased by Swisscom, 2010.)

Metroweb New Entrant

Netherlands Reggefiber New entrant (acquired by KPN, 2010-13)

CIF Operator Investment fund

Wiericke New entrant (acquired by Vodafone, 2013)

Norway Ventelo-Broadnet Non-incumbent and wireless carrier

Lyse Energy-

Altibox

Consortium of electric utilities

Sweden Banverket ICT Railroad

Telenor Foreign carrier (Norwegian incumbent)

Tele2 Competitive entrant (residential fiber facilities

purchased by Telenor, 2013)

Banhof Publ AB Internet Service Provider

Municipal Fiber

Systems

Over 150 municipally-owned systems

United Kingdom City Fibre New entrant

Horsebridge

Network Systems New entrant (Technology company)


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Table 2 (continued)

Non-Incumbent Companies with FTTP Networks in Major OECD Countries

Country Carrier Type of Business

Canada Olds Fibre Ltd (O-Net) Municipal utility

Novus Entertainment Inc. CLEC

Groupe Maskatel LP CLEC

United States Burlington Telecom (VT) Municipal utility

CDE Lightband (TN) Municipal Utility

Google Fiber Major technology company

LUS Fiber (LA) Municipal utility

Mollala Communications Co.

(OR)

Co-operative entity

Peak Internet (CO) Independent ISP

41. In Sweden, for example, most of the fiber was deployed as much as a decade ago by

municipal utilities, not the regulated incumbent, TeliaSonera. The incumbent began to

invest in fiber much more recently in order to counter the strong platform-based

competition coming from these municipal fiber systems.

42. In Denmark, the incumbent, TDC, has not deployed FTTP, but its ADSL and cable

services compete with fiber-based services provided by electric utilities.23

In Norway, a

variety of electric utilities have formed consortia to deploy FTTP. In the Netherlands, an

independent carrier, Reggefiber, has deployed most of the FTTP. In 2009, KPN acquired

a 41 percent stake in Reggefiber after the fiber network had been deployed; in 2012,

KPN gained control of the company by acquiring another 10 percent of its equity.24

More recently, two new entrants – CIF Operator and Wiericke – have begun to deploy

fiber.

43. In France, three non-incumbents are beginning to deploy fiber.25

One of these carriers is

a new entrant owned by a diversified industrial company, Bouygues. In Italy, a new

entrant, Fastweb, deployed fiber in the larger cities and then was acquired by Swisscom,

the Swiss incumbent. More recently, another entrant, Metroweb, has begun to deploy

fiber.

23 Finn Petersen, “FTTH – The situation in Denmark from a regulatory perspective,” National IT and Telecom

Agency, Denmark, February 2009. 24

See http://www.broadbandtvnews.com/2011/11/09/kpn-to-acquire-full-control-of-reggefiber/. 25

Despite repeated reports that France Telecom and its rivals are about to deploy fiber on a substantial scale, France

still had fewer than 400,000 FTTP connections as of June 2013, according to the OECD Broadband Data Portal. Of

these, about 300,000 were connected to the incumbent, France Telecom. Thus, the entrants that have relied on

unbundled loops have switched only about 100,000 subscribers to fiber – a minuscule amount in a country with

more than 24 million fixed broadband subscribers.


http://www.broadbandtvnews.com/2011/11/09/kpn-to-acquire-full-control-of-reggefiber/

14

44. In Korea, strong platform competition from SK-Hanaro and LG Telecom provide

substantial incentive for KT, the incumbent, to invest in FTTP. Korea relies on a policy

of platform competition rather than mandating network unbundling, thereby

encouraging, KT (the incumbent), SK-Hanaro, and LG Telecom, to compete fiercely

using their own networks. Indeed, Korea’s success in deploying FTTP confirms the

result of many empirical studies of telecommunications: platform competition is far

superior to rivalry artificially induced by network unbundling.26

45. In Japan, NTT has deployed fiber widely, but it faces substantial rivalry from a variety

of carriers. As explained above, electric utilities, USEN Corporation, and KDDI have

also deployed fiber networks rather widely.

46. Finally, in the United States, a major new player, Google, has emerged to challenge the

established telecom and cable companies with greenfield deployments of fiber. Google’s

fiber networks are operating in Kansa City, KS and MO, and Provo, UT, and it has

announced a major deployment in Austin, TX. In 21013, AT&T responded by

announcing that it is extending fiber to the premises in Austin so as to be able to offer as

much as 300 Mbs in broadband speed to its subscribers.27

47. Thus, in most OECD countries where substantial investments in fiber have occurred, the

major deployments of FTTP are often not by the incumbents, but rather a variety of

other entities. Given these diverse sources of investment in FTTP across OECD

countries, it is clear that no incumbent’s prospective investment in a new FTTP network

is likely to constitute an essential facility that is a candidate for network unbundling.

Conclusions

48. In this testimony, I have provided a review of the empirical evidence on the effects of

mandated network sharing on network investment, broadband penetration, and fiber

deployment. This reviews leads me to the following conclusions:

Countries with substantial levels of FTTP either (1) generally do not have

incumbent unbundling mandates or (2) the lion’s share of that FTTP has been deployed by non- incumbents.

26

See, for example, Briglauer, Eckler, and Kugler’s conclusion: “Our results indicate that previous NGA (“next

generation access”) deployment is determined by the extent of infrastructure-based competition stemming from

cable operators and mobile networks… stricter previous sector-specific broadband regulation has negatively affected

NGA deployment.” They then point out that their conclusions comport with the accumulating literature on the

subject.

27 Roger Cheng, AT&T Attempts to Out-Google Google in Austin Fiber Race,” CNET, September 30, 2013,

available at http://news.cnet.com/8301-1035_3-57605381-94/at-t-attempts-to-out-google-google-in-austin-fiber-

race/.


http://news.cnet.com/8301-1035_3-57605381-94/at-t-attempts-to-out-google-google-in-austin-fiber-

15

The “ladder of investment” theory that has been provided as support for

mandated network sharing has not been borne out by the facts over the past

decade.

Competitor access mandates neither increase broadband penetration nor

investment in broadband facilities, particularly in the long run. To the contrary,

they decrease investment in new facilities and, with it, penetration of next-

generation broadband access services. This is the opposite of the desired result.

Numerous non-incumbent companies, such as CLECs, public utilities, and ISPs,

have deployed fiber throughout the developed world, thereby demonstrating that

incumbent FTTP facilities –when they are deployed –are not “essential facilities,”

that should be shared with competitors.


16

Appendix

R O B E R T W. C R A N D A L L

CURRENT POSITION:

Non-Resident Senior Fellow

The Brookings Institution

Washington, DC

ADDRESS:

39 Dinsmore Rd., PO Box 165

Jackson, NH 03846

Phone No. 603-383-4199 e-mail: [email protected]

FIELDS OF SPECIALIZATION:

Industrial Organization, Antitrust Policy, Regulation

PREVIOUS POSITIONS:

Adjunct Professor, School of Public Affairs, University of Maryland, 1987 - 1993

Deputy Director, Council on Wage and Price Stability, 1977 - 1978

Acting Director, Council on Wage and Price Stability, 1977

Adjunct Associate Professor of Economics, George Washington University, 1975 - 1977

Assistant Director, Council on Wage and Price Stability, 1975 - 1977

Associate Professor of Economics, M.I.T., 1972 - 1974

Assistant Professor of Economics, M.I.T., 1966 - 1972

Johnson Research Fellow, The Brookings Institution, 1965 - 1966

Instructor, Northwestern University, 1964 - 1965

Consultant to Environmental Protection Agency, Antitrust Division Federal Trade Commission, Treasury

Department, various years

EDUCATION:

Ph.D., Economics, Northwestern University, 1968

M.A., Economics, Northwestern University, 1965

A.B., Economics, University of Cincinnati, 1962

MEMBERSHIPS:

American Economic Association

PUBLICATIONS:

Books:

First Thing We Do: Let’s Deregulate All the Lawyers. (with Clifford Winston and Vikram Maheshri) Washington,

DC: The Brookings Institution, 2011.


mailto:[email protected]

17

Competition and Chaos: U.S. Telecommunications since the 1996 Act. Washington, DC: The Brookings Institution,

2005.

Broadband: Should We Regulate High-Speed Internet Access? (edited with James Alleman), AEI Brookings Joint

Center for Regulatory Studies, 2002.

Telecommunications Liberalization on Two Sides of the Atlantic. (with Martin Cave) AEI Brookings Joint Center for

Regulatory Studies, 2001.

Who Pays for Universal Service? When Telephone Subsidies Become Transparent. (with Leonard Waverman)

Washington: The Brookings Institution, 2000.

Cable TV: Regulation or Competition? (with Harold Furchtgott-Roth), Washington: The Brookings Institution,

1996.

Talk is Cheap: The Promise of Regulatory Reform in North American Telecommunications. (with Leonard

Waverman) Washington: The Brookings Institution, 1996.

The Extra Mile: Rethinking Energy Policy for Automotive Transportation. (with Pietro S. Nivola) Washington, DC:

The Brookings Institution/Twentieth Century Fund, 1995.

Manufacturing on the Move. Washington, DC: The Brookings Institution, 1993.

After the Breakup: The U.S. Telecommunications Industry in a More Competitive Era. Washington, DC: The

Brookings Institution, 1991.

Changing the Rules: Technological Change, International Competition and Regulation in Communications.

(Edited with Kenneth Flamm), Washington, DC: The Brookings Institution, 1989.

Up from the Ashes: The Rise of the Steel Minimill in the United States. (With Donald F. Barnett), Washington, DC:

The Brookings Institution, 1986.

Regulating the Automobile. (With Howard K. Gruenspecht, Theodore E. Keeler, and Lester B. Lave), Washington,


Controlling Industrial Pollution: The Economics and Politics of Clean Air. Washington, DC: The Brookings

Institution, 1983.

The Scientific Basis of Health and Safety Regulation. (Ed. with Lester Lave), Washington, DC: The Brookings

Institution, 1981.

The U.S. Steel Industry in Recurrent Crisis. Washington, DC: The Brookings Institution, 1981.

Articles, Reports, and Contributions to Edited Volumes:

“‘Over the Top:’ Has Technological Change Radically Altered the Prospects for Traditional Media?” in James

Alleman (ed.), Demand for Communications Services: Insights and Perspectives, Springer, 2013.

“The Long-Run Effects of Copper Unbundling and the Implications for Fiber’” (with Jeffrey A. Eisenach and Allan

T. Ingraham), March 2012, available at http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2018929.

“Looking the Other Way: Telecom Deregulation in the United States,” Regulatory and Economic Policy in

Telecommunications, No. 7, November 2011.


http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2018929

18

“Antitrust in High Tech Industries, (with Charles L. Jackson), Review of Network Economics, Vol. 38, No. 4, 2011.

“Vertical Separation of Telecommunications Networks: Evidence from Five Countries,” (with Jeffrey Eisenach and

Robert Litan), Federal Communications Law Journal, 2010, available at

http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1471960.

“The Decline of U.S. Manufacturing before and during the Current Crisis,” L’Industria, October-December 2009,

pp. 679-702.

“Letting Go? The Federal Communications Commission in the Era of Deregulation,” Review of Network Economics,

Vol. 7, Issue 4, 2008.

“Extending Deregulation: Make the U.S. Economy More Efficient,” in Opportunity08: Independent Ideas for

America’s Next President. Brookings, 2007.

"Is Mandatory Unbundling the Key to Increasing Broadband Penetration in Mexico? A Survey of International

Evidence," 2007, (with J. Gregory Sidak), available at SSRN: http://ssrn.com/abstract=996065

“The Adverse Economic Effects of Spectrum Set-Asides” (with Allan T. Ingraham), Canadian Journal of Law and

Technology, November 2007, pp. 131-40.

“Does Video Delivered Over a Telephone Network Require a Cable Franchise?” (with Hal J. Singer and J. Gregory

Sidak) Federal Communications Law Journal, Vol. 59 (2007).

“The Failure of Competitive Entry into Fixed-Line Telecommunications: Who Is at Fault?”(with Leonard

Waverman) Journal of Competition Law and Economics, Vol 2, 2006, pp. 113-148.

“Broadband Communications,” in Handbook of Telecommunications Economics, Vol II, Sumit K. Majumdar, Ingo

Vogelsang, and Matin E. Cave (eds.), Elsevier, 2005.

“The Remedy for the ‘Bottleneck Monopoly’ in Telecom: Isolate It, Share It, or Ignore It?” University of Chicago

Law Review, Vol. 72, No.1, Winter 2005.

"Are Vertically Integrated DSL Providers Squeezing Unaffiliated ISPs (and Should We Care)?," (with Hal J.

Singer), in Access Pricing: Theory, Practice and Empirical Evidence, Justus Haucap and Ralf Dewenter eds.,

Elsevier Press, 2005.

“Life Support for ISPs?”(with Hal J. Singer), Regulation, Vol. 28, (2005), pp.46-52.

“Bandwidth for the People” (with Robert Hahn, Robert Litan, and Scott Wallsten), Policy Review, No. 127, October-

November 2004.

“Internet Telephones: Hanging Up on Regulation, “ with Robert W. Hahn, Robert E. Litan, and Scott Wallsten,”

The Milken Institute Review, 2004-III, Vol. 6 No. 3, pp. 30-34.

“Foreign Investment Restrictions as Industrial Policy: The Case of Canadian Telecommunications,” (with Hal J.

Singer), Canadian Journal of Law and Technology, Vol 3, No. 1, March 2004, pp. 19-32.

"Do Unbundling Policies Discourage CLEC Facilities-Based Investment?", (with Allan T. Ingraham, and Hal J.

Singer) Topics in Economic Analysis & Policy, 2004, Vol. 4: No. 1, Article 1.

“Should Regulators Set Rates to Terminate Calls on Mobile Networks?”(with J. Gregory Sidak) Yale Journal on

Regulation, 2004.

“Injunctive Relief in Sherman Act Monopolization Cases,” (with Kenneth G. Elzinga)


http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1471960

http://ssrn.com/abstract%3D996065

19

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TNC 2013-551

Appendix B

Research in Law and Economics, Vol. 21, Elsevier, 2004, pp. 277-34.

“Telecommunications Policy and the Evolution of the Internet,” in The New Economy in East Asia and the Pacific,

Peter Drysdale, ed., RoutledgeCourzon, London, 2004, pp. 60-87.

“Does Antitrust Policy Improve Consumer Welfare? Assessing the Evidence,” (with Clifford Winston) Journal of

Economic Perspectives, Fall 2003, pp. 3-26

“The $500 Billion Opportunity: The Potential Economic Benefit of Widespread Diffusion of Broadband Internet

Access” (with Charles L. Jackson), in Allan L. Shampine (ed) Down to the Wire: Studies in the Diffusion and

Regulation of Telecommunications Technologies, Nova Science Press, Haupaugge, NY, 2003

“An End to Regulation?” in Competition and Regulation in Utility Markets, Colin Robinson, ed., Edward Elgar,

London, 2003.

“Is Structural Separation of Incumbent Local Exchange Carriers Necessary for Competition?” (with J. Gregory

Sidak), Yale Journal on Regulation, Vol. 19, No.2, 2002, pp. 335-411.

“The Empirical Case Against Asymmetric Regulation of Broadband,” (with J. Gregory Sidak and Hal J. Singer)

Berkeley Technology Law Journal, 2002

“Universal Service, Equal Access, and the Digital Divide,” in Bridging the Digital Divide. Hitachi Public Affairs

Forum, California Council on Science and Technology, May 2001, pp. 29-38.

“Telecommunications Policy Reform in the United States and Canada,” (with Thomas W. Hazlett) in Martin Cave

and Robert W. Crandall (eds.), Telecommunications Liberalization on Two Sides of the Atlantic, AEI/Brookings

Joint Center for Regulatory Studies, 2001.

“The Failure of Structural Remedies in Sherman Act Monopolization Cases,” Oregon Law Review, Spring 2001,

pp. 109-98.

“Sports Rights and the Broadcast Industry” (with Martin Cave), The Economic Journal, Vol. 111, February 2001,

pp. F4-F26.

“Bridging the Digital Divide – Naturally,” Brookings Review, Winter 2001, pp. 38-43.

“Local and Long Distance Competition: Replacing Regulation with Competition,” in Randolph J. May and Jeffrey

A. Eisenach (eds.), Communications Deregulation and FCC Reform: What Comes Next? Washington: The Progress

and Freedom Foundation, 2000.

“Competition in U.S. Telecommunications Services: Effects of the 1996 Legislation,” (with Jerry Hausman) in Sam

Peltzman and Clifford Winston (eds.), Deregulation of Network Industries, Washington: The Brookings Institution,

2000.

“Competition in Telecom: The U.S. and Canadian Paths,” (with Leonard Waverman) in Dale Orr and Thomas R.

Wilson (eds.), The Electronic Village: Policy Issues in Telecommunications. Toronto: C.D. Howe Institute, 1998.

“New Zealand Spectrum Policy: A Model for the United States?” The Journal of Law and Economics, October

1998, pp. 821-839.

“The Impact of Telecommunications Deregulation on Midsize Business,” in Gary D. Libecap (ed.), Advances in the

Study of Entrepreneurship, Innovation, and Economic Growth: Legal, Regulatory, and Policy Changes that Affect

Entrepreneurial Midsize Firms. Stamford, CT: JAI Press, 1998, pp. 23-42.


20


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TNC 2013-551

Appendix B

“Telephone Subsidies, Income Redistribution, and Economic Welfare,” in Roger G. Noll and Monroe E. Price, A

Communications Cornucopia: Markle Foundation Essays on Information Policy. Washington: The Brookings

Institution, 1998.

“Electric Restructuring and Consumer Interests: Lessons from Other Industries,” The Electricity Journal, Volume

11, No. 1, January/February 1998.

“Is it Time to Eliminate Telephone Regulation?” in Donald L. Alexander (ed.), Telecommunications Policy: Have

Regulators Dialed the Wrong Number?, Westport, CT: Praeger, 1997, pp. 17-30.

“Competition and Regulation in the U.S. Video Market,” Telecommunications Policy, Vol. 21, No. 7, 1997, pp. 649-

660.

“Are We Deregulating Telephone Services? Think Again.” Brookings Policy Brief, Number 13, March 1997

“Are Telecommunications Facilities ‘Infrastructure?’ If They Are, So What? Regional Science and Urban

Economics, 27 (1997), pp. 161-79.

Economic Deregulation and Customer Choice: Lessons for the Electric Utility Industry. (with Jerry Ellig), Center

for Market Processes, George Mason University, 1997.

“Telecom Mergers and Joint Ventures in an Era of Liberalization,” in Gary Clyde Hufbauer and Erika Wada(eds.)

Unfinished Business: Telecommunications After the Uruguay Round. Washington, DC: Institute for International

Economics, 1997, pp. 107-24.

“From Competitiveness to Competition: The Threat of Minimills to Large National Steel Companies,” Resources

Policy, Vol. 22, Nos. 1/2, March/June 1996, pp.107-118.

“Clearing the Air: EPA’s Self-Assessment of Clean-Air Policy,” (with Frederick H. Rueter and Wilbur A. Steger),

Regulation, 1996, Number 4, pp. 35-46.

“Phone Rates in a Deregulated Market,”The Brookings Review, Summer 1996.

"Competition and Regulatory Policies for Interactive Broadband Networks," (with J. Greory Sidak), Southern

California Law Review, July 1995.

"The Unregulated Infobahn," (with J. Gregory Sidak), Jobs & Capital, Vol. 4, Summer 1995, pp. 28-32.

"Managing the Transition to Deregulation in Telecommunications," in Steven Globerman, W.T. Stanbury, and

Thomas A. Wilson (eds.), The Future of Telecommunications Policy in Canada. University of British Columbia and

the University of Toronto, 1995.

"Productivity Growth in the Telephone Industry Since 1984," (with Jonathan Galst) in Patrick Harker (ed.), The

Service Productivity and Quality Challenge, Dodrecht: Kluwer Academic Publishers, 1995, Chapter 14.

"Cable Television: Reinventing Regulation," The Brookings Review, Winter 1994, pp. 12-15.

"Explaining Regulatory Policy" (with Clifford Winston), Brookings Papers on Economic Activity, Microeconomics,

1994, pp. 1-31.

“Pricing Issues in Telecommunications,” Maine Policy Review,Vol. 3, No. 1, May 1994.

"Regulation and the "Rights" Revolution: Can (Should) We Rescue the New Deal?" Critical Review, Vol. 7 Nos. 2-

3, 1993, pp. 193-204.


21


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TNC 2013-551

Appendix B

"Comment: Transactions Prices," Price Measurement and Their Uses, (Murray F. Foss, Marilyn E. Manser, and

Allan H. Young, eds.), University of Chicago Press, 1993.

"Pollution Controls" in David R. Henderson (ed.), The Fortune Encyclopedia of Economics, New York: Warner

Books, 1993.

"Relaxing the Regulatory Stranglehold on Communications," Regulation, Summer 1992, pp. 26-35.

"Regulating Communications: Creating Monopoly While Protecting Us From It," The Brookings Review, Summer

1992, Volume 10, No. 3, pp. 34-39.

"Policy Watch: Corporate Average Fuel Economy Standards," Journal of Economic Perspectives, Spring 1992, pp.

171-80.

"Why Is the Cost of Environmental Regulation So High?" Center for the Study of American Business. St. Louis:

Washington University, Policy Study No. 110, February 1992.

"Liberalization Without Deregulation: Telecommunications Policy During the 1980s," Contemporary Policy Issues,

October 1991.

"Halfway Home: U.S. Telecommunications (De)Regulation in the 1970s and 1980s," in Jack High (ed.),

Regulation: Economic Theory and History. Ann Arbor: The University of Michigan Press, 1991.

"Efficiency and Productivity," in Barry G. Cole (ed.), After the Breakup: Assessing the New Post-AT&T

Divestiture Era. New York: Columbia University Press, 1991.

"The Politics of Energy: New Fuel Economy Standards?" (with John D. Graham), The American Enterprise,

March/April 1991.

"The Clean Air Act at Twenty," Journal of Regulation and Social Costs, September 1990.

"Fragmentation of the Telephone Network" in Paula Newberg (ed.), New Directions in Telecommunications Policy.

Durham, NC: Duke University Press, 1989.

"The Effect of Fuel Economy Standards on Automobile Safety," (with John D. Graham), Journal of Law and

Economics, April 1989.

"Surprises from Telephone Deregulation and the AT&T Divestiture," American Economic Review, May 1988, pp.

323-327.

"The Regional Shift of U.S. Economic Activity" in Robert E. Litan, et al., American Living Standards, Washington,


"Deregulation and Divestiture in the U.S. Telecommunications Sector" in Economic Deregulation: Promise and

Performance. Proceedings of the 1987 Donald S. MacNaughton Symposium, Syracuse University, 1988.

"Whatever Happened to Deregulation?" in David Boaz (ed.), Assessing the Reagan Years. Washington, DC: The

CATO Institute, 1988.

"Regulatory Reform: Are We Ready for the Next Phase?" in The Brookings Review, The Brookings Institution,

Winter 1988/89.

"Telecommunications Policy in the Reagan Era," Regulation, Washington, DC: American Enterprise Institute,

1988, Number 3, pp. 18-19.


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Appendix B

"A Sectoral Perspective: Steel" in Robert M. Stern, et.al. (eds.), Perspectives on a U.S.-Canadian Free Trade

Agreement, Washington, DC: The Brookings Institution, 1987.

"The Effects of U.S. Trade Protection for Autos and Steel," Brookings Papers on Economic Activity, 1987:2, The

Brookings Institution.

"Has the AT&T Breakup Raised Telephone Rates?" in The Brookings Review, Winter 1987.

"Public Policy and the Private Auto," (with Theodore E. Keeler) in Gordon, et.al. (eds.), Energy: Markets and

Regulation, Essays in Honor of M.A. Adelman. Cambridge, MA: MIT Press, 1986

"Materials Economics, Policy, and Management: An Overview," with Michael B. Bever, in Encyclopedia of

Materials Science and Engineering, Pergamon Press, 1986.

"Metals Industries: International Structure," in Encyclopedia of Materials Science and Engineering, Pergamon

Press, 1986.

"The Steel Industry in Transition," Materials and Society, Pergamon Journals Ltd., Vol. 10, No. 2, 1986.

"The Public Interest in Metals Policy," in David A. Gulley and Paul Duby (eds.), The Changing World Metals

Industries. New York: Gordon and Breach, 1986.

"Economic Rents as a Barrier to Deregulation," The CATO Journal, Spring/Summer 1986.

"The Transformation of U.S. Manufacturing," Industrial Relations, Spring 1986."Investment and Productivity

Growth in the Steel Industry: Some Implications for Industrial Policy," in Walter H. Goldberg, Ailing Steel: The

Transoceanic Quarrel, Gower, 1986.

"The EC-US Steel Trade Crisis," in Loukas Tsoukalis (ed.), Europe, America, and the World Economy, Oxford:

Basil Blackwell, 1986.

"Why Should We Regulate Fuel Economy at All?" in The Brookings Review, Spring 1985.

"An Acid Test for Congress," Regulation, September/December 1984.

"Import Quotas and the Automobile Industry: The Costs of Protectionism," The Brookings Review, Summer 1984.

"Automobile Safety Regulation and Offsetting Behavior: Some New Empirical Estimates," (with John D. Graham),

American Economic Review, Papers and Proceedings, May 1984.

"The Political Economy of Clean Air: Practical Constraints on White House Review," in V. Kerry Smith,

Environmental Policy Under Reagan's Executive Order: The Role of Benefit-Cost Analysis, University of North

Carolina Press, 1984.

"The Marketplace: Economic Implications of Divestiture," (with Bruce M. Owen), in Harry M. Shooshan III,

Discounting Bell: The Impact of the AT&T Divestiture, Pergamon Press, 1984.

"Environmental Policy in the Reagan Administration," (with Paul R. Portney), in Paul R. Portney (ed.), Natural

Resources and the Environment: The Reagan Approach, The Urban Institute and Resources for the Future, 1984.

"The Emerging Competition in the U.S. Telecommunications Market" in New Opportunities for Entrepreneurship,

The Kiel Institute, 1984.

"Deregulation: The U.S. Experience," Zeitschrift fur die gesamte Staatswissenshaft, October 1983, pp. 419 - 434.

Review of John Zysman and Laura Tyson, American Industry in International Competition, Science, Vol. 222,

October 21, 1983.


23


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TNC 2013-551

Appendix B

"Air Pollution, Environmentalists, and Coal Lobby," in Roger G. Noll and Bruce M. Owen (eds.), The Political

Economy of Deregulation, American Enterprise Institute, 1983.

"The Use of Environmental Policy to Reduce Economic Growth in the Sun Belt: The Role of Electric-Utility Rates"

in Michael A. Crew (ed.), Regulatory Reform and Public Utilities, Lexington Books, 1982.

"The Cost of Automobile Safety and Emissions Regulation to the Consumer: Some Preliminary Results," (with

Theodore E. Keeler and Lester B. Lave), American Economic Review, May 1982.

"Environmental Policy," Regulation, March/April 1982.

"Has Reagan Dropped the Ball?" in Regulation, November/December 1981.

"The Use of Cost-Benefit Analysis in Regulatory Decision-Making," Annals New York Academy of Sciences, 1981.

"The Deregulation of Cable Television," (with Stanley M. Besen), Law and Contemporary Problems, Duke

University School of Law, Vol. 44, No. 1, Winter 1981.

"The Impossibility of Finding a Mechanism to Ration Health Care Resources Efficiently" in A New Approach to the

Economics of Health Care, Mancur Olson (ed.), American Enterprise Institute for Public Policy Research, 1981.

"Pollution Controls and Productivity Growth in Basic Industries" in Productivity Measurement in Regulated

Industries, Academic Press, 1981.

"Where is the Public Interest in Broadcasting Regulation?" in Regulation and the Future Economic Environment-Air

to Ground, Charles F. Phillips, Jr. (ed.), December 1980.

"The Environmental Protection Agency," (On Saving the Kingdom: Advice for the President-Elect), Regulation,

November/December 1980.

"Steel Imports: Dumping or Competition?" in Regulation, July/August 1980.

"Regulation and Productivity Growth" in Proceedings: Conference on Productivity, Federal Reserve Bank of

Boston, Martha's Vineyard, June 1980.

"The Prospects for Regulatory Reform," Government Regulation: New Perspectives, Andrew Blair, ed., Pittsburgh:

University of Pittsburgh, 1980.

"The Economics of the Current Steel Crisis in OECD Member Countries" in Steel in the 80's, Organisation for

Economic Co-operation and Development, Paris, 1980.

"Environmental Control Is Out of Control," Chemical and Engineering News, Vol. 57, April 23, 1979.

"Paying for Government Policy Through the Price Level" in Clarence C. Walton (ed.), Inflation and National

Survival, 1979.

"Is Government Regulation Crippling Business?" in Saturday Review, January 20, 1979.

"Federal Government Initiatives to Reduce the Price Level," Brookings Papers on Economic Activity, 1978:2.

"Competition and 'Dumping' in the U.S. Steel Market," Challenge, July/August 1978.

"Regulation of Television Broadcasting: How Costly is the 'Public Interest'?" in Regulation, January/February 1978.


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TNC 2013-551

Appendix B

"Placing a Value on the Electromagnetic Spectrum: A Suggested Approach for FCC Decision-Making,"

Proceedings of the Conference on Telecommunications Policy Research, Airlie House, 1977.

"Theoretical Issues in the Regulation of Communications Common Carriage" in Rate of Return Regulation, FCC

Future Planning Conference, July 1976.

"The Postwar Performance of the Motion Picture Industry," The Antitrust Bulletin, Spring 1975.

"An Econometric Model of the Low-Skill Labor Market," (with C.D. MacRae and Lorene Y.L. Yap), The Journal of

Human Resources, Winter 1975.

"The Economic Case for a Fourth Commercial Television Network," Public Policy, Harvard University Press, Fall

1974.

"The Profitability of Cable Television: An Analysis of Acquisition Prices," The Journal of Business, University of

Chicago, October 1974.

"A Reexamination of the Prophecy of Doom for Cable Television," (with Lionel L. Fray), The Bell Journal of

Economics and Management Science, Spring 1974.

"Monopoly," The Dictionary of American History, Charles Scribner's & Sons, 1973.

"FCC Regulation, Monopsony, and Network Television Program Costs," The Bell Journal of Economics and

Management Science, Autumn 1972.

Study Guide for Basic Economics (with R.S. Eckaus), Little, Brown and Company, 1972.

Contemporary Issues in Economics: Selected Readings (with R.S. Eckaus), Little, Brown and Company, 1972.

"Economic Subsidies in the Urban Ghetto," (with C.D. MacRae), Social Science Quarterly, December 1971.

"The Economic Effect of Television-Network Program 'Ownership'," The Journal of Law and Economics, Vol.

XIV, October 1971.

"The Decline of the Franchised Dealer in the Automobile Industry," The Journal of Business, University of

Chicago, January 1970.

"Motor Vehicle Repair, Repair-Parts Production, and the Franchised Vehicle Dealer," Hearings: The Automobile

Industry, U.S. Senate Antitrust Subcommittee of the Committee on the Judiciary, 1969.

"Vertical Integration and the Market for Repair Parts in the United States Automobile Industry," The Journal of

Industrial Economics, Oxford: Basil Blackwell, July 1968.

*** End of Document ***


TELUS Communications Company - Appendix C · THE EFFECTS OF MANDATED NETWORK UNBUNDLING ON FTTP...

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Transcript of TELUS Communications Company - Appendix C · THE EFFECTS OF MANDATED NETWORK UNBUNDLING ON FTTP...