The responses to the FCC’s call for input on deregulation amount to an ambitious and even unprecedented plan for rewriting almost all aspects of the telecoms rulebook
Operators and industry bodies submitted their recommendations for the FCC’s Delete, Delete, Delete deregulation agenda
On 11 April 2025, the open comment period on the US Federal Communications Commission’s (FCC) Delete, Delete, Delete initiative ended. The consultation, which was elsewhere described as “crowdsourcing ideas for deregulation in telecoms and media markets”, invited interested parties to submit input on specific rules that could be acting as a barrier to modernising networks, developing infrastructure and offering innovative and advanced capabilities. The FCC encouraged submissions that included specific and detailed analysis on the impact of the rules discussed, including through cost-benefit considerations, experience gained from implementing the rules and updates on market changes or technological advancement. The open call received 910 initial submissions from operators, industry associations, consumer groups, academics and individual consumers. The FCC will also accept reply comments, in which those who responded by the initial deadline can provide additional comment on other submissions, until 28 April 2025.
Fixed operators are focused on easier discontinuation of legacy voice services alongside copper deregulation in light of BEAD-funded fibre rollouts
While a number of respondents applauded the regulator’s recent orders to rollback regulation around copper network retirement, they pressed for further deregulation of legacy service retirement, citing the continued financial strain of maintaining outdated infrastructure. USTelecom (the trade organisation representing fixed operators), as well as Verizon argued that the massive growth in mobile voice services (and the related decline in fixed voice subscribers) makes fixed voice regulation out of date. The body noted that regulation around agency approvals for the discontinuation of these services reflect a period when consumers normally only had access to voice services offered by one fixed network incumbent operator, which is no longer the case. USTelecom further recommended that the FCC reconsider the obligations placed on “eligible telecommunications carriers” (ETCs) be updated to reflect the incoming overbuild funded by new federal programmes. Specifically, the organisation recommended that the incumbent copper network operators restricted by the terms of their ETC designation be released from their obligations not only when their networks are overbuilt by Universal Service Fund (USF) sponsored projects but when they’re overbuilt by projects funded through a number of new federal programmes, including under the American Rescue Plan Act and the Broadband Equity, Access, and Deployment (BEAD) Program. Again, USTelecom noted that the availability of public funding for network build has grown far beyond that offered by the USF and a failure to update regulation to reflect those changes would categorically disadvantage operators who have provided reliable service to hard to reach communities for years.
While operators focused predictably on newer Biden-era consumer protections, some also took aim at bipartisan scams and fraud interventions
Given the focus of the prior Biden Administration on developing stronger consumer protections in telecoms, a number of organisations also recommended the reconsideration of ongoing rulemaking procedures as well as the rollback of relatively new consumer protection rules. The CTIA (the Wireless Association), which is the mobile industry body, industry groups representing small and rural providers, the Consumer Technology Association (CTA), and both Verizon and AT&T outlined a list of Biden-era consumer protection regulations to rollback, including:
Some requirements in how broadband advertising labels are presented to consumers;
Rules on “all-in” or transparent pricing information for cable and satellite video services;
Rules on multi-factor authentication and consumer notification requirements to prevent SIM swap and number port-out fraud;
Rules on network-level SMS/MMS blocking based on Do Not Originate (DNO) lists;
Rules on remedying and preventing digital discrimination;
Pending rules banning mobile operators from locking devices, in favor of voluntary industry standards;
Pending rules banning limits on data usage and related overage charges; and
Equipment authorisation and labelling requirements for electronic devices and their packaging.
Many of these recommendations align with expectations that the FCC, under Chairman Brendan Carr, would work quickly to rollback consumer protection interventions. Some suggested changes, particularly to rules aimed at addressing the growing problem of scams and fraud in the US, take aim at bipartisan, unanimously adopted standards that are less likely candidates for ‘deletion’.
Satellite operators and industry bodies requested a streamlining of existing regulation and rulemaking processes while also calling for updated spectrum sharing rules
In terms of satellite, requests from respondents largely overlapped. Amazon’s Kuiper, the Satellite Industry Association (SIA) and SpaceX all called for rulemaking and regulatory procedures to be streamlined, criticising lengthy paperwork, slow inter-agency coordination and even "superfluous language” for their impact on satellite operators. The SIA in particular complained that these burdensome procedures were hampering operators’ ability to obtain licences in a timely manner. Similarly, these same respondents were keen to highlight the regulations they deemed burdensome and unnecessary, not just the processes behind them. SpaceX called for a modernisation of certain rules to move towards a faster, more flexible and efficient regulatory framework, citing the need to modernise outdated protections for legacy geostationary orbit (GSO) systems. Despite SpaceX’s criticisms of the existing regulatory framework, the operator was confident that an improved framework would not be difficult to implement due to the majority of burdensome issues lying in best practice standards and guidance, rather than directly in regulation. Kuiper also highlighted how this regulatory framework could be swiftly amended by the FCC. Both Kuiper and SpaceX also requested a number of alterations to current spectrum sharing rules, most of which centred around freeing up more spectrum for mobile and fixed satellite services in order to promote competition and more efficient sharing. SpaceX went further, stressing the need for the establishment of a satellite spectrum pipeline to enable future innovation in satellite communications, which would mark a unique approach to the future of satellite communications, potentially cementing the US’s leadership in space innovation. The Computer and Communications Industry Association (CCIA) also argued that existing regulation was putting this position at risk, taking aim at the regulation it dubbed the “no-more satellites” rule which prohibits licensees from launching any non-geostationary (NGSO) satellites if they are found to miss a deployment milestone on any other satellite.
Other responses pushed for a restructuring of the regulator itself, matching the Trump Administration’s aim of cutting federal staff and spending
More broadly, respondents, such as the US Chamber of Commerce, urged the FCC to refrain from increasing the regulatory burden with any further interventions. The SIA raised concerns about new regulation that would demonstrably change the existing status quo, arguing that this is unnecessary. Among a long list of proposed deletions and modifications, the Chamber of Commerce also proposed omnibus reforms of the FCC’s enforcement powers, which would see existing rules folded into a simplified and more streamlined set of powers, potentially providing greater clarity for industry. The Chamber of Commerce argues these existing powers are problematic for their lack of sufficient due process protections and the enforcement board’s pursuit of enforcement actions through “novel” interpretations of FCC regulations. The Information Technology and Innovation Foundation (ITIF), a technology policy think tank, also recommended structural changes to the FCC as a regulatory body, recommending it get rid of its Wireline Competition Bureau entirely, which is the agency’s largest internal office and the staff responsible for fixed market regulation. The organisation suggested that the Bureau had already achieved its purpose in facilitating a competitive fixed market and any further work would result in poor outcomes for consumers. While going beyond the apparent scope of the open call for the Delete, Delete, Delete initiative at the FCC, the push to shrink the capacity of the regulator and strictly limit its ability to intervene in markets aligns well with the Trump Administration’s broader interest in cutting federal staff and programming at scale.
