One of the FCC's goals is to encourage investment and deployment of broadband access networks so all Americans can enjoy the benefits of a world that is increasingly driven by digital technology. Comcast embraces this goal. Well before Comcast began offering competitive voice service, we invested billions in deploying an advanced broadband network to provide multiple communications services, including both voice and data.

In 2005, we began offering consumers a new choice in voice services with our introduction of Comcast Digital Voice. At the time we entered the market, there wasn't wide-scale facilities-based competition for residential local voice services. We filled that void, and today, we are the largest residential competitive provider of voice services in the country, serving more than nine million customers. Our customers want to make and receive phone calls, and we make that possible by connecting our access network to other networks, including, of course, the older telephone network, with its outdated communications technology. Billions of minutes of traffic move across our network, and our customers expect us to complete calls without regard to the underlying technology. Interconnecting our network with the rest of the industry is also expected of us as a carrier. There is a mutual benefit for carriers to interconnect their networks to serve customers. As the old networks have transitioned to the new networks of today, it requires the cooperation of providers on all sides to ensure that all customers throughout the United States enjoy the nationwide connectivity that is a hallmark of this country's telephone network; calls from the plain old telephone network are completed by new providers, and vice versa. That mutual contribution by all network operators should be fairly compensated.

Of course, we offer much more than a substitute for plain old telephone service. We provide not only high-quality voice service but innovative multi-platform features and functionalities like Universal Caller ID to the TV, PC and mobile devices as well as Smart Voicemail which allows you to access your messages anytime, anywhere on your computer or smartphone. These features are all made possible by employing IP technology. Importantly, it is this very network that has the flexibility to support converged communications services that consumers are increasingly demanding today and will even more so in the future. Plain old telephone service has been increasingly replaced by IP-based services. It is precisely these technologies and network enhancements that the FCC seeks to encourage and promote through its universal service and intercarrier compensation reform and establishment of the Connect America Fund.

The FCC should not be distracted by arguments about subsidies and entitlements associated with networks that are antiquated and unable to support the vast array of services that can be provided over modern networks. We are pleased the FCC seeks to reform outdated rules and subsidy mechanisms to ensure that all players are fairly compensated, rather than focusing its policies on propping up an outdated "plain old telephone service" network that simply cannot support broadband services. Comcast is poised and excited to be part of the solution to make innovative technologies and services available to all Americans.