54
FCC, GN Dkt. Nos. 14-28 & 10-127, at 10 (Feb. 19, 2015).
Because “[t]he interconnection point is simply a literal
extension of the [broadband provider’s network],”
COMPTEL explained, “applying the same open Internet rules
to the point of interconnection is a logical extension of the
2010 Open Internet Order and clearly in line with the
Commission’s . . . proposal [in the NPRM].” Id.
US Telecom next argues that our decision in Verizon
prevents the Commission from regulating interconnection
arrangements under Title II without first classifying the
arrangements as an offering of telecommunications to edge
providers and backbone networks. As US Telecom points
out, Verizon recognized that broadband, and thus
interconnection arrangements, provides a service not only to
end users but also to edge providers and backbone networks,
namely, the ability to reach the broadband provider’s users.
Verizon, 740 F.3d at 653. According to US Telecom, Verizon
therefore requires the Commission to classify this service to
edge
providers
and
backbone
networks
as
a
telecommunications
service
before
it
regulates
interconnection arrangements under Title II.
US Telecom misreads Verizon. Although Verizon does
recognize that broadband providers’ delivery of broadband to
end users also provides a service to edge providers, id., it does
not hold that the Commission must classify broadband as a
telecommunications service in both directions before it can
regulate the interconnection arrangements under Title II. The
problem in Verizon was not that the Commission had
misclassified the service between carriers and edge providers
but that the Commission had failed to classify broadband
service as a Title II service at all. The Commission overcame
this problem in the Order by reclassifying broadband
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