Delete, Delete, Delete

On April 10, 2025, the Cloud Communications Alliance (CCA) filed comments in response to the FCC’s recently initiated “Delete Delete Delete” proceeding, championed by Chairman Carr. The Delete Delete Delete proceeding aligns with President Trump’s broader deregulatory agenda, as detailed in Executive Orders such as Executive Order 14192 titled “Unleashing Prosperity Through Deregulation” and Executive Order 14219 titled “Ensuring Lawful Governance And Implementing The President’s ‘Department Of Government Efficiency’ Deregulatory Initiative.” The proceeding seeks recommendations for eliminating outdated regulations that no longer serve the public interest and impose unnecessary burdens on communication providers. Announcing the proceeding last month, Chairman Carr emphasized:

“Under President Trump’s leadership, the Administration is unleashing a new wave of economic opportunity by ending the regulatory onslaught from Washington. For too long, administrative agencies have added new regulatory requirements beyond their authority or maintained outdated regulations far past their usefulness, creating unnecessary barriers for our nation’s innovators, entrepreneurs, and small businesses.”

He further affirmed the FCC’s dedication to eliminating regulations that no longer serve the public interest and encouraged active public engagement in identifying obsolete rules for removal. Chairman Carr concluded, “The American people expect and deserve a government that will efficiently deliver great results. We are committed to doing exactly that at the FCC.”

In its comments, authored by Jonathan Marashlian of Marashlian & Donahue, PLLC, The CommLaw Group, and Michael Pryor of Brownstein Hyatt Farber Schreck, LLP, CCA seeks regulatory reform in three critical areas:

1. DELETE – PSAP Outage Reporting Requirements: CCA advocates for eliminating the FCC’s recently adopted Public Safety Answering Point (PSAP) outage notification rules scheduled to take effect on April 15, 2025, under Part 4 of the FCC’s regulations. As detailed in a recent advisory (available at: New FCC PSAP Outage Notification Rules), these rules impose excessively complex and burdensome reporting obligations that disproportionately impact smaller communications providers. CCA emphasizes that these requirements provide minimal incremental public safety benefits compared to the significant compliance costs and operational complexities imposed. Eliminating or substantially revising these obligations would streamline regulatory processes, allowing providers to allocate more resources toward rapid outage restoration and enhanced customer care during critical service disruptions.
2. DELETE – “Mandatory” Universal Service Fund (USF) “De Minimis” Exemption: CCA recommends converting the current mandatory USF de minimis exemption into a voluntary option. The mandatory application of the existing exemption creates substantial administrative burdens and operational complexity, particularly disadvantaging small service providers and new market entrants. These providers often struggle to accurately determine and transparently communicate USF surcharges due to their dependency on underlying suppliers’ revenue allocation methods. This dependency frequently leads to unnecessary and avoidable friction between wholesalers and resellers, customer confusion, and even competitive disadvantages. Allowing providers to elect voluntary exemption would align with the original goal of the de minimis rule, simplifying compliance processes and promoting clearer, more predictable billing practices for both providers and their customers.
3. DELETE STATE REGULATION – By Affirming Vonage Preemption: CCA strongly urges the FCC to reinforce and reaffirm the Vonage Preemption Doctrine, which explicitly prevents conflicting and burdensome state-level regulations from impacting VoIP providers. Recent actions by the California Public Utilities Commission (CPUC) threaten to erode this essential federal doctrine, potentially subjecting VoIP and SaaS providers offering interconnected VoIP services to extensive and fragmented state-level regulatory obligations. Affirming Vonage Preemption is vital to preserving a consistent federal regulatory framework, encouraging innovation, and preventing significant increases in compliance complexity and associated costs. For additional insights on CCA’s position, please visit the Cloud Communications Alliance announcement and detailed coverage in Telecom Reseller.

The Delete Delete Delete proceeding presents a vital opportunity for the FCC to remove unnecessary and burdensome regulatory constraints, fostering greater innovation, competition, and consumer benefits within the communications industry. Joe Marion, President of CCA, stressed the importance of active engagement:

“The CCA strongly encourages our members and the broader industry to recognize and address the potential negative impacts that unchecked state-level regulation could impose on VoIP services. It is crucial for industry voices to be heard clearly and urgently, ensuring that states like California do not gain unchecked authority to undermine federal regulatory supremacy. CCA remains committed to advocating forcefully on behalf of our members, including wholesale VoIP providers and their reseller customers, to secure regulatory reforms essential to maintaining a vibrant, competitive, and innovative cloud communications marketplace.”

For additional details on the regulatory topics discussed in CCA’s comments or to explore submitting supportive reply comments (due by April 28), please contact Jonathan Marashlian at jsm@commlawgroup.com. To learn more about joining the CCA or to support the CCA-CVA Petition for Declaratory Ruling (currently undocketed), which seeks affirmation of Vonage Preemption and “deletion” of the CPUC’s VoIP regulatory framework, please reach out to Joe Marion at jmarion@cloudcommunications.com.