ICLE Comments to the FCC on Unlawful Robocalls
I. Introduction and Overview
The International Center for Law & Economics (ICLE) submits these comments in response to the Federal Communications Commission’s (FCC) Public Notice seeking comment on the Advanced Methods to Target and Eliminate Unlawful Robocalls Further Notice of Proposed Rulemaking.[1] ICLE is a nonprofit, nonpartisan research center that applies law & economics to public-policy questions, with particular attention to consumer welfare in fast-changing, technology-driven markets such as telecommunications.
ICLE supports the FCC’s goal of reducing illegal robocalls, which continue to harm consumers and erode trust in the voice network. The central question is not whether to combat illegal calls, but how. Existing rules already require providers to take “affirmative, effective measures” to know their customers and prevent illegal traffic from entering their networks. They also give providers flexibility to tailor those measures to the wide range of customers, services, and business models across the calling ecosystem.[2]
That flexibility is economically sound. Originating providers are best positioned to assess their customers because they possess granular, real-time information about account behavior and traffic patterns that no static agency checklist can capture. A rule specific enough to audit would also be static enough to game, giving sophisticated bad actors a roadmap that the FCC could not revise quickly enough to keep pace.[3]
Market incentives reinforce this flexible approach. Providers that tolerate illegal traffic face downstream blocking, traceback and mitigation costs, reputational harm, and enforcement risk.[4] At the same time, the FCC’s intercarrier-compensation reforms and the transition to internet protocol-based networks are eliminating the arbitrage opportunities that once made high-volume junk traffic profitable regardless of legitimacy.[5] Under bill-and-keep, the marginal revenue from an illegal call approaches zero, while the marginal cost of carrying it remains positive.
Where public and private incentives align, the FCC should use a flexible performance standard rather than a rigid compliance code. At most, it could pair that standard with a safe harbor that subjects genuinely high-risk customers, services, and traffic to greater scrutiny.
A prescriptive regime would also leave consumers worse off—the opposite of the Further Notice’s stated aim. Requiring providers to collect sensitive identity information from every customer and retain it for years after service ends would turn providers and their retail channels into high-value targets for data theft. The resulting repositories would concentrate irreversible identity-theft risks on law-abiding consumers, while determined bad actors could still rely on stolen or synthetic identities.[6]
Rigid credential requirements would also deny or delay essential service for legitimate consumers who cannot produce a fixed set of documents. That group includes students, international visitors, domestic-violence survivors, low-income consumers, and prepaid users for whom a single connection may be a lifeline. Re-verification mandates could likewise strand longstanding customers who cannot respond promptly.[7]
The costs would be substantial, largely fixed, and especially burdensome for small and rural providers. Providers would pass many of those costs to consumers through higher prices or divert resources from network investment, service quality, and modernization.[8] In each case, the harm to legitimate consumers is concrete. The claimed benefit over the existing flexible standard remains speculative.
II. Flexible Standards Better Prevent Illegal Calls
The FCC’s existing rules require originating providers to take “affirmative, effective measures” to know their customers and prevent illegal calls, while preserving “flexibility to determine what works best on their networks.”[9] In 2023, the FCC reaffirmed that an “outcomes-based standard is most appropriate” because it allows providers to adapt to changing calling patterns.[10]
The FCC should preserve that approach. Providers hold the best information to assess customer and traffic risks, while rigid checklists quickly become roadmaps for evasion. Flexible standards also reinforce market incentives: Providers already face blocking, traceback, reputational, and enforcement costs when they carry illegal traffic. Meanwhile, the FCC’s intercarrier-compensation reforms are eliminating the arbitrage profits that once made high call volumes lucrative regardless of legitimacy.
An outcomes-based regime can therefore prevent illegal calls more effectively and at lower social cost than a uniform compliance checklist.
A. Why Flexible Standards Work Better
Three economic principles favor an outcomes-based standard over a prescriptive checklist.
First, providers hold the best information to implement know-your-customer (KYC) measures. Originating providers have real-time knowledge of their customers, traffic patterns, network architecture, and the anomalies that may signal illegal calling.[11] A uniform FCC checklist cannot capture that provider-specific information. It would apply the same verification process to a rural household, a national business, and a wholesale Session Initiation Protocol (SIP) trunk customer, despite their sharply different risk profiles.[12]
Regulation works best when it assigns decisions to the party that can make them most accurately and at the lowest cost. Here, that party is the provider. The FCC should require providers to know their customers and restrict illegal traffic without prescribing one fixed method for doing so.
Second, static checklists give bad actors a roadmap. Illegal callers continually change their tactics. A rule that specifies the exact information and verification steps providers must use tells fraudsters what they must fabricate, steal, or obtain to pass.[13] The FCC cannot amend its rules as quickly as bad actors can adapt. An outcomes-based standard instead lets providers revise their defenses as threats evolve.
Third, prescriptive rules increase both kinds of verification error. False positives deny or delay service to legitimate customers. False negatives allow bad actors to pass verification.[14] A one-size-fits-all mandate risks more of both: It burdens the roughly 99% of customers who pose little risk, while determined fraudsters may still pass by using stolen or synthetic credentials.
A flexible, risk-based approach better limits these errors by directing greater scrutiny toward customers and traffic that present greater risk.[15]
B. FCC Reforms Have Removed Arbitrage Profits
Historically, the intercarrier-compensation system could make high call volumes profitable even when the calls had little or no legitimate value.[16] Under that system, carriers paid one another per-minute charges for originating, transporting, or terminating calls. Some providers exploited those payments through access stimulation and similar schemes that generated large volumes of traffic primarily to collect fees. The FCC has repeatedly condemned these practices as wasteful arbitrage [17]
Those payments helped make illegal traffic profitable for the small number of providers willing to tolerate it. The FCC has spent more than a decade dismantling that incentive and is now close to completing the transition.
Most recently, the FCC proposed moving the remaining access charges—including charges for originating switched access, toll-free 8YY calls, tandem switching and transport, and traffic exchanged between internet protocol and traditional telephone networks—to bill-and-keep over 24 months. It also proposed ending tariffs for those services and phasing out Connect America Fund Intercarrier Compensation (CAF ICC) support.[18]
These reforms matter because they remove the revenue that once rewarded sheer call volume, including illegal traffic.
C. Bill-and-Keep Aligns Provider Incentives
Under bill-and-keep, each provider generally recovers its costs from its own customers rather than charging other carriers for each minute of traffic exchanged. As intercarrier-compensation payments approach zero, so does the additional revenue from originating another call, whether legitimate or illegal.
The costs of illegal traffic remain substantial. Providers that fail to control it may have their calls blocked by downstream carriers. They must maintain compliant Robocall Mitigation Database filings to retain network access, respond to Industry Traceback Group requests, and avoid enforcement penalties.[19] Illegal traffic can also cause call-analytics systems to label or block a provider’s legitimate calls, damaging its reputation and service quality.
The economic result is straightforward: Illegal calls generate little or no additional revenue while exposing providers to real and rising costs. Providers therefore have strong incentives to prevent illegal traffic without a prescriptive KYC mandate.
KYC remains an important tool, but it operates within a broader framework that already aligns provider interests with the FCC’s consumer-protection goals. The FCC should build on those incentives rather than replace provider judgment with a static checklist.
III. Prescriptive KYC Rules Would Harm Consumers
The FCC seeks to protect consumers from illegal calls.[20] But a rule cannot serve that goal while increasing data-breach risk, denying or delaying access to essential communications service, and raising costs that reduce investment, choice, and service quality.
Those harms are concrete and foreseeable. The proposal’s added robocall-prevention benefit over the FCC’s existing flexible standard is not. Before replacing an outcomes-based framework with a prescriptive KYC mandate, the FCC should weigh the proposal’s privacy, access, and affordability costs.
A. Mandatory Data Collection Increases Consumer Risk
The FNPRM would require originating providers to collect and verify sensitive personal information—including government-issued identification numbers and supporting documents—from every new and renewing customer, then retain it for four years after the relationship ends.[21] That proposal conflicts with a principle the FCC and Federal Trade Commission have long embraced: Collect only the sensitive information needed for a legitimate purpose, and retain it only as long as necessary.[22]
The risk is straightforward. The information the FNPRM would require is precisely what identity thieves and other cybercriminals seek. Aggregating it across an entire customer base and retaining it for years after service ends would create large, high-value targets.[23] A breach could expose consumers to identity theft, financial fraud, and harms that cannot be fixed by changing a password. Enforcement actions have repeatedly recognized that communications providers are frequent targets of cyberattacks and that retaining sensitive information longer than necessary can itself harm consumers.[24] Data that is never collected—or deleted when no longer needed—cannot be stolen or misused.
The proposal would also spread that risk beyond providers. Many providers sell service through third-party retailers and vendors. Compliance would require sensitive information to move through and remain stored across those retail channels, including at small businesses with limited cybersecurity resources.[25] The rule would therefore increase the number of repositories holding identity documents and expand the attack surface available to criminals.
Legitimate consumers would bear almost all of that risk. Bad actors could avoid the rules or satisfy them with stolen or synthetic identities. The resulting databases would consist largely of authentic information from law-abiding customers, increasing their exposure without a corresponding reduction in illegal calling. That is the opposite of data minimization and difficult to reconcile with the FCC’s consumer-protection mission.
B. Rigid Rules Deny Service
A documentary-verification mandate would condition service on a consumer’s ability and willingness to produce a fixed set of credentials. Many legitimate consumers cannot—or reasonably will not—do so. A government-issued-identification requirement would burden students and teenagers without driver’s licenses, seasonal and younger workers, international visitors and temporary workers without U.S. identification, and consumers with heightened privacy needs, including domestic-violence survivors and whistleblowers.[26] Others may simply decline to entrust sensitive personal information to a provider or retailer.
An alternate-telephone-number requirement creates a circular barrier. Consumers seeking their first line, including many low-income and unbanked consumers, cannot satisfy a rule that assumes they already have the service they are trying to obtain.[27]
These barriers would fall hardest on those least able to absorb them. Prepaid service often serves as a lifeline for people experiencing homelessness, financial or medical instability, or other hardship. Many rely on a single connection to reach employers, health care providers, social services, and support networks. For them, stricter onboarding may mean losing communications access altogether.
Applying the requirements to renewing and existing customers would deepen the harm.[28] Providers could be forced to pause, restrict, or terminate service for longstanding customers who cannot promptly reverify, even without evidence of misuse.[29] The rule would interrupt service for administrative noncompliance rather than conduct tied to illegal calling. A consumer-protection rule that leaves legitimate customers without a working phone line defeats its own purpose.
Significant penalties would also encourage defensive overcompliance. Faced with open-ended liability for a vetting decision the FCC might later deem inadequate, providers would rationally resolve close cases against the customer. They would delay or deny service whenever documentation appeared incomplete, unusual, or uncertain.[30] Sophisticated fraudsters can plan around fixed requirements. Ordinary consumers with imperfect, nonstandard, or unavailable records cannot.
C. Compliance Costs Fall on Consumers
A prescriptive KYC regime would impose substantial and recurring costs.[31] Those costs would reach consumers through higher prices, reduced investment, lower service quality, or some combination of the three.[32]
A uniform mandate raises the cost of every customer relationship. In a market where providers compete on affordability, ease of enrollment, and service quality, those added costs make service more expensive and harder to obtain. That result would undermine the FCC’s affordability goals at a time when wireless and broadband prices have been falling and consumer choice has expanded.
The burden would also fall unevenly. Because many compliance costs are fixed, small and rural providers must spread them across fewer subscribers, producing higher per-customer costs. For a provider serving only a few thousand voice customers, new compliance obligations are not a minor administrative expense. They divert staff and capital from network operations.
That diversion is the larger consumer harm. Every dollar spent collecting, securing, and retaining sensitive data is unavailable to expand coverage, modernize networks, improve reliability, or enhance service quality. For providers operating on thin margins, especially in high-cost rural areas, cumulative mandates can make some offerings uneconomic. That would reduce access to affordable service, including prepaid and entry-level plans on which vulnerable consumers often depend.
Some smaller providers and third-party retailers may leave parts of the market rather than bear the compliance costs and liability risk. Consumers would feel the result through higher prices, fewer choices, slower network improvement, and, for some, the loss of an affordable path to service.
IV. Conclusion
All parties in this proceeding seek the same result: fewer illegal calls and greater trust in the voice network. The dispute concerns how best to achieve it.
The FCC’s existing outcomes-based framework puts responsibility where it belongs—with providers that possess the best information about their customers, traffic, and networks. Their incentives increasingly point in the same direction. Blocking, traceback, reputational, and enforcement risks make illegal traffic costly, while the FCC’s intercarrier-compensation reforms are eliminating the arbitrage profits that once rewarded sheer call volume.
A prescriptive, one-size-fits-all KYC mandate would add little deterrence against sophisticated bad actors who can evade static checks with stolen or synthetic identities. It would instead impose concrete costs on legitimate consumers: larger repositories of sensitive data, greater breach risk, delayed or denied service, higher prices, fewer choices, and less network investment. Those burdens would fall especially hard on small and rural providers and the consumers who depend on affordable prepaid and entry-level service.
The FCC should preserve its flexible, outcomes-based standard, focus heightened scrutiny on genuinely high-risk customers and traffic, and continue directing enforcement toward the actors responsible for illegal calls. A properly designed safe harbor could reinforce that approach without turning every customer relationship into a compliance exercise.
ICLE appreciates the opportunity to participate in this proceeding.
[1] Call Authentication Trust Anchor; Advanced Methods to Target and Eliminate Unlawful Robocalls, WC Docket No. 17-97, CG Docket No. 17-59, Further Notice of Proposed Rulemaking, FCC 26-32 (rel. May 21, 2026), https://docs.fcc.gov/public/attachments/FCC-26-32A1.pdf [hereinafter FNPRM].
[2] 47 C.F.R. §§ 64.1200(n)(4), 64.6305(d)(2)(ii) (2025).
[3] CTIA—The Wireless Ass’n, Comments, CG Docket Nos. 17-59, 02-278, at 4, 11 (filed June 25, 2026), https://www.fcc.gov/ecfs/document/26109929171/1 (“Rigid rules risk making it easier for bad actors to game the system and evade KYC processes,” while inflexible rules “can provide bad actors with a roadmap for circumventing safeguards . . . .”).
[4] See 47 C.F.R. § 64.6305; Improving the Effectiveness of the Robocall Mitigation Database; Call Authentication Trust Anchor; Advanced Methods to Target and Eliminate Unlawful Robocalls, WC Docket Nos. 24-213 & 17-97, CG Docket No. 17-59, Draft Further Notice of Proposed Rulemaking, FCC-CIRC2607-04 (rel. July 1, 2026), https://docs.fcc.gov/public/attachments/DOC-422744A1.pdf; Robocall Mitigation Database Filers, File No. EB-TCD-24-00036891, Order, DA 25-694 (Enf’t Bur. Aug. 6, 2025), https://docs.fcc.gov/public/attachments/DA-25-694A1.pdf.
[5] Int’l Ctr. for L. & Econ., Comments, Reforming Legacy Rules for an All-IP Future; Accelerating Network Modernization, WC Docket Nos. 25-311 & 25-208 (filed May 22, 2026), https://laweconcenter.org/wp-content/uploads/2026/05/ICC-CAF-comments.pdf.
[6] See NCTA—The Internet & Television Ass’n, Comments, CG Docket Nos. 17-59, 02-278, at 8–10 (filed June 25, 2026), https://www.fcc.gov/ecfs/document/26109926613/1.
[7] See CTIA—The Wireless Ass’n, supra note 3, at 13–16 (students, teenagers, international travelers, seasonal workers, and domestic-violence survivors may lack or decline to provide government identification; alternate-phone requirements exclude first-line and low-income consumers; prepaid service serves as a lifeline for vulnerable populations; and re-verifying existing customers could disrupt service without evidence of misuse); USTelecom—The Broadband Ass’n, Comments, CG Docket Nos. 17-59, 02-278, at 4 (filed June 25, 2026), https://www.fcc.gov/ecfs/document/26109928939/1 (international travelers and minors may lack government identification, while limits on prepaid-service data collection protect the privacy of domestic-violence survivors); INCOMPAS, Comments, CG Docket Nos. 17-59, 02-278, at 9–10 (filed June 25, 2026), https://www.fcc.gov/ecfs/document/26109927965/1 (periodic re-verification could interrupt service for elderly and other legitimate customers); NCTA—The Internet & Television Ass’n, supra note 6, at 6–7, 11–12 (customers who cannot or will not provide the required information could face paused, restricted, or denied service).
[8] See NTCA—The Rural Broadband Ass’n, Comments, CG Docket Nos. 17-59, 02-278, at 2–6 (filed June 25, 2026), https://www.fcc.gov/ecfs/document/26109923001/1 (compliance costs would fall hardest on small rural providers); CTIA—The Wireless Ass’n, supra note 3, at 17–20 (providers would pass costs to consumers, undermining affordability and potentially driving retailers from the market); USTelecom—The Broadband Ass’n, supra note 7, at 4–7 (consumers would bear the costs, with smaller providers facing disproportionate burdens).
[9] 47 C.F.R. § 64.1200(n)(4) (2025); Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, Fourth Report and Order, ¶ 32, FCC 20-187 (rel. Dec. 30, 2020), https://docs.fcc.gov/public/attachments/FCC-20-187A1.pdf.
[10] Advanced Methods to Target and Eliminate Unlawful Robocalls; Call Authentication Trust Anchor, CG Docket No. 17-59, WC Docket No. 17-97, Seventh Report and Order, ¶ 34, FCC 23-37 (rel. May 19, 2023), https://docs.fcc.gov/public/attachments/FCC-23-37A1.pdf.
[11] See USTelecom—The Broadband Ass’n, supra note 7, at 5–6, 8.
[12] See CTIA—The Wireless Ass’n, supra note 3, at 5–6; see also NCTA—The Internet & Television Ass’n, supra note 6, at 5–6.
[13] CTIA—The Wireless Ass’n, supra note 3, at 11.
[14] On erroneous denials of service to legitimate customers, see NCTA—The Internet & Television Ass’n, supra note 6, at 6–7 (customers who cannot or will not provide the required information could face paused, restricted, or denied service); CTIA—The Wireless Ass’n, supra note 3, at 13–16 (credential requirements could exclude students, international travelers, domestic-violence survivors, and first-line and low-income consumers); INCOMPAS, supra note 7, at 9–10 (re-verification could interrupt service for legitimate customers, including the elderly). On bad actors who pass verification but commit fraud anyway, see USTelecom—The Broadband Ass’n, supra note 7, at 8 (fabricated identities can satisfy static verification checks); Nat’l Cable & Telecomms. Ass’n, supra note 6, at 9–10 (stolen, synthetic, and shell-entity identities can evade verification); INCOMPAS, supra note 7, at 2–3 (bad actors can satisfy know-your-customer (KYC) requirements using legitimately obtained credentials).
[15] N. Am. Numbering Council, Call Authentication Trust Anchor Working Grp., Best Practices for the Implementation of Call Authentication Frameworks 9 (2020), https://docs.fcc.gov/public/attachments/DOC-367133A1.pdf.
[16] Updating the Intercarrier Compensation System to Eliminate 8YY Access Arbitrage, WC Docket No. 18-155 et al., Report and Order, FCC 20-143, ¶ 2 (rel. Oct. 1, 2020) (describing “traffic pumping” by robocallers and the resulting incentive to inflate intercarrier charges).
[17] See Updating the Intercarrier Compensation Regime to Eliminate Access Arbitrage, WC Docket No. 18-155, Report and Order, 34 FCC Rcd. 9035, 9036 ¶ 3 (2019), https://www.fcc.gov/ecfs/document/0927225032050/5.
[18] Reforming Legacy Rules for an All-IP Future; Accelerating Network Modernization, 91 Fed. Reg. 14,408 (proposed Mar. 24, 2026), https://www.federalregister.gov/documents/2026/03/24/2026-05727/reforming-legacy-rules-for-an-all-ip-future-accelerating-network-modernization.
[19] See 47 C.F.R. §§ 64.6301, 64.6305 (2025); Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, Eighth Report and Order, FCC 25-15 (rel. Feb. 28, 2025); Call Authentication Trust Anchor, WC Docket No. 17-97, Report and Order, 35 FCC Rcd. 3241 (2020).
[20] FNPRM, supra note 1, ¶ 1.
[21] Id. ¶¶ 9, 24.
[22] NCTA—The Internet & Television Ass’n, supra note 6, at 8–10.
[23] See USTelecom—The Broadband Ass’n, supra note 7, at 6–7.
[24] See NCTA—The Internet & Television Ass’n, supra note 6, at 8–10 & n.10 (collecting authorities).
[25] CTIA—The Wireless Ass’n, supra note 3, at 16–19.
[26] See CTIA—The Wireless Ass’n, supra note 3, at 13–16 (a government-issued-identification requirement would exclude or burden students and teenagers without driver’s licenses, seasonal workers, international travelers without U.S. identification, and consumers with heightened privacy needs, including domestic-violence survivors, whistleblowers, journalists, and undercover law-enforcement officers); USTelecom—The Broadband Ass’n, supra note 7, at 4 & n.4 (international travelers and minors may lack government identification, while limits on prepaid-service data collection protect the privacy of domestic-violence survivors, whistleblowers, and witnesses); NTCA—The Rural Broadband Ass’n, supra note 8, at 6 & nn.16–17 (some consumers need anonymity to protect their personal safety).
[27] See CTIA—The Wireless Ass’n, supra note 3, at 14 (many consumers seeking their first phone line have no secondary number, so requiring one could deny service to low-income consumers); INCOMPAS, supra note 7, at 6–7 (an alternate-number requirement would disadvantage students, foreign visitors, and consumers whose prior service lapsed, and a verified email address should suffice instead); USTelecom—The Broadband Ass’n, supra note 7, at 4 & n.4 (the requirement would burden consumers seeking basic service, including low-income individuals and youth transitioning out of foster care).
[28] See FNPRM, supra note 1, ¶¶ 9, 22–23.
[29] See NCTA—The Internet & Television Ass’n, supra note 6, at 3, 12 (re-verifying existing customers would impose substantial burdens and raise the prospect of disconnecting longstanding customers who fail to respond despite no evidence of illegal calling; the record contains little evidence linking longstanding customers to misconduct); INCOMPAS, supra note 7, at 9–10 (periodic re-verification could unnecessarily interrupt or terminate service for legitimate customers, including the elderly); USTelecom—The Broadband Ass’n, supra note 7, at 5 (re-verifying existing residential customers is unreliable and could cause unwarranted service interruptions).
[30] See NCTA—The Internet & Television Ass’n, supra note 6, at 3, 12–13 (the threat of substantial penalties would encourage overly cautious compliance, leading providers to deny or terminate service whenever customer information raises even modest uncertainty; a de facto strict-liability regime would incentivize providers to refuse entire categories of customers to avoid liability); INCOMPAS, supra note 7, at 11 (per-call penalties could expose providers to open-ended liability despite good-faith compliance efforts that a future FCC might later deem insufficient); ACA Connects—Am.’s Commc’ns Ass’n, Comments, CG Docket Nos. 17-59, 02-278, at 7 (filed June 25, 2026), https://www.fcc.gov/ecfs/document/26109923927/1 (open-ended liability would encourage smaller providers to decline service).
[31] See NTCA—The Rural Broadband Ass’n, supra note 8, at 2–5 (compliance costs recur over time, strain provider resources, and must be spread across small customer bases, in addition to existing STIR/SHAKEN, robocall-mitigation, and call-blocking obligations); USTelecom—The Broadband Ass’n, supra note 7, at 4–5 (new data-collection systems would impose significant compliance costs that providers ultimately pass on to consumers); CTIA—The Wireless Ass’n, supra note 3, at 17–19 (collecting, securely storing, and coordinating customer data across retail channels would increase costs); NCTA—The Internet & Television Ass’n, supra note 6, at 7 (enhanced KYC requirements necessarily increase costs for providers and customers alike); INCOMPAS, supra note 7, at 16 (engineering, interface, training, and customer-education requirements would impose additional costs).
[32] On the pass-through of telecommunications regulatory costs to consumers and the resulting effects on investment and deployment, see Eric Fruits & Geoffrey A. Manne, Quack Attack: De Facto Rate Regulation in Telecommunications, Int’l Ctr. for L. & Econ. (Mar. 30, 2023), https://laweconcenter.org/resources/quack-attack-de-facto-rate-regulation-in-telecommunications; Geoffrey A. Manne, Kristian Stout & Ben Sperry, The Return of (De Facto) Rate Regulation: Title II Will Slow Broadband Deployment and Access, Truth on the Mkt. (Feb. 8, 2022), https://truthonthemarket.com/2022/02/08/the-return-of-de-facto-rate-regulation-title-ii-will-slow-broadband-deployment-and-access; Jeffrey Westling, The Last Mile Is a Paper Trail: Why Broadband Gets Stuck, Truth on the Mkt. (Apr. 22, 2026), https://truthonthemarket.com/2026/04/22/the-last-mile-is-a-paper-trail-why-broadband-gets-stuck.