There’s ‘absolutely no rational public policy basis’ for imposing...

use as unbundled network elements (UNEs) to provide local phone service. ILECs fear those combinations also could be used by long distance providers to avoid paying special access rates to ILECs. EELs, based on Total Element Long-Run Incremental Cost (TELRIC) rates, are cheaper than special access tariffs. CompTel said local competitors had to lease higher priced special access alternatives from ILECs such as T-1 lines, multiplexing and transport because EELs rarely were available. “The only effect of the use of restrictions is to guarantee the ILECs a certain revenue stream from their tariffed special access services,” association said. ALTS urged FCC to take several steps to improve access to EELs: (1) Endorse process in which CLECs would self- certify that they were using EELs in approved way. (2) Implement process that set deadlines for ILECs to make billing change that transferred CLECs from special access to EELs. (3) Let CLECs use EELs for data services. (4) Establish enforcement procedure to assure ILECs provided EELs to CLECs. SBC and Verizon filed joint comments warning that sanctioning EEL combinations “would confer an undue windfall” on long distance providers that would use them to get “unwarranted discounts” from special access rates they now paid. On other hand, denying CLECs access to high-capacity loop- transport combinations wouldn’t “impair” competitors, SBC and Verizon contended.