UNE Fight Continues at FCC, This Time Over Reconsideration
A focus on fiber-based collocation understates the abilities of competitors without unbundled network elements (UNE) access to transport, Verizon said in the latest round of comments on the petitions for reconsideration of UNE rules. Several commenters, however, defended the earlier FCC decision.
Sign up for a free preview to unlock the rest of this article
Communications Daily is required reading for senior executives at top telecom corporations, law firms, lobbying organizations, associations and government agencies (including the FCC). Join them today!
Ia. Telecom’s petition for reconsideration, which is supported by BellSouth, Qwest, and Verizon, argues that the FCC’s impairment test for dedicated transport didn’t account for fiber-based networks’ wire centers. “Such fiber-based networks show that it is possible for CLECs to compete by completely bypassing the incumbent’s network in that wire center, as well as in comparable wire centers,” said the Verizon reply.
Ia. Telecom, Cbeyond, T-Mobile, several payphone service providers (PSPs), and others filed replies defending their petition for reconsideration. “The facilities needed to interconnect such competitive dedicated interoffice transport networks to ILEC switches are widely available to such competitive providers and can be easily obtained,” Ia. Telecom said.
The other CLECs hope to expand requirements for UNE, especially for DS1 and DS3 high-capacity loops and dedicated transport. Regarded by CLECs as incomplete, the analysis conducted of DS1 and DS3 transports by the ILECs is attacked in many of the petitions. Cbeyond, for example, said the incumbents failed to examine “costs of collocation, conversions and DS3 transport acquired from the lowest priced non-UNE source for DS3 network.” It also said its experience with BellSouth transport demonstrates the need for redundancy, since “failures would have caused Cbeyond’s customers to lose service.”
The payphone providers said their revenue data “constitutes the best data available and accurately reflects the revenues available from a payphone line.” ILECs had attacked the revenue data as incomplete, but the providers said it “consists of the aggregated revenues per line of three CLECs serving over 100,000 independent payphone lines across 20 states, representing 20-25% of all independent PSP lines.”