UNE Orders Great News for CLECs

UNE Orders Great News for CLECs
Provides ILECs Some Protection
from Competition
By Jonathan E. Canis
Posted: 01/2000

In our November 1999 article (page 20), we noted the FCC adopted new rules defining UNEs that appeared to provide dramatic new opportunities for CLECs. Well, the FCC finally released the full text of its order in early November, and a clarification of the order in late November, and we are delighted to affirm the positive impact the FCC's rules will have on local competition. This article talks about two of the most dramatic new UNE developments now available--the UNE "Platform" and the enhanced extended link (EEL).

The UNE Platform: The Platform is a combination of all UNEs necessary to provide local dialtone service to a residence or business--loop, local switching, inter-office transport, tandem switching, and the entrance facility that delivers it all to the competitive carrier's switch. ILECs will be allowed to effectively eliminate the Platform by eliminating the local switching piece if four criteria are met: (1) it is in one of the top 50 metropolitan statistical areas (the 50 largest telecom markets in the country); (2) it is in "Density Zone 1" (high-density urban areas defined by the ILECs); (3) it is eliminated only for users with four or more lines (this means the Platform will always be available for residential and small-business users, even in the largest urban markets); and (4) EELs are available.

EEL: Unlike the Platform, the EEL does not provide switching. Rather, EELs offer CLECs high-capacity dedicated transport from their equipment to an end user location. Typically, it combines loops, multiplexing and inter-office transport.

The FCC appears to place two restrictions on EELs. First, although the FCC's order is not clear on this point, it appears a CLEC must be collocated in some ILEC facility (tandem, end office, serving wire center or remote terminal) to obtain the EEL. Second, and this is perfectly clear from a supplemental order issued by the FCC, the EEL must be used to provide a "significant" amount of local traffic (it can't be used solely to carry long distance traffic). The FCC adopted these limitations to prevent the largest IXCs from converting massive amounts of the switched and special access circuits they buy from ILECs to UNEs--the FCC is concerned such conversions may deprive ILECs of too much access revenue over a short period of time.

One of the most attractive features of the Platform and EELs is that they can be ordered as switched or special access services, and then later converted to UNEs. Because ILECs provision access services much quicker than UNEs (it can take months to get a UNE, vs. five to 10 days for an access service), which means much speedier implementation. Moreover, the FCC has vowed to ensure the prompt availability of these UNE combinations. The Platform and EEL provide dramatic cost reductions below ILEC access service rates and reduce the need for CLECs to collocate in multiple ILEC offices. As such, they will be important new tools for speeding competitive entry into local markets.