Twenty-two more companies have joined forces with the Association of Communications Enterprises (ASCENT) (www.ascent.org) in the competitive industry’s efforts to have the FCC raise the three-line restriction to the DS-1 level on unbundled local switching (ULS) in the 50 largest metropolitan service areas (MSAs).
The Bells, meanwhile, are waging their own unified fight against such a request.
The crux of the argument is that the unbundled network element platform, or UNE-P, is a critical entry strategy for competitors, who also say that ULS is key to accessing the UNE-P.
While the ILECs are legally obligated to provide UNE-P in most U.S. markets, the FCC several months ago established an exception.
The FCC ruled that the ILECs have no obligation to provide switching facilities to competitive carriers in the most heavily populated zones of the top 50 MSAs when those carriers seek to serve customers with more than three access lines.
Without access to switching in these urban markets, competitors say there is no access to the UNE-P. And without access to the UNE-P, an entry strategy essentially is being roped off before competitors can use it.
When ASCENT initially wrote to FCC (www.fcc.gov) Chairman Michael K. Powell about this restriction, 35 individual competitive companies supported ASCENT in lifting the three-line threshold.
Yesterday, ASCENT resubmitted another letter to Powell listing the 22 additional companies joining in the campaign.
“We believe the DS-1 threshold would permit competitive local exchange carriers to economically serve all customers in all markets,” according to Ernest B. Kelly III, ASCENT’s president and author of the letter to the FCC. “Certainly a primary beneficiary of this policy would be thousands of small businesses in the downtown areas of major cities.”
The three-line threshold means that CLECs cannot serve the huge number of small businesses that have at least four analog voice lines but fewer voice lines and data requirements than can be served economically by a DS-1, according to ASCENT.
Because of this, the association believes many urban small businesses are relegated to a distinct local phone market that’s occupied by “basically the incumbent LEC.”
Raising the threshold to the DS-1 level would allow new entrants with modest resources to focus their capital expenditures on state-of-the-art OSSs and on growing their customer base, according to ASCENT.
“Furthermore, once critical mass and economies of scale are achieved, these providers likely would opt to deploy facilities that would reduce their dependence on the [ILEC] network,” Kelly wrote.
The Bells, on the other hand, want ‘high-cap’ loops and dedicated transport taken off the FCC’s UNE list.
BellSouth Corp. (www.bellsouth.com), Verizon Communications Inc. (www.verizon.com), and SBC Communications Inc. (www.sbc.com) have asked the FCC to rule that they don't have to unbundle high-capacity loops, which are the circuits with a DS-1 (1.544 mbps) transmission capacity or higher, or dedicated transport facilities.
Together, the three incumbent carriers filed a joint petition with the FCC claiming that there are “ample alternatives for these elements available outside the ILECs’ networks.”
The three telcos also cited statistics showing that several CLECs are using their own switching facilities to serve customers with less than 20 lines. Therefore, the BOCs claim, the “switch carve-out” is not hindering competition.
But ASCENT says that few CLECs are actually doing this.
Kelly says that the broad support among many companies on this issue should speak volumes to the FCC about the importance of ULS and the UNE-P to competitive service providers.
“This is something positive that the FCC can do to help competitors,” Kelly said. “We hope the Powell commission will endorse this change, which reflects the view that both facilities-based and non-facilities based carriers play important roles in creating and sustaining competitive markets.”
The additional 22 companies who have joined ASCENT are: 1-800-RECONEX Inc.; A R C Communications Ltd.; Benchmark Equity Group; Business Telecom Inc.; Ciera Network Systems Inc.; DialMex LLC; Eastern Telephone; G. Marshall Communications; General Energy Services Inc. (GENERGY); IDS Telcom LLC; Intelecom Solutions Inc.; InternetConnect; ITC^DeltaCom Inc.; Local Gateway Exchange Inc.; North American Communications Control Inc.; NorthStar Communications Inc.; Pound Capital Corp.; RateXchange; RSL COM U.S.A. Inc.; TCAST Communications Inc.; Telecare Inc.; and TRI-M Communications Inc., which does business as TMC Communications.
