North American Network Operators Group
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Re: latest FCC rulings

  • From: Matt Hess
  • Date: Sat Dec 18 10:49:03 2004 
James Edwards wrote:
Wire centers serving more than 38,000 business lines or at least 4 fiber
based CLEC's (this means their own fiber, I think) do not have to offer
DS1 CO to CO loops to a CLEC. For DS3/Dark Fiber it is 24,000 business
lines or 3 fiber based CLEC's. This is interoffice transport, the CLEC's
transport between its colos, which they lease from the LEC per their
interconnect contract. It can be quite inexpensive. Why bother coloing
if you can't get good transport between the colos ?


Yes this is what I've gotten out of it.. facility feeder loops are still available but interoffice transport lines have been all but killed..
It would appear that the FCC's intention was to force the clecs to compete among themselves and leave the ilec out of the fray in large population centers.. which really makes no sense unless the fcc is attempting to stifle the business of clecs and limit them to less populated/rural areas.. hence, providing a quasi monopoly..

Much the same for customer loops from your colo.
Unbundling, IIRC, is what the xLEC's got from the Telcom act. The loops and fiber. These unbundeled elements can only be accessed by colocation
with the LEC, for most cases. For wire centers that meet the limits,
key here is it has to be both sides meetings the limits for interoffice
transport (CO to CO), a colocated CLEC cannot get ds1, ds3, and dark
fiber to build their network.


With these rulings I think they have all but killed the UNE platform.
We are in several Qwest CO's in New Mexico, this is one of the few times
it has been good to live in NM, in the context of telecommunications.
Fiber based xLEC's, not many, and we only have one city that can be
considered big.

The questions we had are work were about the business lines. Does it
include CLEC lines ? If is does not, business lines are where the LEC's
have seen a big decrease and any counts are suspect as they may be old.
So is the xLEC supposed to buy interoffice transport from the fiber
based folks in the colo ? Can they get loops, too ?


We asked the Colorado PUC and they have interpreted it to mean total business lines.. clecs and lecs totaled together.. funny thing is.. we checked out the line count at denver main at it was under the 38k line limit.. struck me as rather funny. It would appear that the FCC intention is for clecs to buy from other fiber clecs.. but at least out here in colorado it would appear very expensive to do that.. much more so then back haul loops would be.

I am not sure about how this effects DS0's. Voice and
HSDSL. DSL line share is gone so you have to do voice
to offer DSL, in the wholesale context.

What are they up too ? They limit competition in locations
where there are several major providers or a lot of business customers.



Well, in a nutshell my interpretation is that the ilecs have gone to the fcc and through many rounds of lobbying and somewhat shady filings.. (like qwest's recent filing to become completely deregulated) they have told the fcc that since this administration wants to see broadband grow and push out to more areas the fcc needs to get the clecs off their back and then the ilecs will build it for them.

The fcc has done so by really hurting the interoffice transport (back haul loops, dark fiber restrictions, death of UNE etc.). They really neutered the Telecommunications Act of 1996.. for some sick reason they think the clecs have an equal chance against the ilecs. Heck, 2 of the commissioners were against the rulings.. but who cares.. a simple majority needs to be held to pass the rules and screw the industry.. sounds like a bargain deal for the ilecs.. buy 3 commissioners, get 2 free.

I find commissioner Jonathan Adelstein's opinion on this a great help to laying it out as to what's about to happen..
(http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-255344A5.pdf)



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