latest FCC rulings

Sat Dec 18 15:45:07 UTC 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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