Attachment A
THE VERIZON TELEPHONE COMPANIES
The Verizon telephone companies are the local exchange carriers affiliated with Verizon Communications Inc. These are:
Contel of the South, Inc. d/b/a/ Verizon Mid-States GTE Midwest Incorporated d/b/a/ Verizon Midwest GTE Southwest Incorporated d/b/a/ Verizon Southwest The Micronesian Telecommunications Corporation Verizon California Inc. Verizon Delaware Inc. Verizon Florida Inc. Verizon Hawaii Inc. Verizon Maryland Inc. Verizon New England Inc. Verizon New Jersey Inc. Verizon New York Inc. Verizon North Inc. Verizon Northwest Inc. Verizon Pennsylvania Inc. Verizon South Inc. Verizon Virginia Inc. Verizon Washington, DC Inc. Verizon West Coast Inc. Verizon West Virginia Inc.
Attachment B
Before the Federal Communications Commission Washington, D.C. 20554
In the Matter of ) ) Review of the Section 251 Unbundling ) Obligations of Incumbent Local ) CC Docket No. 01-338 Exchange Carriers ) ) Implementation of the Local Competition ) Provisions in the Telecommunications ) CC Docket No. 96-98 Act of 1996 ) ) Deployment of Wireline Services ) Offering Advanced Telecommunications ) CC Docket No. 98-147 Capability )
UNE FACT REPORT 2002
Prepared for and Submitted by BellSouth, SBC, Qwest, and Verizon
April 2002
TABLE OF CONTENTS
I. COMPETITIVE OVERVIEW...... I-1
A. Competitive Facilities and Networks...... I-1
B. Competitive Lines Served...... I-5
C. Capital Investment...... I-10
D. Revenues...... I-12
E. Outlook...... I-15
II. LOCAL SWITCHING ...... II-1
A. CLEC Circuit Switches...... II-4
1. Geographic Areas Served by CLEC Circuit Switches...... II-5
2. Use of CLEC Switches To Serve Mass-Market Customers...... II-10
B. Packet Switches as Substitutes for Circuit Switches...... II-20
C. Wireless Switches as Substitutes for Circuit Switches...... II-33
III. INTEROFFICE TRANSPORT...... III-1
A. Fiber-Based Collocation...... III-1
B. CLEC Fiber...... III-6
C. Wholesale Suppliers of Local Fiber...... III-8
IV. LOCAL LOOPS...... IV-1
A. High-Capacity Loops...... IV-1
1. CLEC Fiber as a Substitute for High-Capacity ILEC Loops...... IV-1
2. CLECs Are Making Little Use of Unbundled High-Capacity Loops...... IV-6
B. POTS Loops...... IV-8
1. Cable Networks as Substitutes for ILEC Loops...... IV-9
2. Mobile Wireless as Substitute for POTS Loops...... IV-12
3. Direct Competitive Overbuild of ILEC Loops...... IV-15
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C. Broadband Loops...... IV-18
V. FACILITIES-BASED COMPETITION VERSUS RESALE ...... V-1
A. Efficient Facilities-Based Entry...... V-3
1. Incremental Development of Facilities-Based Competition...... V-4
2. Economies of Scope and Scale...... V-6
3. Emergence of Competitive Resale Markets...... V-9
4. Geographic Expansion ...... V-11
B. The Failure of Non Facilities-Based Competition...... V-13
1. The Failure of UNE-Platform Competition...... V-14
2. The Failure of the DLEC Model...... V-14
C. Anti-Competitive Impacts of Expanding UNEs into Competitive Markets. ....V-18
1. Conversion of Special Access Circuits to UNEs...... V-18
2. Conversion of Transmission Services for Wireless Carriers...... V-20
3. Conversion of Broadband Services for Information Service Providers...... V-22
D. Facilities-Based Investment in New Broadband Infrastructure...... V-22
APPENDICES
APPENDIX A. ESTIMATING CLEC LINES
APPENDIX B. CLEC CIRCUIT SWITCHES
APPENDIX C. WIRE CENTERS IN THE TOP 100 MSAS WHERE CLECS HAVE ACQUIRED CUSTOMERS THROUGH PORTED NUMBERS
APPENDIX D. RATE EXCHANGE AREAS IN THE TOP 100 MSAS WHERE CLECS HAVE OBTAINED NXX CODES
APPENDIX E. CLEC PACKET SWITCHES
APPENDIX F. WIRELESS SWITCHES
APPENDIX G. COMPETITIVE COLLOCATION PROVIDERS IN THE TOP 50 MSAS
APPENDIX H. HOT-CUT PERFORMANCE
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APPENDIX I. CLECS PROVIDING ATM AND FRAME RELAY
APPENDIX J. ADDITIONAL INFORMATION ON SOFTSWITCHES
APPENDIX K. CLEC NETWORKS BY MSA
APPENDIX L. ESTIMATING CLEC SPECIAL ACCESS MARKET SHARE
APPENDIX M. ADDITIONAL SOURCES (including full citations for short cites used in this report)
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I. COMPETITIVE OVERVIEW
The Commission conducted its last comprehensive review of local exchange competition in 1999. Since that time, CLEC customer bases have been growing at significant rates, more than tripling in the last three years. ILECs are losing roughly an equal number of lines to wireless and cable networks as they are to wireline CLECs. At least 10 million wireline access lines already have migrated to wireless networks, and several million more have migrated to cable networks. For three years running, the number of lines served by ILECs has declined – a trend never witnessed before in a century of growth of telephone service. And competitive alternatives are available to far greater numbers than are actually subscribing today.
A. Competitive Facilities and Networks.
The competitive networks of CLECs, wireless carriers, and broadband providers have all grown significantly in the three years since the Commission conducted its last comprehensive UNE review. See Table 1. The number of cities with CLEC networks has increased by more than 70 percent, CLEC fiber has grown by more than 80 percent, CLEC circuit switches and packet switches have both nearly doubled, and buildings served by CLECs have more than tripled. See id. CLECs now serve more lines using entirely their own facilities (including their own local switches and loops) than they do by relying entirely on ILEC networks (through resale or the UNE Platform). See Figure 1. All of these figures are conservative, because they are drawn from public sources or from the necessarily limited data available to the BOCs.
Table 1. Competitive Networks YE 1998 YE 2001 Wireline Cities with Voice Networks 540 930 CLECs Circuit Switches 700 1,300 Packet Switches 860 1,700 Route Miles of Fiber (local and long-haul) 100,000 184,000 Average Number of CLEC Networks in Top 100 MSAs 10 16 Buildings Served (on- and off-net) 106,000 330,000 Homes with access to cable telephony service <2,000,000 >10,000,000 Wireless % of population in counties with 3 or more wireless operators n/a >91 % of population in counties with 5 or more wireless operators n/a >75 Wireless Carriers Offering Data Services 2 7 Broadband % of homes with access to cable modem service 20 66-77 % of homes with access to two-way satellite 0 >90 Markets with MMDS 0 58 Sources: See Appendix M.
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Figure 1. Breakdown of CLEC Lines by Mode of Entry*
Resale 13%
Entirely Over CLEC Facilities UNE Platforms 52% 23%
Using CLEC Switches and UNE Loops 12%
*The number of lines provided entirely over CLEC facilities and using CLEC switches is based on the number of E911 listings CLECs have obtained. Because the actual number of lines that CLECs are serving with their own switches is likely much higher, this method will, if anything, understate the percentage of all lines that CLECs are serving in whole or in part over facilities they have deployed themselves. The number of lines that CLECs are serving entirely over CLEC facilities was derived by subtracting the total number of stand-alone POTS loops from the total number of CLEC E911 listings.
Switches.1 At the time of the last UNE review, CLECs had deployed approximately 700 traditional local circuit switches. Today, CLECs operate approximately 1,300 known local circuit switches. CLECs are now using their switches to serve no fewer than 16 million local lines, and likely closer to 23 million local lines, a more than three-fold increase since 1998. CLEC switches are now so geographically widespread that they are being used to serve actual local customers in wire centers that contain approximately 86 percent of the Bell companies’ access lines.
CLECs are using their switches to serve mass-market customers as well as large business customers. As of year-end 2001, CLECs were serving at least three million residential lines using their own switches, and were offering service to millions more. Circuit-switched cable telephony has been deployed in 20 states and is now available to more than 10 million U.S. homes – approximately 10 percent of the mass market. Cable telephony is now available ubiquitously in some smaller states (e.g., Cox service in Rhode Island) and to a large and growing fraction of homes in a number of larger states (e.g., AT&T service in and around Pittsburgh, Boston, Chicago, and the Bay Area, and Cox service in San Diego, Orange County, and the Tidewater area of Virginia).
Packet and wireless switches are now placing significant, additional competitive pressure on the ILECs’ traditional circuit switches. Some eight million users now have broadband cable or wireless data links that terminate directly on a competitive packet switch, bypassing ILEC circuit switches altogether. Since the last UNE review, the installed base of the CLECs’ known packet switches has nearly doubled, from 860 to more than 1,700. The number of wireless subscribers has increased from about 69 million as of year-end 1998, to an estimated 130 million today. A rapidly growing number of subscribers are using wireless service as a substitute for second and additional lines, and some consumers have abandoned wireline service entirely in favor of wireless. And wireless switches are displacing usage on wireline switches even more
1 See Section II.
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rapidly. Wireless carriers have deployed hundreds of switches, which handle an estimated 12 percent of all U.S. phone calls.
Interoffice Transport.2 It is clearly economical for competitors to run fiber-optic networks to a large fraction of ILEC wire centers. Since the time of the last UNE review, CLECs have increased their fiber networks from approximately 100,000 route miles to at least 184,000 route miles, and the majority of this fiber is used for local transport. The number of CLEC networks in the 150 largest MSAs – which encompass nearly 70 percent of the U.S. population – has grown from approximately 1,100 to approximately 1,800 in the last three years. Local fiber also is now being supplied to CLECs by carrier-agnostic wholesale suppliers, utility companies, and interexchange carriers. CLECs are now using their own fiber networks to capture between 28 and 39 percent of all revenues for special access services, which are provided through a combination of transport and high-capacity loops.
CLECs that provide competitive transport typically do so by collocating transmission equipment in an ILEC central office and connecting that equipment to their own fiber-optic network. This “fiber-based collocation” supplies the simplest and most unambiguous indicator of the extent of competition in the transport market. As of year-end 2001, one or more CLECs had obtained fiber-based collocation in BOC wire centers that contain more than half of all business lines served by the Bell companies. As of that same date, one or more CLECs had obtained fiber-based collocation in more than 60 percent of all BOC wire centers with more than 10,000 business lines. These figures are highly conservative because, with all the competitive fiber that has been deployed, a considerable amount of traffic also now bypasses ILEC wire centers completely.
High-Capacity Loops.3 CLEC fiber networks now pass through a large number of commercial office buildings, which contain an even larger number of high-volume customers. CLECs now serve at least 156 million voice-grade equivalent circuits, the majority of which are provided over high-capacity lines. And CLEC fiber networks are now so extensive that they readily can be – and routinely are – extended as needed to pick up additional traffic from new, off-net customers. CLECs accordingly serve the vast majority of their customers using their own last-mile facilities. For example, CLECs serve between four and seven times more business customers over high-capacity fiber that the CLECs own themselves, than they do over loops obtained from ILECs. CLECs have purchased only 70,000 high-capacity loops in the four BOCs’ regions combined. Virtually all of the high-capacity loops that CLECs have purchased are DS-1 loops; CLECs have purchased only 140 DS-3 loops, and not a single loop above the DS-3 level.
POTS Loops.4 Technologies that compete directly against traditional POTS loops are rapidly being deployed across the country. Cable telephony services were available in only a few markets at the time of the last UNE review. Today, they have been expanded to the point where they are now offered to more than 10 percent of all U.S. homes; that figure is projected to
2 See Section III. 3 See Section IV.A. 4 See Section IV.B.
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rise rapidly over the next few years. As noted above, cable telephony is now available ubiquitously in some smaller states and to a large and growing fraction of homes in a number of larger states.
Wireless services compete much more significantly against wireline than they did at the time of the last UNE review. The quality of wireless services has improved significantly in the last three years, and prices have dropped dramatically. More than 90 percent of the U.S. population now lives in counties served by three or more mobile wireless operators; more than three-quarters of the population live in counties served by five or more. Two in five Americans have a mobile phone.
Broadband Loops.5 Broadband loops represent an increasing share of all loops provided to mass-market customers – more than 6 percent as of year-end 2001. Broadband cable modem service is now available to more than two-thirds of the residential population. Cable operators serve more than twice the number of broadband subscribers as ILEC networks, and satellite and fixed wireless providers offer additional competition. Two satellite providers now offer two-way broadband service nationwide. Broadband wireless services also are much more widely available today than they were three years ago.
Interconnection of Competitive Networks and ILEC Networks. Since the last UNE review, CLECs have significantly increased the level of interconnection between their networks and ILEC networks, and the amount of traffic exchanged between them. See Table 2. The number of CLEC collocation arrangements has grown nearly six-fold since the Commission conducted the last UNE review. See id. End offices serving more than 80 percent of all BOC access lines now have one or more CLEC collocators.6 The number of CLEC interconnection trunks has more than quadrupled since the last UNE review. See Table 2. Minutes of traffic exchanged on these trunks have increased by about five-fold. See id.
Table 2. Interconnection of CLEC and ILEC Facilities Collocation Arrangements Interconnection Minutes Exchanged Trunks 1998 2001 1998 2001 1998 2001 Verizon* 1,100 7,000 663,000 3.4 million 32 billion 193 billion SBC** 2,000 9,900 541,000 3.1 million 23 billion 125 billion BellSouth 870 4,700 326,000 1.3 million 21 billion 98 billion Qwest 240 3,300 285,000 927,000 20 billion 78 billion Total 4,300 24,900 2 million 9 million 96 billion 493 billion Totals may not equal sum of parts due to rounding. *1998 collocation arrangements exclude the former GTE service area. Minutes exchanged data exclude CLEC-terminated minutes for the former GTE service area. **1998 minutes exchanged data exclude the Ameritech service area.
5 See Section IV.C. 6 See Section II.A, Table 10.
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B. Competitive Lines Served.
Since the last UNE review, CLECs, wireless, and broadband providers have very significantly increased the number of customers and lines that they serve. See Table 3. There has been especially large growth in the number of lines that CLECs serve with their own facilities. By contrast, ILEC access lines have steadily declined in each of the last three years, an unprecedented trend in a century of steady annual growth. See Figure 2.
CLECs serve no fewer than 16 million lines and likely closer to 23 million lines – including approximately three million residential lines – wholly or partially over facilities they have deployed themselves, facilities that invariably include their own local switches.7 These line totals represent a more than three-fold increase since 1998, and a more than thirty-fold increase in facilities-based residential lines. Many of the lines that CLECs serve are high-capacity lines; CLECs now serve at least 156 million voice-grade equivalent circuits.8 CLECs also serve more than 9 million lines – including more than 5 million residential lines – via resale of ILEC service or through the UNE Platform. The corresponding figures three years ago were approximately 2.7 million CLEC lines, including 1.5 million residential lines. Today, the largest CLECs serve more than one million access lines each, and large numbers of CLECs serve 500,000 or more. See Figure 3.
Table 3. Competitive Lines/Subscribers YE 1998 YE 2001 Wireline CLECs Facilities-Based Business Lines 5-6 million 13-20 million Facilities-Based Residential Lines >80,000 3 million Resale/UNE-P Business Lines 1.2 million 3.8 million Resale/UNE-P Residential Lines 1.5 million 5.6 million Wireless Wireless Subs. 69 million 130 million Wireless Data Subs. n/a 6.7 million Broadband Cable Modem Subs. <300,000 7.5 million Fixed Wireless/Satellite Subs. 0 >200,000 Sources: See Appendix M.
7 See Section II.A. 8 See Sections II.A & IV.A; see also Table 4, infra, and Appendix A.
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Figure 2. Decline of BOC Access Lines
200 Trend (based on 1996-1998 average annual growth rate of 4.4%) 195 Actual 190 185 180 175 170 Access Lines (in millions) (in Lines Access 165 1998 1999 2000 2001 Sources: Credit Suisse First Boston; FCC. See Appendix M.
Figure 3. CLEC Access Line Distribution 12 11 11 10 1998 10 9 2001 8 8 8
6 5 4 4 3
Number of CLECs of Number 2 0 0 50,000 - 99,999 100,000 - 249,999 250,000 - 499,999 500,000 - 999,999 1 million or more Source: New Paradigm Resources Group. See Appendix M.
The CLECs’ share of access lines in BOC regions is at least 16 percent, and likely closer to 20 percent. See Figure 4. Their share of BOC residential lines is approximately 9 percent, and their share of BOC business lines is at least 26 percent, and likely closer to 33 percent. In some BOC regions, the CLECs’ share of lines is even higher. And, as noted above, at least two- thirds of all CLEC lines are provided wholly or partially over facilities they have deployed themselves.
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Figure 4. Percentage of Total Access Lines Served by CLECs in BOC Regions Facilities-Based* (based on interconnection trunks*2.75) Resale UNE Platforms Facilities-Based (based on E911 listings) 40% 26-36% 25-35% 35% 33% 26-33% 23-31% 30%
25% 17-22% 16-20% 15-19% 19% 20% 13-17%
15% 11% 9% 9% 10% 8% 6% 5% 0% BusResTotal Bus Res Total Bus Res Total Bus Res Total Bus Res Total Verizon** SBC*** BellSouth Qwest Total
*The totals for facilities-based lines based on interconnection trunks multiplied by 2.75 represents the additional lines produced by this methodology over the number of E911 listings that CLECs have obtained. **Verizon data do not include CLEC or ILEC lines in the former GTE service area. ***SBC data do not include CLEC or ILEC lines in Connecticut and Nevada.
Even at their lower end, the totals for facilities-based lines that we report here are considerably higher than the totals that CLECs themselves have reported to the FCC for incorporation into the FCC’s February 2002 Local Telephone Competition Report. As discussed in Appendix A, however, our low-end totals have been obtained from CLEC-supplied listings in the E911 databases. For obvious reasons, these databases are highly reliable; ILECs and CLECs alike have the strongest possible incentives to maintain them accurately. In filing their line-total reports with the FCC, by contrast, many CLECs do not appear to be following the Commission’s express instructions relating to the conversion of high-capacity lines into “voice-grade equivalent lines.”9 In contrast, the CLECs do make a distinction between lines and “voice-grade equivalents” in the reports they make to investors and securities regulators. See Table 4. The Commission indicates that CLECs collectively report serving a total of only 8.6 million lines wholly or partially over their own facilities. Yet AT&T alone has informed the investment community that the company serves “over 30 million” voice-grade equivalent lines over its own network. And 11 other CLECs that report their voice grade equivalent lines to investors have reported serving an additional 125 million voice-grade equivalent lines.
9 The FCC’s instructions specify that carriers are to report “voice-grade equivalent lines,” which it defines as “a line or channel that directly connects an end user to a carrier and allows the end user to originate and terminate local telephone calls on the public switched network.” FCC, Instructions for the Local Competition and Broadband Reporting Form, FCC Form 477 at 5-6 (data as of Dec. 31, 2001) (emphasis in original).
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Table 4. CLEC Reporting of Voice-Grade Equivalent Lines to Investors CLEC-Reported Totals WorldCom 76.4 million “as of December 31, 2000, our domestic local voice grade equivalents had increased 98% to 65.5 million versus the prior year amount.” “Voice Grade Equivalents 2001: 76,415,566” – WorldCom, Inc., Form 10-K (SEC filed Mar. 13, 2002) AT&T >30 million “Over 30 [million] DS0 equivalents.” – D. Dorman, President, AT&T, Presentation Before the Lehman Brothers T3 Telecom, Trends & Technology Conference (Dec. 6, 2001) XO 21.2 million “Voice Grade Equivalents (VGE, 64 Kbps capacity), a measure used by XO to evaluate the utilization of its network, grew to 21.2 million in the fourth quarter of 2001.” – XO Comm. Press Release, XO Communications Reports 74 Percent Increase in Annual Revenues and Reduced EBITDA Losses (Feb. 14, 2002) Time Warner 16.7 million “DS-0 Equivalents: 16,736,000” as of YE01 Telecom – Time Warner Telecom Press Release, Time Warner Telecom Announces Fourth Quarter Results (Feb. 5, 2002) Adelphia 4.6 million “Voice Grade Equivalent Circuits: 4,624,032” Bus. Solutions – Adelphia Business Solutions, Form 10-Q (SEC filed Nov. 13, 2001) KMC Telecom 3.6 million “Total lines (DS-0 equivalents – the combination of access lines and dedicated lines) grew to over 3.6 million at the end of the third quarter 2001.” – KMC Telecom Press Release, KMC Telecom Reports Financial and Operational Results for the Third Quarter 2001 (Nov. 8, 2001) Cox 1.8 million “Voice Grade Equivalent Circuits: 1,773,340” as of YE01.” – Financial Data attached to Cox Press Release, Cox Communications Announces Fourth Quarter Financial Results for 2001 (Feb. 12, 2002) CTC 589,000 “Access Line Equivalents in Service at 589,000” as of YE 2001 – CTC Communication Press Release, CTC Communications Group Announces Fourth Quarter and Year End Results, Restructured Lease Financing Agreement and Amended Bank Facility (Mar. 7, 2002) CoreComm/ 495,000 “Toll-related access line equivalents: 495,300” as of 3Q01 ATX – CoreComm Press Release, CoreComm Limited Announces Financial Results for the Third Quarter of 2001 (Nov. 14, 2001) Pac-West 235,000 “Total DS0 equivalent lines in service, which include wholesale and on-network retail DS0 line equivalents, were 235,244 in the fourth quarter of 2001.” – Pac-West Press Release, Pac-West Telecom Announces Fourth Quarter and Year-End 2001 Results (Feb. 12, 2002) PaeTec 233,000 “PaeTec . . . has installed 232,848 access line equivalents.” – PaeTec Press Release, PaeTec Exceeds 232,000 Access Lines (Feb. 5, 2002) Integra >120,000 “more than 120,000 ALEs” [access line equivalents] as of YE01 – Integra Press Release, Integra Telecom Reports Strong 2001 Growth (Feb. 4, 2002) Total 156 million
As the totals for facilities-based competition make clear, CLECs have achieved significant economies of scope and scale, and have done so largely without relying on UNEs. More than half of all competitive lines are served entirely over CLECs’ own facilities, and nearly two-thirds of competitive lines are served by CLECs’ own switches. See Figure 1, supra. Moreover, these totals demonstrate that CLECs have chosen initially to focus on the most lucrative customer segments, and have therefore made much larger inroads than their count of lines would suggest. Indeed, as discussed below, the CLECs’ share of revenues is considerably higher than their share of lines.
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To the extent that CLECs continue to rely on the UNE Platform, market experience demonstrates that they are not migrating UNE-Platform customers to their own facilities to any significant degree (if at all) – despite the fact that they have already deployed the switches they need to do so, and have already built up very large customer bases. See Figures 5 & 6.10 Indeed, many CLECs that have obtained UNE Platforms concede that they have no plans to convert these customers to their own switches. Contrary to the intent of the Commission’s unbundling rules, these CLECs are treating UNE-Platform competition as an end in itself, rather than as a stepping stone to facilities-based competition. And in doing so, they are devaluing the efforts of CLECs that have decided to make the investment in facilities-based competition.11
Figure 5. Use of UNE Platforms by Top 15 Switch-Based CLECs Other Than AT&T and WorldCom 1,600,000 UNE Platforms 1,400,000 Facilities-Based Lines (based on E911 Listings) 1,200,000 1,000,000 800,000 600,000 400,000 200,000 0 Top 15 CLECs represented include: Allegiance Telecom, Cablevision Lightpath, Choice One, Cox, Electric Lightwave, Focal Communications, ICG, Intermedia, McLeodUSA, Mpower, Net2000, RCN, Sprint, WinStar, and XO.
Figure 6. Use of UNE Platforms by CLECs Providing Service to 25,000 or More Residential Lines Using Their Own Switches*
250,000 Residential UNE Platforms Residential Facilities-Based Lines (based on E911 Listings) 200,000
150,000
100,000
50,000
0 *Excludes CLECs providing service over cable facilities. Does not include CLECs in Qwest’s region.
CLECs providing service to 25,000 or more facilities-based residential lines include: ALLTEL, Broadview, Cavalier Telephone, Intermedia, Knology, McLeodUSA, RCN, TDS, and TOTALink.
10 See Sections II.A & V.B. 11 See Section V.B.
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ILECs are also rapidly losing lines due to competition from wireless and cable providers.12 Wireless phones compete directly for second lines, and to a lesser (but growing) extent for primary lines. Analysts estimate that about 10 million total access lines were replaced by wireless lines as of year-end 2001. Approximately 70 percent of all residential broadband subscriber lines are provided over cable networks, and two out of every three new broadband subscribers choose cable modem service.
Finally, a great deal more traffic is migrating off of ILEC networks than the migration of lines would indicate.13 E-mail and instant messaging (IM) now substitute for a large fraction of voice traffic. There are now 900 million e-mail accounts in the U.S. and over 60 million IM users. It is estimated that consumers in the U.S. are sending approximately 3.2 billion e-mail messages and approximately 1 billion IM messages per day. If only 10 percent of the 4.2 billion daily e-mail and instant messages substitute for a voice call, that is equivalent to about 750 billion minutes per year, or roughly one-third of all voice traffic that passes through ILEC networks. A large and growing fraction of e-mail and IM traffic originates and/or terminates on competitive networks. And even when carried over ILEC networks, such traffic displaces significant usage-sensitive (e.g., per-minute or per-call) revenues that otherwise would be earned.
C. Capital Investment.
CLECs, wireless carriers, and broadband providers have made enormous capital expenditures to expand the availability of their services.
CLECs have invested about $50 billion in new capital expenditures since the time of the last UNE review three years ago.14 Significant venture capital has gone into the telecommunications industry.15 CLECs also have raised large sums from strategic and institutional investors,16 and have obtained significant additional funding from debt markets.17
12 See Sections II.B & IV.B. 13 See Sections II.B & II.C. 14 See ALTS, The State of Local Competition 2001 at 20 (Feb. 2001) (citing Paine Webber and NPRG). 15 In the four full years preceding the UNE Remand Order, the telecommunications industry had attracted only $5 billion in venture capital dollars. In 1999 alone, the telecommunications industry raised nearly $8 billion, and in 2000 the industry raised an additional $18 billion. Telecommunications continued to attract significant additional venture capital in 2001, raising nearly $6 billion in venture capital funding. See PricewaterhouseCoopers, PricewaterhouseCoopers/Venture Economics/National Venture Capital Association MoneyTree Survey, Investments by Industry 1995-2001, http://www.pwcmoneytree.com/PDFS/National%20Aggregate%20Data%2095Q1%20- %2001Q4.xls. 16 CLECs raised more than $7.4 billion from strategic and institutional investors in 1999, plus another $3 billion in 2000 and 2001. See ALTS, The State of Local Competition 2001 at 17-18 (Feb. 2001) (1999); W.T. Scott, et al., Morgan Stanley, A Brief Critique – CLEC Events of the Week at 12 (Dec. 12, 2001) (2000/2001); XO Press Release, XO Announced $800 Million Equity Investment from Forstmann Little and Telmex (Nov. 29, 2001); XO Press Release, XO Reaches Definitive Agreement with Forstmann Little and Telmex (Jan. 16, 2002). In addition to these totals, Bill Gates’s private investment groups have invested $500 million in Cox. See Reuters, Gates Invests $500 Million in Cox, CNET News.com (Jan. 24, 2002), http://news.com.com/2100-1001-822792.html. 17 According to one source, CLECs obtained $36 billion in loans in 1999. See NPRG CLEC Report 2002, 15th ed., Ch. 2 at 6.
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Initial public offerings by CLECs raised $2.6 billion in 1999 and 2000.18 CLEC market capitalization has dropped sharply in the past 18-24 months, as it has in most other high-tech sectors. But many CLECs took advantage of the stock bubble, while it lasted, to finance acquisitions, investments, and capital outlays. See Table 5. More recently, stronger CLECs have taken advantage of falling stock prices to purchase their weaker siblings at a bargain price.19
Much of this competitive investment has gone into building urban fiber networks to serve business customers. But CLECs also have invested a great deal in building out their networks to serve residential customers. Cable operators have already invested at least $8 billion to upgrade their networks to provide telephony services.20
Cable operators and other competitive providers also have invested heavily to provide broadband services. The National Cable & Telecommunications Association (NCTA) estimates that the cable industry has invested more than $55 billion “to provide consumers advanced broadband services” since passage of the 1996 Act.21 Satellite and fixed wireless providers also have made very large investments to provide two-way broadband services.22
There has been even more investment in terrestrial wireless facilities. Cumulative capital investment in the wireless industry has jumped from $24 billion at the end of 1995 to $100 billion as of June 2001.23 Wireless carriers spent more than $18 billion in 2000 alone on network upgrades and expansion.24 The cumulative capital investment in the wireless network ($100B) is now roughly one-quarter of the cumulative (depreciated) capital investment in the wireline network ($360B).25 Annual capital spending on the wireless network ($18B) is running at about half of the corresponding figure for the wireline network ($40B), and continues to grow more
18 ALTS, The State of Local Competition 2000 at Graphic D (Feb. 2000); IPO Home, 2000 Year in Review – All 2000 IPOs, http://www.ipohome.com/marketwatch/review/iporeview.asp?stats=priced. 19 For example, Time Warner Telecom acquired GST’s assets; AT&T acquired NorthPoint’s assets; and WorldCom acquired Rhythms’s assets. See Time Warner Telecom Press Release, Time Warner Telecom Finalizes Purchase of GST Assets (Jan. 10, 2001); AT&T News Release, AT&T Completes Acquisition of NorthPoint Communications (May 25, 2001); WorldCom Press Release, WorldCom Closes Rhythms Transaction (Dec. 5, 2001). 20 See, e.g., JP Morgan Cable Industry Report at 46 & Table 22 (the cost of upgrading a home for circuit- switched cable telephony is $825/line, and there are 10.255 million homes passed by circuit-switched cable telephony). 21 Letter from Robert Sachs, President & CEO, NCTA, to the Honorable Member of Congress (Feb. 8, 2002). 22 See, e.g., Application of EchoStar Communications Corporation, General Motors Corporation, Hughes Electronics Corporation, Transferors, and EchoStar Communications Corporation, Transferee, For Authority to Transfer Control, Consolidated Application for Authority to Transfer Control at 46, CS Docket No. 01-348 (FCC filed Dec. 3, 2001) (“Each of ECC (EchoStar Communications Corporation) and Hughes has already made significant broadband investments and plans future deployment of additional high speed Internet access.”). 23 See CTIA’s Semi-Annual Wireless Industry Survey Results. 24 See CTIA, Telephia Study Finds Outstanding Wireless Network Performance While Industry Experiences Rapid Growth, http://www.wow-com.com/articles.cfm?ID=553. 25 CTIA’s Semi-Annual Wireless Industry Survey Results; FCC Statistics of Common Carriers at Table 2.7 (1995-2001 eds.).
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rapidly (averaging 35 percent growth each year for the last five years, while wireline investment has grown at an average of 14 percent each year).26
Table 5. CLEC Mergers & Acquisition Activity Acquirer Target Firm Value Date Closed NEXTLINK Concentric Network $2.2 billion June 2000 McLeodUSA SplitRock Services $1.8 billion April 2000 CoreComm ATX $900 million September 2000 Advanced Radio Telecom Broadstream $365 million August 2000 Mpower Primary Network $145 million June 2000 Choice One US XChange $515 million August 2000 Covad BlueStar $202 million September 2000 Gabriel TriVergent November 2000 Time Warner Telecom GST $690 million January 2001 WorldCom Intermedia $5.5 billion July 2001 McLeodUSA CapRock $532 million December 2000 Hughes Electronics Telocity $180 million April 2001 AT&T NorthPoint assets $135 million May 2001 Allegiance Coast-to-Coast Communications $27 million September 2001 Cavalier Telephone Conectiv Communications n/a November 2001 WorldCom Rhythms NetConnections $31 million December 2001 IDT Corp. WinStar $42.5 million December 2001 Choice One Fairpoint (comm. assets only) undisclosed December 2001 Comcast AT&T Broadband $72 billion announced Dec. 2001 Allegiance Intermedia Business Internet undisclosed January 2002 assets acquired from WorldCom Cavalier Telephone Net2000 (VA, MD, DC) $25 million January 2002 Broadview Networks Net2000 assets (NY/MA/NJ) undisclosed January 2002 acquired from Cavalier New Edge Networks @Work $1.5 million February 2002 Cogent Allied Riser n/a February 2002 Broadview Networks Network Plus undisclosed announced Feb. 2002 Sources: See Appendix M.
D. Revenues.
Though precise figures of CLEC local revenues are elusive,27 facilities-based CLECs are now generating substantial revenues. According to New Paradigm Resources Group’s CLEC
26 Compare FCC Statistics of Common Carriers at Table 2.7 (1995-2001 eds.) with CTIA’s Semi-Annual Wireless Industry Survey Results. 27 Many CLECs are not public companies and do not therefore report their revenues to the Securities Exchange Commission. While most CLECs do report revenues to the FCC, the FCC releases this data in only aggregate form. Complicating matters, the revenue categories reported by the FCC have fairly amorphous parameters. For example, it is difficult to distinguish revenues generated from exchange access services from those generated from intraLATA toll and special access services. This is particularly true with respect to those revenues generated by I-12
Report – a source relied on by the CLEC industry28 – total CLEC revenues (excluding long distance revenues) increased five-fold between year-end 1998 ($8.5B) and year-end 2001 ($44B). See Figure 7.29 New Paradigm estimates that CLEC revenues from switched local services increased from $3.5 billion in 1998 to $9.5 billion in 2001.30 The latest revenue data compiled by the FCC show CLECs with a total of $8.5 billion in local revenues as of year-end 2000.31 Since the time of the last UNE review, the number of CLECs earning $100 million or more has nearly doubled. See Figure 8.
CLECs specifically target customers that generate high levels of traffic and revenues32 – analysts and the FCC report that the CLECs’ share of revenues is between 12 and 20 percent higher than their share of lines.33 And the CLECs’ share of high-end local services is considerably higher than their share of local revenues overall. For example, the CLECs’ share of special access revenues is between 28 and 39 percent.34 The big three interexchange carriers control more than two-thirds of the revenues for ATM and Frame Relay services.35
CLECs that provide local services also earn significant revenues from the provision of other telecommunications services. According to New Paradigm, CLECs now earn nearly $25 billion from the provision of data and data-related services such as Internet access, frame relay, carriers that are both CLECs and interexchange carriers, including AT&T and WorldCom – the largest carriers in both categories – who report their revenues as both kinds of entities. See Appendix L. 28 See, e.g., ALTS, The State of Local Competition 2001 (Feb. 2001); ALTS, An ALTS Analysis: Local Competition Policy & The New Economy (Feb. 2, 2001); ALTS, The State of Competition in the U.S. Local Telecommunications Marketplace (Feb. 2000). 29 See NPRG CLEC Report 2000, 12th ed., Ch. 1 at Table 3; NPRG CLEC Report 2002, 15th ed., Ch. 3 at Table 9. “Other” revenues reported by New Paradigm (i.e., reciprocal compensation and non-telecom related revenues) are excluded from these totals. Credit Suisse First Boston estimates that total CLEC revenues (excluding long-distance and data revenues) have grown from approximately $5 billion in 1998 to approximately $12.5 billion in 2001. See CSFB 4Q00 CLEC Vital Signs Review at Table 11 (4Q1998); CSFB 3Q01 CLEC Vital Signs Review at Exh. 9 (1Q 2001-3Q 2001 results; 4Q 2001 estimate). 30 Compare NPRG CLEC Report 2000, 12th ed., Ch. 1 at Table 3 with NPRG CLEC Report 2002, 15th ed., Ch. 2 at Table 8. Credit Suisse First Boston estimates that CLEC revenues from switched local services has increased from approximately $3.7 billion in 1998 to $10.8 billion in 2001. See CSFB 4Q00 CLEC Vital Signs Review at Table 11 (4Q1998); CSFB 3Q01 CLEC Vital Signs Review at Exh. 9 (1Q 2001-3Q 2001 results; 4Q 2001 estimate). 31 FCC Telecommunications Industry Revenues, 2002 ed. at Table 7; NPRG CLEC Report 2002, 15th ed., Ch. 2 at Table 8. 32 See, e.g., Legg Mason, Telephone Wars: Local Competition Update at 2 (May 22, 2001) (“The CLEC sales figures reflect larger market share gains than those calculated on the basis of line lost, since the majority of lines lost are of the high-usage commercial type.”). 33 See, e.g., id. at 3 (At the end of 1Q01 “the CLEC share of the total US line market was 7.6%,” while “the CLEC’s share of the gross industry revenues was approximately 9.2%,” a difference of 21%.); FCC Local Competition Report, Feb. 2002 ed. at 4, Table 1 (“The share of local service revenues claimed by carriers competing with the ILECs” was 8.9% in 2000 while CLECs reported a 7.7% share of end-user switched access lines in December 2000, a difference of 15.6%); CSFB 3Q01 CLEC Vital Signs Review at Exh. 9 (Through 3Q01, local competitors’ share of U.S. access lines was 9.7%, while local competitors’ share of the local market revenues at quarter end was 10.9%, a difference of 12.4%). 34 See Section V.C & Appendix L. 35 See Section II.B, Figure 5.
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ATM, DSL, “and other enhanced data and Web-related services.”36 CLECs other than the big interexchange carriers earn an additional $3 billion from the provision of long distance services.37 Cable telephony providers are able to bundle video and data services with the voice services they provide, and analysts expect “video/voice” to be the “most popular” bundle of service desired by consumers.38
Figure 7. CLEC Revenues 100 90 Local Switched Services 80 Data Services 70 60 Total CLEC Revenue 50 52% 40 $ Billions 30 52% 51% 21% 20 20% 27% 39% 21% 10 41% 37% 26% 25% 4% 13% 0 1996 1997 1998 1999 2000 2001 2005 (est.) Source: New Paradigm Resources Group. See Appendix M.
Figure 8. CLEC Revenue Distribution 30 29 1998 25 2001 20 16 15 9 8 10 7 5 Number of CLECs of Number 5 4 4
0 $25 - $49 million $50 - $99 million $100 - $499 million $500 million or more Source: New Paradigm Resources Group. See Appendix M.
If cable companies are counted among them, CLECs earn substantial revenues in the local, high-speed data transport sector as well. Cable companies earned an estimated $2.3 billion from the provision of high-speed data services in 2001, and that figure is projected to exceed $10 billion by 2006.39
Wireless carriers also are competing directly with ILECs for a large and increasing share of revenues. As of year-end 2000, wireless carriers reported $62 billion in revenues, which
36 NPRG CLEC Report 2002, 15th ed., Ch. 3 at 3. 37 See id.; see also FCC Trends in Telephone Service, Aug. 2001 ed. at Table 10.1 ($1.3 billion in toll revenues earned by CAPs and CLECs as of year-end 2000). 38 JP Morgan Cable Industry Report at 42. 39 See R.A. Bilotti, et al., Morgan Stanley, Dean Witter, Broadband Cable Television at 9 (July 3, 2001).
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represents more than half of the revenues that wireline carriers reported for local service.40 At the time of the last UNE review, wireless revenues were at $37 billion, about one-third the amount of wireline local revenues.41
E. Outlook.
As a percentage of the overall telecommunications market, wireline local voice is rapidly declining, as local traffic moves on to wireless and data networks, and the volumes of data traffic continue to surge. See Figure 9. Wireline local voice revenues grew by an average of 2.7 percent per year between 1996 and 2001, but are expected to remain constant over the next five years.42 While wireline local voice revenues represented approximately 44 percent of all local revenues in 2001, they are expected to represent only 26 percent by 2006.43
Figure 9. Wireless and Data Overtaking Voice
350 Local Data Data: $130B IP Voice: $180B 300 Wireless Data 250 Wireless Voice Data: $43B Local Voice 200 Voice: $147B
150 Data: $8B Voice: $96B 100
Revenues ($ Billions) ($ Revenues 50 0 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 (est.) (est.) (est.) (est.) (est.) (est.)
Source: JP Morgan H&Q. See Appendix M.
Cable telephony providers are expected to “have more than 10 million circuit-switched telephony customers in 2006.”44 Cable operators will have deployed IP-telephony widely by that time as well, and are expected to serve nearly five million telephony customers over packet- switched networks.45
Data traffic has already overtaken voice traffic on the telephone network, and data traffic is growing much faster than voice. Most access-line growth between 1996 and 2000 was due to data, with customers adding second lines as a dedicated Internet/fax line.46 These lines are now
40 See FCC Telecommunications Industry Report, 2002 ed. at Table 1. 41 See CTIA’s Semi-Annual Wireless Industry Survey Results. 42 See JP Morgan Telecom Services 2001 Report at Table 1. 43 See JP Morgan Telecom Services 2001 Report at Table 1. 44 Forrester Sizing US Consumer Telecom Report at 10. 45 See Forrester Sizing US Consumer Telecom Report at 10-12. 46 See, e.g., Gartner U.S. Residential Wireline Report at 5 (“additional line growth rates have been significantly higher among online households than their offline counterparts.”).
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in rapid decline, with most customers opting for a wireless or cable connection instead of a second line.47 By 2006, it is expected that 17 million circuit-switched lines will have been superceded (i.e., rendered technologically obsolete) by wireless, cable modem, and non-DSL packet-switched connections.48 Local data revenues are expected to grow to nearly $70 billion in the next five years.49 By that time, data is expected to make up 46 percent of all local revenues, up from 24 percent today. See Figure 9. A great deal of data traffic is carried on non-ILEC networks. Cable modem is adding residential broadband subscribers much faster than DSL, and cable is expected to maintain a two-to-one lead over DSL five years from now.50
Wireless carriers are adding subscribers much faster than their wireline counterparts – in percentage terms, and in absolute terms, too. Some twenty million new subscribers are being added annually.51 IDC estimates that, by 2005, wireless “lines” will have cumulatively displaced a total of approximately 20 million wirelines (counting both primary and secondary access lines).52 Wireless minutes of use are growing at over 60 percent per year, while landline minutes are growing at “low single digits.”53 By 2003, wireless voice revenues are expected to surpass wireline voice revenues. See Figure 10.
Figure 10. Wireless vs. Wireline Growth Wireless Lines 250 $120 Wireline Lines 200 Wireless Voice Revenues $100 Wireline Voice Revenues $80 150 $60 100 $40
50 (billions) Revenues Access Lines (millions) Lines Access $20
0 $0 1996 2001 (est.) 2006 (est.) Source: JP Morgan H&Q. See Appendix M.
47 See, e.g., id. at 7-9 (finding that, from January to June 2001, 6 million households (6 percent of all households) have replaced a traditional telephone access line with another form of communications line, and 61.5 percent of those 6 million have chosen wireless or cable); see also Sections II.C & IV.B. 48 See Forrester Sizing US Consumer Telecom Report at Figures 6 & 8-1. 49 JP Morgan Telecom Services 2001 Report at 25. 50 See, e.g., JP Morgan Telecom Services 2001 Report at Table 16 (Nov. 2, 2001) (showing 25.9 million residential cable modem subscribers and 12.9 million residential DSL subscribers in 2006.); see also Morgan Stanley Cable Modem/xDSL Report at Exh. 1; Section IV.C. 51 See CTIA’s Semi-Annual Wireless Industry Survey Results. 52 See IDC Wireless Displacement Report at Figure 23; see also Forrester Sizing US Consumer Telecom Report (“Over the next five years, the mobile business will take a cut at fixed-line revenues. Wireless operators will ravage the fixed-line business as 5.5 million consumers give up secondary lines, and an additional 2.3 million cut the cord on their primary line.”). 53 3g Rollouts Inch Along, But Kagan Research Indicates Wireless Minutes Roaring Ahead, Set to Dominate Telecom Landscape by 2005 Leading Executives to Debate Market Demand, Technology and Financing at Kagan’s Wireless Telecom Summit May 2-3 in New York, Bus. Wire (Apr. 27, 2001); see Section II.C.
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Next-generation broadband technologies are now being deployed.54 Much of the copper distribution plant will have to be replaced with fiber in order to support the growing demand for broadband services. Wireless broadband services – both fixed and mobile – are coming, too. Analysts predict that 3G mobile networks will be widely deployed by 2004 or 2005. The Commission also has recently taken the first steps to “pave the way for new types of products incorporating ultra-wideband (UWB) technology” – devices that may be able to operate on spectrum already occupied by existing radio services without causing interference. It has also resolved to explore the introduction of “software defined radio” (SDR) technology, which could allow a single device to be quickly reprogrammed to transmit and receive on any frequency within a wide range using virtually any transmission format. There also are a host of other technologies currently under development that will be capable of provisioning wireless broadband services. These include Digital SMR, third generation mobile systems, 2 GHz MSS satellite systems, L-Band satellites, and Big LEO satellites. Recent advancements in fixed wireless technologies – particularly Non-Line-of-Sight technologies – are expected to “cause a spur in service provider deployments.”
Entirely new telecommunications networks are being deployed to satisfy surging demand for high-speed packet-switched data services. Much of this new infrastructure has little relation to the old. Fiber is replacing copper in the loop; packet switches are replacing circuit switches in the central office; and the transport between these packet switches is using very different routes than the rigid point-to-point connections between central offices that have prevailed in the past. In deploying this new infrastructure, ILECs will enjoy no particular advantages over competing carriers.
Most of the broadband market that is now emerging remains up for grabs. Most of the technology that will ultimately be used to provide ubiquitous broadband service has not yet been developed. Most of the capital has not yet been committed. Most of the customers are not yet being served. And because broadband digital services will ultimately absorb and displace the old, analog voice and video, no established player in telecom, cable, or broadcast markets today has any assurance of winning any durable share of the vast digital market ahead.
54 See Section V.D.
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II. LOCAL SWITCHING
At the time of the FCC’s last UNE review, CLECs had deployed approximately 700 local circuit switches.1 Today, CLECs operate approximately 1,300 known local circuit switches. See Appendix B.2 At the time of the last UNE review, CLECs were serving about six million lines using switches they had deployed.3 As of year-end 2001, CLECs were serving no fewer than 16 million local lines, and likely closer to 23 million local lines – including approximately three million residential lines – over their own switches. CLEC switches are now so geographically widespread that they are being used to serve local customers in wire centers that contain approximately 86 percent of the Bell companies’ access lines. In the 100 largest Metropolitan Statistical Areas (MSAs), CLECs are using their switches to serve local customers in wire centers that contain approximately 96 percent of the BOC access lines in those MSAs. See Appendix C. All of these figures are conservative, because they are drawn from public sources or from the necessarily limited data available to the BOCs.
More than 200 CLECs of all sizes have actually deployed local circuit switches in the Bell companies’ regions. While the two largest CLECs (AT&T and WorldCom) account for more than 25 percent of these switches, the next 15 largest CLECs (measured by switch ownership) account for an additional 37 percent of all local circuit switches. See Figure 1. The number of CLECs operating 10 or more circuit switches has increased from 15 to 27 since the time of the last UNE review, while the number operating 20 or more has increased from 6 to 16.4 And with the exception of AT&T and WorldCom, the 15 largest switch-based CLECs (measured by switched-based lines served) make virtually no use of unbundled switching, either on a stand- alone basis or as part of the so-called UNE-Platform. See Figure 2.
Cable companies have deployed large number of circuit switches that they are using, in combination with their own loops, to provide cable telephony service that bypasses ILEC networks completely. This service is now available to more than 10 percent of all U.S. homes and there are more than 1.5 million actual subscribers. Cable telephony is now available statewide in some smaller states (like Cox service in Rhode Island) and to a large and growing fraction of homes in a number of larger states (e.g., AT&T service in and around Pittsburgh, Boston, Chicago, and the Bay Area, and Cox service in San Diego, Orange County, and the Tidewater area of Virginia).
1 See UNE Remand Order ¶ 254 (“As of March 1999, approximately 167 different competitors have deployed approximately 700 switches throughout the country.”). 2 See Telcordia, January 2002 LERG. New Paradigm Resources Group (“NPRG”) reports that, as of year-end 2001, CLECs had deployed 1,244 circuit switches with another 92 circuit switches planned. See NPRG CLEC Report 2002, 15th ed., Ch. 2 at 20. That figure is based on the circuit switches of 70 companies profiled by NPRG. See id. By comparison, the LERG database indicates that approximately 200 competing carriers have deployed circuit switches. See Appendix B. 3 This figure is based on the number of interconnection trunks CLECs had obtained as of year-end 1998 (see Section I, Table 3), and assumes that for each trunk a CLEC had obtained as of that date, the CLEC was serving 2.75 lines. See Appendix A (describing this methodology in more detail). 4 See Section V, Figure 1.
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Figure 1. Distribution of CLEC Switches 491 500 467 1998 ITC^DeltaCom, XO, TW Telecom, 184 Other Level 3, ICG , CLECs 400 2001 366 McLeodUSA, KMC, Adelphia, AT&T Allegiance, Choice WorldCom One, Intermedia, 300 263 e.spire, 269 Global Crossing, Intermedia, Teligent, 148 Other 192 WinStar, Teligent, ALLTEL/WinStar/ CLECs 200 GST, XO, TW Focal (tied) WorldCom Telecom, e.spire, AT&T KMC, Frontier, Hyperion, Focal, 100 Allegiance, US LEC, Cox/ICG/
Number of Local Circuit Switches Mpower(tied) 0 Two Largest CLECs Next 15 Largest CLECs Other CLECs Sources: Telcordia, Local Exchange Routing Guide (LERG). See Appendix M.
Figure 2. Use of UNE Platforms by Top 15 Switch-Based CLECs Other Than AT&T and WorldCom 1,600,000 UNE Platforms 1,400,000 Facilities-Based Lines (based on E911 Listings) 1,200,000 1,000,000 800,000 600,000 400,000 200,000 0 Top 15 CLECs represented include: Allegiance Telecom, Cablevision Lightpath, Choice One, Cox, Electric Lightwave, Focal Communications, ICG, Intermedia, McLeodUSA, Mpower, Net2000, RCN, Sprint, WinStar, and XO.
Packet and wireless switches are now placing significant, additional competitive pressure on ILECs’ traditional circuit switches. At the time of the last UNE review, 36 million households still relied on dial-up connections – and thus on ILEC circuit switches – for their data services.5 As discussed further in Section IV.C, however, nearly eight million users now have broadband cable or wireless data links instead, which bypass the circuit switch completely and terminate directly on a competitive packet switch. If all of these broadband users would otherwise be using dial-up connections, the packet switches used to provide these services now displace at least 4 percent of all circuit-switched minutes of use, even assuming that the average data line is used only as much as the average voice line. The total would be far higher if one takes into account the fact that data calls generally last much longer than voice calls. Since the last UNE review, the installed base of CLECs’ known packet switches has jumped from 860 to more than 1,700.6 See Appendix E.
5 See JP Morgan Cable Industry Report at Table 13 (36.7 million online households in 1998 minus 700,000 broadband households equals 36 million dial-up households). 6 See NPRG CLEC Report 2000, 12th ed., Ch. 6 (1998 total); NPRG CLEC Report 2002, 15th ed., Ch. 4 at II-2
The dramatic rise of wireless services since the last UNE review is certainly having a similar impact on circuit-switched ILEC traffic. As of year-end 1998, there were about 69 million wireless subscribers; as of year-end 2001, there were an estimated 130 million, as compared to about 190 million wireline switched access lines.7 Today, a large and rapidly growing number are using wireless service as a substitute for second and additional lines, and a growing number are abandoning their wireline phones altogether. There were approximately 200 billion billable minutes of wireless use in the first half of 2001, and by the end of 2001 wireless calls accounted for an estimated 12 percent of all U.S. phone calls. Many wireless carriers offer particularly attractive long-distance calling plans; when the wireless phone is used for long-distance calls, the ILEC loses traffic not only in end office switches but in access tandems, too. Wireless carriers not affiliated with the Bell companies have deployed at least 950 local switches. See Appendix F.
A large and growing fraction of business customers also locate switching equipment directly on their premises, which enables them to perform a portion of their local switching in- house, rather than outsource it to an ILEC’s circuit switch. Today, there are approximately 56 million lines served through private branch exchanges (PBXs). A PBX performs all the local switching between the lines that connect to it directly. Moreover, a new generation of PBXs that use IP-based packet switching instead of circuit switching make PBXs economical for an even larger share of businesses.
Table 18 (2002 total). This is a highly conservative estimate. It does not include the 840 packet switches NPRG lists for competitive Independent Operating Companies, utility CLECs, data providers, or Gig-E providers. In addition, it does not include the 7,000 packet switches that NPRG lists for AT&T as of year-end 2001. According to NPRG’s prior reports, AT&T had only 50 packet switches as of year-end 2000. Because one-year growth of this magnitude is unlikely, in an abundance of caution we have used the 2000 figure for AT&T’s packet switches. 7 CTIA’s Semi-Annual Wireless Industry Survey Results; CTIA, CTIA’s World of Wireless Communications, http://www.wow-com.com (131 million U.S. wireless subscribers as of Feb. 12, 2002); CSFB 3Q01 CLEC Vital Signs Review at Exh. 9 (189 million U.S. access lines as of 4Q2001).
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Table 1. Competition for ILEC Circuit-Switched Local Traffic Switches Subscribers/Lines Minutes Revenues CLEC 1,300 CLEC circuit At least 16 million 493 billion minutes $10 billion (CLECs Circuit switches (plus 360 lines, and likely closer originating/terminating switched local service Switches remote switches) to 23 million lines on CLEC switches per revenues) served on CLEC year switches Wireless 950 non-BOC wireless 130 million wireless 500 billion minutes $64 billion (wireless switches subscribers originating/terminating voice revenues) on wireless switches per year Data 1,700 CLEC packet 8 million residential Six times more data $2 billion cable switches cable/wireless/satellite traffic than voice modem revenue broadband subscribers Traffic over broadband $6 billion CLEC/IXC connections exceeds ATM/Frame Relay traffic over narrowband revenue PBX n/a 56 million PBX lines Intra-PBX switching n/a on 44 percent of all business lines Sources: See Appendix M.
A. CLEC Circuit Switches.
By very conservative estimates, CLECs are serving no fewer than 16 million local lines, and likely closer to 23 million local lines – including approximately three million residential lines – over the local circuit switches they have deployed. See Table 2 & Appendix A. CLECs serve a far larger number of actual circuits using their switches, because many of the lines they serve are high-capacity lines.8
Table 2. Lines Served over CLEC Switches, YE 2001 Based on E911 listings Based on Business Residential Total Interconnection Trunks* Verizon** 3.7 million 1.0 million 4.7 million 7.8 million SBC*** 4.5 million 1.2 million 5.7 million 8.6 million BellSouth 1.8 million 300,000 2.1 million 3.5 million Qwest 2.9 million 500,000 3.4 million 2.5 million Total 13 million 3 million 16 million 23 million *Assumes a ratio of 2.75 lines per interconnection trunk. See Appendix A (providing basis for this methodology). ** Verizon E911 listings and interconnection trunk data do not include the former GTE service area. *** SBC E911 listings data do not include Connecticut.
CLECs are using their switches to serve local customers in one of two ways. First, they are porting numbers from ILEC switches to their own switches using local number portability (LNP). Second, they are using NXX codes obtained from the North American Numbering Plan administrator.
8 See Sections I.B, Table 4 & IV.A; see also Appendix A.
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CLECs have ported approximately 14 million telephone numbers in the Bell companies’ regions, virtually all of which have been ported since the time of the last UNE review.9 In the last year alone, the number of CLEC ported numbers has grown by more than 70 percent. See Table 3. This demonstrates that CLECs have not only significantly increased their deployment of circuit switches, but also that they are now using these switches extensively to win local customers.
Table 3. Growth of Ported Numbers 2000 2001 Growth Verizon 2.7 million 4.7 million 77% SBC* 3.0 million 5.1 million 73% BellSouth 1.1 million 1.8 million 64% Qwest 1.4 million 2.4 million 71% Total 8 million 14 million 73% Growth percentages may not equal the differences shown due to rounding. * SBC data do not include Connecticut.
1. Geographic Areas Served by CLEC Circuit Switches.
As the FCC has recognized, competition for switched services may be assessed by analyzing where CLECs have obtained ported numbers and NXX codes.10
The Bell companies maintain internal data of the wire centers in which CLECs have ported telephone numbers from the BOCs’ switches to the CLECs’ own switches.11 Each number ported from a BOC’s switch to a CLEC’s switch represents a telephone served by that competitor’s own switch. Each wire center in which a CLEC has obtained a ported number therefore represents a geographic area where a CLEC is actually competing for local customers today using switches that it has deployed itself.
9 See Telephone Number Portability, Third Memorandum Opinion and Order on Reconsideration, 13 FCC Rcd 16090, ¶ 2, n.7 (1998) (first requiring ILECs to implement LNP in the 100 largest MSAs by December 31, 1998). 10 See, e.g., FCC Local Competition Report, Aug. 1999 ed. at 2, 43, Tables 4.1-4.3 & 5.1 (summarizing NXX code assignment activity and supplying information on ported numbers which “should provide insights into the number of customer lines served by competitors”); id. at 43 (using an NXX-based analysis for identifying “new entrants in the switched market.”); id. (“A local service competitor that owns a telephone switch must acquire a numbering code for that switch before commencing operation as a facilities-based CLEC providing mass market telephone service.”); UNE Remand Order ¶ 254 (noting with approval SBC’s evidence of competition for switching “using a methodology that tracks requesting carriers’ switches by examining migration of lines using ported numbers.”); id. ¶ 285 (relying on data of CLEC switches with NXX codes as basis for creating exception to national unbundled switching rule in Zone 1 wire centers). 11 A wire center is “the location of a local switching facility containing one or more central offices.” 47 C.F.R. § 54.5; see id. (“wire center boundaries define the area in which all customers served by a given wire center are located.”); see also Policy and Rules Concerning Rates for Dominant Carriers and Amendment of Part 61 of the Commission’s Rules to Require Quality of Service Standards in Local Exchange Carrier Tariffs, Memorandum Opinion and Order, 12 FCC Rcd 8115, ¶ 7, n.14 (1997) (A wire center “might have one or several class 5 central offices, also called public exchanges or simply switches.”).
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These ported number data demonstrate that CLECs are using their switches to serve local customers ubiquitously throughout the BOCs’ regions.12 As of year-end 2001, one or more CLECs had ported a telephone number to its own switch in 47 percent of BOC wire centers, which contain approximately 86 percent of all BOC switched access lines, including approximately 89 percent of all business lines and approximately 84 percent of all residential lines. See Tables 4 & 5. Significant numbers of BOC access lines are in wire centers served by multiple CLEC switches. See id.
The totals are even higher in the largest metropolitan areas. In the 100 largest MSAs, one or more CLECs had ported a telephone number to its own switch in 83 percent of BOC wire centers in those MSAs, which contain approximately 97 percent of all BOC switched access lines in those MSAs. See Appendix C.
Table 4. Percentage of Wire Centers Where CLECs Have Acquired Customers Through Ported Numbers Percentage of Wire Centers Served by: 1 or more 2 or more 3 or more 4 or more CLEC switch Verizon 44 32 26 22 SBC 47 35 28 25 BellSouth 58 39 32 28 Qwest 43 32 26 23 Total 47 34 28 24
Table 5. Percentage of Access Lines in Wire Centers Where CLECs Have Acquired Customers Through Ported Numbers Percentage of BOC Switched Access Lines in Wire Centers Served by: 1 or more 2 or more 3 or more 4 or more CLEC switch Bus. Res. Tot. Bus. Res. Tot. Bus. Res. Tot. Bus. Res. Tot. Verizon 90 83 85 84 75 79 80 69 73 75 64 68 SBC 88 83 85 82 75 77 74 66 69 70 62 65 BellSouth 94 90 91 85 79 80 79 71 74 73 65 67 Qwest 89 83 85 82 75 77 75 68 71 71 64 66 Total 89 84 86 83 76 78 77 68 71 72 63 66
12 For purposes of this report we have included in the analysis switches owned by CLECs that have declared bankruptcy. Most such CLECs are still operational. Moreover, switches are a sunk investment, so if one company ceases to use its switch it is highly likely that another company will quickly seize the opportunity to do so (and will probably be able to obtain the switch at a fire-sale price). In addition, even though some CLECs may now be experiencing financial troubles, the fact that they were able to deploy so many switches at one time is still highly probative of the ability of CLECs to deploy switches generally. In any event, switches operated by CLECs that have declared bankruptcy (as of March 31, 2002) represent no more than 17 percent of the total counted for purposes of this report.
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The areas that CLECs are capable of serving with their own switches also can be determined based on the NXX codes that CLECs have obtained. Each NXX code is associated with a “rate exchange area” served by an incumbent LEC.13 The rate exchange areas where CLECs have obtained NXX codes are the areas where CLECs have determined they may use their own switches to compete directly with incumbent LECs.
Telcordia’s Local Exchange Routing Guide (LERG) database contains the location of each CLEC switch, the NXX codes associated with those switches, and the rate exchange areas served by those NXX codes.14 These data demonstrate that, as of year-end 2001, one or more CLECs had obtained an NXX code to serve approximately 47 percent of BOC rate exchange areas, and that significant numbers of rate exchange areas are served by multiple CLEC switches. See Table 6. In the 100 largest MSAs, one or more CLECs had obtained an NXX code to serve more than 85 percent of BOC rate exchange areas in those MSAs. See Appendix D.
Table 6. Rate Exchange Areas Where CLECs Have Obtained NXX Codes Percentage of Rate Exchange Areas Served by: 1 or more 2 or more 3 or more 4 or more CLEC switch Verizon 43 26 20 16 SBC 46 25 14 8 BellSouth 64 41 29 19 Qwest 46 21 13 10 Total 47 27 19 14
The percentage of wire centers and rate exchange areas served by CLEC switches is a highly conservative measure of the extent to which CLECs actually serve – or have the ability to serve – customers using their own switches.
First, the data count only CLECs switches actually up and running, and only the locations that are presently served by these switches. CLECs could readily extend the geographic reach of existing switches, or deploy still more switches. As the Commission has found, whereas each ILEC switch typically serves only a single rate exchange area, CLECs can and do use their switches to serve multiple rate exchange areas.15 As one CLEC explains, “[t]he advent of fiber
13 Rate exchange areas are “geographically defined areas within which calls that originate and terminate (i.e., remain within the area) are considered local calls.” FCC Local Competition Report, Dec. 1998 ed. at 41, n.17. 14 In the Triennial Review Notice, the FCC asked whether the LERG database “is a reliable indication of whether competitors can serve the mass market using their own switches.” Triennial Review Notice ¶ 57. As an initial matter, while the LERG is itself a reliable source of the geographic areas to which CLECs have access with their switches, we also rely here on ported number data to make this showing. Thus, even if the Commission were concerned about the reliability of the LERG, it may rely on this alternative source of data. Moreover, as discussed below, once a CLEC has deployed a switch and is using that switch to serve business customers, it may readily expand the use of that switch to serve mass-market customers. Indeed, many competing carriers have done just that. 15 See UNE Remand Order ¶ 261 (“switches deployed by competitive LECs may be able to serve a larger geographic area than switches deployed by the incumbent LEC, thereby reducing the direct, fixed cost of purchasing circuit switching capacity and allowing requesting carriers to create their own switching efficiencies.”); id. ¶ 258 II-7
optic technologies and multi-function switching platforms have, in many cases, allowed carriers . . . to serve an entire statewide or LATA-wide customer base from a single switch platform.”16
CLECs themselves report that they can and do use their switches to serve very large geographic areas – as large as an entire LATA, an entire state, or even multiple states. AT&T has stated that its “local switches serve geographic areas that are comparable to the areas served by SWBT’s tandem switch.”17 For example, AT&T claims to serve both the entire Dallas LATA (LATA 552) and the entire Houston LATA (LATA 560) with one local switch apiece, whereas SBC serves these LATAs with 8 and 7 tandem switches, respectively, plus dozens of end-office switches.18 Numerous other CLECs have made similar claims. See Table 7.
Table 7. Use of CLEC Switches to Serve Large Geographic Areas WorldCom “WorldCom uses state-of-the-art equipment and design principles based on technology available today . . . which makes it possible to access and serve a large geographic area from a single switch.” “[W]hile WorldCom uses 4 local switches and a transport network to serve these [26] rate centers, BellSouth utilizes 5 local tandems and a multitude of end offices to serve this area.” ICG “[T]he ICG switch provides services to customers in a geographic area at least as large as that serviced by the ILEC tandem.” AT&T “It is important to note that in some cases, the AT&T switch serving a LATA is not physically located in the LATA.” Intermedia “Instead of deploying a multiplicity of switches to cover an area, as is BellSouth’s custom, Intermedia deploys a single switch to cover a very large area. Intermedia can do this because the switches it deploys are very capable and have a very large capacity.” “From this map, it is clear that all the areas we serve in Jacksonville, Orlando, Tampa and Miami are each served by a single switch. This is a great deal of territory, all covered by four Intermedia switches.” US LEC “For example, in the Jacksonville market, out network is designed to facilitate traffic termination to the same market as 2 BellSouth tandem switches. Our central office acts as tandem switch and as end office switch for the same 19 rate centers served by the two BellSouth switches.” Sources: See Appendix M.
Switch manufacturers have specifically designed their equipment to meet CLECs’ needs to serve large geographic areas.19 For example, Lucent’s 5ESS – the most popular circuit switch
(“facilities-based competitors need not deploy switches in exactly the same network configuration as an incumbent, thus allowing competitors to achieve their own unique and competitive efficiencies by deploying their own switches.”). 16 Prefiled Direct Testimony of Michael Starkey, ICG, NC Docket No. P-582, Sub. 6 at 21 (NC PUC filed May 27, 1999). 17 Direct Testimony of Jon A. Zubkus on Behalf of AT&T Communications of Texas et al., Proceeding to Examine Reciprocal Compensation Pursuant to Section 252 of the Federal Telecommunications Act of 1996, Docket No. 21982, at 3 (TX PUC filed Mar. 17, 2000). 18 Id. (“[T]he TCG switch in Dallas serves the entire 552 LATA which SWBT also serves with 8 tandems. In Houston, the TCG switch serves the entire 560 LATA which SWBT also serves with 7 tandems.”). 19 See, e.g., Lucent Technologies, 5ESS 2000 – Switch Mobile Switching Center, http://www.lucent.com/products/solution/0,,CTID+2008-STID+10048-SOID+824-LOCL+1,00.html (5ESS provides “a unique and very attractive low-cost solution . . . to support growth opportunities in startup areas where existing II-8
among CLECs – has “[r]emote switching capabilities” that make it possible to serve customers that are 2000 miles away from the host.”20 As of December 2001, CLECs had deployed approximately 360 remote switches in addition to the more than 1,300 host switches they have deployed.21
CLECs also may extend their competitive reach by deploying new switches or expanding the capacity of existing switches. In the last few years, switch manufacturers have made it easier and more cost-effective than ever for CLECs to purchase and deploy new circuit switches.22 Switches have modular designs that enable a carrier to start small and add capacity as they grow.23 The latest generation of switches also has very large maximum capacities – as much as 600,000 lines.24
Second, the data are based only on conventional CLEC circuit switches, even though all forms of circuit-switched traffic (including fax, e-mail, and data) are now being switched on packet rather than circuit switches. As described in Section II.B below, CLECs are rapidly traffic may not justify installing a standalone” switch.); Nortel Networks, DMS-10 Carrier Class Switching System, Remote Switching Center-S, http://www.nortelnetworks.com/products/01/dms-10/rscs.html. (Nortel remote switches “[e]xtend[] a full complement of host switch features to subscribers up to 650 miles from a DMS-100 or DMS-500 host, up to 100 miles from a DMS-10 host.”). 20 Lucent Technologies, 5ESS Switch, http://www.lucent.com/products/solution/0,,CTID+2002-STID+10055- SOID+935-LOCL+1,00.html (“Lucent 5ESS Website”); Lucent Technologies, 5ESS 2000-Switch Mobile Switching Centre (MSC), http://www.lucent.com/products/solution/0,,CTID+2008-STID+10048-SOID+824-LOCL+1,00.html. 21 Telcordia, January 2002 LERG. 22 See, e.g., Lucent Technologies, Maximize Your Opportunities With the Remoting Capabilities of the 5ESS- 2000 Switch, http://192.11.229.2/livelink/163997_Brochure.pdf (CLECs may “establish a presence in a new or small market at minimal cost,” and “without making major capital investments.”); P. Korzeniowski, Pieces of Concern – The Communications Market Is One Big Puzzle, and CLECs Are Scrambling To Find the Right Fit, tele.com (May 29, 2000) (quoting Pat Price, Lucent’s director of switch product marketing: “We’ve cut the size of our switch in half and disabled some residential services, so a CLEC should be able to install a new central office switch in a month”); M. Reddig, Top 10 Advances in Switching (quoting Dan Lakey, senior market manager for CLECs, Taqua Systems: “Even the legacy switching products are consolidating common equipment into half as many cabinets and increasing port density on line and trunk modules.”); Ericsson Marketing Brochure, AXE Local 7.2, http://www.ericsson.com/multiservicenetworks (AXE Local 7.2 switch reduces “costs for installation, operation and maintenance” with “new options for remote control [that] sav[e] time and money on service personnel.”). 23 See, e.g., Lucent 5ESS Website (5ESS “allows growth in increments simply by adding modules”); Nortel Networks, DMS-10 Carrier Class Switching System, http://www.nortelnetworks.com/products/01/dms-10/index.html (DMS-10 is specifically “[d]esigned for small to medium applications”); Siemens Press Release, Siemens Debuts Denser Version of Its World-Leading Class 5 Switch to Meet Service Demands and Space Limitation (June 4, 2001) (EWSD SX switch is “finding great popularity with carriers of all sizes who need exceptional functionality on a smaller footprint.”). 24 See, e.g., Siemens A.G., EWSD Powernode, http://www.siemens.ie/fixedoperators/CarrierNetworks/ switching/ewsd.htm (“The EWSD PowerNode can handle up to 600,000 subscribers and 240,000 trunks per switch and it supports ultra large Remote Switching Units, which can handle up to 50,000 subscribers or 8,500 trunks. The EWSD PowerNode is based on your current EWSD infrastructure, which qualifies it as a tool to consolidate your network.”); Lucent Technologies, Products and Services – 5ESS® Switch, http://www.lucent.com/products/solution/ 0,,CTID+2002-STID+10055-SOID+935-LOCL+1,00.html (“A full-sized 5ESS® switch serves up to 250,000 subscriber lines and over 100,000 trunk lines.”); Nortel Networks, Products – DMS 500: DMS 500 System Advantage, http://www.nortelnetworks.com/products /01/dms500/collateral/74038.16-09-97.pdf (the Nortel DMS-500 can support up to 122,278 lines and 45,288 trunks).
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deploying packet switches to provide data services, and also are increasingly using these switches to provide voice services. The tabulated data also exclude wireless switches, even though wireless networks now switch at least one-quarter of the amount of voice traffic as wireline networks.25
Third, the tabulated data exclude PBXs. The FCC and independent analysts have all reached the conclusion that PBX systems compete directly with circuit-switched services.26 As of year-end 1998, there were 45 million installed PBX lines in the United States.27 As of year- end 2001, the number had grown to 56 million.28 This means that on approximately 44 percent of all ILEC switched access lines serving business customers at least some of the switching was done by a switch other than an ILEC’s own circuit switch.29
2. Use of CLEC Switches To Serve Mass-Market Customers.
As of year-end 2001, CLECs were serving approximately three million residential lines using their own switches. CLECs that are serving mass-market customers using their own switches have typically done so either by expanding the services on their existing large- customer-focused networks, or by expanding the geography of their existing broad-customer- based networks into adjacent territories. This service and geographic expansion typically involves the use or extension of existing facilities, not the conversion of unbundled local switching leased from an ILEC.
Service-Based Expansion To Serve Mass-Market Customers. CLECs have generally deployed switches to serve large business customers, in the first instance. Having done so, however, it is both straightforward and cost-effective for them to use these same switches to serve mass-market customers, and facilities-based CLECs are now doing so aggressively. See Table 8. Indeed, the wire centers in which CLECs already are serving business customers also contain the vast majority of all residential lines. As noted above, for example, the wire centers in
25 See note 141, infra. 26 See, e.g., Amendment of Part 69 of the Commission’s Rules Relating to Private Networks and Private Line Users of the Local Exchange, Notice of Proposed Rulemaking, 2 FCC Rcd 7441, ¶ 44 (1987) (decision to apply the surcharge to Centrex leakage as well as PBX leakage was “based upon a recognition that Centrex and PBX switches competed directly with one another.”); KLF Electronics v. Indiana Bell Telephone, Memorandum Opinion and Order, 1 FCC Rcd 502, 503 n.3 (1986) (“Centrex service performs some of the same functions performed in a PBX, and therefore telephone exchange carriers offering Centrex compete with companies . . . that provide PBX switches.”); H. Peterzell, Centrex III – Some Other Considerations (May 8, 1998), http://www.phonehelp.com/p-1-31.htm (“I know of nothing that can be accomplished with either of these technologies [PBX and Centrex] that cannot be accomplished with the other. Functionality, interestingly enough, is not a consideration.”). 27 Multimedia Telecommunications Association, 1998 Multimedia Telecommunications Market Review and Forecast at 92 (1998). 28 Id. (installed base of nearly 44 million PBX lines as of year-end 1997); Multimedia Telecommunications Association, 2001 Multimedia Telecommunications Market Review and Forecast at 105, 108 (2001) (12 million new add-on PBX lines shipped between 1998 and 2001) (2001 add-on lines estimated using average percentage of shipments attributed to add-on lines, 1998-2000). 29 This figure was derived as follows: PBX lines in use today (55,868,000) divided by combined Business Switched Access Lines and Special Access Lines (128,015,263). FCC Statistics of Common Carriers, 2000/2001 ed. at Table 2.4.
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which CLECs have ported numbers to their own switches contain 84 percent of all BOC residential access lines, in addition to 89 percent of all BOC business lines.
Cable operators have used a comparable at-the-margin strategy for getting into mass- market voice service. Here, video and data services have provided the economic entry point that has justified the initial build out of the network. The cable telephony that has been commercially deployed to date relies on the same type of circuit-switches that ILECs and CLECs use. See Table 9. At least five cable operators – including AT&T, Cox, Comcast, Cablevision and Insight – have actually deployed commercial circuit switched cable telephony.30 Circuit-switched cable telephony has been deployed in 20 states and is now available to more than 10 million U.S. homes – approximately 10 percent of the mass market.31 More than 1.5 million homes subscribe.32 Cable operators are adding over 70,000 customers a month for their residential telephony services.33 By the end of 2002, circuit-switched cable telephony is expected to be available to more than 11 percent of all homes, with an estimated 2.4 million of these homes actually subscribing.34
In some states, cable telephony is already far more widely available than nationwide averages suggest. For example, the Commission has recognized that Cox already has the “capability to provide cable telephony service to 75 to 95 percent of Rhode Island customers.”35 AT&T offers cable telephony services to large fractions of the nearly three million homes its cable network passes in the Boston Area,36 the approximately 600,000 homes it passes in the Pittsburgh area,37 the 3.5 million homes it passes in the Chicago area,38 and the 2.7 million
30 See M. Stump and K. Brown, Comcast Plunges Into Telephony, Multichannel News at 5 (Dec. 24, 2001); Cabling Home, Nashville Bus. J. at 17 (Feb. 1, 2002); Eighth Video Competition Report; T. Kerver, Operator of the Year, Cablevision (Oct. 22, 2001). There currently are two major cable operators – AT&T and Cox – and a third smaller one, Insight, that are actively deploying circuit-switched cable telephony to new areas. See Yahoo! Business, AT&T and Comcast Remain On Watch Neg (Dec. 20, 2001), http://biz.yahoo.com/bw/011220/202353_1.html; K. Darce, Local Phone Arena Gets New Players, Times-Picayune at 1 (Feb. 8, 2002); Insight Communications, Services, http://www.insight-com.com/services/. 31 See JP Morgan Cable Industry Report at Table 22; NCTA Cable Telephony Report at 2. 32 See NCTA, US Cable Telephony Subscribers (in Thousands 1998-2001), http://www.ncta.com/ industry_overview/indStats.cfm?statID=13. 33 See NCTA Cable Telephony Report at 1. 34 See JP Morgan Cable Industry Report at Table 22. 35 See, e.g., Rhode Island Order ¶ 105. 36 See Dan Somers, President and CEO, AT&T Broadband, Operational Overview, AT&T Broadband, Investor Presentation, July 2001, at 16 (stating that AT&T’s network in Boston has “2.9 million homes passed,” that “plant upgrades [are] nearly complete, [to be] able to offer complete bundle,” and that there is already “11% telephony penetration” and “>100k customers.”). 37 As of mid-2000, AT&T offered cable telephony to at least 165,000 of its approximately 400,000 subscribers in the Pittsburgh Area. See Company Offers Free Phone Service in Bid for Customers, Associated Press State & Local Wire (Aug. 31, 2000); NCTA, Top 25 Cable Systems, http://www.ncta.com/industry_overview/ aboutIND.cfm?indOverviewID=56. AT&T’s network passes roughly 600,000 homes, assuming a nationwide cable penetration rate of approximately 66 percent. 38 See Dan Somers, President and CEO, AT&T Broadband, Operational Overview, AT&T Broadband, Investor Presentation, July 2001, at 17 (stating that AT&T’s network in Chicago has “3.5 million homes passed,” a II-11
homes it passes in the Bay Area.39 And, as discussed below, most major cable operators have stated that they soon plan to deploy cable telephony even more broadly by relying on packet- switched, IP-based technology.
Table 8. CLECs Providing Facilities-Based Residential Service CLEC State ALLTEL AR, FL, NC, NE, OH, “ALLTEL began offering local telephone service to area [Raleigh] PA residents this week, two months after launching local telephone service to [Raleigh] area businesses.” AT&T CA, CT, FL, GA, IN, “AT&T Broadband now markets cable telephony to approximately seven KY, MD, MA, MN, NH, million households in 16 markets, has over one million customers (or PA, UT, VA, WA 14.8% of its marketable homes with penetration rates reaching 30% in some communities), and continues to expand the availability of competitive local telephony services to homes throughout the former TCI and MediaOne footprints.” BayRing NH “BayRing owns and operates two CLASS 5 Digital Switches that are housed at the Pease International Tradeport in Portsmouth, NH”; “offers residential and business customers competitively priced local, long distance, Internet and dedicated access services.” Broadview Networks MA, NJ, NY, PA “Broadview Networks…is a network-based electronically integrated communications provider (e-ICP) serving small and medium-sized businesses and communications-intensive residential customers in the northeastern and mid-Atlantic United States.” Cablevision CT, NJ, NY “[Cablevision] provides residential telephone and cable modem internet access service in portions of the greater New York City metropolitan area and parts of southern Connecticut.” “At December 31, 2000, the Company served approximately 239,000 modem subscribers and approximately 12,000 residential telephone subscribers.” Cavalier Telephone DE, MD, PA, VA “Cavalier targets business and residential customers, the latter composing 60 percent of its customer base. It generally markets residential services to employees of the various businesses it serves.” CenturyTel LA “The Company is currently offering CLEC services to residential and small and medium sized business customers in Shreveport and Monroe, LA. CenturyTel will employ an ‘edge-out’ strategy for its CLEC expansion.” Comcast MI “It now seems that Comcast has 15,000 circuit-switched telephony customers across a base of 150,000 homes passed in 12 Michigan towns, including Ann Arbor, Birmingham and Dearborn.” CoreComm IL, MI, OH, PA, WI “CoreComm is a national, partially facilities-based CLEC serving both the residential and the business markets, primarily in the Midwest and the Northeast.” Cox AZ, CA, CT, LA, NE, “[B]y March 31, 2001 Cox Communications was serving 300,000 OK, RI residential customers using 410,000 residential access lines, making Cox the equivalent of the 12th largest telephone company in the country.” CTC Exchange NC “The CLEC is deploying two strategies…The second as a Greenfield that the Company calls SLEC…building infrastructure in new residential and business developments.”
“strong telephony roll-out” with “backbone and headend segments of rebuilds nearly complete,” “18% telephony penetration” and “some suburbs have 40% penetration.”). 39 See id. at 18 (stating that AT&T’s network in the Bay Area has “2.7 million homes passed,” “backbone and headend segments of rebuilds nearly complete,” “19% telephony penetration” and “many communities in high 20s”).
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Table 8. CLECs Providing Facilities-Based Residential Service CLEC State CTSI NY, PA “CTSI will continue to focus on its three original ‘edge-out’ markets (Wilkes-Barre/Scranton/Hazleton, Harrisburg and Lancaster/Reading/York, PA). CTSI has its own host switches in Harrisburg and in Wilkes-Barre, PA. CTSI serves the Lancaster/Reading/York market with remote switches connected by fiber to CTSI’s Harrisburg host switch.” Grande TX “Grande Communications is building a ground-up deep fiber broadband Communications network to homes and businesses. Grande will deliver high-speed Internet Network, Inc. access, local and long distance telephone and cable television entertainment services over its own advanced broadband network to communities in Texas.” Insight KY “Insight Communications Co. is moving forward on a cooperative voice deal it signed last year with AT&T Broadband. Insight has rolled out primary-line cable telephony in Louisville, Ky., a system that serves 25,000 marketable homes.” Knology AL, FL, GA, SC, TN “Knology Broadband offers residential and business broadband services, including analog and digital cable television, local, and long distance telephone, high-speed Internet access service, and other services including broadband carrier services (BCS) using two-way high capacity hybrid fiber/coaxial Interactive Broadband Networks.” LecStar AL, FL, GA, KY, MS, “LecStar Corporation is a facilities-based integrated communications NC, SC, TN carrier (ICC).” “LecStar offers a full array of fixed wire-line voice, data, Internet and operator services to business and residential customers throughout BellSouth’s Southeastern operating territory.” NTELOS KY, VA, WV “NTELOS Inc…is a regional telecommunications provider offering a wide range of services to business and residential customers in Kentucky, Virginia and West Virginia.” “NTELOS is pursuing an edge-out build strategy. NTELOS enters markets that are physically proximate to its existing ILEC operations and uses its brand and existing infrastructure to expand into them.” NTS Communications, NM, TX “The Company currently offers facilities-based local telephone service in Inc. the cities of Amarillo, Lubbock, Abilene, Wichita Falls, Midland/Odesa, San Angelo, and San Angelo TX, and also in Albuquerque, NM.” “With NTS’s facilities-based local dial tone product, you use NTS’s network facilities – not those of the traditional telephone company.” RCN CA, DC, MA, NY, PA “Our multi-service network is presently operating in Boston, Manhattan, Lehigh Valley, Washington, D.C., San Francisco, Queens, Chicago, and Philadelphia. . . . The Company’s telephone switching network utilizes either the Lucent 5ESS-2000 or the Nortel DMS-100 switching platforms as the local switching element, and the network is designed to provide highly reliable lifeline telephony service. In each of the markets which are operational, a telephone switch is installed and fully operational.” Rio OR “Rio Communications has invested $1 million to set up its own switch in Eugene, said Ed Marcotte, president and part-owner of Rio. The 5-year- old, Eugene-based firm operates roughly 1,000 phone lines, serving about 30 customers. It is adding about 500 business lines a month and hopes to launch residential service by the fall, Marcotte said.” Sources: See Appendix M.
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Table 9. Commercial Circuit-Switched Cable Telephony Deployment Homes Passed for Cable Telephony Future Plans Cable Telephony Subscribers AT&T approximately 1 million (EOY2001) AT&T expects to expand service to 7 million approximately 5-6 million homes per year Cox Orange County; San 400,000 (EOY2001) “Since December [2001], Cox has launched Diego; Omaha; residential phone service over its cable television Oklahoma City; network in St. Charles and St. Bernard parishes. Phoenix; Tucson; Phone service will be extended to Jefferson Parish RI; CT; Tidewater by mid-summer [2002] and to Orleans by the end area, VA of the year, Cox spokesman Steve Sawyer said.” Comcast 150,000 40,000 (EOY2001) Using AT&T switches, plans soon to deploy circuit-switched telephony to 1 million Comcast homes Cablevision Long Island, NY 12,500 (June 2001) Plans to deploy IP Telephony more broadly Insight Louisville, KY 2,000 (Oct. 2001) The first telephony customers have been connected in parts of the Louisville, KY and Evansville, IN systems, with launches to follow in Lexington, KY and Columbus, OH later this year. Sources: See Appendix M.
Geographic Expansion to Mass-Market Customers. As discussed in more detail in Section IV.B.3, a number of incumbent local exchange carriers have been pursuing edge-out strategies, pushing into the territories of adjacent ILECs.40 For example, CTSI – the CLEC subsidiary of Commonwealth Telephone (the second largest ILEC in Pennsylvania) – operates a competitive voice network in Verizon’s service territory in Wilkes-Barre, Harrisburg, and Lancaster that serves business and residential customers.41 ALLTEL has deployed competitive facilities – including switches – adjacent to its ILEC service territories in Little Rock, Charlotte, Cleveland, Jacksonville, and Tallahassee.42
Some existing cable telephony providers also are engaging in geographic expansion, and many other cable operators could no doubt do so. For example, AT&T’s merger partner,
40 See, e.g., NPRG CIOC Report 2001, Ch. 2 at 1 (“[Competitive Independent Operating Companies (‘CIOCs’)] target RBOC markets that are geographically proximate to their existing ILEC holdings. This ‘edge-out’ strategy allows the CIOC to take advantage of the synergy of its ILEC and CLEC operations while entering typically underserved non-urban markets. CIOCs are able to employ infrastructure, brand, and local experience to gain market penetration and achieve profitability.”); id. Ch. 2 at 2 (“All CIOCs target business customers and depending on individual market characteristics, also target residential customers through the use shared lines or through infrastructure overbuilds.”). 41 See Commonwealth Telephone Enterprises, Inc., Form 10-K (SEC filed Mar. 27, 2001); NPRG CLEC Report 2001, 14th ed., Ch. 13 – CTSI, Inc. at 7; CTE Press Release, CTE Announces Restructuring of CTSI Subsidiary (Dec. 6, 2000). 42 See ALLTEL, Coverage Maps: National Map, http://www.alltel.com/news_information/maps/download/ bigjpgs/US.jpg; NPRG CIOC Report 2001, Ch. 7 at 8-9. In March 2002, ALLTEL announced that it will discontinue its CLEC operations in seven of ten states (representing less than 20 percent of ALLTEL’s CLEC access lines); however, the company has not identified which states will be affected by this change. See ALLTEL Corp., Form 10- K405 (SEC filed Mar. 5, 2002).
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Comcast, states that it can easily and cheaply use AT&T’s existing switches to provide residential telephony service to Comcast’s existing cable subscribers.43 Comcast’s Treasurer, John Alchin, states that “‘when you look at what AT&T has already done in terms of infrastructure and the huge investment they’ve made . . . we can more easily piggyback off that in an economically efficient way.’ Between 70% and 80% of Comcast’s existing systems are within ‘striking distance’ of existing AT&T Broadband switching services . . . ‘making the incremental roll-out of telephony in Comcast legacy systems compelling.’”44 Comcast plans to roll out circuit-switched phone service to as many as one million Comcast households upon closing its proposed merger with AT&T.45
Collocation and Hot-Cut Issues. As discussed in Section IV.A, CLECs that serve large business customers with their own switches typically do so directly through fiber connections they have deployed. Mass-market customers do not always generate enough traffic to justify a fiber link, so many CLECs that seek to serve such customers with their own switch will do so through an unbundled loop obtained from an ILEC. In order to do so, the CLEC will first obtain collocation in the ILEC’s central office. Where the customer that the CLEC seeks to serve already is receiving dial-tone service from the ILEC, the CLEC will typically request that a hot cut be performed on the loop serving that customer. A hot cut involves moving the end-user customer’s loop from the ILEC’s switch to the CLEC’s switch.
At the time of the UNE Remand Order the Commission declined to curtail availability of the switching UNE primarily because of the time and cost associated with obtaining collocation space and local loops through the hot-cut process.46 Concerns about collocation and hot-cut performance have been fully addressed since the time of the last UNE review, however.
43 See, e.g., Cable Companies Tell Analysts They’re Confident About Prospects, Warren’s Cable Regulation Monitor (Jan. 14, 2002) (“With switches already in place in 8 of 10 biggest U.S. markets, only $5-$50 million is needed to be invested to complete phone service for residences.”); M. Farrell, AT&T Wants to Tweak Digital Packages Again, Multichannel News (Jan. 14, 2002) (“[Comcast President Brian] Roberts had been lukewarm on cable telephony in the past – before the merger agreement, Comcast had said repeatedly that it would wait for lower-cost Internet- protocol telephony to become a reality – but he’s now one of its biggest proponents. . . . Roberts said telephony can be rolled out in Philadelphia and Detroit for between $5 and $50 per customer, because AT&T has already invested in the switching infrastructure in those markets. That $5 to $50 cost would mainly power the phone service at each customer home.”); J. Borland, Comcast, AT&T Cable Deal To Create Net Giant, CNET News.com (Dec. 20, 2001) (“Steve Burke, president of Comcast Cable, said in Thursday’s conference call that introducing phone services to Comcast customers could generate $600 million to $800 million annually within the next five years. ‘If we overlay their expertise, their investment, their people and learning, and roll out telephony to our footprint, it could represent a very significant opportunity,’ he said.”). 44 M. Scanlon, AT&T Broadband Deal Lets Comcast Accelerate Telephony, Cable World (Jan. 7, 2002). 45 See Applications and Public Interest Statement of AT&T Corp. and Comcast Corporation at 38, Application for Consent to the Transfer of Control of Licenses, Comcast Corporation and AT&T Corp., Transferors, to AT&T Comcast Corporation, Transferee, MB Docket No. 02-70 (FCC filed Feb. 28, 2002) (“Comcast President (and AT&T Comcast CEO) Brian L. Roberts has announced that the merged company intends to begin to deploy telephone service in the Philadelphia and Detroit markets currently served by Comcast, after closing, bringing facilities-based local telephone choice to about one million additional homes.”). 46 See UNE Remand Order ¶¶ 269-271.
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The Commission has expanded the range of collocation options and imposed standard time limits.47 And collocation in BOC regions has risen very sharply. At the end of 1998, for example, CLECs had obtained roughly 4,000 collocation arrangements in BOC regions; by year- end 2001 there were approximately 25,000 CLEC collocation arrangements in place. CLECs are now collocated in central offices that serve approximately 81 percent of BOC access lines – including approximately 79 percent of BOC residential lines. See Table 10.
Table 10. Collocation by Region Verizon SBC BellSouth Qwest Total Collocation Arrangements 1,100 2,000 870 240 4,300 YE 1998 (excl. GTE) Collocation Arrangements 7,000 9,900 4,700 3,300 24,900 YE 2001 % of Residential Lines in 74 83 77 84 79 WCs served by collocation % of Business Lines in 84 87 87 90 86 WCs served by collocation % of Total Lines in 78 85 80 86 81 WCs served by collocation Totals may not equal sum of parts due to rounding.
The availability in the market of alternatives to traditional collocation also has been greatly expanded in recent years due to the rapid rise of alternative collocation providers (so- called collocation “hotels”), which give competitive local carriers places to deploy their switches and interconnect their networks. These companies provide “high-security facilities operated by independent companies that put telecom gear as close as possible to incumbent central offices without actually being there.”48 They permit CLECs to “easily connect with, and hand off traffic to, the IXCs and each other.”49 They allow “[m]ost new business telecom providers . . . to bypass the traditional infrastructure.”50 Today, there are alternative collocation providers in virtually all major metropolitan areas throughout the country. See Appendix G.
With respect to hot cuts, any concerns about hot-cut performance have been reduced as both sides have gained further experience and worked out the rough spots in their respective processes. Indeed, since the UNE Remand Order, the FCC has repeatedly found that BOC
47 See, e.g., Deployment of Wireline Services Offering Advanced Telecommunications Capability, Order on Reconsideration and Second Further Notice of Proposed Rulemaking, 15 FCC Rcd 17806 (2000); Deployment of Wireline Services Offering Advanced Telecommunications Capability, Fourth Report and Order, 16 FCC Rcd 15435 (2001). 48 D. Culver, Construction Boom for Colocation. 49 A. Lindstrom, Checking Out Carrier Hotels, America’s Network (Nov. 1, 1997). 50 V. McCarthy, Local Carriers Take Over Office Buildings, Interactive Week (May 22, 2000), http://www.zdnet.com/intweek/stories/news/0,4164,2574580,00.html (quoting Sean Dohety, president, Urban Media).
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performance in providing hot-cuts to CLECs is satisfactory.51 And, as demonstrated in Appendix H, the Bell companies’ hot-cuts performance is now excellent.
Migration of Mass-Market UNE-P Customers to CLEC Switches. Collectively, CLECs use their own switches to serve most of their customers. See Figure 3. Some CLECs, however, continue to rely primarily on the UNE Platform, which of course includes the switching element, to serve mass-market customers.52 These CLECs maintain that they remain dependent on ILEC switches to serve mass-market customers because they “cannot rationally invest in switches . . . until they have used UNE-P to build up a customer base.”53 But that assertion cannot be squared with the economics of switch deployment, and with the actual marketplace track record that other CLECs have established.
Figure 3. Breakdown of CLEC Lines by Mode of Entry Using ILEC Switches (UNE Platforms and Resale) CLEC Lines Provided: Using CLEC Switches* (based on E911 listings)
100%
80%
60%
40% CLEC Lines CLEC 20%
0% Verizon** SBC BellSouth Qwest Total
*The number of lines provided entirely over CLEC facilities and using CLEC switches is based on the number of E911 listings CLECs have obtained. Because the actual number of lines that CLECs are serving with their own switches is likely much higher, this method will, if anything, understate the percentage of all lines that CLECs are serving in whole or in part over facilities they have deployed themselves. **Verizon data do not include the former GTE territory.
It certainly is clear that some CLECs are not migrating mass-market UNE-Platform customers to their own facilities, and have no plans ever to do so. In New York, for example, AT&T and WorldCom together provide UNE-P service to well over one million residential customers54 – enough customers, in other words, to fill five to ten switches. Together, AT&T
51 See, e.g., New York Order ¶ 291; Massachusetts Order ¶ 159; Connecticut Order ¶ 13; Pennsylvania Order ¶ 86; Texas Order ¶ 256; Kansas/Oklahoma Order ¶ 199; Arkansas/Missouri Order ¶ 102. 52 In the Bell companies’ regions, approximately two-thirds of all platforms are used to serve residential customers, and the percentage is even higher in Verizon’s and SBC’s regions (80 percent and 70 percent, respectively). Most of the platforms used in the business sector appear to be used to serve small business customers, which the FCC previously has held are part of the same “mass market.” See, e.g., Bell Atlantic/NYNEX Merger Order ¶ 70. For example, nearly 25 percent of all platforms used to serve business customers are sold in BellSouth’s region, and half of those are sold to business customers with only 1-3 lines. 53 Ex Parte Letter from Robert W. Quinn, AT&T, to William F. Caton, FCC, CC Docket No. 01-347 (Mar. 1, 2002). 54 S. Alexander, Judge Recommends Qwest Be Fined for Impeding Local Service by AT&T; But AT&T Says It Won’t Enter Market, Star Trib. (Feb. 26, 2002) (AT&T vice president Tom Pelto said that AT&T uses the UNE- Platform to provide local residential phone service to about 1 million people in New York.); M. McDonald, Local II-17
and WorldCom also operate 28 local circuit switches in New York state.55 Yet these two carriers do not appear to have converted any residential customers in New York to their own switches.56 The experience has been no different in other states where AT&T and WorldCom have signed up large numbers of UNE-P customers. Other CLECs that have obtained UNE Platforms to serve mass-market customers also have conceded that they have no plans to convert these customers to their own switches, even after they have acquired a large customer base. They view UNE-P competition as an end in itself, rather than as a stepping stone to facilities-based competition.
Their position is based on business judgment, however, not on any economic imperatives. The UNE-P-forever CLECs have simply decided that there is more to be gained from relying on UNEs at TELRIC prices than from deploying their own facilities.
To begin with, many other CLECs are deploying switches to serve mass-market customers. Indeed, most of the CLECs that have deployed one or more switches, and that also serve mass-market customers, make little if any use of unbundled BOC switching. Leaving aside service provided over cable networks, at least nine CLECs in Bell company regions provide facilities-based service to 25,000 or more residential lines (based on their E911 listings). See Figure 4. Seven of the nine buy no UNE-P service at all. The remaining two represent only 3 percent of all facilities-based residential lines. But for one of these two CLECs, UNE Platforms represent only five percent of the residential lines that this carrier serves.
The same circuit switch in the same wire center can and routinely does serve both business and residential customers – ILECs use their switches in precisely that way, and many CLECs do too. For example, many of the cable operators that are now providing circuit- switched cable telephony are doing so using switches deployed originally by their CLEC affiliates to serve business customers.57 With switching, perhaps more so than with any other
Phone Fight Gets Put on Hold, Crain’s N.Y. Bus. at 1 (Mar. 5, 2001) (WorldCom accumulated 400,000 customers in New York). 55 See Appendix B. 56 See Declaration of Vijetha Huffman ¶ 5, attached to Comments of WorldCom, Inc., Application of Verizon New Jersey, Inc., Bell Atlantic Communications, Inc. (d/b/a Verizon Long Distance), NYNEX Long Distance Company (d/b/a Verizon Enterprise Solutions), Verizon Global Networks Inc. and Verizon Select Services Inc. for Authorization To Provide In-Region, InterLATA Services in New Jersey, CC Docket No. 01-347 (FCC filed Jan. 14, 2002) (“UNE-P . . . is the only service-entry vehicle that WorldCom uses to offer local residential service, and it is the only service- delivery option that WorldCom currently views as even potentially viable.”); Supplemental Declaration of Michael Lieberman on Behalf of AT&T Corp. ¶ 20, attached to Ex Parte Letter of Peter Keisler, Sidley Austin Brown & Wood (representing AT&T), to William F. Caton, FCC, CC Docket No. 01-324 (Feb. 8, 2002) (AT&T has recently stated that it has not pursued a strategy of converting platform customers to its own facilities “to provide basic local residential service to customers anywhere in the country.”). 57 See, e.g., K. Zia, Deutsche Banc Alex. Brown, Investext Rpt. No. 8089704, Cablevision Systems Corp. – Company Report at *5 (Apr. 16, 2001) (“On the cable telephony front, Cablevision has introduced a switched-circuit residential solution in its Long Island, NY and Connecticut markets, which leverages the infrastructure and switches of its CLEC subsidiary, Lightpath.”); K. Zia, Deutsche Banc Alex. Brown, Investext Rpt. No. 8089709, Adelphia Communications – Company Report at *6 (Apr. 16, 2001) (“Adelphia plans to roll out residential telephony using packet-switched (IP) technology in 2002, with the substantial advantage over most others in the industry of being able to tap its relationship with its CLEC subsidiary Adelphia Business Solutions. Leveraging ABS’s already laid fiber, switches, co-location agreements with ILECs and back-office infrastructure, should provide Adelphia with significant time-to-market and cost structure advantages.”).
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network element, residential service can readily be added at the margin. And the vast majority of residential customers are now in reach of CLEC switches already in operation. CLEC switches are up and running in wire centers that serve 86 percent of all BOC access lines. And these same wire centers serve about 84 percent of BOC residential lines.
Figure 4. Use of UNE Platforms by CLECs Providing Service to 25,000 or More Residential Lines Using Their Own Switches*
250,000 Residential UNE Platforms Residential Facilities-Based Lines (based on E911 Listings) 200,000
150,000
100,000
50,000
0 *Excludes CLECs providing service over cable facilities. Does not include CLECs in Qwest’s region.
CLECs providing service to 25,000 or more facilities-based residential lines include: ALLTEL, Broadview, Cavalier Telephone, Intermedia, Knology, McLeodUSA, RCN, TDS, and TOTALink.
The only other justification that CLECs have given for their failure to convert mass- market customers from Platforms to their own switches relates to the cost of migrating the customer, not the cost of deploying or operating the switch itself. This does not establish that the UNE Platform is necessary for competition; to the contrary, it establishes that facilities-based competition will develop faster if CLECs do not build their customer base on UNE-P service at all.
As described above, the costs associated with collocation have fallen sharply since the UNE Remand Order, as the Commission has created numerous alternatives to traditional physical arrangements. The rates for hot cuts are set using TELRIC principles, and the BOCs’ hot-cut performance is closely monitored by state commissions. As a result, the transactional costs that CLECs seeking to use their own switch must incur are no different than the costs that any other network provider – including ILECs and cable companies – would need to incur to connect loops to its own switches.
But even assuming that hot-cut costs remain significant, substantial numbers of customers that seek phone service are entirely “new” customers in that they are first-time subscribers at the location at which they are requesting service. Wireline telephone companies add approximately six million subscriber lines each year.58 And, because people move, a significant fraction of existing customers terminate their current phone service and initiate new service at some other location every year.59 Together, these two groups define a large base of
58 See FCC Trends in Telephone Service, Aug. 2001 ed. at Table 8.1. 59 See, e.g., U.S. Census Bureau, Statistical Abstract of the United States: 2001 at 28 (Nov. 2001) (from 1999-2000, 15 percent of the U.S. population, or approximately 40 million people, changed residences).
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customers who can be served without incurring the transaction costs associated with moving an established customer off of an ILEC switch and on to a CLEC alternative.
B. Packet Switches as Substitutes for Circuit Switches.
CLEC packet switches are already a very significant competitive alternative to ILEC circuit switches.
Packet switches substitute for circuit switches to the extent that traffic can be routed directly to a packet switch, without first being routed through a circuit switch. All forms of telecommunications traffic can now be transmitted and switched, end-to-end, in digital rather than analog format. And because packet switches are far more efficient in handling digital traffic than circuit switches, the economics of migrating traffic from circuit to packet switches have become incredibly compelling. Indeed, there already is far more data traffic than voice traffic, even on the circuit-switched public telephone network.
Of course, the CLEC packet switches in many cases also either are or are capable of being used to provide voice services. Long-distance carriers have been migrating their traffic to high-speed packet switches for several years. Having gained a robust, profitable entry point in high-speed data, local providers are now offering messaging and voice services over those networks too. The number of customers with local data links to packet switches is already large and growing very rapidly. And a large and growing share of these data links connect to packet switches that competing carriers – including CLECs, wireless carriers, and cable providers – own and operate.
Direct Customer Links to Packet Switches. At the time of the last UNE review, 98 percent of online households still relied on dial-up connections – and thus on ILEC circuit switches – for their data services.60 As discussed further in Section IV.C, however, nearly eight million residential users – or roughly 9 percent of online households – now have broadband cable or wireless data links instead, which bypass ILEC networks completely, and terminate directly on a competitive packet switch.61 If all eight million of these broadband users would otherwise be using dial-up connections, the packet switches used to provide these broadband services now displace at least 4 percent of all circuit-switched minutes of use, even assuming that the average data line is used only as much as the average voice line.62 The total would be far higher if one takes into account the fact that data calls generally last much longer than voice calls, and that data lines are therefore used much more, on average, than voice lines.63
60 JP Morgan Cable Industry Report at Table 13. See also D. Lathen, Cable Services Bureau, FCC, Broadband Today: A Staff Report to William E. Kennard, Chairman, Federal Communications Commission, On Industry Monitoring Sessions Convened by Cable Services Bureau at App. A (Oct. 1999). 61 See Gartner U.S. Consumer Telecommunications and Online Market Report at Table 7-1; Morgan Stanley Cable Modem/xDSL Report at Exh. 3 (cable modem). 62 This was derived as follows: (8 million cable/wireless broadband lines)/(174 million ILEC access lines + 8 million cable/wireless broadband lines). See FCC Local Competition Report, Feb. 2002 ed. at Table 1 (as of June 2001, the ILECs served 174 million access lines, which has been declining in each of the last three years). 63 See, e.g., T. Taesler, Home Internet Solution – Always-On Internet Access, Ericsson Review, Special Issue (1998), http://www.ericsson.com/about/publications/review/1998_01b/article42.shtml (“In general, Internet call II-20
The competitive impact is certainly at least double that, when one adds in the effect of data traffic from business customers, and takes into account the fact that high-speed data links carry far more traffic per user than low-speed voice links.64 Indeed, a recent study found that, for the first time, total hours spent on the Internet using high-speed connections have eclipsed the number of hours spent using dial-up connections.65 And broadband access usage is growing at more than 60 percent a year, while dial-up access usage is steadily declining.66
Cable and DSL providers (ILECs among them) are now adding new broadband data connections at a rate of some five million new connections a year.67 Cable supplies about two out of three of these connections.68 But even if they are using DSL services over ILEC loops, these customers no longer rely on the ILEC switch to route their data traffic: a splitter in the central office diverts data traffic directly to a packet-switched network before it ever reaches an ILEC circuit switch.69
Many business customers likewise rely on high-capacity connections of some kind – such as T-1 lines, or higher capacity loops – to provide direct connections between their LANs and their data carriers. As discussed in Sections III.B and IV.A, CLECs have deployed extensive fiber networks to connect business customers directly to packet-switched networks.70 In addition, there are a large number of carrier-agnostic wholesale fiber suppliers that operate fiber networks in most major metropolitan areas.71 And the economic viability of deploying fiber is increasing as the demand for greater bandwidth continues to grow at rapid rates.72
sessions last about 10 times longer than voice phone calls: 30 to 40 minutes on average, compared to the 3- to 4- minute duration of a voice call.”); Lucent Press Release, Lucent Technologies Media Gateway Enhancements Complement Lucent Softswitch, Providing Path to IP-Based Networks (Jan. 16, 2001) (“Most people access the Internet by using dial-up modems connected through the public switched telephone network (PSTN). Those calls tend to last much longer than voice calls, which use up more channels and create congestion on the Internet.”); S. Deng, Engineering and Economic Benefits of Off-loading Dial-Up Traffic from the PSTN, Nortel Networks White Paper (July 1999), http://www.nortelnetworks.com/products/library/collateral/80009.25-07-99.pdf (“The emergence of dial-up traffic is changing the PSTN traffic pattern considerably, causing network congestion. An average dial-up call lasts 20 minutes (or 12 CCS versus three CCS for a voice call), and 40 percent of the calls last an hour or longer.”). 64 See, e.g., Broadband 2001 at Charts 16 and 17 (as broadband users, survey participants spent on average 21.4 hours per month online, as compared to 15.9 hours with a narrowband connection. These same users also spent more time per session (32 minutes vs. 21 minutes), spent more days online (18 vs. 17) and viewed more pages per month (1,828 vs. 1,561)); Jupiter Media Metrix Press Release, Over 40 Percent of US Online Households to Connect Via Broadband by 2006, Reports Jupiter Media Metrix (Oct. 17, 2001) (“Broadband consumers continue to use their connections more intensively than narrowband consumers do”). 65 See Broadband Access Usage Outpaces Dial-Up Access, Reuters (Mar. 5, 2002). 66 See id. 67 See TeleChoice DSL Deployment Summary (residential DSL); Morgan Stanley Cable Modem/xDSL Report at Exh. 3 (cable modem). 68 See TeleChoice DSL Deployment Summary; Morgan Stanley Cable Modem/xDSL Report at Exh. 3. 69 See G. Garceau, Network Access Economies, Telcordia Technologies White Paper (Apr. 12, 1999). 70 See also Appendix K. 71 See Section III.C. 72 See id.
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Wireless services provide additional links to packet-switched networks. Paging spectrum is now being used extensively for e-mail and instant messaging, and new devices to support such services are emerging rapidly.73 Cell phones, paging services (like the BlackBerry service), and personal digital assistants (PDAs) now provide wireless e-mail that is superior to dial-up wireline in that it is both mobile and “always on.”74 The Commission’s Sixth CMRS Report concluded that about 2.5 million customers, or about 2.3 percent of all mobile telephone subscribers, were using wireless web services at the end of 2000.75 A more recent analyst report found 6.7 million users of wireless data services.76 Wireless data has grown from a virtually non-existent market in 1998 to $250 million in 2001, and is expected to grow to $2 billion by 2003.77
An increasing number of business customers also are making direct connections to packet switches using a new generation of IP-Based PBXs.78 Although IP-PBX devices invariably provide connections (through a trunk) to the circuit-switched network, one of their key advantages is to send a great deal of voice traffic over private data networks such as a corporation’s local area network or wide area network. Because traffic remains on a private network, rather than going on to the public Internet, the corporation can configure the network to optimize quality to ensure high-level voice communications.79 IP-PBXs cost less to purchase and operate than traditional PBXs,80 and are more flexible in terms of adding new services.81
73 See, e.g., R. Cihra, ING Baring Furman Selz, Investext Rpt. No. 2422947, Palm Inc. – Company Report at *5 (Jan. 4, 2001) (“We see huge consumer and wireless Internet potential for handhelds, with their largest, yet still relatively untapped, opportunity in the corporate enterprise.”); R. Cihra, ABN AMRO, Investext Rpt. No. 8264582, PC System & Appliances: Things to Watch in ’02 – Industry Report at *2 (Nov. 7, 2001) (“[w]e see handhelds increasingly being deployed as mobile thin-clients for business-critical data access/entry.”); Legg Mason Wireless Industry Scorecard at 28 (“We believe continued uptake of two-way messaging and lower-speed wireless data products will increase familiarity and acceptance”). 74 See Sixth CMRS Report at 56-74. 75 Id. at 60. 76 See Legg Mason Wireless Industry Scorecard at Exh. 11. 77 See JP Morgan Telecom Services 2001 Report at Table 1. 78 See, e.g., A. Sulkin, On-Going Evolution of IP-PBX Systems, Bus. Comm. Review at 14 (May 1, 2000) (“The core architecture platform of PBX systems is undergoing an important transition from circuit-switched to packet- switched transmission and coding techniques.”); C.Wilde, IP PBX Basics, Informationweek.com News (May 14, 2001), http://www.informationweek.com/shared/printArticle?article=infoweek/837/ ippbx_side.htm&pub=iwk. (An IP- PBX “delivers PBX-like services, but over IP-based LANs or WANs rather than circuit-switched networks.”). 79 See, e.g., VoIP: Shouldn’t You Be Using It?, Distribution Management Briefing at 14 (Nov. 27, 2001) (“With a private data network . . . an organization can . . . optimize . . . [b]y labelling voice packets, prioritising them over other traffic and using queuing techniques and buffers to control the flow of packets, organizations can ensure that packets are delivered to their destination at a constant rate.”); Communications Daily at 7 (Jan. 23, 2002) (Companies that have converted their traditional PBX systems to IP local area networks report that they are “satisfied with the reliability and voice quality of these initial systems”) (quoting results of study by InfoTech, IP LAN Telephony: Probing the Shift in Market Demand); A. Joch, Enterprises Tuning in to a Brand-new Voice - Satisfied with Service Quality, Many Enterprises Are Expanding VOIP Use, eWeek at 41 (June 25, 2001) (IP-PBX vendors – including 3Com and Cisco – now incorporate data-coding protocols into their VOIP hardware to give voice packets network priority when there’s heavy network traffic). 80 See, e.g., M. Desmond, Enterprise Technology: IP Telephony Goes to Work, PC World.com (Aug. 2001) (“For growing small businesses – 200 users or more – ‘Cisco makes [an IP] gateway that’s about $25,000. But when you look at an investment into a PBX, it’s typically $150,000 to $200,000 for comparable hardware.’”) (quoting Ken Camp, Mill Associates); D. Drucker, Modest Victories for VoIP – While big enterprises ponder over deployment, II-22
According to analyst studies, “17 percent of U.S. businesses began the implementation of IP LAN telephony in the year 2000,”82 and, as of year-end 2001, “[m]ore than 40% U.S. companies with 500 employees or more have begun conversion of phone systems to IP telephony.”83 Analysts predict that, within the next four years, more than 80 percent of all U.S. enterprises will adopt some form of VoIP.84 According to Frost & Sullivan, the North American IP-PBX market generated $375 million in 2000, and is expected to reach $4.8 billion by 2007.85
Packet Switching is Fully Competitive. The Commission has already concluded that CLECs stand on equal footing with ILECs in their ability to deploy and operate packet switches.86 Since the last UNE review, the installed base of CLECs’ packet switches has jumped from 860 to at least 1,700.87 More than 55 CLECs have deployed packet switches.88 See Appendix E. CLECs have deployed packet switches in more than 200 different cities. See id. In the top 100 MSAs, the average number of packet switches per MSA has grown by an average of nearly 150 percent since the last UNE review. See Table 11.
smaller users find savings, InternetWeek at 24 (Sept. 17, 2001) (“The IP PBX cost about one-quarter of what a traditional PBX deployment would have cost.”); S. Sleeper, Networking Giant Finds Its Voice, Investor’s Bus. Daily (May 29, 2001) (“Because they are Web-based, [IP-PBXs] are easier to customize, cheaper to maintain than older networks and simpler to operate”); ZDNet Tech Update: Advantages of Network PBX (maintenance costs of IP-PBX can be cut by as much as 5 to 70 percent compared to conventional PBX equipment). 81 A traditional PBX system is proprietary, and “customers usually have to ask their vendor to add new applications and pay for the service.” C. Wilde, IP PBX Basics, Informationweek.com (May 14, 2001). In contrast, with an IP-PBX, “a few clicks from a management console or a Web Browser gets the job done.” ZDNet Tech Update: Advantages of Network PBX. See also Sphere, IP PBX, http://www.spherecom.com/solutions/ippbx.htm (“Setting up new users and tasks like moves/adds/changes get done with a point-and-click instead of physically moving wires and phones.”). 82 J. Thompson, VoIP: The Quiet Revolution, Boardwatch Magazine (June 2001). 83 Communications Daily at 7 (Jan. 23, 2002) (quoting results of study by InfoTech, IP LAN Telephony: Probing the Shift in Market Demand); see also S. Sleeper, Networking Giant Finds Its Voice, Investor’s Bus. Daily (May 29, 2001) (“Sage Research Inc. of Natick, Mass., found that 52% of firms surveyed plan to install at least a partial IP system by September vs. 16% in September 2000.”). 84 See, e.g., J. Thompson, VoIP: The Quiet Revolution, Boardwatch Magazine at 50 (June 2001); see also B. Sullivan, IP PBX: The Quiet Storm, Communications Today (Feb. 14, 2001), http://www.findarticles.com/cf_0/ m0BMD/29_7/70458948/print.jhtml (Avaya President and CEO Don Peterson: “IP is not a question anymore. IP will be the core”). 85 K. Mayer and D. Callahan, This Old Enterprise, Communications Solutions (Sept. 2001); see also id. (Frost & Sullivan “anticipates that IP-PBX desktops will account for more than half the total number of CPE stations shipped by 2006.”). 86 See, e.g., UNE Remand Order ¶ 307 (“Competitive LECs and cable companies appear to be leading the incumbent LECs in their deployment of advanced services.”); id. ¶ 308 (packet switches “are available on the open market at comparable prices to incumbents and requesting carriers alike. Incumbent LECs and their competitors are both in the early stages of packet switch deployment, and thus face relatively similar utilization rates of their packet switching capacity. . . . It therefore does not appear that incumbent LECs possess significant economies of scale in their packet switches compared to the requesting carriers.”). 87 See NPRG CLEC Report 2000, 12th ed., Ch. 6 (competing carriers had 860 packet switches as of year-end 1998); NPRG CLEC Report 2002, 15th ed., Ch. 4 at Table 18. As noted above (see note 6, supra), this figure is highly conservative. 88 NPRG CLEC Report 2002, 15th ed., Ch. 4 at Table 18.
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Table 11. Average Number of CLEC Packet Switches in Top 100 MSAs MSA Rank 1998 2001 Percent Increase 1-25 7 16 125 26-50 4 10 158 51-75 2 7 246 76-100 1 2 60 Source: New Paradigm Resources Group. See Appendix M.
The two main kinds of packet switches used today are Frame Relay and ATM switches.89 One new packet-switching technology – Gigabit Ethernet – has recently been deployed, and is growing as an alternative to Frame Relay and ATM for very high-bandwidth applications.
The largest providers of both Frame Relay and ATM services are AT&T, WorldCom, and Sprint, which control more than two-thirds of the nationwide market for these services. See Figure 5.90 While the precise numbers of Frame Relay and ATM switches these carriers operate are unavailable, it is clear that they all operate vast nationwide Frame Relay and ATM networks. See Appendix I.91 As one analyst has noted, “[t]he Big 3 IXCs own the U.S. frame relay market, have scale economies and are best positioned to influence users and move the market.”92 Numerous other CLECs also provide ATM or Frame Relay service. See Appendix I.93 And while the Bell companies compete in the provision of these packet switching services as well, they have been significantly hampered by the fact that they cannot provide interLATA packet- switching services, despite the fact that customers typically desire a single carrier to provide both intraLATA and interLATA packet switching.94
89 See IDC Packet Switching Report at 1 & Figure 2 (frame relay and ATM services account for 96.4 percent of the packet-switching market). 90 See IDC Packet Switching Report at Figures 9, 31 (AT&T, WorldCom, and Sprint together accounted for 65.8 percent of revenues for ATM, and 68.4 percent of revenues for frame relay in 2000); Stratecast ATM/Frame Relay Report at 10 (“Tier 1 service providers continue to dominate the U.S. market, controlling over 70% of the market.”); id. at 17 (“In 2000, AT&T held the largest share of ATM service revenues, with a 36% share of [the] market; WorldCom and Sprint held the second and third leading position in the market with shares of 26% and 22%, respectively. As in the frame relay market, the RBOCs collectively represent a small share of the ATM services market.”). 91 AT&T Corp., AT&T ATM Service, Brochure, http://www.ipservices.att.com/brochures/atm.pdf (AT&T’s domestic Frame Relay and ATM network has over 620 Points of Presence (POP)); IDC Packet Switching Report at 137 (700+ POPs for WCOM); WorldCom, US Products, Data Networking, Frame Relay, http://www.worldcom.com/us/ products/datanetworking/framerelay/index.phtml (402 Frame Relay POPs); Sprint Corp., Sprint Business, Dedicated Access, Service and Support, http://www.sprintbiz.com/small_business/dedicated_ip/ (320 POPs). 92 Stratecast ATM/Frame Relay Report at 12. 93 The FCC already has recognized in the past that “it is precisely in the provision of services like frame relay that competition is most intense, and we acknowledge the sensitivity of the LECs’ position as they face increasing competition, especially regarding these services that are likely to be related to nonregulated and highly competitive services.” Policy and Rules Concerning Rates for Dominant Carriers, Memorandum Opinion and Order, 8 FCC Rcd 7474, ¶ 63 (1993). 94 As noted by industry analysts and CLECs alike, Bell companies are limited in their broadband offerings due to restrictions on the provision of interLATA services. See, e.g., Stratecast ATM/Frame Relay Report at 12 (“Thus far, the RBOCs have held a very small share of the frame relay market, primarily because they have only been allowed to II-24
The newest packet-switching technology being provided in metropolitan areas is Gigabit Ethernet.95 Competitive carriers also lead in the deployment of Gigabit Ethernet switches.96 As one analyst notes, “metro Ethernet services [are] being aggressively marketed by companies such as Yipes[,] Time Warner Telecom, XO, and Telseon.”97 These services are now available in central business districts of top tier markets, but also are being deployed more widely. Revenues for Gigabit Ethernet are still small – most estimates say under $100 million – but are expected to grow to as much as $4 billion by 2005.98 A recent survey of corporate users found that, although less than one percent of enterprise networks are using Gigabit Ethernet as their primary LAN transport today, nearly one-quarter expect to deploy Gigabit Ethernet within two years.99
offer intra-LATA services.”); WorldCom, Metro Frame Relay Service, http://www.worldcom.com/us/products/ datanetworking/framerelay/metro (WorldCom’s Metro Frame Relay service “offers an aggressive price position compared to that offered by LECs. LECs can offer local (intraLATA) service, but they aren’t able to cross LATA boundaries or move into other Regional Bell Operating Company (RBOC) territories. WorldCom is in the unique position to provide both interLATA (IXC) and intraLATA frame relay service by capitalizing on our wholly owned nationwide network.”). 95 See Broadband 2001 at 124 (Gigabit Ethernet (GigE) “Internet access providers connect large enterprises, educational institutions, and small and medium enterprises in large office buildings (MTUs) to the Internet. . . . GigE players also offer LAN-LAN connectivity, also know as transparent LAN services (TLS), to medium and large enterprises. . . . GigE service providers offer wholesale MAN connectivity, providing the infrastructure for high-speed metro backbones.”); Cisco, Technology Brief: Introduction to Gigabit Ethernet, http://www.cisco.com/warp/public/cc/ techno/lnty/etty/ggetty/tech/gigbt_tc.htm (Gigabit Ethernet is typically offered at speeds of 1.25 Gbps). 96 See, e.g., Yipes Communications, Yipes Announces Nationwide Availability of Instantly Scalable Bandwidth (Sept. 11, 2001) (“Yipes Communications, Inc. [is] the defining provider of optical Gigabit Ethernet networks”); Telseon Press Release, Telseon Announces Service Promotion to Drive Metropolitan Gigabit Ethernet Service Adoption (Apr. 24, 2001) (“As one of the GigE service leaders, Telseon is showing that speed and simplicity of deployment are possible in the metro optical network.”) (quoting George Peabody, Aberdeen Group, Vice President and Practice Manager, Communications Infrastructure and Services). 97 Stratecast ATM/Frame Relay Report at 17. See also S.M. Milunovich, Merrill Lynch Capital Markets, Investext Rpt. No. 2779422, Tech Strategy; All’s Not Quiet on the GIGE Front – Industry Report at *1 (Apr. 10, 2001) (Yipes Communications “has built a 20-city, all-optical, all-GigE network in less than two years,” which “offers at least a 5-to-1 cost advantage versus IP over ATM/SONET.”); S. Clavenna, Metro Optical Ethernet, Lightreading.com (Nov. 13, 2000), http://www.lightreading.com/document.asp?doc_id=2472 (Cogent Communications “has built a network around the sole proposition of providing 100-Mbit/s Ethernet services to tenants of office buildings for $1000 per month, roughly the price of a traditional T1 (1.5 Mbit/s) line.”); D. Allen, Will Gigabit Ethernet WAN Services Make Us Forget About SONET?, Network Magazine (July 5, 2001) (Telseon has more than 120 Gigabit Ethernet POPs in 20 cities). 98 See L. Cooper & T. Moore, Corporate America Implementing New Gigabit Ethernet Strategies; Industry Trend or Event, Communications News (Aug. 1, 2001) (citing Infotech Consulting). 99 See id.
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Figure 5. Market Share of Nationwide ATM and Frame Relay Revenues ATM Frame Relay Other including 11% Other Global One 4% including 13% Broadwing 2.5% Global One 5% BellSouth Infonet 3% 1% WorldCom/ BellSouth Qwest Intermedia 4% 26% 5% Qwest AT&T 35% Verizon 5% 6% Verizon* 4% SBC 7% SBC 4%
Sprint AT&T 10% Sprint 23% 22% WorldCom/ Intermedia *Bell Atlantic share. GTE share included in “Other.” 25% Source: R. Kaplan, IDC, U.S. Packet/Cell-Based Services Market Forecast and Analysis, 2000-2005 at Figures 9 & 31 (2001).
Migration of Traffic to Packet-Switched Networks. Data traffic overtook voice traffic on the phone network in 1998. Since that time, the volume of data traffic has continued to grow much faster than voice.100 CLECs in particular earn almost half of all their revenues from data services – some $27 billion is the projection for 2002.101 Data services are the fastest growing source of CLEC revenue.102 See Figure 6 & Table 12.
However it is used, whether for pure “data” (like a spreadsheet) or for data traffic (like messaging) that may in fact compete with voice, the packet switch provides an entry point for CLECs into the provision of switching services in direct competition against ILEC circuit switches. Packet switches compete against circuit switches for all traffic that would otherwise move through a dial-up circuit-switched connection, but that now is conveyed instead to a packet switch directly. And, of course, these packet switches in many cases either are or are capable of being used to provide voice services along with the more traditional data services.
Residential and business customers alike now use e-mail and instant messaging (IM) as direct substitutes for many voice calls.103 A large and growing fraction of e-mail and IM traffic originates and/or terminates on competitive networks. And even when carried over ILEC networks, such traffic displaces significant usage-sensitive (e.g., per-minute or per-call) revenues that otherwise would be earned.
100 See, e.g., William E. Kennard, Chairman, FCC, The Telecom Act at Three: Seeing the Face of the Future, address at the Comptel 1999 Annual Meeting and Trade Exposition, Atlanta, GA (Feb. 8, 1999) (“last year, for the first time, data traffic eclipsed voice traffic on phone lines.”); J. Linnehan, Thomas Weisel Partners, LLC, Investext Rpt No. 2295458, Company Report – Level 3 Communications at *3 (Sept. 15, 2000) (“Data traffic has surpassed voice traffic at a three to two ratio.”); S. Wadhwani, Dain Rauscher Wessels, Investext Rpt No. 2150061, Avanex Corp. – Company Report at *3 (May 3, 2000) (“While voice traffic is growing at only 3%-5% annually, data traffic is estimated to be growing upward of 30%-50% annually.”). 101 See NPRG CLEC Report 2002, 15th ed., Ch. 3 at Table 10. 102 See id., Ch. 3 at Table 10; Ch. 2 at Table 8; Ch. 3 at Table 9. This category includes “all data and data- related services (e.g., frame relay, ATM, and Internet access).” Id. 103 As the chairman of AOL’s Internet division has stated, “People are not on the telephone anymore.” AOL Promises Open Instant Messenger, ITworld.com (July 23, 2001), http://www.itworld.com/App/300/ IDG010723openaol/.
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There are now 900 million e-mail accounts in the U.S. and over 60 million IM users.104 It is estimated that consumers in the U.S. are sending approximately 3.2 billion e-mail messages105 and approximately 1 billion IM messages106 per day. If only 10 percent of these 4.2 billion daily e-mail and instant messages substitute for a voice call (of 5 minutes average duration), that is equivalent to about 750 billion minutes per year, or roughly one-third of all local traffic that passes through ILEC networks.107 And while estimates vary, consumer surveys find that the actual rate of voice substitution is considerably higher. See Table 13. E-mail and IM support voice services directly, too, particularly voice messaging services. Voice capabilities are already a standard feature of Instant Messaging.108 Yahoo!, MSN and AOL all offer voice messaging services over their instant-messaging networks.109
Figure 6. CLEC Revenues 100 90 Local Switched Services 80 Data Services 70 60 Total CLEC Revenue 50 52% 40 $ Billions 30 52% 51% 21% 20 39% 20% 27% 21% 10 41% 37% 26% 25% 4% 13% 0 1996 1997 1998 1999 2000 2001 2005 (est.) Source: New Paradigm Resources Group. See Appendix M.
104 See D. Whelan, The Instant Messaging Market, American Demographics (Dec. 2001). 105 See T. Shinkle, Time for a New Look at Email Management, Computer Technology Review at 48 (June 2001). 106 See R. Gann, Fast Talking Instant Messaging Software, Internet Magazine at 140 (Jan. 1, 2001). 107 FCC Statistics of Common Carriers, 2000/2001 ed. at Table 5.8 (Total 1999 Dial Equipment Minutes of 4.414 trillion divided by 2 yields 2.207 trillion conversation minutes; 750 billion/2.207 trillion = 33%). 108 See, e.g., S. Spanbauer, Browsing & Beyond: We Pick 13 Must-Have Tools For Today’s Internet, Including The Best In Browsers And Add-Ons, E-Mail, Instant Messaging, And Much More, PC World (Feb. 1, 2002) (“Odigo is the only IM tool we looked at that doesn’t let you do PC-to-PC voice chat.”); see also C. Seper, ‘Bots’ Add Touch of Humanity, Artificial Intelligence Brings Real Business to Instant Messaging, Plain Dealer (Dec. 31, 2001). 109 See Yahoo!, Yahoo! Pager Turns Up The Volume On Instant Messaging, New Voice Chat Feature Allows Users to Talk Live Over the Internet (May 13, 1999); ICQ Press Release, ICQ, Inc.and Net2Phone Sign Four-Year, Multi-Million Dollar Internet Telephony Agreement (July 20, 1999); C. Crouch, MSN Gives Messenger a Voice, PC World.com (July 19, 2000); New MSN Messenger 3.0 Is the Only IM Service to Offer Free Long Distance to the United States and Canada, M2 Presswire (July 20, 2000); AOL Press Release, AOL Announces Next Generation of AOL Instant Messenger – Version 4.0 – For Windows and Mac Users (Apr. 10, 2000).
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Table 12. Selected CLEC Data Service Offerings CLEC Data Offerings AT&T AT&T Local Frame Relay and ATM Services: “provide ubiquitous, feature-rich networking options to fit your local (intraLATA) networking needs. . . ideal for companies whose primary business communications needs are heavily concentrated within one or several metropolitan areas (i.e. LATAs).” Cablevision “Lightpath offers both high quality asynchronous transfer mode (ATM) and advanced frame relay data Lightpath networks to support demanding high-speed data requirements.” Choice One “Lucent’s 7R/E Packet Solutions . . . will allow Choice One to create a multi-service packet network that integrates voice, video and data services all on a single converged packet network.” Global Frame Relay: “Link multiple locations with a fast, reliable data transmission network.” ATM: “Support Crossing multiple applications over a single connection — only ATM technology offers the Quality of Service (QoS) necessary to efficiently support voice, video, and data.” Time Warner “National network is built on ATM technology [DS-3, fractional DS-3, DS-1 and fractional DS-1], with facility Telecom and equipment redundancies.” US LEC “US LEC Frame Relay Service is the premier method of fast-packet data communications delivery service in the industry.” WorldCom Metro Frame Relay Service: Available “to more than 350 metropolitan areas serviced by 402 points of presence (POPs) across the nation.” “[O]ffers an aggressive price position compared to that offered by LECs. LECs can offer local (intraLATA) service, but they aren’t able to cross LATA boundaries. . . . WorldCom is in the unique position to provide both interLATA and intraLATA frame relay service.” XO “We also have been installing Asynchronous Transfer Mode (ATM) routers and switches in our local network, which will enable us to meet the demands of large, high volume customers.” Sources: See Appendix M.
Table 13. Growth of E-mail and Instant Messaging
C 53 percent of consumers use e-mail daily and use it for an average of 29 minutes a day. C IM, online chat, and mobile messaging are used for 15 minutes daily. C 37 percent of email users have cut back on their landline calling. C According to the Gartner Group, 60 percent of all real-time online communication – voice or text – will be driven through instant messaging technology. C According to InsightResearch survey: “Forty-seven percent of consumers said they use instant messaging. And of those, 96 percent said they use IM at home and 20 percent use instant messaging at work. . . . Nearly half of all respondents, 49 percent, use instant messaging as a replacement for a telephone call while one third, 35 percent, use it in place of sending an e-mail.” C “American workers send and receive approximately 2.2 billion messages every day.” C In a study by Vault.com, 45 percent of respondents said e-mail has replaced phone calls. C 73 percent of teenagers use the Internet. For one-fifth of them, instant messaging beats the telephone and e-mail as the primary channel for remote communication with friends. Sources: See Appendix M.
It is now clear that packet-switched networks are capable of and are being used to provide voice service along with traditional data services.110 Long-distance carriers have been
110 Both AT&T and WorldCom, for example, have launched retail voice-over-IP (VoIP) services to business customers; this “marked the first instance of two major telecom companies visibly transitioning to all-data networking that supports voice services.” M. Smetznnikov, AT&T Bets on Voice-Over-IP, Interactive Week (Feb. 5, 2001), http://www.zdnet.com/intweek/stories/news/0,4164,2681792,00.html .
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migrating voice traffic to high-speed packet switches for several years.111 Many CLECs have now begun to migrate their local voice traffic onto ATM and Frame Relay networks as well. See Table 14. All of the major packet switch manufacturers have developed voice capabilities for their packet switches.112 Growth for packet-based voice equipment outpaced all other telecom gear in first half of 2001.113 Analysts now agree that markets for both packet switches and voice- over-packet services will grow rapidly in the next few years.114
111 See, e.g., A. Lindstrom, Talkin’ ‘Bout Next-Generation Telcos (Level 3 designed its entire long distance network around packet switches from the ground up); T.K. Horan, CIBC Oppenheimer, Investext Rpt. No. 2749262, Telecom Services: Daily Teletimes – Industry Report at *1 (Mar. 1, 1999) (“Frank Ianna, president of AT&T Corp.’s network unit announced that by the end of the year, AT&T plans to stop buying traditional voice switches (circuit switches) in its long-distance network. The company will instead buy predominantly ATM switches for its long- distance network, which will allow data and voice to be carried on the same network more effectively. We note that Sprint also announced that it would stop buying circuit switches after 1999.”); Communications Daily (Apr. 14, 2000) (according to MCI Chief Technology Officer Fred Briggs, in April 2000, WorldCom announced that “[a]s part of converging voice and data services, [WorldCom] is planning to roll out this year soft switch or IP switch to handle Internet and voice services on IP backbone.”). 112 See, e.g., C. Stix, Morgan Stanley, Dean Witter, Investext Report No. 8092537, Cisco Systems – Company Report at *3 (July 20, 2001) (“Today over half of Cisco’s product lines are voice-enabled.”); Lucent Technologies, Circuit to Packet: Extending the Value of Class 4 and 5 Network Infrastructure in Metro/Edge Networks at 1, 2 (May 2001), http://www.lucent.com/businesspartners/clp/stories/circuit-to-packet.pdf. (“The migration from circuit to packet is underway. . . . Voice traffic is beginning to move from circuit-switched networks to data networks, including the Internet.”). 113 Communications Daily at 4-5 (Aug. 28, 2001) (according to a Synergy Research Group report, “Voice over Internet protocol (VoIP) equipment totaled $784 million in first half – 40% increase in year . . . Sales of VoIP for service providers grew to $196 million (1.2 million ports) in 2nd quarter, up 81% in year”). 114 See, e.g., TIA Sees VoIP Nearly Doubling, Telco Bus. Report (June 18, 2001) (The Telecommunications Industry Association has recently predicted that the voice-over-IP equipment market would nearly double this year to more than $3.3 billion); L. Cauley, What’s Ahead for . . . Phones; Internet Telephony Has Been Slow in Coming, But It’s About to Get a Big Boost, Wall St. J. at R9 (June 25, 2001) (According to Cahners In-Stat Group, carriers looking to offer voice-over-IP services spent about $1.127 billion worldwide in 2000. By 2003 that figure is expected to more than double to $2.607 billion, and again double by 2005 to about $5.855 billion.”); E.R. Jackson, U.S. Bancorp Piper Jaffray Inc., Investext Rpt. No. 2442005, Sonus Networks Inc. – Company Report at *2 (Jan. 19, 2001) (“We estimate the market for next-generation voice infrastructure solutions during 2000 to reach more than $1.5 billion. The market is expected to reach well in excess of $5 billion by 2003); L.M. Harris, Josephthal, Investext Rpt. No. 2454183, Sonus Networks Inc.: Initiating Coverage – Company Report at *1 (Jan. 30, 2001) (“While the voice-over-packet switching market in 2000 was probably less than $100 million, we project that it will grow to $250 million in 2001, and to close to $6.5 billion dollars by 2005. At that point, voice-over-packet switching sales could account for 20% or more of total voice switching sales.”).
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Table 14. CLECs Using Packet Switches To Provide Voice Services CLEC Status of Voice-Over-Packet Deployment AT&T “AT&T Corp . . . is offering voice over IP (VoIP) retail services for business, allowing the combination of voice, fax and data traffic on a single integrated IP connection managed by AT&T.” Choice One “Lucent’s 7R/E Packet Solutions, which will allow Choice One to create a multi-service packet network that integrates voice, video and data services all on a single converged packet network.” CTC “CTC has delivered on its promise to having customers utilizing local and long distance voice services on our Cisco Powered packet-based VoIP network by the end of 2000, and its goal of being one of the first carriers to do so.” Global Crossing “Global Crossing will complete the first phase of its U.S. VoIP network by the end of 2000, placing core VoIP gateway centers in a minimum of 15 additional cities”; “[t]he company plans to transfer its voice traffic from the circuit-switched network to the packet-based network by 2002.” Level 3 “Voice Termination from Level 3 is the first Internet Protocol-based voice product of comparable quality to the switched network because it requires no additional equipment or behavior changes on the part of your customers.” US LEC Added high capacity ATM packet switches in all of its 23 existing switching centers in the U.S. as part of its “strategic plan to become an IP (Internet Protocol) based CLEC fully integrating voice and data services economically over high bandwidth networks.” WorldCom “IP Communications” service “will enable businesses to move their voice traffic to an IP network and take advantage of a new generation of multimedia applications.” XO “XO has begun the first phase of an expansive migration to packet-based switching technology, which is expected to deliver the full range of traditional and enhanced local and long distance services.” Sources: See Appendix M.
Cable operators, who have been offering cable telephony on their own circuit switches for several years, are now migrating to packet-switched alternatives as well. The upgrades that allow cable companies to offer cable modem services also make it possible for cable to provide high-quality digital telephone service with only a small incremental investment.115 Uniform industry standards for providing IP telephony over cable are now in place. The North American cable industry has developed and adopted the DOCSIS 1.1 standard.116 Since the adoption of
115 See, e.g., Broadband 2001 at 39 (IP telephony “requires no additional outside plant investment, draws heavily on the core data service infrastructure, and only requires modest incremental equipment investment.”); J. Yoshida, Modem Issues Put Cable Voice-Over-IP Service on Hold (“cable VoIP service can share the same infrastructure already established for high-speed data services.”); NCTA Cable Telephony Report at 5 (“VoIP is not only an incremental expense, it utilizes the data path the industry has already built, and should allow for easy software changes and additions to service packages, and innovative combinations of voice, data, and fax services.”); see also G. Cooke, Taking the Hybrid Road to IP Telephony, CED (Dec. 2000), http://www.cedmagazine.com/ced/0012/12e.htm (a “new, hybrid cable IP telephony architecture has emerged. This new architecture enables cable operators with circuit-switched telephony equipment to begin offering converged IP services over their access network without having to forklift all of their existing circuit-switched equipment out of the network.”). 116 See Cable Datacom News, Standards – Cable Modem Standards and Specifications, http://cabledatacomnews.com/cmic/cmic3.html (The DOCSIS 1.1 specifications add key enhancements to the original standard, such as improved QoS and hardware-based packet-fragmentation capabilities to support IP telephony, and other constant-bit-rate services); CableLabs Press Release, CableLabs® Certifies Two DOCSIS™ 1.1 Modems and Qualifies Two CMTS, Achieving Breakthrough on Advanced Devices (Sept. 27, 2001) (“DOCSIS 1 enables cable operators to deliver twice the level of functionality while reducing operating costs by half.”); J. Yoshida, Modem Issues Put Cable Voice-Over-IP Service on Hold (DOCSIS adds to the previous standard (DOCSIS 1.0, which was designed for cable modem service), “three key elements . . . to support toll-quality telephone calls: upstream packet fragmentation and reassembly techniques, support for a national clock, and an advanced isochronous scheduling system.”).
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DOCSIS 1.1, the widespread deployment of cable telephony has been awaiting “the availability of cable modems based on version 1.1 of the Data Over Cable Service Interface Specification. DOCSIS 1.1,” which was first released in 1999.117 CableLabs began its certification program for compliant products in 2000; CableLabs certified the first DOCSIS 1.1 compliant cable modems in September 2001.118 Further tiers of certification are now nearing completion as well.119
Upgrading existing cable plant to provide IP telephony costs about $700 per line, or about 15 percent less than circuit-switched telephony.120 IP telephony also has lower operating costs (by at least 5 percent) than circuit-switched telephony, owing largely to the fact that “it can share a single infrastructure with data.”121 Cable operators are currently conducting trials of IP telephony. See Table 15. According to analysts, widespread commercial deployment of IP cable telephony (at least as a secondary line service) will begin in late 2002 or early 2003.122 Cable
117 J. Yoshida, Modem Issues Put Cable Voice-Over-IP Service on Hold. 118 See J. Baumgartner, MSOs Will Make Graceful Transition to DOCSIS 1.1, CED (Jan. 1, 2002); D. Iler, Road to PacketCable Passes DOCSIS 1.1, Multichannel News (Nov. 26, 2001) (“The first domino in standards-based voice-over-Internet protocol (VoIP) gear hitting the market fell in late September when two cable modems and two cable-modem termination systems (CMTSs) won Data Over Cable Service Interface Specification (DOCSIS) 1.1 certification and qualification from Cable Television Laboratories Inc. . . . CableLabs certified cable modems from Toshiba America Information Systems Inc. and Texas Instruments Inc. – whose reference design was used in Toshiba’s modem – and qualified CMTSs from Arris Group Inc. and Cadant Inc.”). 119 See J. Baumgartner, MSOs Will Make Graceful Transition to DOCSIS 1.1, CED (Jan. 1, 2002) (“a variety of cable operators are in the middle of evaluating CMTSs based on or upgradeable to DOCSIS 1.1.”); R. Brown & J. Baumgartner, After the Dust Settles; As Network Upgrades Approach Completion, Service Providers Aim to Launch New Services, CED (Dec. 1, 2001) (Cox Communications Senior Vice President of Technology Development Chris Bowick: “Over the last six months or so, we’ve been deep into the evaluation of all the various next-generation CMTS vendors. We have selected two. . . . These are the devices that we will be deploying, or have been deploying for a while, and will continue to deploy through next year in anticipation of becoming fully 1.1-compliant. We’d like to push toward that, toward beginning to get 1.1 compliant through the end of next year.”); D. Iler, Road to PacketCable Passes DOCSIS 1.1, Multichannel News (Nov. 26, 2001). 120 See, e.g., JP Morgan Cable Industry Report at 46; see also AT&T Broadband, Investor Presentation at 37 (July 2001) (AT&T estimates that providing primary line VoIP telephony would involve costs totaling $530-$620 per customer, including $230-$270 for switching and other outside equipment and $300-$350 for customer equipment, while circuit switched primary line telephony would cost $675); JP Morgan Cable Industry Report at 51 (“IP benefits from substantially lower costs in the centralized equipment that resides in the headend.”). 121 B. Michael, Cable VoIP, Computer Telephony at 36 (Aug. 1, 2000). See also JP Morgan Cable Industry Report at 46 (“IP’s operating costs will probably run 5% less than those for circuit voice.”); id. at 54 (“IP voice offers the promise of using a single hardware platform, support system, and staff for both data and telephony services,” which “not only lowers capital and operating costs, but also simplifies operations and provisioning.”); Nortel Networks, White Paper, The Cable Telephony Opportunity; Increasing Profits With Integrated Telephony and Data Services, http://www.gel.ulaval.ca/~mlecours/19504/Modem-cable/NortelCM.pdf. (“By delivering IP telephony and data services over a single DOCSIS cable modem system, headend and customer premise equipment expenditures are reduced. Additionally, operating efficiencies are gained by managing a single telecommunications platform, rather that multiple logical networks. The use of common equipment also simplifies customer provisioning and installation processes.”). 122 See, e.g., R.A. Bilotti, Morgan Stanley, Dean Witter, Investext Rpt. No. 8202634, Cable: The Past Is Prologue to the Future – Industry Report at *5 (Oct. 5, 2001) (“We expect the cable operators to begin offering IP telephony in 2002/2003”); M. Paxton, Cable Telephony – Moving Slowly But Surely, CED (Jan. 2002), http://www.cedmagazine.com/ced/2002/0102/id6.htm (“most [MSOs awaiting IP telephony] remain confident that by late 2002/early 2003, cable telephony will be an important part of their service menu”); J. Baumgartner, No Large VoIP Roll-Outs Until Late 2002, CED at 10 (Jan. 1, 2002) (“[I]t’s expected that cable operators won’t rollout IP telephony in II-31
operators are expected to deploy primary line IP cable telephony service shortly thereafter.123 Analysts expect that there will be between five and seven million cable IP telephony subscribers by 2006.124
Table 15. Cable IP Telephony Cable Operator IP Telephony Trials Plans For Future Deployment Time Warner Portland, ME As of March 2001, Time Warner planned to attract 1,000 IP voice Rochester, NY customers by September 2001, and to then monitor usage and calling patterns before embarking on a full deployment. IP telephony “will be offered some time [in 2002] in the [Tampa] bay area and central Florida.” AT&T Broadband Boulder, CO “We’re looking to deliver IP as quickly as possible.” (Jim Wood, vice president of advanced technology, Sept. 2001) Cox planned “Our strategy is to launch circuit-switched technology in our markets, and we’ve done that. . . . IP telephony is nearly ready for prime time. We’re watching it very closely.” (Tom White, Director of Marketing, Apr. 2001) “Cox is confident that IP telephony will add great value for our customers . . . We envision circuit switched and IP services will coexist in all of our networks.” (Jim Robbins, CEO, May 2001) Comcast Alexandria, VA Customers could see IP telephony service in 2002. (Steve Craddock, Union, NJ (completed) senior VP of new media, Apr. 2001) Philadelphia, PA Adelphia Buffalo, NY As of June 2000, Adelphia expects to launch commercial service first in Buffalo. Other markets will include Pittsburgh and its suburbs, Florida, Colorado Springs, Southern California, and other areas served such as Vermont, Virginia and Ohio. Cablevision Long Island, NY Cablevision’s digital and interactive television service, iO, is currently available to 550,000 homes in Long Island; the company plans to roll out iO throughout its service area, passing 4.7 million homes. The iO digital box will enable the provision of IP telephony to residential subscribers. Cablevision is currently testing this service in 300 homes and intends to begin commercial deployment in 2002. Charter Wausau, WI Charter plans to begin IP-telephony tests in 2002. St. Louis, MO Charter has already conducted two technical VoIP trials; the company will launch a marketing trial of both primary and secondary line IP service in Stevens Point, Wisc. Sources: See Appendix M.
earnest until the latter part of 2002. Until then, we’ll probably see more lab trials and pilot efforts in the field to make certain that everything works as advertised and that it’s a service with consumer demand”); A.B. Green, Lehman Bros. Inc., Investext Rpt No. 8302989, Broadband Access Technologies at *3 (Dec. 14, 2001) (“Our sense from the cable show is that operator interest and deployments of cable telephony are a likely story for the second half of 2002.”); J. Duffy, DOCSIS Compliance Delaying Cable IP Telephony, Network World (Aug. 13, 2001) (“It will be late 2002 or early 2003 before widespread deployments of IP-based cable telephony occur, the research firm [Cahners In-Stat Group] predicts.”). 123 See, e.g., JP Morgan Cable Industry Report at 46 (“we suspect that most MSOs will deploy primary-line IP voice in 2004 or 2005”); Strategis Group U.S. IP Cable Telephony Report at 52-53 (predicting that AT&T, Cox, Adelphia, Comcast, and Charter will begin deploying primary line IP telephony in late 2003/early 2004). 124 See id. at Table 3.9 (predicting 7.36 million IP telephony lines by 2006); Forrester Sizing US Consumer Telecom Report at 10-12 (“[B]y 2006, [cable companies] will reap the rewards of conversion to IP – an increased set of offerings at lowered costs – in the form of 4.8 million new packet lines.”).
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There are strong incentives for CLECs and cable operators to migrate to packet switching.125 Packet switches serve the most dynamic, rapidly growing sector of the industry – the data sector. They are much more compact than circuit switches,126 and they are much cheaper to purchase and deploy.127
A new generation of “softswitch” packet switches is now accelerating all of these trends.128 They are fast enough to switch voice, data, video, and other forms of traffic; they are thus far more compact and efficient than the arrays of media-specific hardware that they can displace. Equipment manufacturers, CLECs, and industry analysts all agree that these new switches can serve as complete “replacements” for Class 5 switches. See Appendix J, Tables 1 & 2. Numerous CLECs have already deployed softswitches. See Appendix J, Table 3. The Yankee Group expects worldwide sales of softswitches to rise from $16 million in 1999 to $824 million in 2003.129 Frost and Sullivan predicts that “providers will invest more than $39 billion in softswitch technology by 2006 and will realize $85 billion for services delivered using the technology that year.”130
C. Wireless Switches as Substitutes for Circuit Switches.
Wireless switches substitute for wireline switches at the margin, in much the same way as packet switches do. The marginal buyer of wireline service is the residential buyer of second-
125 See, e.g., A. Lindstrom, Talkin’ ‘Bout Next-Generation Telcos (“New business models based on the use of IP-oriented switches . . . enable gross margins in the 60 percent-plus range and the ability to provide differentiated offerings.”); J. Boyd, The End of the Central Office, http://www.internetwk.com/infastructure/infra081400-3.htm (Aug. 14, 2000) (“The huge price differences between Class 5 switches and new convergent platforms will allow more start- up CLECs like ACD.net to enter the market.”) (citing Andrew Clay, analyst, Aberdeen Group). 126 See, e.g., E.R. Jackson, U.S. Bancorp Piper Jaffray Inc., Investext Rpt. No. 2267558, Sonus Networks Inc.: Initiating Coverage – Company Report at *4 (Aug. 21, 2000) (packet switches “can result in a reduction of up to 90% in equipment space requirements.”). 127 See, e.g., id. (“packet telephony offers potential reductions of up to 50% in switch per-port costs” compared to traditional circuit switches.” This “[f]aster, cheaper, smaller, and more versatile switching equipment is transforming the central office.”); Wall St. Transcript Corp., Investext Rpt. No. 2003080, Analyst Interview: Telecommunications – Industry Report at *3-*4 (Sept. 22, 2000) (Trent Spiridellis, Principal and Senior Equity Research Analyst, Banc of America Securities: the price performance of an IP network “doubles . . . every 20 months.”). 128 See, e.g., M. Reddig, Top 10 Advances in Switching (“The most important development in switching over the past 3 years has been the rapid development, innovation and standardization of softswitches.”) (quoting Constantine Gavrilidis, Broadriver Communications.”); id. (“Three years ago, softswitches were just a concept. Today they are an integral part of an important milestone in the history of telecommunications.”); M. Johnston & D. Pappalardo, WorldCom Sees Promise in Move to Softswitches, Network World (Jan. 29, 2001) (As WorldCom’s Chief Technology Officer has noted, softswitches are “not pie in the sky,” but rather “stuff that we are deploying today.”). 129 See P. Korzeniowski, Pieces of Concern – The Communications Market Is One Big Puzzle, and Clecs Are Scrambling To Find the Right Fit, tele.com (May 29, 2000) (citing Yankee Group). 130 M. Reddig, Softswitches Emerge from the Shadows (citing Frost & Sullivan, World Softswitch Markets). See also id. (citing estimate by The Pelorus Group, Softswitches and Broadband Switching: The New Environment that “the softswitch market will grow from a revenue base of $200 million in 2000 to roughly $4 billion by 2004.”).
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line service. And as “margins” go, this is a big one: approximately 26 percent of U.S. residential customers buy second-line service from a wireline phone company.131
As of February 2002, there were an estimated 130 million wireless subscribers in the United States – up from 34 million at the end of 1995132 – as compared to the approximately 190 million users of switched landline telephone service.133 Two in five Americans – with all adults and children included in that count – have a mobile phone. 134 Some twenty million new subscribers are being added annually.135 Wireless carriers are adding subscribers much faster than their wireline counterparts – in percentage terms, and in absolute terms, too.136 See Figure 7.
Figure 7. Wireless vs. Wireline Growth Wireless Lines 250 $120 Wireline Lines 200 Wireless Voice Revenues $100 Wireline Voice Revenues $80 150 $60 100 $40
50 (billions) Revenues Access Lines (millions) Lines Access $20
0 $0 1996 2001 (est.) 2006 (est.) Source: JP Morgan H&Q. See Appendix M.
All of this wireless traffic is switched traffic. Wireless carriers other than those affiliated with Bell companies have deployed a total of more than 950 circuit switches nationwide. See Appendix F.137 Many of the switches that wireless carriers are using are indeed the same switch types that CLECs are using – for example, the Lucent 5ESS, Nortel DMS 100, and Ericsson AXE-10.138
131 See Forrester Sizing US Consumer Telecom Report at 2. 132 See CTIA’s Semi-Annual Wireless Industry Survey Results; CTIA, CTIA’s World of Wireless Communications, http://www.wow-com.com (131 million current U.S. wireless subscribers as of Feb. 12, 2002). 133 See CSFB 3Q01 CLEC Vital Signs Review at Exh. 9; see also FCC Local Competition Report, Feb. 2002 ed. at 1. 134 See Michael Powell, Chairman, FCC, Consumer Policy in Competitive Markets, remarks before the Federal Communications Bar Association, Washington, D.C. (June 21, 2001). 135 See CTIA’s Semi-Annual Wireless Industry Survey Results. 136 Compare FCC Statistics of Common Carriers, 2000/2001 ed. at Table 4.10 (total switched access lines and residential switched access line growth, 1995-2000) with CTIA’s Semi-Annual Wireless Industry Survey Results (estimated wireless subscribers, 1995-2000). 137 These figures are conservative, because they are drawn from public sources or from the necessarily limited data available to the BOCs. 138 See, e.g., Lucent Technologies, Switching Solutions, Switching, 5ESS Switch, http://www.lucent.com/ products/solution/O,,CTID+2002-STID+10055-SOID+935-LOCL+1,00.html (“The 5ESS® switch can deploy all II-34
At the end of 2001, wireless calls already accounted for an estimated 12 percent of all U.S. phone calls.139 There were approximately 200 billion billable minutes of wireless use in the first half of 2001, up 77 percent from June 2000, and up 34 percent from December 2000.140 Wireless networks now switch at least one-quarter of the amount of traffic as wireline networks.141 And wireless minutes of traffic are growing at over 60 percent per year, while landline minutes are growing at “low single digits.”142
A second very large margin for which wireless switches compete is switched access traffic. In addition to completing local calls, local switches serve the second function of providing switched access to long-distance networks. Local access revenues represent approximately 14 percent of all local service revenues;143 long-distance calling minutes (i.e., access minutes) represent about one-quarter of all switched minutes on local plant.144 Wireless plant certainly competes directly against wireline plant here, too.
types and combinations of services from a single platform including wireline, wireless, voice and data.”); Nortel Networks, Products, Services & Solutions, DMS Switching Portfolio, DMS-100 Wireless Switching System, http://www.nortelnetworks.com/products/01/dms100w/index.html (The DMS-100 “offers a flexible and cost effective way for a service provider to establish a single point of presence in both traditional wireline and wireless markets, as well as new data and internet telephony markets.”); Alcatel, Products and Services, Alcatel 1000 Multimedia Multiservice Exchange, http://www6.alcatel.com/products/ (The Alcatel 1000 MM “handles any combination of fixed and mobile application.”). 139 See V. Bajaj, Daytime Calling Clogs Spur Wireless Companies to Expand Night Minutes, Dallas Morning News (Dec. 13, 2001) (citing David Bornowski, AT&T Wireless Services Inc.’s vice president/general manager for Texas and Louisiana). This number is projected to increase to nearly 50 percent by 2005. See The Bull Market Report Daily, www.bull-market.com (Jan. 12, 2001), http://www.bull-market.com/daily/Jan01/011201.htm. In terms of talk minutes, wireless is projected to account for over 40 percent of all conversation minutes by 2005. J. Sarles, Wireless Users Hanging Up on Landline Phones, S.F. Bus. Times (Mar. 23, 2001). 140 See R. Whickham, Don’t Kid Yourself, Wireless Review (Dec. 1, 2001), http://industryclick.com/ magazinearticle.asp?releaseid=9715&magazinearticleid=136835&siteid=3&magazineid=9; see also CTIA, Telephia Study Finds Outstanding Wireless Network Performance While Industry Experiences Rapid Growth, http://www.wow- com.com/articles.cfm?ID=553 (“Minutes of use increased by 75% last year - from 147 billion minutes used in 1999 to 259 billion minutes used in 2000.”). 141 Wireline networks switch approximately 4.4 trillion local dial equipment minutes (“DEMs”) per year, and there are two DEMs counted for each conversation minute, resulting in approximately 2.2 trillion originating and terminating minutes. There are 130 million wireless subscribers and the average subscriber uses 339 minutes per month (4,068 per year) on her wireless phone, resulting in approximately 529 billion originating and terminating wireless minutes per year. Both totals include toll minutes. See L.F. Carvalho, Morgan Stanley, Dean Witter, Investext Rpt. No. 8285600, Wireless Services: Industry Outlook: Life After 50 – Industry Report at *5 (Nov. 28, 2001) (average of 339 monthly MOUs per wireless subscriber in 2001); CTIA, CTIA’s World of Wireless Communication, http://www.wow-com.com (130 million wireless subscribers); FCC Statistics of Common Carriers, 2000/2001 ed. at Table 5.8 (4.4 trillion Dial Equipment Minutes; “two [dial equipment minutes] are counted for every conversation minute”). 142 See 3g Rollouts Inch Along, But Kagan Research Indicates Wireless Minutes Roaring Ahead, Set to Dominate Telecom Landscape by 2005 Leading Executives to Debate Market Demand, Technology and Financing at Kagan’s Wireless Telecom Summit May 2-3 in New York, Bus. Wire (Apr. 27, 2001). 143 See FCC Telecommunications Industry Revenues, 2002 ed. at Table 2. 144 See FCC Statistics of Common Carriers, 2000/2001 ed. at Table 5.8 (3.4 trillion local dial equipment minutes, both originating and terminating); id. at Table 2.5 (790 billion interLATA billed access minutes, both originating and terminating).
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At least twenty million wireless customers (and counting) have plans that do not charge extra for long-distance.145 The average price of a wireless long distance call is comparable to the average price of a long distance call made via wireline.146 Many wireless carriers heavily market the “free long-distance” aspects of their service. Analysts report that “[t]he bundling of long distance calling at price points that are perceived as ‘nearly free’ to consumers is already making wireless long distance calling a more cost-effective alternative to wireline long distance calling to many wireless consumers.”147 Thus, “wireless continues to take share from wireline local and long distance usage.”148 AT&T recently noted that its wireline long-distance minutes of use were down about 10 percent, while its wholesale wireless long-distance traffic was running up about 35 percent.149
While wireless-wireline competition starts at the margin, it by no means ends there. Wireless is increasingly competitive with core primary-line wireline services. When the comparison is made between equivalent bundles of service, it is clear that wireless services are now price-competitive with wireline. Almost all wireline CLECs focus on selling bundles of service – not just basic access, but bundled long-distance and additional features as well.150 And so do almost all wireless carriers. And so do most of the ILECs themselves. Regulation does require ILECs to offer unadorned, basic, local service at a very low price to all residential customers. But the vast majority of wireline customers buy much more – long-distance service, to begin with, which generates additional local-carrier revenues by way of access charges. And often, as well, other value-added features like call waiting, voice mail, and caller ID. A November 2001 Gartner Dataquest study concludes that wireless calling prices are already “competitive with, and in some case better than, wireline calling rates.”151
145 Sixth CMRS Report at 32-33. The Strategis Group estimates that this number will grow to 90 million in 2005. See A. Backover, AT&T Loss Reflects Long-Distance Shift Consumers Turn to Calling Cards, Wireless, USA Today at 3B (Jan. 30, 2001). 146 For example, Cricket offers long distance service at 8 cents per minute without monthly service charges or minimum usage charges. See Cricket, Denver and Northern Colorado, http://www.cricketcommunications.com/ Denver_Colorado_2.asp; see also M. Rollins, Salomon Smith Barney, Investext Rpt. No. 2421667, Wireless by the Minute: Reviewing the Wireless Economic Model – Industry Report at *4 (Jan. 3, 2001) (“With buckets of minutes, wireless customers have a marginal cost of zero relative to wireline, which generally has a marginal cost of $0.05-$0.15 per minute.”). 147 IDC Wireless Displacement Report at 20. See also L.R. Mutschler, Merrill Lynch Capital Markets, Investext Rpt. No. 8247725, Sprint PCS Group – Company Report at *4 (Oct. 31, 2001) (“[T]he free long distance option in the Sprint PCS plan should make them attractive to subscribers that are interested in replacing wireline long distance minutes with wireless minutes.”). 148 M. Rollins, Salomon Smith Barney, Investext Rpt No. 8223022, Sprint PCS Group – Company Report at *4 (Oct. 18, 2001). 149 See A. Quinton, Merrill Lynch Capital Markets, Investext Rpt No. 8232517, AT&T Corp. – Company Report at *5 (Oct. 24, 2001). 150 See, e.g., G.P. Miller, et al., Jefferies & Co., Investext Rpt. No. 2918156, Telecom Services Weekly Update – Industry Report at *11 (Aug. 9, 1999) (“The CLECs have [] built much of their platform on offering competitively priced bundled and personalized service.”). 151 Gartner U.S. Consumer Telecommunications and Online Market Report at 33.
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Wireless prices continue to decline rapidly – by as much as 10 to 20 percent a year in recent years.152 While the length of the average wireless user’s local call has increased, the average local monthly wireless bill has fallen from $97 in 1987 to $45 in 2001.153 Analyst IDC attributes the dramatic growth in wireless usage, particularly in home and business locations that provide wireline access too, primarily to the fact “that wireless service pricing is rapidly approaching wireline service pricing.”154 At prices now in effect, wireless “is viewed as a cost- effective and compelling alternative to wireline.”155 Numerous analysts have reached the same conclusion.156
The Commission itself has agreed with this assessment in its July 2001 Sixth CMRS Report. It found that the wireless phone has “become a mass-market consumer device,” that most wireless customers use their phones “primarily for personal calls,” and that three in ten wireless users would prefer to give up their landline phone, if forced to choose, and that number rises to almost one in two among younger users.157 The Commission’s Report went on to discuss wireless services that are specifically being marketed as alternatives to wireline service.158 Citing a Yankee Group survey, the report also found that at a quite sizable number of consumers – about 3 percent of wireless subscribers – have now abandoned wireline – in favor of wireless – entirely, “rely[ing] on their wireless phone as their only phone.”159 A more recent USA Today/CNN/Gallup poll found that 18 percent of cell phone users “use cell phones as their primary phones.”160
152 See, e.g., Sixth CMRS Report at 6. 153 CTIA’s Semi-Annual Wireless Industry Survey Results. 154 IDC Wireless Displacement Report at 11. 155 Id. at 19. 156 See, e.g., Gartner U.S. Consumer Telecommunications and Online Market Report at 41 (Gartner Dataquest: “Average mobile per-minute pricing will continue to decrease,” with an “increased cross-elastic impact on wireline services.”); see also Argus Research Company and Foliofn, Sector Outlook: Telecomms Second Quarter 2001 (Second Quarter 2001), http://www.foliofn.com/content/forum/research/01Q2Telecom.pdf (Argus Research: “Pricing for wireless service has fallen to levels comparable with wireline service in many areas of the country, and more and more consumers are opting for wireless as their primary telecom connection.”); J. Moran, Phones: Cheaper and Better, Hartford Courant at L28 (Feb. 25, 2001) (“The cost of wireless voice will continue to decline,” [Peter Firstbrook, META Group research analyst] said. “You’ll finally have competition for the [local phone companies]. I think we’re at the transition right now where wireless prices are reaching parity with wireline.”). 157 Sixth CMRS Report at 32. 158 See id. at 33-34. 159 Id. at 32 (citing J. Sarles, Wireless Users Hanging Up on Landline Phones, Nashville Bus. J. (Feb. 2, 2001)). The Commission noted that CTIA estimated that this number “could be as high as 5 percent.” Sixth CMRS Report at 32 n.207 (citing Consumers Replacing Landline Phones with Wireless, Knight Ridder/Trib. Bus. News (Jan. 10, 2001). 160 M. Kessler, 18% See Cell Phones as Their Main Phones, USA Today (Jan. 31, 2002).
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III. INTEROFFICE TRANSPORT
The interoffice transport UNE comprises links between ILECs’ and requesting carriers’ wire centers or switches, and between ILEC switches.1 A “wire center” is an end office where local loops terminate at an ILEC switch.2 Interoffice transport does not include transport between an ILEC or CLEC switch and a customer.
The provision of interoffice transport is now highly competitive. The first competitors entered urban markets in 1985, and they have been laying competitive fiber optic networks ever since. The Commission first directed ILECs to provide collocation to competitive access providers in 1992.3 Today, competitors have established fiber connections in a large fraction of BOC wire centers, which serve a significant percentage of BOC access lines. Many of the competitive transport facilities that CLECs have deployed are used to provide special access services; competitors now earn between 28 and 39 percent of all special access revenues.
As detailed below, it clearly is economical for competitors to serve an even larger number of wire centers with their networks than they currently do. With each additional mile of competitive fiber that gets deployed, the marginal cost of extending the network to reach an additional wire center gets lower. And the rise of the Internet has made it all the more attractive for CLECs to extend their fiber networks to ILEC end offices. Data connections generate a lot more traffic than voice calls do; the total volume of data traffic overtook voice traffic in 1998.4
A. Fiber-Based Collocation.
CLECs that provide competitive transport typically do so by collocating their own transmission equipment in an ILEC central office and connecting that equipment to their own fiber-optic network. This “fiber-based collocation” supplies the simplest and most unambiguous indicator of the extent of competition in the transport market, albeit a very conservative one that sharply underestimates the full extent of competition.
With few exceptions, competitively supplied transport begins in a CLEC collocation cage.5 At the time of the last UNE review, the data required to determine where CLECs had
1 See 47 C.F.R. § 51.319(d)(1)(i) (defining dedicated transport as “transmission facilities . . . between wire centers owned by incumbent LECs or requesting telecommunications carriers, or between switches owned by incumbent LECs or requesting telecommunications carriers.”); id. § 51.319(d)(1)(iii) (defining shared transport as “transmission facilities . . . between end office switches, between end office switches and tandem switches, and between tandem switches, in the incumbent LEC network.”). 2 See Newton’s Telecom Dictionary 995 (16th ed. 2000). Wire centers vary widely in size, from fewer than 500 lines in rural areas, to over 300,000 in the most densely populated urban areas. 3 See Expanded Interconnection with Local Telephone Company Facilities, Report and Order and Notice of Proposed Rulemaking, 7 FCC Rcd 7369 (1992). 4 See Section II, note 100. 5 See, e.g., W.T. Scott, et al., ING Baring Furman Selz LLC, Investext Rpt. No. 2787890, Telecommunications/Fiber Vs. Fiberless (Sept. 30, 1998) (quoting then-WinStar CEO, Bill Rouhana: “The fundamental underpinning of the strategy of most fiber-based companies in the industry today is that we will build to a central office, and we will co-locate with a regional bell operating company.”); id. (quoting Allegiance Telecom CEO III-1
obtained fiber-based collocation was not available.6 It is today. The Commission’s August 1999 Pricing Flexibility Order makes the presence of fiber-based collocation the trigger for pricing relief for special access services, and ILECs have therefore begun to compile such data systematically.7
As shown in Table 1, fiber-based collocation is now widespread. As of year-end 2001, one or more CLECs had obtained fiber-based collocation in 13 percent of the wire centers served by the Bell companies, which contain 54 percent of the business lines and 44 percent of all access lines served by the Bell companies. See Table 1. There also are multiple CLECs with fiber-based collocation in a large number of BOC wire centers, which contain a significant share of BOC access lines. See id.
Table 1. Competitive Interoffice Transport by Region Percentage of Wire Centers and Access Lines Served by: 1 or more 2 or more 3 or more 4 or more fiber-based CLEC collocation nodes % Bus. % Total % % Bus. % Total % % Bus. % Total % % Bus. % Total % Lines Lines WC Lines Lines WC Lines Lines WC Lines Lines WC Verizon 55 44 12 37 25 5 28 17 3 17 10 2 SBC 50 41 13 35 25 7 23 15 4 15 9 2 BellSouth 62 53 19 52 43 13 43 34 9 34 26 6 Qwest 56 45 13 40 28 7 27 18 4 19 12 3 Total 54 44 13 38 28 7 28 19 4 19 12 3
In large metropolitan areas the totals are even higher. For example, in the 25 largest MSAs served by each BOC, an average of one or more CLECs had obtained fiber-based collocation in 35 percent of the wire centers served by the Bell company in those MSAs (containing 61 percent of all access lines within those MSAs). See Table 2. And, again, there
Royce Holland: “We enter the market and put in switches, routers, both central office and frame-relay switches. We co-locate in a huge number of COs. We’ve targeted over 500 central offices to be in within the next few years. It represents a huge addressable market and then we go out and lease capacity initially, and as we reach the crossover point in terms of traffic, we either lease dark fiber or overbuild it. For instance, in New York, the crossover point is 40,000 lines. We have already moved to stage two, in which we acquired dark fiber from Metromedia Fiber Network.”); KMC Telecom Holdings Inc., Form 10-K (SEC filed Apr. 17, 2001) (“[i]n all of our operational markets, we have completed our backbone construction connecting the market’s central business district with outlying office parks, large institutions, the locations of long distance carriers’ transmission equipment and major incumbent local exchange carrier central offices.”); Adelphia Business Solutions, Form 10-K (SEC filed Apr. 2, 2001) (Adelphia claims that “[t]he broad deployment of fiber optic cable in Adelphia Business Solutions’ markets typically enables connectivity among the Company, the ILEC central offices and the Company’s customers.”); Network Plus, Form 10- K at 13 (SEC filed Mar. 30, 2000) (Network Plus’s fiber provides connections for the company’s “co-location footprint.”). 6 As one analyst report notes, “detailed information on actual fiber deployment on an industry wide basis is not available.” Broadband 2001 at 92. To analyze competitive fiber, it is therefore necessary to “build a ground-up view of where such fiber is or is likely to be deployed.” Id. 7 See Pricing Flexibility Order ¶¶ 81-86, 147-152.
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are multiple CLECs with fiber-based collocation in a large number of BOC wire centers in the largest MSAs, which contain a significant percentage of BOC access lines. See id.
Table 2. Competitive Interoffice Transport in the 25 Largest MSAs Served by Each BOC Percentage of Wire Centers and Access Lines Served by: 1 or more 2 or more 3 or more 4 or more fiber-based CLEC collocation nodes % Lines % WCs % Lines % WCs % Lines % WCs % Lines % WCs Verizon 58 35 36 16 25 10 16 6 SBC 61 35 37 18 23 10 13 5 BellSouth 69 37 57 27 47 20 35 14 Qwest 60 32 38 19 25 11 18 7 Total 61 35 40 19 27 12 18 7
It is clearly economical for competitors to deploy fiber in an even larger share of wire centers than they currently serve. Some 30 percent of all wire centers contain 5,000 or more business lines, and those wire centers contain 84 percent of all business lines.8 In those quantities, independent analysts have found that voice lines readily generate traffic in volumes sufficient to justify competitive fiber-optic transport.9 And the actual experience of CLECs in the marketplace bears this out.
As shown in Table 3, one or more CLECs has obtained fiber-based collocation in nearly half of BOC wire centers with 5,000 or more business lines. See Table 3. And in wire centers with larger numbers of business lines, it is even more likely that at least one CLEC has obtained fiber-based collocation in that wire center. See id.
Table 3. Competitive Interoffice Transport in Large Wire Centers Percentage of all wire centers with X or more business lines that contain Y or more CLECs with fiber-based collocation: X= 5,000 10,000 20,000 30,000 Y= 1 2 3 4 1 2 3 4 1 2 3 4 1 2 3 4 Verizon 51 26 16 9 66 39 27 15 78 65 50 31 93 84 69 41 SBC 38 21 11 6 51 32 18 10 73 53 41 19 80 64 45 28 BellSouth 66 51 37 25 81 75 62 47 91 91 86 75 100 100 100 100 Qwest 48 28 16 11 65 41 24 17 86 68 48 33 94 76 64 42 Total 48 28 17 10 61 41 27 17 78 62 49 30 87 74 58 39
8 See Broadband 2001 at 96. 9 See, e.g., Broadband 2001 at 95 (Central offices “with more than 5,000 business lines . . . require [CLECs to gain] no more than 8% share [to break even] and therefore are well within the ‘sweet spot’ of even multiple CLECs per CO.”); see also id. (“As might be expected, it is apparent that businesses residing with larger central offices spend up to one-third more on average per business per month than those businesses in smaller central offices.”).
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A fiber-based collocation test for the availability of competitive transport certainly provides a reliable indicator of which ILEC wire centers are served by competing fiber networks. It is worth emphasizing, however, that this test takes no account of the considerable amount of traffic that now bypasses ILEC wire centers completely. As one appellate court has noted, the fiber-based collocation metric “fails to account for the presence of competitors that . . . have wholly bypassed incumbent LEC facilities.”10
This is all the more true because the ILEC wire center is no longer the only – or even the principal – point of traffic concentration. So if it is economical for a CLEC to run competitive fiber to reach an ILEC wire center, it is often economical to extend the fiber, directly to datacom hotels, large business customers, data ISPs, wireless carriers, cable headends, and countless other points of traffic concentration.11
Many private customers also now generate sufficient quantities of traffic to justify their own fiber optic connections. As discussed in Section IV.A, there are now direct CLEC fiber connections to tens of thousands of buildings in the U.S. – buildings that house a substantial fraction of all business customers.
CLEC networks also converge today at many other points of high traffic concentration, including interexchange carrier POPs and Network Access Points (NAPs). “Collocation hotels” – like those operated by Switch & Data, Cable & Wireless (formerly Exodus Communications), Global Switch, and Metro Nexus – create additional points of traffic concentration. These centers provide large (typically 10,000-50,000 square foot), high-security facilities to house servers, data storage equipment, and the network interface equipment used by telecom carriers and ISPs.12 They give multiple CLECs and IXCs points at which to station their equipment and interconnect their networks.13 Many of them are located right on the doorstep of existing ILEC wire centers.14 In terms of how much traffic they originate and terminate, these facilities are as large as – and often much larger than – ILEC wire centers.15 Data traffic at these centers is now
10 WorldCom v. FCC, 238 F.3d. 440, 462 (D.C. Cir. 2001) (quoting Pricing Flexibility Order ¶ 95). This framework also is conservative because it examines only fiber-based collocation, even though competitive carriers have obtained thousands of collocation arrangements that, although not fiber based today, could easily be modified to connect to third-party fiber. 11 See, e.g., Wall Street Transcript Corp. Interview, John Peters – Sigma Networks (John Peters, CEO, Sigma Networks: “[W]e’ve targeted our network to address the interconnection needs principally between all of the major sources and links of data traffic in the metro. We’ve targeted the major carrier hotels, the major data centers, the Internet backbone connection points ‘the MAEs, the PAIXs’ and the broadband backbone networks.”). 12 See D. Culver, Construction Boom for Colocation. 13 See R. Duran, Checking into Telecom Hotels, Bus. Xpansion J. (Feb. 2001), http://www.bxjonline.com/ issues/feb2001/telecom_hotels.asp. 14 See D. Culver, Construction Boom for Colocation (collocation hotels provide “high-security facilities operated by independent companies that put telecom gear as close as possible to incumbent central offices without actually being there.”). 15 See, e.g., R.J. Sherman, Janney Montgomery Scott, Investext Rpt No. 2121566, Exodus Communications – Company Report at *2 (Apr. 4, 2000) (“It is estimated that 50% of all Internet traffic flows from Exodus’ data centers.”); F. Billimoria, et al., Hambrecht and Quist Inc., Investext Rpt No. 2724275, Exodus Communications – Company Report at *2 (Nov. 20, 1998) (“The company estimates that 10-12% of traffic that is carried over the Internet
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growing at 100 percent a year, “and will consume 40% of total metro bandwidth by 2005.”16 Datacom hotels “tend to be concentrated in the top 15 Tier One metros, which account for 80% of demand.”17 Nonetheless, today there are alternative collocation providers in virtually all major metropolitan areas throughout the country. See Appendix G.
That there are many different points of traffic concentration is competitively significant in two important respects. First, high-traffic-volume nodes provide network economies of scale to many smaller competitors, by consolidating their traffic at a single physical location. To obtain competitive transport, a CLEC no longer has to grow organically; it can, instead, just locate itself in the right building. Second, the major competitive fiber-optic providers in an area are all very likely to route their networks to these locations – thus effectively providing connection to all points served by all the competing networks combined. The CLECs themselves can hand off traffic to each other, or an intermediary can bundle and resell their services as a single, integrated competitive service. Thus, while any single competitive fiber network may serve only a select number of point-to-point routes, that carrier will have access to the point-to- point networks of other competing carriers as well. The universe of total competitive fiber – not the point-to-point routes of any individual competitor – defines the geographic areas within which competitive transport facilities are now available.
Three years ago, the Commission downplayed the competitive significance of competitive transport on the ground that CLECs “require dedicated transport facilities that are more extensive than those that are currently deployed along the point-to-point routes.”18 The Commission stated that, “[w]ithout access to the incumbent’s ubiquitous transport facilities, competitive LECs are faced with the delays and costs of deploying their own transport facilities to meet the demand” or “must utilize a patchwork of competitive alternatives, where available, to collect and route traffic to the required destination.”19 Whatever the merits to that concern three years ago, the market itself has overtaken it today. Competitive transport networks now overlap and converge. Today, CLECs routinely seek out competitive suppliers of fiber; the supposed administrative costs of building patchwork solutions have been readily overcome.
Marketplace experience firmly establishes that carriers will seek out competitive suppliers of fiber, even where it means relying on a patchwork of different networks, rather than the ubiquitous facilities of an ILEC.20 This is precisely the way the competitive access business began, with the large interexchange carriers purchasing competitive fiber in just a single goes through an EXDS data center. They also noted that during peak periods, they are transmitting sustained levels of 2.4 gigabits/sec of traffic across the Internet, which we believe makes EXDS the 3rd or 4th largest generator of traffic.”). 16 Lehman/McKinsey MAN Report at 6. 17 Id. at 6-7. 18 UNE Remand Order ¶ 346. 19 Id. 20 See, e.g., Joint Comments of Allegiance Telecom, Inc. and Focal Communications Corporation at 5, Implementation of the Local Competition Provisions of the Telecommunications Act of 1996, CC Docket No. 96-98 (FCC filed June 11, 2001) (“Where it is available, Allegiance and Focal purchase transport and fiber from third parties.”).
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location, at first, and slowly expanding from there.21 AT&T and WorldCom found the business so compelling, that they spent $25 billion to acquire their two largest suppliers.22 Today, as discussed in more detail below, CLECs are purchasing as much fiber as they can from wholesale suppliers, even though these suppliers do not necessarily offer fiber everywhere. These suppliers obviously wouldn’t even be in business if CLECs were willing to purchase transport only from suppliers who offered them ubiquitous connectivity.
B. CLEC Fiber.
At the time of the UNE Remand Order, the Commission found that, based on market conditions at the end of 1998, “competitive LECs have deployed transport facilities along selected point-to-point routes, primarily in dense market areas.”23
Since that time there has been a further, sharp increase in the availability of competitive alternatives to ILEC interoffice transport facilities.24 At the time of the UNE Remand proceedings, for example, CLEC fiber networks spanned approximately 100,000 route miles (both local and long-haul).25 Today, CLEC networks consist of at least 184,000 route miles of fiber (both local and long-haul).26 While many CLECs do not publicly report how many purely local route miles of fiber they operate, information from CLECs that do release such totals confirms that the majority of this fiber is local.27
While CLECs have significantly expanded their own local fiber networks, there also has been a rapid increase in local fiber supplied by “carrier-agnostic” wholesale suppliers. These companies have invested well over $1 billion in deploying local fiber networks that they sell or lease to other carriers. As a result, for a growing number of CLECs, the fiber provided by these wholesale suppliers satisfies a large part of their demand for interoffice transport.
21 See Section III.B. 22 See AT&T News Release, AT&T Completes TCG Merger (July 23, 1998); WorldCom Press Release, WorldCom, Inc. and MFS Announce Merger to Form Premier Business Communications Company (Aug. 26, 1996). 23 UNE Remand Order ¶ 333. 24 This competitive transport is available to wireless carriers, just as it is to CLECs. Moreover, wireless base stations and switches (MTSOs) typically handle sufficient volumes of traffic to justify new fiber connections. 25 See NPRG CLEC Report 2000, 12th ed., Ch. 6 at Table 5 (restated 1998 route miles). As described in the following note, the latest NPRG report excludes fiber for competitive Independent Operating Companies, utility CLECs, data providers, and Gig-E providers. To make an apples-to-apples comparison with the 2001 totals, we have removed from the 1998 totals the fiber for carriers that NPRG has placed in one of these categories. 26 NPRG CLEC Report 2002, 15th ed., Ch. 2 at Table 7; Ch. 4. This is a highly conservative estimate. It does not include 117,000 route-miles of fiber that NPRG lists for competitive Independent Operating Companies, utility CLECs, data providers, or Gig-E providers. Moreover, the total miles for 2001 have been adjusted downward to address the concerns that CLECs raised in the Special Access proceeding in April of 2001 (CC Docket No. 96-98). 27 For example, of the 33 CLECs for which NPRG provides fiber-route miles, we have found only four examples (Adelphia, McLeod, Time Warner Telecom, and XO) where, based on CLECs’ own public disclosures, the total route miles reported by NPRG appear to include significant amounts of long-haul fiber. At the same time, the total route miles reported by NPRG are lower than local-only route-mile totals provided by at least two CLECs (AT&T and Cablevision) and do not include any fiber route miles for WorldCom, which is one of the two largest CLECs.
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The first competitive transport services involved the provision of “access” between large business customers and interexchange carriers. New York authorized interoffice competition in 1985, and that year Teleport built a fiber-optic network in lower Manhattan, to provide special access service to business customers, where the most concentrated wire centers in the nation reside. Sixteen other states had followed New York’s lead by August 1986.28 Institutional Communications Company (ICC), the second major CAP, was formed in 1986 in Washington, D.C.; it is now a part of MCI/WorldCom’s MFS.29 In 1987, Chicago Fiber Optic (soon to be MFS) began building a network to provide special access in downtown Chicago.30 By 1990, CLECs had deployed 20 networks in 15 cities.31 By 1995, 29 CAPs had deployed fiber-optic networks in approximately 100 cities, consisting of more than 21,000 route miles of fiber.32
Since the last UNE review, the number of “operational” and “on-net” CLEC networks in the 150 largest MSAs – which contain nearly 70 percent of the U.S. population33 – has grown from approximately 1,100 to nearly 1,800. See Appendix K.34 During this period, the average number of CLEC networks in the 150 largest MSAs grew by more than 60 percent. See Table 4. Today, 91 of the top 100 MSAs are served by at least three CLEC networks; 77 are served by at least seven, 59 are served by at least 10. See Appendix K. As these data make clear, CLEC fiber is by no means limited to dense urban areas. CLECs also have deployed fiber far outside of urban areas to reach large business customers in suburban and rural areas.35
Table 4. Average Number of CLEC Networks by MSA MSA Rank 1998 2001 Percentage Increase 1-25 19.6 32.2 64% 26-50 10.2 15.0 47% 51-75 5.2 9.0 73% 76-100 4.0 6.6 65% 101-125 2.8 4.8 71% 126-150 2.8 3.4 21% Sources: See Appendix M.
28 See Semilof, IntraLATA Competition: Lata Barrier Falls, Network World at 11 (Aug. 25, 1986). 29 See NPRG 1999 CLEC Report, 10th ed., Ch. 2 at 3. 30 See NPRG 1999 CLEC Report, 10th ed., Ch. 2 at 3. 31 See U.S. Dep’t of Commerce, U.S. Industrial Outlook at 33-7 (1990). 32 See Connecticut Research, 1995/96 Local Telecommunications Competition at Table II-2 (7th ed. 1995). 33 Rand McNally, Commercial Atlas and Marketing Guide 2001 at 60-61, 83 (132nd ed. 2000). 34 For purposes of these totals, we have counted all “voice networks” and “data networks” that NPRG’s CLEC Report 2002 lists as “operational.” These totals may include some networks or parts of networks that CLECs operate with facilities leased from a third party, including an ILEC. 35 See also, e.g., K. Fairbank, RAIL SWITCH; Union Pacific Develops High-Tech Subsidiary, Dallas Morning News at 1D (Oct. 18, 2000) (Ekanet, a subsidiary of the Union Pacific railroad, “aims to provide services to underserved, primarily rural, markets west of the Mississippi River”); Fujitsu Equipment Drives New Fiber Network Serving Northwestern South Dakota, Bus. Wire (Nov. 6, 2000) (South Dakota Network “is now offering advanced telecommunications services to customers in rural northwest South Dakota through a 600-mile fiber-optic network”).
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Finally, there are new technologies on the near horizon that would enable additional fiber to be deployed without digging up city streets, which “could cut the time and cost of fiber installation in half.”36 For example, “CityNet Telecommunications aims to revolutionize the rollout of broadband services in cities by dispatching tiny robots to lay fiber-optic cables in sewer pipes.”37 The company already has agreements to deploy fiber in nine major cities (Houston, Pittsburgh, Dallas, Scottsdale, Indianapolis, Fort Worth, Omaha, San Antonio, and Albuquerque),38 and is in talks with dozens of other cities. In April 2001, the company announced that it had secured $275 million in a new round of financing, which “underscores the novelty and promise of the . . . company’s business.”39
Many of the competitive transport facilities that CLECs have deployed are used to provide special access services. Special access revenues constitute a very large share of all interoffice transport revenues. Moreover, these revenues are highly concentrated in a relatively small number of wire centers,40 making them an easy target for CLECs to serve with their own facilities. The Commission has found that “the revenues of competitive LECs come primarily from special access and local private line services.”41 CLECs now account for between 28 and 39 percent of all special access revenue, which is significantly larger than their share of the local exchange market as a whole.42
C. Wholesale Suppliers of Local Fiber.
In the past few years, there has been a dramatic increase in fiber supplied by alternative wholesale suppliers, which typically sell or lease dark fiber to other carriers, but do not
36 P. Davidson, Robots Lay Fiber Optics in City Sewers, USA Today (Nov. 27, 2000). 37 Id. 38 CityNet News Release, City of Houston and CityNet Telecommunications Announce Agreement To Wire City with Fiber Optic Networks Through Sewers (Jan. 9, 2002); CityNet News Release, City of Pittsburgh and CityNet Communications Announce Agreement to Wire City with Fiber Optic Networks Through Sewers (Oct. 26, 2001); CityNet News Release, Mayor Touts “Smart” Alternative to Trenching Streets (Oct. 16, 2000); CityNet News Release, CityNet Inaugurates the First-Ever U.S. Fiber Optic Network Deployment Through City Sewer System (Feb. 20, 2001); CityNet News Release, CityNet Launches Last-Mile Fiber Optic Network in Indianapolis (June 13, 2001). 39 CityNet Wins $275 Million in Funding, Wash. Post (Apr. 10, 2001). 40 See USTA, Competition for Special Access Service, High-Capacity Loops, and Interoffice Transport, CC Docket No. 96-98, at 3 & Table 1 (FCC filed Apr. 5, 2001) (“more than 80 percent of SBC’s special access revenues are generated in less than 25 percent of the wire centers in which it is providing special access. In Verizon’s region, more than 80 percent of special access revenues are generated from about 20 percent of Verizon’s total wire centers. In Qwest’s region, more than 60 percent of special access revenues are generated from 11 percent of Qwest’s total wire centers. In BellSouth’s region, 91 percent of special access revenues are generated from 20 percent of BellSouth’s total wire centers.”). 41 Promotion of Competitive Networks in Local Telecommunications Markets, First Report and Order and Further Notice of Proposed Rulemaking in WT Docket No. 99-217, Fifth Report and Order and Memorandum Opinion and Order in CC Docket No. 96-98, and Fourth Report and Order and Memorandum Opinion and Order in CC Docket No. 88-57, WT Docket No. 99-217; CC Docket No. 96-98; CC Docket No. 88-57, FCC 00-366, ¶ 24 (rel. Oct. 25, 2000). 42 See Appendix L & Section V; see also Section I.D.
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themselves engage in the provision of telecommunications services. See Table 5.43 Five of these alternative fiber suppliers have formed an industry coalition – the Coalition of Competitive Fiber Providers – which states that its members’ business plans involve the “provision of competitive fiber-based transport services and dark fiber to competitive local exchange carriers . . . collocated in ILEC central offices.”44 The Coalition claims that its “members together represent a total capital investment of approximately $1 billion.”45 According to analysts, metropolitan fiber suppliers have raised about $2 billion in capital since the third quarter of 2000, and are still “some of the few getting capital.”46 These companies have recently raised significant additional funding through debt and vendor financing.47 According to consulting firms Cambridge Strategic Management Partners and McKinsey & Co., “[t]he market for reselling . . . dark fiber to ISPs and telecom carriers is projected to grow from about $2 billion today to about $10 billion by 2006.”48
Just like CLECs, alternative wholesale suppliers of fiber connect end users to their fiber rings, which in turn connect to interexchange carrier POPs and ILEC central offices.49 Because
43 See, e.g., J. Grubman, Salomon Smith Barney, Grubman’s State of the Union at 15 (Mar. 21, 2001) (“there is an avalanche of metro capacity being deployed.”); Robertson Stephens Provides Outlook on Telecom Services, PR Newswire (Sept. 7, 2000) (“We believe that we have reached the beginning of the end of the metropolitan bandwidth bottleneck . . . We are seeing a new generation of metropolitan bandwidth operators that will provide 100 Mbps plus connectivity at low cost to end users.”). 44 Coalition of Competitive Fiber Providers, Petition for Declaratory Ruling at 2, Application of Sections 251(b)(4) and 224(f)(1) of the Communications Act of 1934, as amended, to Central Office Facilities of Incumbent Local Exchange Carriers, CC Docket No. 01-77 (FCC filed Mar. 15, 2001) (“Coalition of Competitive Fiber Providers Petition”). The five coalition members are American Fiber Systems, Fiber Technologies, Global Metro Networks, Telergy, and Telseon. 45 Coalition of Competitive Fiber Providers Petition at 2. 46 P. Brown, Despite Tighter Purse Strings, Cash Is Still Streaming to Metro Providers, Tele.com (Aug. 13, 2001) (citing the Yankee Group and quoting Lehman Brothers Equity Research telecom analyst Blake Bath). 47 See, e.g., Looking Glass Networks Press Release, Looking Glass Networks Nets Huge Debt Financing Round (Mar. 2, 2001) (Looking Glass raised $275 million in debt in February of 2001); Metromedia Fiber Network Press Release, Metromedia Fiber Network Successfully Completes $611 Million Financing Package (Oct. 2, 2001) (Metromedia raised a total of $611 million in September of 2001); Yipes Press Release, Yipes Closes $200 Million “C” Round of Funding (Feb. 5, 2001) (Yipes secured $200 million in equity financing); Telseon Press Release, Telseon Receive $175 Million in Financing (Feb. 6, 2001) (Telseon secured $100 million in equity financing and $75 million in capital lease financing.). 48 N. Orman, Networking Startups Battle for Cities, Silicon Valley/San Jose Bus. J. (Oct. 26, 2001). 49 See, e.g., Coalition of Competitive Fiber Providers Petition at 1 (emphasis added) (Our members “provide, or will provide, advanced fiber-based transport services, including interoffice transport, and/or dark fiber to end users and other telecommunications carriers. Coalition members together offer these services and products in virtually every region of the ‘lower 48’ states and the District of Columbia.”); Looking Glass Networks, FAQ, http://www.lglass.net/ aboutus/faq.jsp (Looking Glass’s target customers include “Long Haul Carriers (IXCs), Incumbent Local Exchange Carriers (ILECs), Competitive Local Exchange Carriers (CLECs), Internet Service Providers (ISPs), data centers, bandwidth trading organizations, storage facility providers, wireless data providers and large enterprise customers.”); Wall Street Transcript Corp. Interview, John Peters – Sigma Networks (John Peters, CEO, Sigma Networks: We’re a Carrier’s carrier. Our customers tend to be the backbone carriers that are looking to extend their reach within the metro, the service providers that host applications within the various data centers that need to get traffic to and from the various backbone networks, and then third would be broadband access networks, cable, DSL, and fixed wireless suppliers that need to interconnect their access networks into the metro to get to the data centers and the backbones.”).
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these alternative suppliers are “carrier agnostic,” they can use their networks to serve multiple carriers at once, significantly improving the economics of deploying fiber.50 For a growing number of CLECs, the fiber provided by these wholesale suppliers satisfies a large part of their demand for last-mile local connectivity and interoffice transport.51 In fact, these alternative suppliers’ networks are so expansive that even ILECs have begun purchasing fiber from them.52
In addition to this new breed of wholesale fiber suppliers, many of the nation’s utility companies are now supplying local fiber to CLECs. See Table 6. Utility companies control a significant portion of the nation’s fiber infrastructure – as much as 35 percent according to one source.53 These companies have the advantage of being able to deploy fiber using their existing infrastructure. As one analyst notes, “If a company already has wires or pipes in the ground, the cost of entry is comparatively low.”54 Another analyst notes that “roughly half of the new metro networks being built in the United States are being constructed by utilities.”55
Finally, several of nation’s largest operators of long-haul fiber networks have recently constructed metropolitan fiber networks. See Table 7. These carriers have sold dark fiber on their long-haul networks to CLECs for many years, and have now begun leasing dark fiber on
50 See, e.g., Wall Street Transcript Corp. Interview, John Peters – Sigma Networks (John Peters, CEO, Sigma Networks: “[E]ach of these metro networks requires a very large amount of traffic to drive the unit cost down to a reasonable level. So by having us deploy a common network infrastructure that can be used by many carriers, we can get the traffic volumes aggregated on our network much more easily than any individual carrier can do on their own and therefore we can drive unit cost down faster.”); id. (John Peters, CEO, Sigma Networks: “We take a position of neutrality with regard to our customers. . . . We’re a neutral provider of broadband interconnections.”); Looking Glass Networks, Collocation, http://www.lglass.net/products/collocation.jsp (Looking Glass Networks provides “carrier- neutral facilities”); F.J. Governali, et al., Credit Suisse First Boston Corp., Investext Rpt. No. 2699472, Northeast Optic Network – Company Report at *3 (Sept. 10, 1998) (NEON’s business plan “is lower risk than most of the emerging nationwide network builders” because it “plans to only operate as a carrier’s carrier, which takes away the risk of competing with other carriers for end-user services and significantly decreases operating expenses.”). 51 See, e.g., Allegiance Telecom Inc., Form 10-K405 (SEC filed Mar. 30, 2001) (Allegiance has leased fiber from suppliers in 25 markets, and claims that “[t]hese fiber rings are expected to provide [Allegiance] with a reliable, diverse and robust connection to most of [its] central office locations throughout a market.”); CTC Communications Announces Fully Funded Local Fiber Build-Out Plan; High Bandwidth Core Fiber Network to Be Extended to Verizon Local Switching Offices, Bus. Wire (Dec. 19, 2000) (CTC purchased from a “number of dark fiber suppliers” “local fiber in selected geographical areas of eastern Massachusetts, southern New Hampshire, southern Maine and Rhode Island,” which it claims will “extend CTC’s existing high bandwidth fiber network backbone to Verizon local switching offices,” and enable it to “eliminate the need for leased inter-office Verizon facilities.”); Sprint Press Release, Sprint Signs Multiyear Contract with Metromedia Fiber Network for Enhanced Access to Major U.S. Markets (Dec. 4, 2001) (Sprint expects to begin using MFN networks in initial markets in the second quarter of 2002 and in all 10 cities by the end of 2002). 52 See, e.g., B. Wallace, Bell Atlantic Eyes Further Expansion, TechWeb (Oct. 18, 1999), http://www.informationweek.com/757/atlantic.htm (Bell Atlantic invested $550 million to gain access to MFN’s local fiber networks in 50 cities); D. Rohde, Looking for SBC Over the Horizon, Network World Fusion (Aug. 21, 2000), http://www.nwfusion.com/columnists/2000/0821rohde.html?nf (SBC will buy local dark fiber nationwide from MFN). 53 See J. Krause, They’ve Got the Power, The Standard (Dec. 27, 1999). 54 I. McDonald, Butterfly Companies: The Web Has Transformed These Utilities Firms, The Street.com (Nov. 3, 2000), http://www.thestreet.com/funds/fundjunkie/1155477.html. 55 K. Maddox, New Era, New Partner – Old-Line Manufacturer Chooses Cinergy for Network Build, tele.com (Mar. 5, 2001) (citing Forrester analyst Maribel Dolinov).
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their metropolitan fiber networks as well. These carriers also have begun providing competitive local services to customers directly. To cite just one example, in January of this year, the District of Columbia City government agreed to lease dark fiber from Level 3 to create a high-speed data network linking government buildings at various locations across the city.56
56 Level 3 Selling Dark Fiber to District of Columbia City Government, CLEC.com (Jan. 31, 2002), http://www.clec.com/newsprint.asp?ContentID=2147455397.
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Table 5. Wholesale Local Fiber Suppliers Cities with Operational and Network Details Planned(*) Networks Metromedia Fiber Seattle, Portland, San Francisco/Bay Area, Los “Our existing intra-city networks consist of Networks Angeles, Phoenix, Denver, Dallas, Houston, approximately 1,579,000 fiber miles covering in Kansas City, Chicago, Miami, Boston, New York, excess of 3,987 route miles in the United States.” Washington D.C., Atlanta Fiberworks Atlanta, Charlotte, Birmingham*, Orlando*, “Fiberworks has installed over 3,000 fiber route Miami/Ft. Lauderdale*, Jacksonville*, Tampa/St. miles.” Petersburg*, New Orleans*, Raleigh/Durham*, Greenville/Spartanburg*, Nashville*, Dallas/Ft. Worth*, Austin*, San Antonio*, Houston* American Fiber Salt Lake City, Kansas City, Nashville, AFS plans to “help alleviate the band-width capacity Systems Minneapolis, Cleveland shortage by installing more than 1.4 million miles of AFS is developing dark fiber optic rings in 126 fiber-optic strands in second and third-tier U.S. other cities across the country. cities over the next seven years.” Fibertech Networks Albany, Buffalo, Rochester, Syracuse. Fiber Technologies “planned network infrastructure Pending Completion: Hartford, Indianapolis, New and diverse ring topology will encompass more than Haven, Springfield, MA, Worcester, Columbus, 40 cities, 6,400 route miles and in excess of 306,000 Pittsburgh, Providence. fiber miles.” Planned: 48 additional markets Yipes Santa Clara, Atlanta, Boston, Chicago, Dallas, “Yipes has now over 3,600 route miles of fiber in Denver, Ft. Collins, Ft. Lauderdale, Houston, our twenty-one markets, which is twice the route Longmont, Miami, New York, Palo Alto, miles we had in December. With multiple fibers in Philadelphia, Pittsburgh, Riverside, San Diego, San each of its markets, Yipes has now lit 32,000 miles Francisco, Seattle, Washington, D.C., Worcester of fiber encompassing 128 metropolitan rings.” Telseon Atlanta, Chicago, Cincinnati, Dallas, Denver, “In 2001, Telseon increased its network points of Detroit, Houston, Los Angeles, Miami, New York, presence from 120 to 160 locations . . . In 2002, Northern Virginia, Orlando, Philadelphia, Phoenix, Telseon will continue to expand its network to San Diego, San Francisco Bay Area, Seattle, include multiple tenant buildings and large Silicon Valley, St. Louis, Tampa enterprises.” Looking Glass Seattle, San Francisco, Los Angeles, Dallas, With “over $15 million in signed customer Houston, Atlanta, Chicago, Washington D.C., New contracts,” Looking Glass “offers the full range of York, Boston carrier class SONET, Ethernet and Wavelength lit services from 10 Mbps to 10 Gbps, along with dark fiber and carrier neutral collocation.” Northeast Optic Baltimore*, Boston, Bridgeport, Hartford, Keene, NEON’s “interstate, intercity, and local loop Network (NEON) Manchester, Nashua, New Haven, New York, facilities comprise a network of approximately Newark*, Philadelphia*, Portland, Portsmouth, 1,900 route miles and more than 81,000 fiber Providence*, Springfield, Stamford, Washington, miles.” D.C.,* White Plains, Worcester Progress Telecom Atlanta, Miami, New York, Raleigh, Saint “Progress Telecom incorporates approximately Petersburg, South Florida, Tampa, Washington 130,000 fiber miles and 7,200 route miles in its D.C. network including over 150 Points-of-Presence (POPs).” EPIK The lit network reaches 12 key cities, including the EPIK has lit a 1,850 mile regional fiber in network Communications cities of Atlanta, Jacksonville, Orlando, Tampa, in the Southeastern United States. EPIK is also and Miami; EPIK is also developing fiber “metro developing fiber metro rings in Atlanta, rings” in these five cities totaling approximately Jacksonville, Orlando, Tampa, and Miami totaling 400 route miles. 400 route miles. NEESCom Providence, Worcester, Metro West (MA region NEESCom has deployed “more than 700 route east of Worcester) miles of dark fiber.” Sources: See Appendix M.
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Table 6. Utilities Providing Local Fiber Alameda Power & Telecom “finalized a $16 million contract with Evansville, Ind.-based Vectren Communications Services for construction of a hybrid fiber optic/coaxial telecommunications network.,” which “will allow the municipal utility to offer telecommunication services to its customers.” Bristol Virginia Utilities “Six businesses now have high-speed Internet connections through the city’s fiber-optic Board network, and two dozen others have requested the service. . . . Several telecommunications companies are interested in leasing the capacity to provide . . . telephone service.” Cinergy Communications Cinergy Communications (a telecom subsidiary of Cincinnati’s gas and electric provider, Cinergy Corp.) has begun leasing its fiber network that circles Cincinnati. ConEdison Communications “ConEdison has embarked on a push to become a fiber-based carrier’s carrier in the New York of New York metro area, and is deploying all new fiber in ConEd’s conduits. . . . ‘If you’re a retail provider and you touch our network at any POP, you could buy whatever unit of bandwidth you want into any building we have on the network,’ [Peter Rust, president and CEO of ConEdison Communications] explained. ‘You could go after that building, sell one or two customers, buy just what you need to cover those two customers and grow the bandwidth as you need it.’” Edison Carrier Solutions “San Diego’s Edison Carrier Solutions has built a Southern Cal. network 2nd only to the incumbent phone provider and concentrates on SONET transport, also offering managed wavelength service and dark fiber leasing.” Electric Power Board of “EPB, the [Chattanooga] city-owned electric utility, expanded two years ago into Chattanooga telecommunications to capitalize on the utility’s fiber-optic lines originally installed to help with communications for its electricity service.” El Paso Global Networks El Paso Global Networks (a subsidiary of natural gas and energy company El Paso Corp.) plans to spend $2 billion over the next four years on a nationwide fiberoptic network and “plans to overbuild its metropolitan areas to provide better connectivity.” FPL FiberNet FPL FiberNet (a subsidiary of the utility holding group that includes Florida Power & Light) has a 2000 mile fiber network in Florida. It provides connectivity to major telecom centers in Florida, “including leading carrier hotels, NAP initiatives, international cable-heads and large central offices.” Grant County Public Utility “GCPUD will provide video services over its existing fiber-optic infrastructure, known as Zipp. District When completed in 2005, the Zipp network will contain some 50,000 mi of fiber in its effort to reach 40,000 homes, businesses, and farms throughout Grant County. To date, the network passes about 7,000 homes with approximately 2,000 customers ‘lit’ and receiving services.” Lafayette Utilities System “The Lafayette Utilities System has completed a 65-mile, 96-strand fiber-optic loop that offers broadband throughout the city. The loop passes within 1 mile of nearly every home in the city limits.” PPL Telecom PPL Telecom will market its services in five metropolitan areas that company officials believe are underserved – the Lehigh Valley, Lancaster, Harrisburg, Scranton/Wilkes-Barre and Williamsport. “Our fiber, as it exists today, is within half a mile of 20,000 office buildings.” Progress Telecom Progress Telecom is “building local metropolitan fiber networks to try to get the capacity out close to the buildings and the consumers where they need it.” Reliant Energy Operates a 67-route mile fiber backbone in Houston. Sempra Communications of “L.A. utility firm Sempra Communications found a technique for running fiber conduit through Los Angeles pipelines without interrupting gas transmission and is attacking the last mile as ‘the gold mine of the [telecom] industry.’ Telergy MidAtlantic “Business customers in Northern New Jersey and Pennsylvania now have access to a powerful new source for telecommunications services. TMA combines the resources of Telergy’s established telecom network with GPU’s extensive last mile reach and communications construction experience.” Touch America (formerly Owns and operates a 23,000-route-mile, state-of-the-art, high-speed fiber-optic network that will Montana Power) span 26,000-route miles, cross 40 states, and reach more than 140 major cities in 2002. Its network is used for long-haul services and “for Touch America’s own direct connections to individuals and businesses through its wireless services, metropolitan fiber offerings, and private line, long-distance and Internet applications.”
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Table 7. Local Fiber Networks of IXCs That Supply Dark Fiber Company Cities with Operational and Planned(*) Networks Williams Anaheim, Atlanta, Baltimore, Boston, Chicago, Dallas, Houston, Los Angeles, Miami, Minneapolis, New York, Newark, Philadelphia, Phoenix, San Francisco, San Jose, Santa Clara, Seattle, St. Louis, Washington, D.C. (*construction is planned in 40 more cities by the end of 2001) Level 3 Atlanta, Baltimore, Boston, Chicago, Cincinnati, Dallas, Denver, Detroit, Jersey City, Houston, Long Island, Los Angeles, Miami, New York, Newark, Orlando, Philadelphia, Phoenix, San Diego, San Francisco, San Jose, Seattle, St. Louis, Stamford, Tampa, Washington, D.C. Global Crossing New York, Philadelphia, Washington, D.C., Atlanta, Miami, Dallas, Chicago, San Francisco, San Jose, Los Angeles Qwest Baltimore, Chicago, Dallas/Ft. Worth, Houston, Kansas City, Los Angeles, New York, Sacramento, San Francisco, San Jose, St. Louis, Washington, D.C. Sources: See Appendix M.
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IV. LOCAL LOOPS
As the Commission has recognized, loops come in a wide range of capacities. The availability of competitive substitutes varies accordingly. In addition, the availability of substitutes varies significantly among geographic markets.
A. High-Capacity Loops.
The FCC defines a “high-capacity loop” as a loop from a customer to an ILEC central office that is capable of supporting a service at DS-1 speeds (i.e., 1.544 Mbps) or higher.1 A DS- 1 facility consists of 24 individual 64 kbps DS-0 circuits, the bandwidth normally used for a single voice channel.2 The individual circuits on DS-1 loops and higher can, however, be configured to provide any mix of voice and data services.3 High-capacity loops are almost always provided to medium or large business customers.
As described in Section III, competitive access providers began deploying fiber networks immediately after the Bell break up, to provide interoffice transport between the ILECs’ Class 5 switches and the Interexchange Carriers’ Class 4 counterparts. CLECs then began extending their fiber between ILEC central offices. They then moved beyond carrier-to-carrier services, extending their fiber to provide a full range of high-capacity local services to large private customers.
The economics of supplying high-capacity loops are exactly the same in the service of large customers as they are in the service of carriers. Either way, high traffic volumes between specific pairs of points justify the deployment of new fiber. And the further the competitive fiber network runs, the more economical it becomes to add customers along the existing route, and to extend the fiber further still.
1. CLEC Fiber as a Substitute for High-Capacity ILEC Loops.
Collectively, CLECs use their own last-mile facilities to serve the vast majority of their large business customers. CLECs serve no fewer than 13 million business lines and likely closer to 20 million business lines using their own switches, yet they have obtained only about 1.5 million stand-alone unbundled loops to serve business customers. See Table 1.4
1 47 C.F.R. § 51.319(a)(1) (“The local loop network element is defined as a transmission facility between a distribution frame (or its equivalent) in an incumbent LEC central office and the loop demarcation point at an end-user customer premises. . . . The local loop includes, but is not limited to, DS1, DS3, fiber, and other high capacity loops.”). 2 See Whatis.com, Digital Signal X, http://whatis.techtarget.com/definition/0,,sid9_gci212004,00.html (DS0 has “a transmission rate of 64 kbps, the bandwidth normally used for one telephone voice channel.” DS1 “is 24 DS0 (64 kbps) signals.”). 3 See Qwest, Data, DS1, http://www.qwest.com/pcat/small_business/product/1,1354,140_3_2,00.html (“Each DS-1 Service comprises 24 channels that may be assigned in a wide variety of ways to support switched access, local exchange service, low-speed data, voice grade communications, audio services and digital data services.”). 4 This calculation is a conservative estimate of the number of larger business customers that CLECs serve over their own loop facilities because many of the stand-alone unbundled loops that CLECs have obtained are likely used for smaller business customers.
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Table 1. CLEC Business Lines Provided Over CLEC-Owned Last-Mile Facilities Total Facilities-Based Unbundled Business Lines Provided CLEC Business Lines Business Loops* Over CLECs’ Own Loops Verizon** 3.7 – 6.8 million 467,000 3.3 – 6.3 million SBC*** 4.5 – 7.4 million 765,000 3.7 – 6.7 million BellSouth 1.8 – 3.2 million 229,000 1.6 – 3.0 million Qwest 2.9 million 63,000 2.8 million Total 13 – 20 million 1.5 million 11 – 19 million *ILECs do not maintain data on whether an unbundled loop is used to serve a business or residential customer. We have developed the estimate of unbundled loops used to serve business customers as follows: CLECs provide at least 3 million residential lines over facilities they have deployed themselves, and approximately 1.5 million of these lines are provided over cable telephony networks. We assume the remaining 1.5 million residential lines are provided using unbundled loops, and that all other stand-alone unbundled loops provided by ILECs to CLECs are used to serve business customers. **Total for Verizon does not include the former GTE service area. ***Total for SBC does not include Connecticut.
Any count of “lines,” however, severely underestimates the CLECs’ actual share of the business market. A high-capacity line represents more market share than a low-capacity line, and CLECs tilt their businesses strongly toward the former. While CLECs as a whole supply a total of between 13 and 20 million business lines using their own switches, 12 of the CLECs included in that total supply over 156 million voice-grade-equivalent circuits.5 AT&T’s Business division reports serving 2.7 million “local voice lines” but “over 30M DS0 equivalents.”6
Based on the highly conservative count of lines that CLECs provide over their own facilities, the CLECs now supply at least 20 percent and likely closer to 28 percent of all business lines nationwide. See Figure 1. That percentage is undoubtedly much higher in major metropolitan areas where the largest business customers are concentrated.7 The FCC’s own data confirm that the CLECs’ share of large business customers is considerably higher than their share of the overall business market.8
5 See Section I.B & Table 4, Appendix A. 6 D. Dorman, President, AT&T, Presentation Before the Lehman Brothers T3 Telecom, Trends & Technology Conference (Dec. 6, 2001). 7 See, e.g., UNE Remand Order ¶ 291, n.573 (“The local competition that has developed has focused on larger business customers in large cities, not on residential or small business customers.”); FCC, Biennial Regulatory Review 2000 – Staff Report, App. IV, Pt. 54, 15 FCC Rcd 21089, 21266 (2000) (“Competition for business customers in metropolitan areas has, in general, developed more rapidly than competition for residential customers or customers in rural areas.”); FCC Local Competition Report, Dec. 1998 ed. at 2 (“Facilities-based CLECs appear to have concentrated in more urbanized areas.”). 8 According to FCC’s most recent Local Competition Report, CLECs’ share of the “Medium to Large Business Market” was nearly four times their share of the “residential and small business market.” FCC Local Competition Report, Feb. 2002 ed. at Table 2.
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Figure 1. Percentage of Total Business Lines in BOC Regions Served Over CLEC Switches interconnection trunks*2.75 (minus residential E911 listings)* 35% business E911 listings 19-30% 30% 30% 19-29% 20-28% 17-26% 25% 20% 15% 10% 5% 0% Verizon** SBC*** BellSouth Qwest Total
*The totals for facilities-based business lines based on interconnection trunks represent the additional lines produced by this methodology over the number of E911 listings that CLECs have obtained. The high-end of the range given on each bar threrfore represents the percentage of lines served using the interconnection trunk method, whereas the low-end of the range represents the percentage using E911 listings. **Verizon data do not include CLEC or ILEC lines in the former GTE territory. ***SBC data do not include CLEC or ILEC lines in Connecticut and Nevada.
These totals also are consistent with the significant inroads that CLECs have made into the special access market. The provision of special access service typically involves both a high- capacity loop and, as discussed in Section III, interoffice transport. Because special access revenues are highly concentrated among a relatively small number of wire centers, CLECs have been able precisely to target their facilities to serve this lucrative market. Today, CLECs account for between 28 and 39 percent of all special access revenue.9
It does not take a very far-flung network to reach a very significant number of high- volume customers. It has been estimated that, in a typical Tier-One MSA, just 200 to 300 multi- tenant units – out of an average of 15,000 or more multi-tenant units in such MSAs – generate an estimated 80 percent of the data revenues generated in those MSAs.10 And the top 15 MSAs generate almost 80 percent of the nation’s data traffic.11 Just four MSAs – New York, San Francisco, Washington, D.C., and Los Angeles – generate some 40 percent.12
Most CLECs do not report how many buildings their fiber networks serve.13 Public data are available for only about 20 CLECs;14 as of year-end 2001 this small subset of CLECs
9 See Appendix L. 10 See Lehman/McKinsey MAN Report at 8 (emphasis added) (“enterprise traffic is currently very concentrated, as in a typical Tier One MSA, 200 to 300 MTUs (of more than 15,000) constitute 80% of data revenues.”). 11 See id. at Figure 3. 12 See id. at 6-7. 13 See, e.g., CSFB 3Q01 CLEC Vital Signs Review at Exh. 16 (total buildings data for 8 of the 14 profiled CLECs were not available); J. Atkin & D. Coleman, Dain Rauscher Wessels, City Light: An Investor’s Guide to Metropolitan Optical Services at 11 (Mar. 22, 2001) (“Few carriers release detailed data on their fiber networks.”). 14 By comparison, there are at least 110 CLECs as well as numerous wholesale fiber suppliers that currently operate metropolitan networks. See NPRG CLEC Report 2002, 15th ed., Ch. 6; Section III.C.
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operated networks that served approximately 330,000 buildings.15 This figure, however, includes “off-net” buildings – buildings served in part using facilities leased or resold from another competing carrier or an ILEC. CLECs have estimated that the number of unique office buildings served entirely by their fiber networks is roughly 30,000 nationwide.16
Given that CLECs route them to large commercial office buildings and other points of high traffic concentration, CLEC networks are clearly capable of serving far more high-capacity business lines than they currently do. Once they extend their network to serve one customer in a building, CLECs can vie for the business of all the other tenants, too. And CLEC fiber networks are now so extensive that they readily can be – and routinely are – extended as needed to pick up additional traffic from new customers in adjacent buildings, or down the block, and on outward, incrementally, from there. Once an initial fiber ring is deployed in a metropolitan area, extending that fiber incrementally to new customers is comparatively cheap.17 When they deploy fiber, carriers invariably deploy far more capacity than they can use immediately, to facilitate precisely this process of incremental future development.18 And the bigger the network grows, the more economical it becomes to extend it to reach additional, lower-traffic, lower- revenue customers.
Rapidly rising traffic volumes make the economics of deploying competitive fiber increasingly attractive. Traffic volumes from “large enterprises” – which generate half of the traffic in metropolitan markets19 – are growing at an estimated 40 percent a year.20 Data traffic for small and mid-size enterprises is growing at an estimated 60 to 70 percent a year.21 As traffic volumes rise, competitive fiber networks quickly move from merely “competitive” to markedly
15 NPRG CLEC Report 2002, 15th ed., Ch. 4 at Table 19. This is a highly conservative estimate. It excludes not only the buildings served by literally dozens of CLECs, but also does not include the 27,000 additional buildings NPRG reports for competitive Independent Operating Companies, utility CLECs, data providers, Gig-E providers, fiber layers, and other providers. See id. Moreover, the total buildings have been adjusted downward to address the concerns that CLECs raised in the Special Access proceeding in April of 2001 (CC Docket No. 96-98). 16 See Joint Comments of Allegiance Telecom, Inc. and Focal Communications Corporation at 25, Implementation of the Local Competition Provisions of the Telecommunications Act of 1996, CC Docket No. 96-98 (FCC filed June 11, 2001); Comments of WorldCom, Inc. at 7, Implementation of the Local Competition Provisions of the Telecommunications Act of 1996, CC Docket No. 96-98 (FCC filed June 11, 2001). 17 As the FCC has noted, “[t]he technological advances in fiber and electronics have made expansion of transport capacity relatively inexpensive. Once a competitor has infrastructure in place, the marginal cost of adding customers is not significant, and competitors are not likely to lack sufficient capacity for an extended period.” Brief of FCC, Respondent, at 36, MCI WorldCom v. FCC, No. 99-1395 et al. (D.C. Cir. filed Nov. 30, 2000). 18 See B. Gain & D. Dunn, Is the Fiber Glut for Real?, EBN (Dec. 10, 2001), http://www.ebnonline.com/ story/OEG20011210S0066 (“Because excavation costs are high, many telcos overbuilt intentionally to avoid having to tear up lines to meet future demand.”); O. Kharif, The Fiber-Optic “Glut” – In a New Light, Bus. Week Online (Aug. 31, 2001), http://www.businessweek.com/bwdaily/dnflash/aug2001/nf20010831_396.htm (“Since the total cost of laying cable can reach $1 million per mile – including everything from digging trenches to obtaining permits – telecoms often drop as much fiber into a ditch as they can. That’s far cheaper than installing capacity as demand dictates.”); Federal-State Joint Board on Universal Service, Tenth Report and Order, 14 FCC Rcd 20156, ¶ 199 (1999) (“industry practice [is to build] distribution plant to meet ultimate demand.”). 19 See Lehman/McKinsey MAN Report at 8. 20 See id. 21 See id.
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superior. Next-generation technologies (SONET-lite, Metro DWDM and Gigabit Ethernet) are estimated to be 30 to 70 percent more cost-efficient than legacy networks.22 Network capacities are rarely if ever an issue; year by year it gets easier and cheaper to boost the capacity of existing fiber by upgrading the electronics that “light” it. Data-carrying capacities are indeed doubling about every 9-10 months.23
In these circumstances, it is not surprising to find that CLECs and wholesale fiber suppliers widely tout their willingness to extend their networks to pick up new customers and traffic.24 One declares that its network is “available” to all businesses that “pass within 6000 feet”25 and will “provide[] the fiber-optic link from its access network directly into the building.”26 Another emphasizes its willingness to “work together with a customer to construct a spur to that customer from an existing fiber ring.”27 Another will “bring our fiber right up to our customers’ floors in their buildings and provide them with wall-to-wall seamless connectivity.”28 Another will “provide its customers with fiber optic connectivity to virtually any location in its service territory” using a process that is “quick and efficient.”29 Another will connect to “the main Class-A buildings in a downtown business district.”30 CLECs also may extend their fiber networks through fixed wireless connections,31 which can be deployed much more quickly and
22 See id. at 1. 23 See, e.g., Industry Buzz, Forbes (Jan. 8, 2001), http://www.forbes.com/forbes/2001/0108/154s01.html (Lucent states that “fiber-optic cable capacity will double in the first nine months of [2001]”); L. Walker, Fiber Optimist Revolution, Amarillo Globe-News (Oct. 15, 2000), http://www.amarillonet.com/stories/101500/ bus_fiberopt.shtml (quoting Dan Schaeffer, Cogent Communications: “Fiber is doubling its capacity to carry data every 10 months.”). 24 Time Warner Telecom’s CEO, Larissa Herda, recently noted that her company was recently able to win a large-customer contract because of their “ability to construct our own fiber facilities into their seven locations in four cities within 30 days.” See Time Warner Telecom Announces Fourth Quarter Results, Conference Call (Feb. 5, 2002). 25 Fiberworks to Light Up Atlanta and Alleviate Atlanta’s Bandwidth Bottleneck, Bus. Wire (Aug. 22, 2000). 26 M. Fuller, Fiberworks to Deploy Carrier-Agnostic All-Optical Local-Access Networks, Lightwave (Nov. 2000). 27 Comments of Yipes Transmission, Inc. at 13, Implementation of the Local Competition Provisions of the Telecommunications Act of 1996, CC Docket No. 96-98 (FCC filed June 11, 2001). 28 A. Lindstrom, Fiber: Part II, America’s Network (Sept. 1, 1998). 29 F.J. Governali, et al., Credit Suisse First Boston Corp., Investext Rpt. No. 2699472, Northeast Optic Network – Company Report at *4 (Sept. 10, 1998). 30 Interview with Robert Manning, CFO, Intermedia Communications, CNBC/Dow Jones (June 25, 1998). 31 See, e.g., E.G. Henderson, Duff & Phelps Credit Rating Co., Investext Rpt. No. 2988183, Telecom Services Update – Industry Report at *7 (Nov. 9, 1999) (XO Communications “establishes a wireless link to buildings first and later builds fiber to the buildings after the company has reached its desired customer penetration rate to justify building.”); Comments of WorldCom, Inc. at i, Amendment of Part 2 of the Commission’s Rules To Allocate Spectrum Below 3 GHz for Mobile and Fixed Services To Support the Introduction of New Advanced Wireless Services, Including Third Generation Wireless Systems, WT Docket No. 00-258 (FCC filed Feb. 22, 2001) (WorldCom has “invested over $1 billion for the rights to use MMDS/ITFS spectrum in 160 markets throughout the United States”); AT&T/TCG Application at 7-8 (“AT&T’s acquisition of TCG holds great promise for the development of facilities- based local competition by taking full advantage of the complementary aspects of AT&T’s long distance and wireless networks and marketing expertise and TCG’s local fiber optic and broadband wireless capabilities and rights-of-way.”).
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cheaply than fiber.32
2. CLECs Are Making Little Use of Unbundled High-Capacity Loops.
Although ILECs have made unbundled high-capacity loops available nationwide, CLECs are purchasing very few such loops. This is a further, strong indication that CLECs are able to serve the vast majority of their high-capacity customers with their own high-capacity facilities.
As shown in Table 2, CLECs have purchased only 72,000 high-capacity loops in the four Bell companies’ regions combined. By comparison, CLECs have purchased approximately three million POTS loops in the BOC regions. See Figure 2. Virtually all of the high-capacity loops that CLECs have purchased are DS-1 loops. See Table 2 & Figure 2. CLECs have purchased only 140 DS-3 loops, and not a single loop above the DS-3 level. See Table 2.
Even the use of DS-1 loops is minuscule when viewed in relation to the number of lines that CLECs serve using their own loop facilities. CLECs have obtained approximately 72,000 unbundled DS-1 loops, while they are serving at least 12.5 million lines (and likely closer to 20 million) using their own loops. See Table 3; see also Table 1, supra.
Table 2. Use of High-Capacity Loop UNEs High-Capacity Loops Purchased by CLECs DS-1 DS-3 OC-3 or Higher Total % of all loops Total % of all loops Total % of all loops Verizon 12,300 1% 60 0.005% 0 0% SBC* 36,500 2% 70 0.004% 0 0% BellSouth 18,600 4% 10 0.003% 0 0% Qwest 4,700 2% 0 0% 0 0% Total 72,000 2% 140 0.004% 0 0% *Does not include Connecticut.
32 See, e.g.,Wall Street Transcript Corp., Investext Rpt. No. 2003080, Analyst Interview: Telecommunications – Industry Report at *4 (Sept. 22, 2000) (“The capital efficiency of fixed wireless technology is attractive relative to the cost of deploying fiber connectivity to customer buildings. . . . fixed wireless technology lowers last-mile capital costs considerably.”) (quoting Trent Spiridellis, Banc of America Telecommunications Analyst); W. Schaff, Taking Stock: No Strings Attached, Information Week (Feb. 22, 1999) (“Nextlink . . . has been concentrating on building fiber-optic connections to large offices and business parks. . . . Nextlink, however, intends to use the wireless system as a way to get to market faster. Once it has established service to a given location, it will build a fiber-optic connection to that location and relocate the radio equipment to another building.”); WinStar Press Release, IDT Corp. Announces the Acquisition of WinStar Communications, Inc. (Dec. 20, 2001) (“WinStar’s fixed wireless technology offers a solid last mile solution and is a great fit with IDT’s long distance services and extensive fiber assets.”).
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Figure 2. Unbundled Loops by Type
3,500,000 3.0 million Qwest 3,000,000 BellSouth 2,500,000 SBC 2,000,000 1,500,000 Verizon 1,000,000 418,000 500,000 72,000 140 0 0 Analog xDSL and ISDN* DS1 DS3 OC-n
*ISDN, HDSL, and IDSL loop volumes for Verizon are included in analog loop data.
Table 3. Use of High-Capacity Loop UNEs vs. Use of Self-Provided Loop CLEC-Provided Loops = E911 Listings – Total Unbundled Loops CLEC-Provided CLEC-Provided State DS-1 Loops Loops State DS-1 Loops Loops Alabama 1,200 116,000 Nevada 320 19,000 Arizona 270 517,000 New Hampshire 540 66,000 Arkansas 1,100 41,000 New Jersey 480 334,000 California 14,000 1,604,000 New Mexico 2 18,000 Colorado 240 571,000 New York 2,600 1,120,000 Delaware 660 12,000 North Carolina 2,600 179,000 Florida 3,900 482,000 North Dakota 50 5,800 Georgia 2,300 509,000 Ohio 1,600 207,000 Idaho 10 32,000 Oklahoma 790 100,000 Illinois 970 908,000 Oregon 1,300 332,000 Indiana 400 141,000 Pennsylvania 3,500 608,000 Iowa 7 45,000 Rhode Island 330 71,000 Kansas 1,500 24,000 South Carolina 1,900 79,000 Kentucky 470 30,000 South Dakota 20 31,000 Louisiana 3,000 103,000 Tennessee 2,900 214,000 Maine 190 (2,300) Texas 9,300 500,000 Maryland 490 256,000 Utah 120 258,000 Massachusetts 1,700 733,000 Vermont 20 4,200 Michigan 1,700 260,000 Virginia 1,100 431,000 Minnesota 620 477,000 Washington 2,000 645,000 Mississippi 390 16,000 Washington, D.C. 100 145,000 Missouri 2,800 145,000 West Virginia 290 (6,000) Montana 30 5,100 Wisconsin 1,600 173,000 Nebraska 5 114,000 Wyoming 1 (250) Total 72,000 12.5 million Data do not include the former GTE service area and Connecticut.
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B. POTS Loops.
Technologies that compete directly against traditional POTS loops are rapidly being deployed across the country. Today, ILECs are losing about as many lines to wireless and cable networks as they are to wireline CLECs.33 The number of lines served by ILECs has declined for the last three years running – a trend never witnessed before in a century of telephone service.34 See Figure 3. And the trend is all the more dramatic given the year-over-year growth that ILECs have historically experienced. See Figure 4.
Figure 3. Access Line Growth (1998 – 2001) +59.8 M 20
+14.6M 15
10
5 +1.42 M 0
Access Lines (in millions) (in Lines Access -2.5M -5 ILEC CLEC Wireless Cable Telephony Sources: Credit Suisse First Boston, JP Morgan H&Q, Kinetic Strategies, and NCTA. See Appendix M.
Figure 4. Decline of BOC Access Lines 200 Trend (based on 1996-1998 average annual growth rate of 4.4%) 195 Actual 190 185 180 175 170 Access Lines (in millions) (in Lines Access 165 1998 1999 2000 2001 Sources: Credit Suisse First Boston; FCC. See Appendix M.
33 See, e.g., R. Chopra, et al., Deutsche Banc Alex. Brown, Competitive Local Exchange Carriers (CLECs) at 9 (Jan. 15, 2002) (estimating that SBC has lost an equal number of lines to CLECs and “technological substitution”); Gartner U.S. Residential Wireline Report at 5 (“A number of key factors contribute to this decline [in ILEC lines]: residential dial tone competition and customer adoption of new modes of communications that effectively displace 100- year-old-telephone technology.”); see also JP Morgan Telecom Services 2001 Report at 41. 34 ILEC end user lines declined from 181 million in December of 1999, to 179 million in June of 2000, to 177 million in December of 2000, and 174 million in June of 2001. See FCC Local Competition Report, Feb. 2002 ed. at Table 1; see also Gartner U.S. Residential Wireline Report at 5 (“With the release of second quarter 2001 financial and operational results, these incumbent providers (Verizon, SBC, BellSouth, Qwest) reported aggregate reductions in the number of residence access lines served within their territories, resulting in a 1.8 percent year-over-year decline and a 0.9 percent quarter-over-quarter sequential decline.”); S. Flannery, et al., Morgan Stanley, Dean Witter, Telecom – Wireline: Telecom Trend Tracker: Defense is Best Strategy at Exh. 2 (Aug. 17, 2001) (Year-over-year, Verizon, SBC and BellSouth had drops in access lines of 0.4 percent, 1.1 percent, and 0.8 percent, respectively, from 2Q00 to 2Q01).
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1. Cable Networks as Substitutes for ILEC Loops.
Congress anticipated the emergence of cable/telephone competition in 1996.35 In its 1999 UNE Remand Order, however, the Commission was not yet ready to conclude that cable offered a viable alternative to ILEC loops, because service was still “largely restricted to residential subscribers, and [cable] generally supports only one-way service, not the two-way communications telephony requires.”36 As of year-end 1998, cable operators offered two-way capabilities to only about 20 percent of all homes (i.e., to no more than 20 percent of the homes that cable served).37
In the past three years, cable operators have added two-way capabilities to almost all of their networks, using a hybrid-coax-fiber (HFC) architecture. See Figure 5. Cable operators now offer two-way capabilities to approximately 77 percent of all homes (approximately 82 percent of homes passed by cable).38 Two-way capabilities are expected to reach 85 percent of all homes by 2004.39 Although they depend on many of the same upgrades to the cable network,40 these two-way capabilities have been implemented as two distinct services – (1) cable telephony, and (2) high-speed cable modem service.
Figure 5. Growth of Cable as a Voice and Data Competitor
1998 2001 2004 (est.)
17 - 21 M
85% 82% 77% 66%
45% 7.5 M 7.4 M
20% 19% 10% 1.5 M 271,000 80,000
U.S. Homes Passed by U.S. Homes Passed by U.S. Homes Passed by Cable Modem Subscribers Cable Telephony Two-Way Service Cable Modem Service Cable Telephony Service* Subscribers * Data on U.S. homes passed by cable telephony in 1998 were unavailable. Sources: See Appendix M.
35 See Senate Conference Report 104-230, Telecommunications Act of 1996 at 148, 104th Congress, 2nd Session (Feb. 1, 1996). 36 UNE Remand Order ¶ 189. 37 See UNE Fact Report at III-20 & n.54. 38 See Broadband 2001 at Table 6. 39 See id. 40 See NCTA Cable Telephony Report at 1 (“[T]he same upgrades that allow cable companies to offer high- speed Internet access and digital cable service help make it possible for cable to provide high-quality digital telephone service.”).
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As discussed in Section II.A.2, at least five cable operators have actually deployed commercial circuit-switched cable telephony. These cable operators currently offer circuit- switched telephony services to about 10 million U.S. homes – approximately 10 percent of all homes – in 20 states.41 In some states, cable telephony is far more widely available than that.42 For example, Cox offers service to nearly all of the one million homes in Rhode Island, and AT&T offers cable telephony services to a large and increasing share of the nearly three million homes its cable network passes in the Boston Area, the approximately 600,000 homes it passes in the Pittsburgh area, the 3.5 million homes it passes in the Chicago area, and the 2.7 million homes it passes in the Bay Area.43
Nationwide, more than 1.5 million homes currently subscribe to cable telephony,44 and 70,000 new subscribers are being added every month.45 There are currently two major cable operators – AT&T and Cox – that are actively deploying circuit-switched cable telephony throughout their cable systems.46 And as a result of its proposed merger with AT&T, Comcast plans soon to deploy cable telephony to about one million homes.47
With HFC in place,48 cable plant can be adapted to provide bare bones switched phone service for about $800 to $825 per line.49 This is the cost for providing “primary line” telephone
41 See JP Morgan Cable Industry Report at Table 22; NCTA Cable Telephony Report at 2. 42 See, e.g., Rhode Island Order ¶ 105 (“Cox has the capability to provide cable telephony service to 75 to 95 percent of Rhode Island customers.”). 43 See Section II.A.2, notes 37-39. 44 See NCTA, US Cable Telephony Subscribers (in Thousands): 1998-2001, http://www.ncta.com/ industry_overview/indStats.cfm?statID=13. 45 See NCTA Cable Telephony Report at 1. 46 See Section II.A.2, notes 37-39. 47 See Applications and Public Interest Statement of AT&T Corp. and Comcast Corporation at 38, Application for Consent to the Transfer of Control of Licenses, Comcast Corporation and AT&T Corp., Transferors, to AT&T Comcast Corporation, Transferee, MB Docket No. 02-70 (FCC filed Feb. 28, 2002) (“Comcast President (and AT&T Comcast CEO) Brian L. Roberts has announced that the merged company intends to begin to deploy telephone service in the Philadelphia and Detroit markets currently served by Comcast, after closing, bringing facilities-based local telephone choice to about one million additional homes.”). 48 Broadband 2001 at 39 (“In addition to high-speed Internet and other high-bandwidth applications, new HFC networks can support telephony service over the cable plant.”). 49 See, e.g., JP Morgan Cable Industry Report at 51-52 (about $375 per line for the actual equipment, another $125-$150 for the labor, and $300 for customer premises equipment); AT&T Broadband, Investor Presentation at 37 (July 2001) ($825 per line); NCTA Cable Telephony Report at 10 (“Cox, which has installed 11 switches in its largest markets, estimates its switching costs at $105 per customer (assuming a penetration rate of 25 per cent of homes passed and an average take-rate of 1.5 lines per customer). In addition, Cox spends and additional $505 per customer for the Network Interface Unit (NIU), the drop, the tap and the Headend Interface Terminal (HIT). This combined variable cost of $610 per customer for the provision of local telephony is in addition to the $220 per home passed that Cox must invest to upgrade its cable plant to 750 MHz capacity and to introduce two-way interactivity. It also does not include the $100 per customer that Cox is investing to power its cable networks to ensure that telephone service continues in the event of a power failure.”).
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service.50 Cable telephony systems use the same, commercial, circuit switches and perform all the same functions as ILEC POTS services.
The imminent deployment of IP cable telephony will further accelerate the availability of cable networks as a competitive substitute for ILEC voice loops. As described in Section II.B, each of the major cable operators is now conducting trials of IP cable telephony, or has indicated plans to do so. Commercial deployment of the service as a secondary-line service is expected to begin within the next year or so;51 there are expected to be between five and seven million cable IP telephony subscribers by 2006.52 Cable operators are expected to deploy primary-line IP cable telephony service shortly thereafter.53
Cable operators also provides high-speed Internet access services, which compete directly with ILEC loops that have been used mainly for connecting to the Internet. In the past, many customers bought second phone lines for their computers, to support dial-up Internet connection. Second-line usage peaked in 1999, when approximately 27.5 percent of all households were buying second lines,54 which they used mainly as dedicated data lines.55
Many of those same households are now buying broadband connections instead, and about two out of three of those connections are over cable.56 As of year-end 1998, cable modem service was available to approximately 20 million homes, or roughly 20 percent of the U.S. mass market,57 and there were approximately 500,000 cable modem subscribers.58 Today, the service
50 See, Broadband 2001 at 40; see also AT&T Broadband, Investor Presentation at 35 (July 2001) (“Primary line creates maximum market opportunity: 5-10X greater voice revenue per customer; 7-8X greater cash flow per customer; Less than 10% additional upgrade and rebuild capital required.”). 51 See, e.g., R.A. Bilotti, Morgan Stanley, Dean Witter, Investext Rpt No. 8202634, Cable: The Past Is Prologue to the Future – Industry Report at *5 (Oct. 5, 2001) (“We expect the cable operators to begin offering IP telephony in 2002/2003”); M. Paxton, Senior Analyst, Cahners In-Stat, Cable Telephony – Moving Slowly But Surely, CED (Jan. 2002), http://www.cedmagazine.com/ced/2002/0102/id6.htm (“most [MSOs awaiting IP telephony] remain confident that by late 2002/early 2003, cable telephony will be an important part of their service menu”). 52 See, e.g., Forrester Sizing US Consumer Telecom Report at 10-12 (“[B]y 2006, [cable companies] will reap the rewards of conversion to IP – an increased set of offerings at lowered costs – in the form of 4.8 million new packet lines.); Strategis Group U.S. IP Cable Telephony Report at Table 3.9 (predicting 7.36 million IP telephony lines by 2006). 53 See, e.g., JP Morgan Cable Industry Report at 46 (“we suspect that most MSOs will deploy primary-line IP voice in 2004 or 2005”); Strategis Group U.S. IP Cable Telephony Report at 53 (“The majority of cable telephony subscribers will be lifeline IP users, and deployments are expected to ramp up considerably in 2004 and 2005.”); id. at Table 3.9 (predicting 2.15 million lifeline IP cable telephony customers in 2004). 54 FCC Trends in Telephone Service, Aug. 2001 ed. at Table 8.4 (28.6 million households with second lines in 1999); U.S. Dep’t of Commerce, USA Statistics in Brief (2001) (103.9 million US households in 1999); (28.6 million/103.9 million = 27.5% of homes with second lines). 55 See, e.g., C.J. Lane, Out of Line, Tampa Trib. at 1 (Aug. 13, 2000) (citing Yankee Group study finding that approximately 60 percent of households with second lines use them for Internet access.). 56 Morgan Stanley Cable Modem/xDSL Report at Exh. 3; TeleChoice DSL Deployment Summary. 57 See UNE Fact Report at III-21 & n.61. 58 See NCTA, US Cable Modem Subscribers: 1998-2001, http://www.ncta.com/industry_overview/ indStats.cfm?statID=15.
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is available to between two-thirds and three-quarters of all U.S. homes,59 and approximately 7.5 million homes subscribe.60 One respected analyst now predicts that cable “will capture around 65% of the secondary line market by 2006.”61
2. Mobile Wireless as Substitute for POTS Loops.
At the time of the UNE Remand Order, the Commission concluded that wireless phones did not yet offer a sufficiently robust competitive alternative to ILEC loops to justify any cut back on availability of the loop UNE.62 Wireless service areas were less ubiquitous; they did not offer the same functionality; their data capabilities were “generally inferior;” and their sound quality was not always as good.63 Wireless links offered “promising” but “not yet viable alternatives” to wireline loops.64
As discussed in more detail in Section II.C, conditions have changed significantly since that time. Independent experts now almost uniformly conclude that wireless is a significant competitive substitute for second-line service today.65 For example, IDC found that, as of year- end 2001, “10 million wireline access lines will have been displaced by wireless, primarily by consumers choosing wireless service over installing an additional access line at home.”66 IDC estimates that, by 2005, wireless phones will replace 30 to 35 percent of second and additional wireline access lines.67 Many other independent analysts have reached similar conclusions.68
59See Morgan Stanley Cable Modem/xDSL Report at Exh. 3 (estimating 75 million homes passed by cable modem service as of year-end 2001); JP Morgan Telecom Services 2001 Report at Table 15 (estimating 106.4 million US households as of year-end 2001) (74.92/106.4 = 70.4 percent of US homes passed by cable modem service); see also NCTA Industry Statistics (70 million homes passed by cable modem service as of November 2001); Yankee Group Consumer Broadband Report at 4 (“At year-end 2001, approximately 66% of the households in the United States will have cable modem service available to them.”); Broadband 2001 at Table 6. 60 See Morgan Stanley Cable Modem/xDSL Report at Exh. 3. 61 JP Morgan Cable Industry Report at 53. 62 UNE Remand Order ¶ 188. 63 Id. 64 Id. 65 Wireless service also clearly competes directly, today, against wireline payphone service and other wireline services used outside the home and regular office – hotel phones, for example. See, e.g., Sixth CMRS Report at 32 & n.211; Michael Powell, Chairman, FCC, Question and Answer with Chairman Powell, remarks before the Forrester Research Telecom Forum (May 21, 2001) (“I haven’t picked up the phone in a hotel in five years, because I use my wireless phone.”). 66 IDC Wireless Displacement Report at 1; see also Zacks All-Star Analyst Issues Recommendations for 5 Stocks, PR Newswire (Nov. 15, 2001) (Drake Johnstone, Davenport & Co.: “[C]onsumers are using their wireless phone line as a second phone line.”); T. Fowler, The Low Cost of Going Wireless; More Callers Cut Cords As Cell Phone Rates Fall, Houston Chronicle (Aug. 8, 2001) (“Many [people] are using [wireless phones] as replacements for second lines in their homes.”). 67 See IDC Wireless Displacement Report at Figure 15. 68 See, e.g., Forrester Sizing US Consumer Telecom Report at 9 (“Over the next five years, the mobile business will take a cut at fixed-line revenues. Wireless operators will ravage the fixed-line business as 5.5 million customers give up secondary lines.”); JP Morgan Telecom Services 2001 Report at Table 26 (By 2006, over 2.8 million IV-12
Wireless is now becoming increasingly competitive with primary line wireline services as well. A Yankee Group survey in early 2001 found that about 3 percent of wireless subscribers had now abandoned wireline in favor of wireless entirely.69 A wireless industry association has estimated that the number as of that date “could be as high as 5 percent.”70 A recent USA Today/CNN/Gallup poll found that 18 percent of cell phone users “use cell phones as their primary phones.”71
Many wireless carriers are now marketing their services as direct substitutes for wireline service. The Commission’s Sixth CMRS Report, for example, describes the Cricket service offered by Leap Wireless – a service offered “at a flat rate, paid in advance each month,” in order to be “competitive with traditional landline service.”72 As noted by one industry publication, the Cricket business model “has been successful enough that several regional carriers have started offering their subscribers ‘Leap-alike’ plans,” including ALLTEL’s “Boomerang,” US Unwired’s “Freedom Plan,” and Dobson Cellular’s Cellular One “Breeze” service.73 VoiceStream’s advertisements exhort customers to abandon their wireline phones,74 and the company’s CEO states that they “view wireless as a replacement for wireline.”75
So far as service quality is concerned, wireless is now fully competitive with wireline – and better than competitive in one key respect. In almost all major markets, wireless carriers now offer digital calls with connection quality comparable to the quality of wireline service,76 people will have substituted a wireless phone for a secondary line.); Gartner U.S. Residential Wireline Report at 11 (“Of all households reporting a residence access line replacement over the past six months, 2.3 million or 33 percent of lines were replaced with a cellular/PCS phone.”). 69 Sixth CMRS Report at 32 (citing Yankee Group survey cited in J. Sarles, Wireless Users Hanging Up On Landline Phones, Nashville Bus. J. (Feb. 2, 2001)). 70 Id. at 32, n.207 (citing Consumers Replacing Landline Phones with Wireless, Knight Ridder/Trib. Bus. News (Jan. 10, 2001). 71 M. Kessler, 18% See Cell Phones as Their Main Phones, USA Today (Jan. 31, 2002). 72 Sixth CMRS Report at 33-34; Leap Wireless, Investor Relations, http://www.leapwireless.com/cindex.html. 73 See D. Mendez-Wilson, Cricket Copycats on the Make; ‘Leap-Alike’ Services Hop into Markets Across the Country, Wireless Week at 24 (Aug. 20, 2001). 74 See, e.g., R. Saunders, Don’t Kill the Catalyst for Telecom Competition, Milwaukee Bus. J. (Nov. 16, 2001), http://Milwaukee.bizjournals.com/Milwaukee/stories/2001/11/19/editorial3.html (“VoiceStream Wireless, which provides service in the Milwaukee area, has launched a TV advertising campaign on ways to use your wireless phone for purposes other than conversations with friends and loved ones. One commercial shows a woman using her phone as a meat tenderizer, while another ad suggests that the phone makes a good chew toy for your Labrador retriever. The message is simple: Cellular calling plans are so cheap that you don’t need the local or long-distance phone company anymore.”). 75 E. Mooney, VoiceStream Prepares for Transnational Race for Customers, Radio Comm. Report (Apr. 10, 2000); see also AT&T Wireless and VoiceStream Wireless Petition for Declaratory Ruling at 3, Implementation of the Local Competition Provisions of the Telecommunications Act of 1996, CC Docket No. 96-98 (FCC filed Nov. 19, 2001) (“CMRS providers offer true facilities-based competitive alternatives to incumbent LECs. Increasingly, they are viewed as full-fledged competitors of landline carriers in the provision of telephone exchange service.”). 76 See Telephia, Wireless Network Performance in the U.S. Metro Areas (July 2001) (“A comprehensive study undertaken by Telephia from data collected from November 1999 to April 2001 concluded that ‘wireless customers receive a high level of service in both core and suburban areas . . . Wireless customers on average can place, hold, and complete a call of acceptable audio quality 96-99 percent of the time.’”).
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and in some respects (e.g., operator services) often superior. Nearly 80 percent of wireless customers now subscribe to high-quality digital service;77 dial-up wireline service, by contrast, remains overwhelmingly analog.78 The rate of busy circuits and dropped calls on wireless networks is improving rapidly.79 Wireless E911 location capability is now virtually the same as wireline capability, and it is being rapidly deployed.80 And wireless service is unambiguously superior to wireline in that the wireless phone is mobile. Mobility is, self evidently, a very valuable feature, and one that has historically commanded a high price premium in the market.
Wireless is now price competitive with wireline services, particularly when the comparison is made between equivalent bundles of service. The typical wireline customer purchases not only basic local service, but also long-distance service and some number of value- added features like call waiting, voice mail, or caller ID.81 Wireless carriers typically provide all of these add-on services, and often for no extra charge.82 Taking into account the whole package of service most typically sold, a November 2001 Gartner Dataquest study accordingly concludes that wireless calling prices are already “competitive with, and in some case better than, wireline calling rates.”83 And wireless prices continue to decline rapidly – by as much as 10 to 20 percent a year in recent years.84
77 See, e.g., Dr. Robert F. Roche, CTIA, Measuring Wireless Today, http://wireless.fcc.gov/services/cmrs/ presentations/Bob_Roche_Feb_28_FCC_presentation.pdf (showing approximately 25 million analog subscribers as of June 2001, compared to about 100 million digital subscribers); see also Sixth CMRS Report at 6 (“[A]t the end of 2000, digital customers made up 62 percent of the industry total, up from 51 percent at the end of 1999 and 30 percent two years ago.”). 78 See FCC Statistics of Common Carriers, 2000/2001 ed. at Table 2.3 (162 million analog switched access lines compared to 10 million digital lines). 79 See, e.g., Gartner U.S. Residential Wireline Report at 11 (“It is only over the last year that there has been a measurable shift by consumers to replace their wireline access lines with the cellular/PCS alternative – clearly an indication that cellular/PCS has overcome the quality and reliability weakness in the mind of the consumer.”); AARP, Understanding Consumer Use of Wireless Telephone Service, http://research.aarp.org/consume/ d17328_wireless_1.html. (“Wireless telephones are becoming more popular in the United States as the cost has become more affordable and the quality of wireless service has improved.”). 80 See, e.g., Thomas J. Sugrue, Prepared Testimony before the Subcommittee on Communications, Committee on Commerce, Science, and Transportation, United States Senate, at 6 (Oct. 16, 2001) (“Wireless location technology is available, is being deployed in networks and handsets, and is capable of accurately locating 911 callers.” By October 2002, “the location of 911 calls will be reported in most instances with an accuracy of 100 meters or less. Network equipment and handsets with location capability are now being manufactured and sold to meet and exceed this benchmark.”). 81 See, e.g., JP Morgan Cable Industry Report at 50 (the average voice customer generates approximately $58 in monthly revenues, only $18 of which is for basic local service; the average revenue generated for vertical features is nearly $5, and the average revenue generated in access charges is about $5.50). 82 See, e.g., Sprint PCS, Sprint PCS Wireless Service Plans, http://www1.sprintpcs.com/explore/servicePlans OptionsV2/PlansOptions.jsp (All Sprint PCS service plans include voicemail, call waiting, caller ID, numeric paging, and three way calling.); VoiceStream, Products and Services, Rate Plans, http://www.voicestream.com/products/ services/rateplans/dc_balt.asp (all VoiceStream plans include voicemail, call waiting, caller ID, built-in paging, and conference calling). 83 Gartner U.S. Consumer Telecommunications and Online Market Report at 33. 84 See, e.g., Sixth CMRS Report at 6.
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3. Direct Competitive Overbuild of ILEC Loops.
A number of CLECs are now building their own all-new loop facilities to serve residential customers. The business plans of these CLECs typically involve the provision of service to one small geographic area at a time – anywhere from a single apartment building to a small cluster of homes. They also often involve the deployment of facilities that enable the provision of more than just basic voice service, but video and broadband Internet services as well.
A number of smaller incumbent local exchange carriers have established CLEC affiliates in order to “target RBOC markers that are geographically proximate to their existing ILEC holdings.”85 See Table 4. This geographic “edge-out” strategy enables the CLEC “to take advantage of the synergy of its ILEC and CLEC operations while entering typically underserved non-urban markets.”86 The CLEC may, for example, “leverage the excess capacity on [its] existing plant to reduce startup and entry costs.”87 In many cases, such CLECs will “begin marketing mobile wireless service in new markets before their entry into the competitive market,” so that when they “enter the new wireline markets, customers are already familiar with their reputation and quality of service, providing the [CLEC] with significant competitive advantage.”88
Another overbuild strategy involves the deployment of a broadband pipe (generally either hybrid fiber coax or pure fiber) to provision high-speed bundled service offerings to individual neighborhoods or the approximately 30-35 percent of the population that live in multi-dwelling units. See Table 5.89 Several CLEC affiliates of incumbent LECs – including PennTel and Hickory Tech – have taken this approach.90 This also has been the strategy of RCN, which has been “constructing advanced networks in select markets with high levels of population density and favorable demographics along the West and East Coasts, along with Chicago.” 91 In the fourth quarter of 2001 alone, RCN added nearly 47,000 new subscriber connections (including
85 NPRG CIOC Report 2001, Ch. 2 at 1. 86 Id. 87 Id., Ch. 4 at 1. 88 Id., Ch. 4 at 1-2. 89 See, e.g., Robert Currey, Vice Chairman, RCN Corporation, Prepared Testimony before the Senate Subcommittee on Antitrust, Business Rights, and Competition, Committee on the Judiciary, Cable and Video: Competitive Choices, Federal News Service (Apr. 4, 2001) (“About 30-35 percent of the population lives in multiple dwelling units (MDUs), such as apartments, cooperatives or condominiums.”). 90 NPRG CIOC Report 2001, Ch. 4 at 2. 91 K. Hoexter, Merrill Lynch Capital Markets, Investext Rpt No. 8232380, RCN Corp. – Company Report at *2 (Oct. 24, 2001).
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about 16,000 voice connections) to its network.92 In the approximately four years since it began the process, RCN has built out is network to pass more than 1.5 million homes.93
In addition to overbuilding ILEC networks, some CLECs are pursuing a “greenfield” strategy, which involves deploying facilities in brand-new developments where there is no incumbent provider. For example, in its “Greenfield markets” in Charlotte and Raleigh, CTC deploys “our own remote switching equipment, as well as build a distribution system to in effect, become the local telephone company for each new development.”94 CTC is “working with developers and builders to become the ‘official telecommunications provider’ for their developments.”95 The company states that, “[b]y clustering our projects, we are able to gain capital and service efficiencies.”96 As of September 2001, CTC was “adding about 1,000 CLEC lines a month.”97 Another CLEC – BTI – is targeting new “residential developments,” and was awarded a major contract for a large development in Chapel Hill that includes “three schools, a 500-acre commercial tract and 4,000 homes.”98
Table 4. CLEC Operations of Non-Bell Company ILECs Carriers CLEC Operations ALLTEL “ALLTEL has been successfully utilizing its wireless brand recognition to expand its CLEC operations into areas within its Communications wireless footprint.” “In the markets that have been operational the longest, Little Rock, AR, and Charlotte, NC, the Company has achieved 50% and 8% penetration, respectively.” Blackfoot Tel. Coop. “Blackfoot is anticipating significant growth and is expending $7 million to build out its infrastructure.” CEI Networks “CEI plans to expand service via an edge out strategy once it has fully deployed HFC to its initial markets in 2002.” Century Tel “The Company is currently offering CLEC services to residential and small and medium sized business customers in Shreveport and Monroe, LA. CenturyTel will employ ‘edge-out’ strategy for its CLEC expansion. . . . CenturyTel has budgeted more than $20 million of its 2001 capital expenditures to support this expansion.” CTC Exchange “In 1998, CT Communications began offering CLEC service in markets contiguous to its ILEC market. . . . The CLEC offers Services services similar to those offered by the ILEC by offering facilities based services while leveraging existing back office and billing operations of its parent.” CTC Telcom “CTC Telcom is currently serving over 7,000 CLEC access lines in the communities of Barron, Rice Lake, and Chetek, WI. Each of its CLEC markets is adjacent to its parent company’s ILEC exchanges.” CTS Telecom d/b/a “The Company started offering CLEC services in 1997 to businesses in Battle Creek, Kalamazoo, Galesburg, and Scotts, MI. Climax Tel. Co. The CTS network employs a Lucent 5ESS 2000 switch.”
92 RCN Press Release, RCN Announces Fourth Quarter and Year-End 2001 Results (Feb. 8, 2002); id. (in 4Q01 RCN “added over 43,000 marketable homes to its broadband footprint, and is now selling multiple services to over 1.5 million homes.”). 93 Id. 94 CT Communications, Form 10-K/A at 5 (SEC filed Dec. 19, 2001). 95 Id. at 1; see also J. Engebretson, Edging Out the Incumbent, America’s Network (Sept. 1, 2001) (CTC’s “green-field business had its genesis in a project it did with the Mills Corp., a real estate investment trust that builds shopping malls nationwide. CT won the contract to provide phone service to a new mall Mills was building in BellSouth territory. It now serves every business in the mall. It also has won similar contracts for other new construction projects with Mills and other companies.”). 96 CT Communications, Form 10-K/A at 1 (SEC filed Dec. 19, 2001). 97 J. Engebretson, Edging Out the Incumbent, America’s Network (Sept. 1, 2001). 98 BTI Press Release, Meadowmont Selects BTI as Preferred Telecommunications Provider for Residents (Mar. 31, 2000).
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Table 4. CLEC Operations of Non-Bell Company ILECs Carriers CLEC Operations CTSI Operates CLEC networks in Wilkes-Barre/Scranton/Hazelton; Harrisburg; and Lancaster/Reading/York, PA. “CTSI serves 94% of its access lines by its own switches and 45% of access lines are served solely by the CTSI network.” ExOp of Missouri “ExOp currently offers a variety of services to the population of 5,000 in Kearney, a city just outside of Kansas City, MO.” “Through the partnership with UtiliCorp, ExOp is expanding its fiber network and service offerings. . . into the rural communities that make up UtiliCorp’s energy service territory.” Fidelity Comm. FCS began offering CLEC services in Rolla, MO in March 2001. “FCS is serving business and residential customers in Rolla Services (FCS) from its Lucent 5ESS Class Five switch located in Sullivan, MO.” Goldfield Access “GAN is pursuing an edge-out strategy in offering its services to businesses in nearby communities where the Goldfield name Network (GAN) has brand recognition.” Heart of Iowa “Heart of Iowa began CLEC operations in August 1998. The Company employed an ‘edge-out’ strategy and targeted markets Communications adjacent to those in which it was offering ILEC services. Heart of Iowa is currently serving its CLEC markets from its single Siemens’ EWSD switch.” HickoryTech “The Company used an overbuild strategy, installing its network next to the existing US West network and laying wire directly next to residents’ homes.” “HickoryTech uses a host switch that is owned by its sister company and ILEC, Mankato Citizens Telephone Company. HickoryTech deploys remote switches in the markets it serves.” HTC Communications “HTC began offering CLEC services in 1998. The Company is currently operating its CLEC business in two of its ILEC exchanges, Myrtle Beach and Conway, SC.” Mid-Maine “In 2000, Mid-Maine began operating as a CLEC in several communities in Maine. By the end of the year, the Company had Communications expanded into 12 markets.” “Mid-Maine currently offers local dial tone and DSL to business and residential customers in Auburn, Augusta, Bangor, Brewer, Ellsworth, Lewiston, Portland, and Waterville.” Mid Rivers “Mid-Rivers Communications, offers competitive telephone services to several Tier Three, Four, and Five markets, adjacent Communications to its parent’s ILEC markets, in Montana and a small portion of North Dakota. . . . Mid-River Communications serves its CLEC exchanges from its Siemens EWSD Class Five switch which is installed in Mid-Rivers’ Central Offices located in Glendive, MT.” Nex-Tech The CLEC subsidiary of Rural Telephone in Kansas is “is targeting and capturing new CLEC communities” served by SWBT NTELOS “NTELOS enters markets that are physically proximate to its existing ILEC operations and uses its brand and existing infrastructure to expand into them.” “Wireless is marketed strongly to small and medium-sized business to gain brand recognition and trust. NTELOS later approaches these same customers to offer them CLEC service for their businesses.” Otter Tail “Otter Tail began offering local switched service in January 1999 and currently serves four markets in Minnesota.” Panhandle Telecom. “PTSI began offering CLEC services in Perryton, TX in January 2001 . . . The Company is currently offering competitive Systems services from its Nortel DMS-100 host switch located in Guymon, OK.” Penn Telecom “PTI employs an edge out strategy and has entered markets proximate to the footprint of North Pittsburgh Telephone (d/b/a Penntele.com) Company.” “While PTI has concentrated on small to medium-sized businesses, it is also experimenting with offering its bundled services in the two affluent suburbs of Perrysville and Sewickley.” Sharon Telephone “The Company offers local phone and Internet services from its single Nortel DMS-10 switch in Sharon, WI, to the towns of Company Darien, WI, and Harvard, IL.” Silver Star “Silver Star Communications is currently offering competitive voice and data services in Afton, WY from its single Nortel Communications DMS-10 switch.” TDS Metrocom “TDS Metrocom serves three extended markets in Wisconsin, offering local dial tone, data, and Internet services to both business and residential customers.” Sources: See Appendix M.
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Table 5. Hybrid Fiber Coax (HFC) and Multi-Dwelling Unit (MDU) Providers RCN/Starpower “About 30-35% of the total population lives in multiple dwelling units (MDUs), such as apartments, cooperatives or condominiums. The ability to serve this sector of the market is crucial because it is generally more profitable due to the large number of subscribers in each MDU.” Knology Knology began operating in Montgomery, Ala., and targets towns with between 100,000 and 300,000 homes, including Augusta, Columbus, and West Point, Ga.; Huntsville and Montgomery, Ala.; Charleston, S.C.; and Panama City, Fla., and Knoxville, Tenn. Knology’s network now passes 380,000 homes and 142,008 buildings. “Knology gained more than 30,000 MDU clients [in 2000] alone, a 27% increase from 1999.” MultiBand (Vicom) “MultiBand . . . delivers local dial tone, long distance, satellite based digital cable television, and high speed internet services on one combined billing and delivery platform to residents of multi- dwelling properties.” Grande Communications “Grande is building an advanced deep fiber broadband network that will deliver high-speed Internet, local and long-distance telephone and cable television service to homes, MDUs and businesses in the Austin/San Antonio corridor.” “Grande’s entire MDU portfolio . . . represents over 8,000 units.” Sources: See Appendix M.
C. Broadband Loops.
Broadband services are provided over the telephone network using digital subscriber line (DSL) technology, which relies on the same local loop plant used to provide narrowband voice service.
DSL over ILEC loops is only one of four main last-mile technologies that is currently used to provide broadband services to mass-market consumers. The other three are cable modem, satellite, and fixed terrestrial wireless. Both consumers and providers view all four of these various broadband services as interchangeable. Two or more of the main broadband technologies are frequently available in the same geographic areas.
Cable is the clear leader in the broadband market today, by a wide and growing margin. Cable modem service is currently available to between two-thirds and three-quarters of U.S. households,99 whereas DSL service is available to only about 45-50 percent.100 See Table 6. As of the year-end 2001, there were approximately 7.5 million cable modem subscribers in the U.S., compared to 3.3 million residential DSL subscribers.101 See Figure 6. According to analysts,
99 See Yankee Group Critical Mass Report at Exh. 4; Broadband 2001 at Table 6. See also NCTA Industry Statistics (as of November 2001, 70 million households were passed by cable modem service). The cable industry association estimates that, by year-end 2002, approximately 95 million U.S. homes (or nearly 90 percent of homes passed by cable) will have access to cable modem service. See NCTA, Cable & Telecommunications Industry Overview 2001 at Chart 2 (2001) (citing Morgan Stanley, Dean Witter, Broadband Cable Second-Quarter Review at 9 (Aug. 29, 2001)). 100 See, e.g., Yankee Group Critical Mass Report at Exh. 4 (estimating that DSL will be available to 45 percent of all households by year-end 2001); JP Morgan Cable Industry Report at Figures 12 & 36 (DSL available to 43 percent of U.S. homes as of 1Q2001); P. Roche, DSL Will Win Where It Matters, McKinsey Quarterly 2001, No. 1 (2001) (“40 percent of all phone lines are ready for DSL”). 101 See Morgan Stanley Cable Modem/xDSL Report at Exh. 3 (cable modem); TeleChoice DSL Deployment Summary (residential DSL).
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approximately one-third of all U.S. households currently have access to both cable modem and DSL service,102 and approximately three-quarters of all homes with access to DSL also have access to cable modem service.103
Table 6. Availability of Broadband Services 2001 2002 2003 2004 2005 Cable Modem McKinsey & Co. /JP Morgan 77% 81% 84% 85% 87% Yankee Group 66% 77% 81% 82% 83% DSL McKinsey & Co./JP Morgan 51% 60% 64% 70% n/a Yankee Group 45% 54% 62% 70% 74% Satellite 50 states, covering over 90% of U.S. households Fixed Wireless 3% n/a n/a n/a 41% Sources: See Appendix M.
Figure 6. Market Share of Residential Broadband Subscribers YE 2001 Other* 1%
DSL 30%
Cable Modem 69%
*Satellite and fixed wireless. Sources: Salomon Smith Barney, Morgan Stanley, Dean Witter, and TeleChoice. See Appendix M.
Cable is adding new subscribers at a faster rate than competing high-speed technologies. See Figure 7. And most analysts expect cable to maintain a considerable lead over DSL and other broadband technologies for the foreseeable future.104 The principal reason is simply that
102 See, e.g., JP Morgan Cable Industry Report at Figures 12 & 36; Broadband 2001 at Chart 25. 103 See, e.g., JP Morgan Cable Industry Report at Figures 12 & 36 (JP Morgan estimates that as of 1Q 2001, 10 percent of households had access to DSL only, and 33 percent had a choice of DSL or cable; therefore, approximately one-quarter of households with access to DSL did not have access to cable (10/43=23.3)). 104 See, e.g., Broadband 2001 at Table 9 (estimating that by 2005, cable will have 51 percent of broadband subscribers, while DSL will have 37 percent.); Yankee Group Consumer Broadband Report at Chart 1 (predicting that by 2005, cable will have 48.5 percent of high-speed users, while DSL will have 33.8 percent); Salomon Smith Barney Battle for High-Speed Data Report at 1 (cable will account for 59 percent of subscribers and DSL will account for 34 percent in 2005); M. Pastore, High Speed Access to Pass Dial-Up in 2005, Cyberatlas (Jan. 22, 2001), http://cyberatlas.internet.com/markets/broadband/article/0,1323,10099_567101,00.html (citing Strategis Group Study IV-19
cable modem service is more widely available than DSL.105 While analysts expect the gap between cable and DSL to narrow somewhat, it is expected that by 2005, cable will still reach 12 to 15 percent more homes than DSL will reach by that time. See Table 6.106
Figure 7. Market Share of New Residential Broadband Subscribers Cable Modem DSL Other*
100% 0% 2% 1% 0% 3% 2% 2% 2%
90% 26% 30% 27% 80% 37% 34% 39% 31% 31% 70% 60% 50%
40% 74% 68% 67% 71% 30% 61% 66% 61% 66% 20% 10% 0% 1Q 2000 2Q 2000 3Q 2000 4Q 2000 1Q 2001 2Q 2001 3Q 2001 4Q 2001
*Satellite and fixed wireless. Sources: Salomon Smith Barney, FCC, Kinetic Strategies, Morgan Stanley Dean Witter, and TeleChoice. See Appendix M.
Cable’s advantage is that all cable plant is upgradeable; a significant fraction of the existing telephone plant is not. DSL is provided over the existing local telephone network by connecting digital modems over copper loops to the central office, and then ensuring that those loops are free from various electronics (e.g., load coils) that are needed for voice service but that inhibit the provision of data services.107 DSL service can be provided at high speeds only on loops that are 18,000 feet or shorter,108 which means that “only about two-thirds of U.S. homes are easily addressable for xDSL.”109 And even with respect to the homes that can be upgraded,
which finds that, in 2005, 45 percent of high speed subscribers will go with cable and 40 percent will go with DSL.); TeleChoice Sees Slower But Still Substantial Growth in DSL, xDSL.com (Aug. 13, 2001), http://www.xdsl.com/ content/tcarticles/wp081101.asp. 105 See, e.g., JP Morgan Cable Industry Report at 36 (“Assuming that each platform takes 50% share in markets where both services are available, cable enjoys a more than 2:1 advantage in what each platform’s “natural” market share would be, holding all other variables – price, performance, bundling benefits – constant.”). 106 See, e.g., Yankee Group Critical Mass Report at Exh. 4 (cable modem service is expected to be available to 83 percent of households by 2005, while DSL service is expected to be available to 74 percent of households.); Broadband 2001 at Chart 32 (projecting that about 70 percent of households will have both cable modem and DSL service available by 2005). 107 There are two main variations of DSL: asymmetric (ADSL), which has a higher downstream than upstream transmission rate; and symmetric (SDSL), which offers an equal downstream and upstream rate. ADSL is the most common form of DSL, and is used most often with residential customers, whereas SDSL is used primarily for business customers. See Second Advanced Services Report ¶¶ 36-37. 108 See, e.g., A. Gilroy & L. Kruger, Broadband Internet Access: Background and Issues, Congressional Research Service – Policy Papers (May 18, 2001); D. Sweeney, Ultra Long-Reach DSL : A Whole New Crop of Companies Aims To Boost DSL Performance, America’s Network (Sept. 15, 2001). 109 Broadband 2001 at 40.
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cable has lower upgrade costs than DSL.110 This means “that relative to its telco competitors, [cable] has the retail pricing power to under-price competitors while preserving an attractive return.”111
The two wireless broadband services widely deployed today are broadband provisioned via satellite and terrestrial fixed wireless broadband (MMDS). Broadband satellite services are provided using the same constellation of Direct Broadcast Satellites (DBS) that currently provide video services to more than 17 million subscribers.112 DBS companies have, in the last year, deployed a two-way high-speed Internet service capable of competing on equal footing with cable modems and digital subscriber lines.113 The main fixed wireless services provided to residential customers use Multichannel Multipoint Distribution System (MMDS), which uses spectrum in the 2 GHz band.114 WorldCom and Sprint “own most MMDS spectrum in the United States,” and “have commercially deployed MMDS in a handful of markets.”115 WorldCom has recently stepped up efforts to deploy MMDS service, and has begun offering service in four new markets since the beginning of 2002.116
Subscribership numbers for broadband satellite remain low: there are an estimated 200,000 subscribers to two-way satellite and fixed wireless broadband services as of year-end 2001.117 But analysts project that these totals will soon begin to rise rapidly.118 Whereas
110 See, e.g., Broadband 2001 at 69 (“xDSL starts life at a much higher cost point (close to $800) than cable modem (about $470) primarily because cable makes use of shared head-end terminating equipment, whereas DSL requires dedicated line cards for each subscriber.”). 111 Bear Stearns Byte Fight! Report at 82. 112 See Eighth Video Competition Report, App. C at Table C-1; SkyReport, National DTH Counts: November 2000 – November 2001, http://www.skyreport.com/dth_us.htm. 113 Broadband 2001 at 45 (a “true advantage” satellite data services have over wireline alternatives is “instant near-ubiquity”). 114 See Broadband 2001 at 131. 115 Broadband 2001 at 47. In October 2001, Sprint announced the end of customer acquisition for MMDS services, and a freeze on the number of MMDS markets served “until substantial progress is made on second- generation MMDS technology. The current MMDS customer base will be maintained, as will all video services offered through the fixed wireless spectrum.” Sprint Press Release, Sprint to Terminate ION Efforts (Oct. 17, 2001). 116 See WorldCom Press Release, WorldCom Launches New High-Speed, Fixed-Wireless Service in Lafayette (Feb. 21, 2002); WorldCom Press Release, WorldCom Launches New High-Speed, Fixed-Wireless Service in Pensacola (Feb. 20, 2002); WorldCom Press Release, WorldCom Launches New High-Speed, Fixed-Wireless Service in Springfield (Jan. 9, 2002); WorldCom Press Release, WorldCom Launches New High-Speed, Fixed-Wireless Service in Hartford (Jan. 8, 2002). 117 See Yankee Group Fiber and Fixed Wireless Report; Echostar Hopes New Plan Will Boost Deal’s Chances, Communications Daily at 3 (Feb. 27, 2002). 118 See, e.g., Yankee Group Consumer Broadband Report at 4 & Exh. 1 (“[S]atellite broadband will reach 300,000 households in the United States by the end of this year and grow to 4.5 million households by the end of 2005 . . . this will translate into a market share jump from 2.81% at the end of 2001, to 14.48% at the end of 2005.”); Broadband 2001 at Table 9 (estimates show satellite market share expanding from 1 percent in 2000 to 10 percent in 2005); Business Communications Company, Inc. Press Release, Market for Broadband Internet Access Continue to Soar (Nov. 1, 2001) (“Two-way satellite broadband Internet access will be the fastest growing single-access technology, with expenditures growing at an AAGR of 36.6% from $ 1.14 billion (or 12.8% of all broadband related expenditures) to $ 5.42 billion, or 20.5% of expenditures.”).
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wireline services generally get rolled out incrementally, wireless services tend to get “turned on” for an entire geographic area in a single step. Wireless, by its nature, generally provides complete geographic coverage in a region – or, in the case of satellite service – the entire country. That wireless providers currently lag behind wireline providers in serving broadband customers reflects the none-to-all dynamic of wireless roll out, more than anything else.
Several companies also plan to offer residential broadband services using unlicensed spectrum bands, including the 2.45 GHz Industrial-Scientific-Medical (ISM) band and the 5.8 GHz Unlicensed National Information Infrastructure (UNII) band.119 As noted above, WorldCom has recently accelerated its efforts to deploy MMDS service. Customers within “35 miles of a centrally located transmittal tower” can obtain “high-speed broadband Internet access in as little as five to ten days.”120 The Commission’s staff found that the “MDS industry has invested several billion dollars to develop the band for fixed wireless data systems,” and that “these systems will provide a significant opportunity for further competition with cable and digital subscriber line (DSL) services.”121
Competitors are supplying last-mile broadband connections to small business customers, as well as residential customers. Cable operators are beginning to extend their cable networks to provide high-capacity loops to serve small and medium-sized business customers. This push is being driven by the advent of next-generation Voice-over-Internet-protocol technology, which has “solved” “previous difficulties such as [Quality of Service] problems, incompatible and incomplete standards, and lack of equipment.”122 Today, “[b]usiness trials of [Fiber to the Business] are underway . . . with deployment expected this spring.”123 Numerous cable operators already have realized that there are many businesses that lie in close proximity to their networks, and that it makes sense to build out their networks incrementally to serve them.124
119 See Broadband 2001 at 49 (“A host of small start-ups are deploying some limited services over unlicensed bands, and some larger providers are running unlicensed spectrum trials.”); S. Buckley, MMDS Hits the Airwaves, Telecommunications Magazine (Feb. 2001) (“IGI Consulting predicts that by 2005, there will be at least 1000 unlicensed wireless ISPs in operation and 1.3 million subscribers. . . . Unlike licensed MMDS holders that are restricted by the FCC’s stringent rules, unlicensed carriers such as Clearwire, Fuzion Wireless and PSInet can set up shop immediately.”). 120 WorldCom Press Release, WorldCom Launches New High-Speed, Fixed Wireless Internet Service in Springfield (Jan. 9, 2002). 121 Carroll McHenry, Chairman and CEO, Nucentrix Broadband Networks, Third Generation Wireless, remarks before the Senate Subcommittee on Communications, Committee on Commerce, Science and Transportation, Washington, D.C. (July 31, 2001) (citing FCC “Final Report” at 13). Fixed wireless operators offer consumer broadband services which are priced comparatively to terrestrial broadband services, such as cable modems and DSL. See, e.g., E. Tahmincioglu, For High-Speed Access to the Web, a Dish-to-Dish Route, N.Y. Times (Oct. 11, 2001) (“The fixed-wireless connection…costs $40 to $60 a month, depending on the provider. Installation and equipment can total around $300 but some companies waive the fees.”). 122 TIA Press Release, Cable’s Fiber to the Business Deployment Spurred by VOIP (Feb. 14, 2002). 123 Id. 124 See, e.g., G. Lawyer and C. Wolter, The Cable Giant Stirs, Sounding Board Magazine (Dec. 1, 2001), http://www.soundingboardmag.com/articles/1c1vox.html (quoting Geoff Tudor, president and CEO, Advent Networks: “Cox realized there were 300,000 small businesses within 50 feet of their coaxial drops, easily reachable. . . That could greatly expand the network’s revenue-generation potential.”); C. Weinschenk, Cable Makes Advances Into CLECs’ IV-22
Satellite providers have designed service offerings specifically targeted at small business customers. For example, Hughes offers DirecWay service, which is a “business edition Internet access” service that gives “small business[es] access to the same advanced technology that powers global enterprises.”125 The DirecWay service gives business customers the option of much higher throughput and downstream bandwidth than is available with Hughes’s basic consumer offering.126 WorldCom has announced that it would be reselling Hughes’s DirecWay Service to small- and medium-sized business customers beginning in January 2002, and rebranding that service with WorldCom’s name.127
While the provision of broadband services is undeniably competitive today, the most important competitive opportunity over the longer term centers on the chase for far more bandwidth than existing “broadband” networks currently offer. The upgrading of cable, telephone, and wireless networks will not end in the foreseeable future; appetites for bandwidth continue to grow faster than infrastructure can be built. Cable and telephone companies alike will push fiber deeper and deeper into the local exchange, until it finally reaches the home. Wireless providers will multiply and shrink cells, and boost capacities, to keep pace. Much of this new infrastructure will have little relation to the old. ILECs will accordingly enjoy no particular advantages over competing carriers in deploying this new infrastructure.
Wake, Multichannel News at 18 (Dec. 3, 2001) (Charter likewise has, in addition to over 1,300 small and medium-sized business customers, fiber connections to approximately 400 businesses; these 400 businesses serve approximately 4,200 home workers with VPNs); M. Reilly, New Cable Modem Target: Businesses, CityBusiness (May 18, 2001) (Michael Fox, vice president and general manager of Time Warner Cable in Minneapolis, said roughly 50,000 businesses were located within range of the company’s cable service area, though one-third of the businesses already signed up needed some sort of network buildout. However, “[i]t made a lot of sense to expand into the business sector.”). 125 DirecWay, For Small Business, http://www.hns.com/direcway/for_small_business/learn_more/ overview.htm. 126 There are three service plans for business service: Business Basic (500 MB throughput, up to 400 kbps downstream); Business Plus (800 MB throughput, up to 750 kbps downstream); Business Premium (1000 MB throughput, up to 1000 kbps downstream). DirecWay, Business Edition Internet Access, http://www.hns.com/ direcway/for_small_business/learn_more/business_edition.htm. 127 WorldCom’s service will be available in 600 kbps, 800 kbps, or 1 Mbps download speeds, with 128 kbps upload speeds. WorldCom’s service level agreement with Hughes guarantees an upload speed of 128 kbps. J. Wagner, WorldCom Is Now Truly Long Distance, ISP News (Nov. 27, 2001), http://www.internetnews.com/isp-news/article/ 0,,8_929181,00.html.
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V. FACILITIES-BASED COMPETITION VERSUS RESALE
The Commission has affirmed that, “in the long term, the most substantial benefits to consumers will be achieved through facilities-based competition.”1 “Facilities-based competition is the ultimate objective” of the Commission’s competition policy.”2 At the same time, however, the Commission has attempted to craft its unbundling regulations to promote the “rapid introduction of competition in all markets.”3 The Commission’s other stated objective has been to encourage CLECs “to serve the greatest number of consumers as rapidly as possible.”4
Experience since the 1996 Act establishes that facilities-based competition has evolved largely apart from UNE-based forms of competitive entry – and that regulatory policies focused on promoting the indiscriminate use of UNEs advances the short-term appearance of competition over the long-term substance.
The enormous increase in facilities-based competition over the past six years has had very little to do with the availability or use of UNEs. Competitors have instead relied on facilities-based strategies from the outset. They have grown incrementally, establishing a foothold and then expanding core network facilities step by step into new geographic and product markets. Over time, this strategy has delivered robust competition to very significant numbers of both business and mass-market customers.
Overall, however, the current regulatory structure has favored the rapid proliferation of small, under-funded, technically unsophisticated competitors, over the more measured evolution of robust and durable ones. All too often, it has been easier and cheaper for a CLEC to piggy- back on the incumbent’s network permanently rather than build out a network of its own. Such CLECs have attempted to enter local markets very rapidly, on a very large scale, by relying predominantly – and all too often exclusively – on UNEs. The Commission expected these competitors to rely on UNEs only until it “was practical and economically feasible to construct their own networks.”5 But many CLECs have adopted business strategies that center on long- term reliance on UNEs, with no expectation at all of ever building facilities to replace them. A significant number rely on ILEC networks from end-to-end, which they do primarily through the
1 Promotion of Competitive Networks in Local Telecommunications Markets, Notice of Proposed Rulemaking and Notice of Inquiry in WT Docket No. 99-217 and Third Further Notice of Proposed Rulemaking in CC Docket No. 96-98, 14 FCC Rcd 12673, ¶ 4 (1999); see also UNE Remand Order ¶ 110 (“the construction of new local exchange networks” benefits consumers, the Commission has explained, because facilities-based carriers “can exercise greater control over their networks, thereby promoting the availability of new products that differentiate their services in terms of price and quality”); Michael K. Powell, Chairman, FCC, Digital Broadband Migration – Part II at 4 (Oct. 23, 2001), http://www.fcc.gov/Speeches/Powell/2001/spmkp109.pdf (“Facilities-based competition is the ultimate objective” of the Commission’s competition policy.); id. (unbundling policy “should provide incentives for competitors to ultimately offer more of their own facilities”). 2 Michael K. Powell, Chairman, FCC, Digital Broadband Migration – Part II at 4 (Oct. 23, 2001), http://www.fcc.gov/Speeches/Powell/2001/spmkp109.pdf. 3 UNE Remand Order, 15 FCC Rcd at 3705. 4 Id. 5 Id. ¶ 6.
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effective “resale” of ILEC service that is made possible by the unrestricted availability of the UNE Platform.
Many of the CLECs pursuing UNE-centric strategies have failed. Investors have recognized that these CLECs are engaged in highly speculative ventures of regulatory arbitrage, and offer no true value of their own. The UNE-centric CLECs have harmed their facilities-based counterparts, too. Facilities-based CLECs recognize that the unrestricted availability of UNEs priced at a regulator’s estimation of long-term incremental cost can ruin a business making steep capital investments at here-and-now, real-world prices. These facilities-based CLECs view the availability of the full UNE Platform as particularly harmful to facilities based competition. See Table 1.
Table 1. CLECs Opposing the Availability of UNE Platforms Allegiance Telecom, Cablevision Lightpath, Cbeyond Communications, Time Warner Telecom, XO: “[T]he evidence submitted in this proceeding since the UNE Remand Order was released confirms that competition is thriving in markets where the requirement to provide unbundled switching has been removed.” Allegiance Telecom: Expanding “the availability of the UNE-P” “threatens to harm those CLECs that have built their own facilities and do not need to rely on the UNE-P to serve customers.” UNE-P pricing levels “could well be too low,” which “mak[es] it more difficult for efficient, facilities-based [competitive local exchange carriers] to compete.” “[O]nly carriers that make investments in networks and equipment are able to deliver the product, technology and service innovations that provide competitive alternatives to the ILEC.” Choice One: “Choice One’s business experience demonstrates that new entrants can provide service to small business customers . . . without the need to rely on unbundled local switching purchased from an incumbent LEC. . . . We are unaware of any reason why another carrier could not replicate it using unbundled loops and self- deployed switches, even in second and third tier urban markets. The Commission’s rules governing unbundled local switching should reflect this fundamental fact.” TCG (pre AT&T merger): The FCC should “ensure that wholesale competition does not drive out or diminish the development of strong, facilities-based competition.” Sources: See Appendix M.
Based on the first comprehensive study of its kind, one of the Commission’s own economists recently found that “states with lower UNE prices have less facilities-based entry.”6 Other noted economists, scholars, and jurists have reached the same conclusion: unbundling ultimately undermines facilities-based investment.7 If an incumbent carrier aggressively sold its
6 James Eisner, FCC, & Dale Lehman, Fort Lewis College, Regulatory Behavior and Competitive Entry, for presentation at the 14th Annual Western Conference Center for Research in Regulated Industries, at 2 (June 28, 2001). According to its authors, this study does not necessarily represent the views of the FCC itself. 7 AT&T v. Iowa Utils. Bd., 525 U.S. 366, 429 (1999) (Breyer, J., concurring in part and dissenting in part) (“Increased sharing by itself does not automatically mean increased competition. It is in the unshared, not in the shared, portions of the enterprise that meaningful competition would likely emerge. Rules that force firms to share every resource or element of a business would create, not competition, but pervasive regulation, for the regulators, not the marketplace, would set the relevant terms.”); M. Stanton Evans, Last Mile Is the Hardest, Consumers’ Research Magazine (Aug. 1, 2001) (quoting economist Tom Hazlett: “Neither local phone nor cable companies will make the enormous capital investment necessary to expand broadband, he argues, if ‘open access’ rules require them to share the resulting infrastructure with their competitors at below-market rates.”); MCI Restarts Marketing Local Residential Service in N.Y., Comm. Daily (Feb. 4, 1999) (quoting James Cicconi, executive vice president and general counsel, V-2
own services below cost on its own initiative, or even just pared prices down to zero-margin “imaginary network” levels, it would be accused of “predatory pricing” – of attempting to discourage or ruin real competitors that were building competing networks alongside.
The unrestricted availability of UNEs discourages new ILEC investment, too. There is no incentive to invest in risky new infrastructure when the threat of future unbundling mandates directed at those facilities eviscerates the business case for deploying them. As AT&T’s chairman has put it, “[n]o company will invest billions of dollars to become a facilities-based broadband services provider if competitors who have not invested a penny of capital nor taken an ounce of risk can come along and get a free ride on the investments and risks of others.”8
But facilities-based investment is precisely what is needed. As the Commission has recognized, “the widespread deployment of broadband infrastructure has become the central communications policy of the day.”9 This will require “the complete or near-complete replacement of copper lines with end-to-end fiber optic transmission facilities.”10 The existing UNE regime significantly discourages investment in this new infrastructure, by both the facilities-based CLECs, and by the ILECs themselves.
A. Efficient Facilities-Based Entry.
The robust levels of competition now offered by numerous CLECs establish that facilities-based competition is possible. The business strategy that works is to enter by way of high-margin markets and value-added markets: the urban carrier and business markets first targeted by local fiber companies, and the wireless and broadband markets targeted by wireless, cable, and other facilities-based providers of switches and alternative forms of transport. These have been the successful entry points; facilities-based competition for the rest of the market has spread out rapidly from there.
AT&T: “[T]he last thing that government should do is create uncertainty that would have a chilling effect on, and perhaps even retard, these investments.”); A. Wilson, Harmonizing Regulation by Promoting Facilities-Based Competition, 8 Geo. Mason L. Rev. 729 (Summer 2000) (“Regulatory uncertainty casts a pall over capital markets and dries up critical financial support. Communications policymakers must therefore create and sustain a stable regulatory environment if they want to nurture the development of facilities-based competition.”); T. Jorden, J.G. Sidak, and D. Teece, Innovation, Investment, and Unbundling, 17 Yale J. on Reg. 8 (2000) (“It makes no economic sense for the ILEC to invest in technologies that lower its own marginal costs, so long as competitors can achieve the identical cost savings by regulatory fiat.”); 3A Phillip Areeda & Herbert Hovenkamp, Antitrust Law ¶ 771(b), at 175 (1996) (When a company is to “provide [a] facility and regulat[es] the price to competitive levels, then the [prospective entrant’s] incentive to build an alternative facility is destroyed altogether.”); R. Cowles, et al., Gartner Dataquest, UNEs: Stifling U.S. Broadband Growth and Ineffective in Promoting Local Competition at 5 (2002) (UNE policy has resulted in a “near-complete halt to advanced infrastructure investment from the incumbents and newcomers.”). 8 C. Michael Armstrong, Chairman and CEO, AT&T, Telecom and Cable TV: Shared Prospects for the Communications Future, remarks before the Washington Metropolitan Cable Club, Washington, D.C. (Nov. 2, 1998). 9 Appropriate Framework for Broadband Access to the Internet over Wireline Facilities, Notice of Proposed Rulemaking, 17 FCC Rcd 3019, ¶ 1 (2002). 10 Id.; see also R. Cowles, et al., Gartner Dataquest, UNEs: Stifling U.S. Broadband Growth and Ineffective in Promoting Local Competition at 8 (2002) (“There is general recognition within the communications and information industry that fiber will ultimately be the most efficient and flexible end-to-end infrastructure”).
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1. Incremental Development of Facilities-Based Competition.
As demonstrated in Section I, the CLEC industry as a whole remains healthy. The most successful individual CLECs are those that have pursued a strategy of facilities-based entry. Their common business strategy has been to deploy facilities to serve high-margin markets first, then build out from there, to extend their competitive reach incrementally, into new service sectors and new geographic markets.
None of the successful competitors has emphasized factors that the Commission has at times deemed important – factors such as “ubiquity,” or “rapid[]” entry to serve “the greatest number of customers.”11 None of the successful competitors has viewed ubiquitous service or instant roll-out as competitively necessary. None has proceeded on the assumption that the evolution of its business required the very rapid development of a very large footprint. To the contrary, they have prospered by emphasizing just the opposite, at the outset: smaller operations, carefully targeted at the most profitable geographic and service sectors.12 Much broader competition has then evolved relentlessly from these facilities-based beachheads. And it has now reached the point where it is developing very rapidly indeed.
Switching. As discussed in Section II, competitive switches were first deployed by large business customers and then by competitive-access providers. This base of competitive switching capacity has since evolved, market by market, to serve smaller business customers and, most recently, residential subscribers. Adding customers and traffic at the margin has grown progressively cheaper. A switch deployed initially to serve the single large customer at a single point then serves a number of smaller customers, and then becomes part of larger network, serving additional, smaller, more widely dispersed sources of traffic.
Packet switching services have evolved in similar fashion. High-speed ATM and frame relay switches are deployed first to provide high-margin broadband data services. E-mail and messaging then begin to substitute, at the margin, for voice calls. Then two-way voice traffic migrates on to these packet switches.
As discussed in Section II, this evolutionary process is now robustly established, and the business model is well understood and mature. There are large numbers of competitive circuit switches in actual service. They can and do serve both large business and mass-market customers. Their geographic reach can be extended with trunks to remotes, and frequently is. Packet switches are multiplying even faster, and packet-switched traffic is now making very substantial in-roads into service areas traditionally served by circuit switches.
Fiber, Transport, and High-Capacity Loops. Competition has evolved in a similar fashion in the markets for transport and high-capacity loops. The interoffice transport and local
11 UNE Remand Order ¶ 107. 12 See, e.g., Time Warner Telecom, Company Growth, http://www.twtelecom.com/cgrowth.html (“growth plans focus on geographic expansion, extension into new market segments and development of new data and Internet- based products and services.”); V. Bajaj, Allegiance Will Borrow $ 350 Million to Invest, Dallas Morning News (Sept. 19, 2001) (Allegiance has “pursued a more deliberate and slower national expansion than most of its competitors.”); Royce Holland, The Top Enterpreneurs, Bus. Week (Jan. 14, 2002) (While its “rivals took on mountains of debt, the chief executive of Allegiance Telecom played it safe, borrowing little and expanding slowly.”).
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loop UNEs are both wireline facilities that transmit information between two fixed points. Here again, the early competitors first targeted a small number of high-margin opportunities, then built out from there. In the mid-1980s, “competitive access providers” ran their networks to the very largest customers in the largest geographic markets – long-distance carriers in the densest urban areas. Then, year by year, the CAPs extended both their networks and their businesses, to serve business customers, and less densely populated areas. Again, this process has matured; there are now extensive networks in place in all major urban markets.
Once a fiber network is deployed and the investment sunk, the facilities can be used to serve other on-net customers, including many whose traffic volumes would never have justified the original deployment of the network. Similarly, networks can be economically extended block by block, to points that would never have been economical to reach mile by mile. When they deploy fiber, carriers invariably deploy far more capacity than they can use immediately, to facilitate precisely this process of incremental future development.
This process of competitive evolution is now accelerating rapidly, for two reasons. Extensive competitive networks are already in place; the marginal cost of extending them to pick up new customers is far lower, now, than it was at the outset. And surging volumes of data traffic make the deployment of competitive fiber increasingly economical, for an ever-expanding base of potential customers. CLECs now routinely offer service to many business customers that are not already served by their fiber networks; the CLEC will extend its network one spur or branch at a time, to pick up the new traffic.
Narrowband Loops. Wireless has emerged as a serious competitor to the narrowband ILEC loop through a similar, at-the-margin process of upgrading the network and capturing economies of scope and scale. Wireless began as a high-priced service for the handful of high- end customers willing to pay a high premium for a mobile loop. Over time, wireless operators were able to begin competing for a greater segment of customers willing to pay for mobility. As they have built out their networks, wireless carriers have begun to compete directly for virtually all second-line loops, and for an increasing share of primary-line loops as well.
Cable, which offers not one but two important alternatives to the ILEC loop, has evolved as competitive alternative in a similar way. Coaxial cable networks were originally deployed to offer video. With these networks in place, a number of cable operators found it economical to add circuit-switched voice telephony and high-speed data capabilities. Cable now competes directly against ILEC loop for the last-mile transport of packet-switched data traffic, which now accounts for substantially more than half of all telecom traffic. And in many areas, cable competes directly with ILECs for primary line voice service as well.
Broadband. A broadband link to the packet-switched network provides a connection to all other Internet users, whether linked through telephone lines, cable modems, land-based wireless connections, or satellite connections. In the past three years, cable operators have completed outfitting the vast majority of their networks with two-way capabilities. Almost all cable operators are now rapidly deploying high-speed data capabilities. The costs of upgrading cable plant have been falling steadily, and cable operators have captured very significant economies of scope in deploying digital platforms that can be used for digital television and high-speed data, as well as packet-switched voice.
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Much of the new broadband infrastructure has had little relation to the old. Fiber has replaced copper in the loop; packet switches have replaced circuit switches in the central office; and the transport between these packet switches has used very different routes than the rigid point-to-point connections between central offices. In deploying this new infrastructure, ILECs have thus enjoyed no particular advantages over competing carriers.
2. Economies of Scope and Scale.
In the UNE Remand Order, the Commission found that, “[b]ecause competitors do not yet enjoy the same economies of scale, scope and ubiquity as the incumbent, they may be impaired if they do not have access, at least initially, to certain network elements supplied by the incumbent LEC.”13 As discussed above, however, the assumption that immediate scale and scope economies are essential to competitive success is not borne out by actual experience in the marketplace. The successful competitors have started out with high-margin business strategies, not high-volume strategies, and expanded incrementally from there. The economies of scope and scale have followed, not led, the competitive process.
With that said, incremental growth has now culminated in a significant number of CLECs that enjoy very significant economies of scale. As Table 2 indicates, the twenty largest CLECs today have 100 percent more switches, 190 percent more fiber-route miles, and earn 150 percent more in total revenues than the twenty largest CLECs at the time of the UNE Remand Order. See Table 2.
13 UNE Remand Order ¶ 14.
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Table 2. Twenty Largest CLECs (by Revenues): 1998 vs. 2001 1998 2001 CLEC Revenues Circuit Fiber CLEC Revenues Circuit Fiber ($millions) Switches Route ($millions) Switches Route Miles Miles AT&T $7,451 88 11,400 WorldCom $16,716 120 n/a WorldCom $4,894 104 8,811 AT&T $16,000 246 16,000 Intermedia $713 31 839 McLeodUSA $1,800 34 31,000 McLeodUSA $604 4 7,120 XO $1,180 39 20,661 ICG $398 9 4,242 Time Warner Telecom $775 38 15,249 General Comm. $247 3 200 Allegiance $545 26 5,000 RCN $245 2 1,400 RCN $520 10 9,030 BTI Telecom $213 n/a 110 ICG $480 35 5,500 ITC^DeltaCom $172 n/a 7,800 Adelphia $475 28 19,186 ALLTEL $167 5 0 KMC Telecom $450 33 2,336 GST Telecom $163 20 6,632 Network Plus $410 3 n/a e.spire $157 18 1,742 ITC^DeltaCom $400 42 9,980 Global Crossing $153 16 0 e.spire $375 25 3,834 WinStar $141 27 0 Cox $350 13 9,000 NEXTLINK $140 18 2,477 Focal Comm. $345 19 n/a Time Warner Telecom $122 18 6,968 CTC Comm. $336 2 8,300 CapRock Comm. $122 n/a 800 General Comm. $330 3 200 Ionex $114 n/a 1,400 BTI Telecom $320 14 4,400 Network Plus $106 2 0 CoreComm $300 7 n/a Electric Lightwave $101 7 3,091 Global Crossing $260 24 400 Sources: Telcordia, Local Exchange Routing Guide (LERG); New Paradigm Resources Group. See Appendix M.
Switches. At the time of the UNE Remand Order, only 15 CLECs had deployed 10 or more circuit switches, and only 6 had deployed 20 or more. See Figure 1. Today, at least 27 CLECs have deployed 10 or more circuit switches, and at least 16 have deployed 20 or more. See id. The increase in the size of CLEC data networks has been equally dramatic. At the time of the UNE Remand Order, only 20 CLECs had deployed 10 or more packet switches, and only 11 CLECs had deployed 20 or more. Today, at least 27 CLECs have deployed 10 or more packet switches, and at least 23 CLECs have deployed 20 or more. See Figure 2.
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Figure 1. Distribution of CLEC Circuit Switches Total Circuit Switches 1998: 700 151 176 2001: 1,300 20 1998 2001
14
11 10 9
4
Number of CLECs of Number 2 2
0 < 10 Circuit Switches 10-19 Circuit Switches 20-49 Circuit Switches 50+ Circuit Switches
Source: Telcordia, Local Exchange Routing Guide (LERG) . See Appendix M.
Figure 2. Distribution of CLEC Packet Switches Total Packet Switches 1998 2001 1998: 860 35 2001: 1,700 30 30 25 20 20 15 13 9 10 9 10
Number of CLECs of Number 4 5 2 0 < 10 Packet Switches 10-19 Packet Switches 20-29 Packet Switches 30+ Packet Switches
Source: New Paradigm Resources Group. See Appendix M.
Fiber, Transport, and High-Capacity Loops. At the time of the UNE Remand Order, only 18 CLECs had deployed 1,000 or more route miles of local and long-haul fiber, only 11 had deployed 3,000 or more, and only 8 had deployed 5,000 or more. Today, at least 25 CLECs have deployed 1,000 or more route miles, 16 have deployed 3,000 or more, and 14 have deployed 5,000 or more. See Figure 3.
Figure 3. Distribution of CLEC Fiber Total Local and Long-Haul Fiber 1998 2001 1998: 100,000 16 14 2001: 184,000 14 14 12 10 9 8 8 7 6 4 3 Number of CLECs of Number 2 2 2 0 500-999 1,000-2,999 3,000-4,999 5,000+ Route Miles Route Miles Route Miles Route Miles Source: New Paradigm Resources Group. See Appendix M.
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Wireless Alternatives to the Narrowband Loop. At the time of the last UNE review, there were only three “nationwide” mobile telephony operators, as the FCC defines that term.14 Today, there are six nationwide operators.15 At the time of the last UNE review, the ten largest mobile wireless operators had an average of 5.1 million subscribers each. Today, the ten largest mobile operators have an average of 9.4 million subscribers each.16
Broadband Alternatives to the High-Frequency Loop. At the time of the last UNE review, deployment of broadband was still “in the early stages of development.”17 At that time, cable operators had only about 300,000 broadband customers.18 Today, by contrast, cable operators have approximately 7.5 million broadband customers.19
3. Emergence of Competitive Resale Markets.
Across the board, competition has now advanced to the point that competitive wholesale markets are now emerging. The players in these markets are the markets’ own answer to the Commission’s UNE regime – they offer reasonably close analogies to unbundled network elements, at wholesale prices.
As discussed in Section III.C, there has been a dramatic increase in fiber supplied by alternative wholesale suppliers. These players typically sell or lease dark fiber to other carriers, but do not themselves engage in the provision of telecommunications services. They have raised about $2 billion in capital since the third quarter of 2000,20 and analysts expect this market sector to grow rapidly.21 A Web-based trading pit for the urban fiber that they provide now includes over 35 fiber wholesalers listing “over 10,000 local route miles” of fiber22 in more than 60 cities.23 For a growing number of CLECs, the fiber provided by these wholesale suppliers satisfies a large part of their demand for last-mile local connectivity and interoffice transport.
14 See Fourth CMRS Report at 9. 15 See Sixth CMRS Report at 13. 16 Compare Fourth CMRS Report, App. B at Table 4 with Sixth CMRS Report, App. C at Table 3. 17 First Advanced Service Report ¶ 16. 18 See Cable Datacom News, December 1998 Highlights, http://cabledatacomnews.com/dec98/dec98-1.html. 19 See Morgan Stanley Cable Modem/xDSL Report at Exh. 3 (cable modem subscribers as of 4Q 2001). 20 P. Brown, Despite Tighter Purse Strings, Cash Is Still Streaming to Metro Providers, Tele.com (Aug. 13, 2001) (citing Yankee Group and quoting Blake Bath, telecom analyst at Lehman Brothers Equity Research). 21 According to consulting firms Cambridge Strategic Management Partners and McKinsey & Co, “[t]he market for reselling . . . dark fiber to ISPs and telecom carriers is projected to grow from about $2 billion today to about $10 billion by 2006.” See N. Orman, Networking Startups Battle For Cities, Silicon Valley/San Jose Bus. J. (Oct. 26, 2001). 22 D. Mohney, Fiberloops.com – One-stop Shopping, ispworld.com (Aug. 22, 2000). 23 Fiberloops.com, Find Fiber and Facilities Fast, http://www.fiberloops.com/Fiberloops/home.html.
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Resale markets have likewise developed for the provision of wireless services.24 As the Commission has noted, wireless resellers “offer service to consumers by purchasing airtime at wholesale rates from facilities-based providers and reselling it at retail prices.”25 According to the Commission’s Sixth CMRS Report, the top 20 resale providers had just over 3 million subscribers as of year-end 2000, twice as many as they did in 1999.26 Wireless carriers hammered out wholesale contracts among themselves years ago, to cover “roaming”; intercarrier roaming rates have been rapidly declining.27 And wireless carriers enter into wholesale deals with large corporate customers, too.28 At least 20 percent of businesses provide wireless services to their employees through deals they have negotiated with carriers to provide discounted rates for preset call volumes.29
A wholesale/resale market for broadband links is now beginning to emerge as well. GTE and AOL began open access trials in 1999, proving that “[c]able providers can easily and affordably open up their networks for high-speed Internet competition.”30 Many cable companies assert that open access will occur naturally, and that it is in both their best interest and that of consumers.31 And many have already entered into agreements to allow unaffiliated ISPs access to their networks.32
24 Early on, the Commission granted cellular A-side carriers certain rights to resell the B-side (i.e., typically incumbent wireline) carriers’ services, to maintain early competitive parity notwithstanding the head-start that the B- side carriers got in building out their networks. See 47 C.F.R. § 20.12 (b)(3). Those resale rights will expire in November 2002, however. 25 Sixth CMRS Report at 34. 26 Id. at 34-35. 27 See, e.g., Yankee Group State of the Wireless Union Report at 6; M. Berghausen, Morgan Stanley Dean Witter, Investext Rpt No. 8313844, AllTel Corp.: Initiating Coverage – Company Report at *3 (Dec. 21, 2001). 28 See, e.g., H. Smith, Verizon Adds to Telematics Stable with Wingcast Partnership, RCR Wireless News at 2 (Dec. 17, 2001) (The one million-plus users of General Motors’ OnStar service in luxury cars, for example, are in fact served via Verizon Wireless’s network. Verizon Wireless has entered into a similar agreement with Wingcast, a joint venture between Ford Motor Co. and Qualcomm.). 29 See, e.g., M. Hamblen, Wireless Merger a Boon for National Coverage, Computerworld (Sept. 27, 1999). 30 GTE Demonstrates Ease of Cable Open Access to Multiple ISPs; Clearwater Trial Shows One-Time Investment of Less Than $1 Per Home Would Provide Consumer Choice, Bus. Wire (Jan. 14, 1999) (quoting AOL senior vice president George Vradenburg). 31 See, e.g., A. Siedsma, Gov Watch a Question of Access, T Sector (Feb. 1, 2001), http://www.thetsector.com/ showStory.cfm?ts_story_id=838 (Bill Geppert, VP and GM of Cox in San Diego, emphasized the “strong willingness on the part of broadband providers to offer multiple ISPs as part of their platform,” with Cox and other companies “moving in that direction.”); M. Martin, Cable’s Connections, Wash. Bus. J. (Jan. 28, 2000), http://washington.bcentral.com/washington/stories/2000/01/31/focus1.html (George Vradenburg, AOL: “open access promotes consumer choice in high-speed Internet service and will encourage innovation in new Internet applications.”); Statements by C. Michael Armstrong, Chairman and Chief Executive Officer, AT&T Corp., in Telecom Mergers: En Banc Hearing on Telecom Mergers To Discuss Recent Consolidation Activities in the Telecommunications Industry, Focusing on Three of the Proposed Mergers Before the Federal Communications Commission (Oct. 22, 1998) (open access is “[f]irst . . . the right thing to do. Second, it’s in our self-interest. . . . Content is essential to make money in networks. The only way to make money in networks is to have the highest degree of utilization.”). 32 See, e.g., AT&T Broadband Opens to Other ISPs, Associated Press (Mar. 13, 2002); M. Mosquera, Time Warner to Open Cable Network to Earthlink, Internet Week (Nov. 20, 2000), http://www.internetweek.com/story/ V-10
4. Geographic Expansion
The Commission stated in the UNE Remand Order that “markets outside of major metropolitan areas . . . have seen minimal competition.”33 That is no longer the case today. CLECs are now using their facilities to serve markets of all sizes, throughout the country. For example, CLECs have obtained collocation arrangements to serve wire centers that contain more than 80 percent of the access lines in the Bell companies’ regions.34 And CLECs are using their own switches to serve customers in wire centers that contain approximately 86 percent of all lines in the Bell companies’ regions.35
Many CLECs have specifically targeted smaller markets, often precisely because the larger markets have already become saturated with facilities-based competition. Analysts have noted that “[i]n tier 2/3 markets, fundamentals are more favorable primarily due to less available capacity.”36 More than a dozen CLECs have adopted a strategy of specifically serving smaller markets (e.g., Tier II, Tier III, or Tier IV markets). See Table 3. In addition, many CLECs that serve larger markets, have expanded into smaller markets as well.37
INW20001120S0002; R. Mark, Cox Begins Its First Open Access Broadband Trials, Internetnews.com (Nov. 6, 2001), http://www.internetnews.com/isp-news/article/0,,8_917471,00.html. 33 UNE Remand Order ¶ 11. 34 See Section II.A.2, Table 10. 35 See Section II.A.1, Table 5. 36 J.M Ackor, RBC Capital Markets, Investext Rpt No. 8239217, Broadband Services – Bandwidth Pricing Update – Industry Report at *1 (Oct. 29, 2001). 37 See, e.g., S. Weinburg, C. Shobrook, G. Mycio and L. Singleton, Appraising the CLEC Landscape, Xchange Magazine (June 2000), http://www.xchangemag.com/articles/061feat1.html (“The current trend, however, shows that while CLECs are developing a foundation among first-mover small and medium-sized businesses in large markets, there is a trickling downward of services into Tier 2 and 3 markets.”).
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Table 3. Examples of CLECs That Have Specifically Targeted Smaller Markets Advanced TelCom Group Offers “bundled Internet, broadband data, and voice services to small and medium-sized businesses in third and fourth tier markets throughout the U.S.”; targets third and fourth tier cities with populations between 100,000 and 750,000 people and between 50,000 and 200,000 business access lines.” AFN Communications “AFN is targeting underserved markets . . . ‘We think this will clearly give them an opportunity to establish a beachhead. They are targeting a market opportunity that has gone untapped by the current crop of service providers.’” BayRing Communications “BayRing is a regional CLEC offering local, long distance, high-speed Internet service, and dedicated access to businesses in Tier 3 markets in New Hampshire and Maine.” Choice One Communications “Our company currently provides service to clients in 30 second and third-tier markets in eleven states where there are fewer competitors than in larger metropolitan areas.” Cinergy Communications “The focus for Cinergy Communications is toward small businesses in the region of Southern Indiana and Western Kentucky. Cinergy believes it can offer telecom services to areas that otherwise do not have many choices.” Volaris Online “DUROCOM is a full service, facilities-based provider of Internet data and (formerly DUROCOM) broadband communications solutions to consumers and small to medium-sized businesses in tier II and tier III markets in the southeastern United States.” e.spire Communications “e.spire’s establishment of footholds in ‘uncrowded’ Tier 2 and Tier 3 markets represented arguably the company’s most significant competitive advantage,” says Lizet Tirres, research analyst, Stratecast Partners. Crescent Telephone “‘Our proven track record in serving rural and suburban customers ideally positions Crescent Telephone to offer complete telecommunications solutions to markets historically underserved by traditional carriers,’ said Jacob Roquet, GIEX president and CEO, and founder of CoastalNet and Crescent.” KMC Telecom “KMC’s business has two distinct components: serving communications- intensive customers in markets with populations between 100,000 and 750,000, referred to as Tier III markets, which larger carriers have typically overlooked; and providing data services on a nationwide basis.” Knology Although CEO Rodger Johnson “admits his markets aren’t crowded with competitors, he says the idea that second and third tier markets are less competitive is a myth. ‘When you get down to markets with 100,000 [homes], you can’t divide that pie up more than about three ways and make it economically viable,’ he says.” LecStar Communications “LecStar focuses on underserved markets in the south… LecStar believes these secondary cities are relatively underserved.” Lightship Telecom “Lightship Telecom is targeting small to medium-sized businesses in Tier Two and Three markets.” NECLEC “NECLEC offers voice and data services primarily in Tier Two, Three, and Four cities in the Northeast/Mid-Atlantic region.” Sources: See Appendix M.
To be sure, facilities-based competition has inevitably emerged earlier in some markets, and later in others. States with larger concentrations of business customers38 are more attractive
38 The percentage of switched business lines as a percentage of total switched lines in the state varies from as low as 25 percent (in Tennessee) to as high as 69 percent (in Washington, D.C.). See FCC Statistics of Common V-12
to competitors.39 More rural states are more costly to serve.40 Regulatory differences have played a major role too. As noted earlier, some states have imposed wholesale rates on ILECs that artificially suppress the emergence of facilities-based competition.41 Some states opened their local markets to competition before the passage of the 1996 Act, and much earlier than some other states.42 Some states have set retail rates – particularly for residential customers – very low, which also discourages entry.43
B. The Failure of Non Facilities-Based Competition.
Since the last UNE review, many CLECs have attempted to enter local markets very rapidly, on a very large scale, by relying exclusively, or almost so, on UNEs obtained from ILECs. The Commission at one time suggested that these competitors would rely on UNEs only until such time as it “was practical and economically feasible to construct their own networks.”44 Many of these ostensible competitors, however, have adopted business strategies that do not involve deployment of their own facilities at any time in the foreseeable future. Investors have grasped that these business models offer little if any true value to customers. Many of the CLECs pursuing UNE-centric strategies have failed.
Carriers, 2000/2001 ed. at Table 2.4. New York, California, Texas, Illinois, and Ohio are home to the greatest number of Fortune 500 company headquarters – more than 200 companies, collectively. No Fortune 500 company has established its headquarters in 10 states (Alaska, Hawaii, Maine, Montana, New Hampshire, New Mexico, North Dakota, Vermont, West Virginia, and Wyoming). See Fortune 500 List, Cincinnati Enquirer (Apr. 2, 2001), http://enquirer.com/editions/2001/04/02/fin_fortune_500_list.html. 39 See, e.g., FCC, Biennial Regulatory Review 2000 – Staff Report, App. IV, Pt. 54, 15 FCC Rcd 21089, 21266 (2000) (“Competition for business customers in metropolitan areas has, in general, developed more rapidly than competition for residential customers or customers in rural areas.”); FCC Local Competition Report, Dec. 1998 ed. at 2 (“Facilities-based CLECs appear to have concentrated in more urbanized areas.”). 40 Rural populations vary widely between states, from a low of 10.6 percent in New Jersey in 1990, to a high of 67.8 percent in Vermont in 1990. See U.S. Census Bureau, Urban and Rural Population: 1900 to 1990 (Oct. 1995) http://www.census.gov/population/censusdata/urpop0090.txt. Under the FCC’s USF cost model, costs of providing service vary significantly (by as much as 50 percent of more) between highly rural and highly urban states. 41 See, e.g., James Eisner, FCC, & Dale Lehman, Fort Lewis College, Regulatory Behavior and Competitive Entry, for presentation at the 14th Annual Western Conference Center for Research in Regulated Industries, at 2 (June 28, 2001). 42 See, e.g., Implementation of the Local Competition Provisions in the Telecommunications Act of 1996, Notice of Proposed Rulemaking, 11 FCC Rcd 14171, ¶ 5 (1996) (“At the time the 1996 Act was signed, 19 states had in place some rules opening local exchange markets to competition, including seven states in which competing firms had already begun to offer switched local service.”). 43 See Sprint v. FCC, 274 F.3d 549 (D.C. Cir. 2001) (noting that one of the reasons put forward by the FCC’s counsel for low rates of competition in the residential market is that “state commissions have historically set relatively low residential rates . . . allowing the incumbent monopoly to make it up in other aspects of their business.”); R. Cowles, et al., Gartner Dataquest, UNEs: Stifling U.S. Broadband Growth and Ineffective in Promoting Local Competition at 7 (2002) (“Most states have frozen residential basic exchange rates at levels at or below cost. . . . it is the regulators themselves (state regulators and the FCC) that have created this regulatory barrier to competitive entry through a pricing policy that includes subsidy.”). 44 UNE Remand Order ¶ 6.
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1. The Failure of UNE-Platform Competition.
The UNE Platform is “physically similar to resale. In each case, the CLEC uses the ILEC network to provide service to the end-user and essentially limits its own functions to marketing, inputting the order into the ILEC’s systems, and billing.”45 UNE-P requires no incremental investment by a CLEC, but – because of regulatory factors alone – it is generally cheaper than deploying facilities. With the exception of certain vertical features that no more than a few Platform-based CLECs actually provide, end-user customers do not receive any services on any facilities from a UNE-Platform provider that they would not also receive in the simple resale of the ILEC’s own service. UNE-P “competition” thus creates little if any opportunity for service differentiation. This competition is not value-added competition at all; it is defined not by expanding output, consumer choice, product quality, or market price, but by federal and state regulators and the TELRIC pricing regime.
As discussed in Section II.A.2, CLECs that rely on the UNE Platform argue that it provides a mechanism for CLECs to build up a customer base before they invest in facilities. But market experience since the time of the UNE Remand Order demonstrates that CLECs are not migrating UNE Platform customers to their own facilities to any significant degree (if at all). Many CLECs instead treat UNE-Platform competition as an end in itself, rather than as a stepping stone to facilities-based competition. These CLECs have obtained UNE Platforms to serve mass-market customers but have no plans to convert these customers to their own switches.46 Conversely, most of the CLECs that serve mass-market customers and that have deployed one or more switches of their own make little or no use of unbundled switching from the BOCs.47
The UNE-centric CLECs are not only failing to create any facilities-based competition of their own, they have harmed their facilities-based counterparts, too. Facilities-based CLECs recognize that the unrestricted availability of UNEs priced at a regulator’s estimation of long- term incremental cost can ruin a business making steep capital investments at here-and-now, real-world prices. As described above, these facilities-based CLECs view the availability of the full UNE Platform as particularly harmful to facilities based competition. See Table 1, supra.
2. The Failure of the DLEC Model.
“Data CLECs” or DLECs made a similar attempt to jumpstart ubiquitous competition, and were equally unsuccessful. Their business model centered exclusively on providing DSL services. Unlike the UNE-P competitors, the DLECs did typically deploy their own packet switches. But in the broadband market, most of the new value is in getting the broadband loop
45 Commerce Capital Markets, Status and Implications of UNE-Platform in Regional Bell Markets (Nov. 12, 2001). 46 See Section II.A.2. 47 See Section II.A.2, Figure 4.
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itself up and running. That’s a difficult challenge on any medium, but an especially difficult one on copper, which wasn’t designed for broadband in the first place.48
The ILECs themselves have certainly found the deployment of DSL service to be a difficult and costly process49 – with all the resources at their command, it has taken ILECS more than three years to make the service available to just over 40 percent of the homes they serve.50 Once the infrastructure is ready for broadband service, it then takes between two and three years to break even on a new DSL customer.51 The DLECs simply ignored these engineering and economic realities. They cultivated the belief that DSL was easy and inexpensive to deploy.52 They promised to deploy broadband services faster and more efficiently than incumbent local telephone companies or cable operators.53
To grow quickly, the DLECs relied on a business model that centered around resale of the ILECs’ loops, with relatively little of the CLECs’ own facilities-based investment. In most of the central offices that they intended to serve, the DLECs planned to deploy only a single
48 See, e.g., L. Gerhardy, et al., Morgan Stanley, Dean Witter, Investext Rpt No. 2262978, Globespan: Initiating Coverage – Company Report at *12 (Aug. 17, 2000) (“While simple in theory, the deployment of high bandwidth services over infrastructures originally designed for simpler purposes has created significant challenges . . . . Most of the Tel-co’s wiring infrastructure is decades old, and only a small portion of the frequency spectrum available on the wire was used. However, new digital technologies that exploit the unutilized Telco bandwidth encounter problems from the legacy analog environment for which the infrastructure was designed.”). 49 See, e.g., P. Harvey, The Last Mile is a Rocky Road, Red Herring (Aug. 1, 2000) (“For DSL providers, one of the biggest hurdles has been the time and expense required to send a truck and technicians to each home that requests service.”); Infinilink Corp. White Paper, Confronting the DSL Bottleneck, or “Why Does It Take So Long to Install DSL?” (Dec. 2000) (Truck rolls cost on average $300 each, and it takes an industry average of 2.7 truck rolls per DSL line deployed.) 50 See JP Morgan Cable Industry Report at Figures 12 & 36 (estimating that DSL is available to approximately 43 percent of households as of 1Q 2001). 51 See, e.g., G. Miller, et al., ABN AMRO, Investext Rpt No. 8150475, Sprint Corp. – Company Report at *8 (Aug. 9, 2001) (“We point out that DSL today is not profitable for a single carrier out there, including SBC, Verizon, and BellSouth. With a payback period of 18 to 24 months, we do not believe any of these carriers will turn a profit until next year, at the earliest.”); Broadband 2001 at 76 (incremental DSL customers break even on a net present value basis after 3.4 years); J. Bellace and S. Bhasin, Jefferies and Co., DSL Update: U.S. Broadband Penetration Forecasted to Increase from 11% at Year-End 2001 to 17% by Year-End 2002 at 4 (Feb. 4, 2002) (“the number of months it takes to breakeven on a DSL subscriber will decline from 24 months in 2001 to 10 months in 2005.”). 52 See, e.g., K. Fong, et al., Hambrecht & Quist Inc., Investext Rpt No. 2658327, Communications Symposium/Data Processing/Telecom – Industry Report at *39 (Apr. 16, 1998) (In early 1998, Covad’s chairman proclaimed that “DSL technology is unique in that it has an almost zero cost-per-home pass, an almost zero up-front, fixed-investment cost. . . it can be deployed rapidly because no one has to dig up the streets, no one has to pay franchise fees, and no one has to get city permits to allow this technology to happen.”); S. Schmelling, DCLECs Declassified: The Big Three of Data Are So Much Cooler Than Their Name, Upstart (Oct. 4, 1999) (Rhythms’s CEO likewise noted that “on a level of difficulty, [DSL is a] two on a scale of one to ten.”). 53 For example, in December 1998 – after being operational for just 10 months – one data CLEC proclaimed that it “will be able to provide DSL service to more business customers than all the Baby Bells combined.” NorthPoint Communications Will Surpass Combined Bells’ DSL Deployment, Bus. Wire (Dec. 15, 1998); see also J. Henry, et al., Bear, Stearns & Co., Inc., Investext Rpt. No. 2748881, Global Telecommunications: Weekly Performance Review – Industry Report at *3 (Mar. 1, 1999) (“Rather than attempting to establish blanket coverage of each market served in order to provide the densest coverage for its wholesale customers, Rhythms seems intent on establishing the most dots on its national network map as soon as possible.”).
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piece of equipment – a Digital Subscriber Line Access Multiplexer (DSLAM). DSLAMs vary in price depending on their capacity, but average “well under $200” per customer line – an investment of just $3 per month per line for each customer (conservatively assuming a five-year customer retention rate).54
The DLECs did not even intend to provide their own facilities-based connections to the Internet. Instead, they enlisted hundreds of Internet Service Providers to take charge of that end of things. The DLECs themselves acted merely as wholesale brokers – obtaining the loop from an ILEC on one side, and a connection to the Internet through an ISP on the other. The DLECs opted not even to attempt to offer voice services, which would have enabled them to collaborate and share facilities with their sibling voice CLECs.55 This strategy, the DLECs maintained, would let them grow very rapidly, on very small capital outlays.56
More than 20 DLECs began providing service between 1998 and the first quarter of 2000.57 Nine completed successful initial public offerings (IPOs), raising more than $1.3 billion in capital. The DLECs that went public had been in operation an average of less than 3 years; they had few lines in operation (an average of only 1,545); and they had a very limited cadre of employees (an average of 273). See Table 4. The companies themselves routinely admitted that
54 D. Burstein, DSL Prime News: The Inside Source, CLEC-Planet (Oct. 2, 2001), http://www.clec- planet.com/tech/oct2dslprimea.html; Broadband 2001 at 70 (cost of buying and operating a DSLAM at $174 per subscriber add); ZD Net, ZD Net Shopper, Resellers, http://zdnetshopper.cnet.com/shopping/resellers/0-11796-1411- 403544-0.html (the Paradyne HotWire 8800 DSLAM 20 slot chassis – 48VDC costs around $4200 or $210 per slot); D. Burstein, DSL Prime Newsletter, CLEC-Planet (May 18, 2001), http://www.clec-planet.com/tech/ 0517dslprimea.htm (“[T]he primary costs involved [with provisioning DSL] are the shared line ($0-6 per month) and the DSLAM (whose price is under $200/ per line, or $4/month over five years).”). 55 As with ordinary Internet access service, DSL quickly became a commodity-like service, “due to the lack of differentiation in the levels of service and increased competition amongst Service Providers.” Cisco Press Release, Cisco Announces Industry’s Most Comprehensive Portfolio of Customer Premises Equipment for Value-Added Business DSL Service (Sept. 18, 2000). See also V. Grover, Kaufman Brothers, Investext Rpt. No. 2205121, Network Access Solutions Corp. – Company Report at *1 (June 28, 2000) (“DLECs . . . are now heavily exposed to commoditization of the access portion of their businesses because they do not own customer relationships and therefore cannot layer enhanced services onto their revenue streams.”); V. Ryan, Headed for a Fall?, Telephone (Dec. 18, 2000) (“DSL wholesalers are trying to rescue customers from bankrupt ISPs and adapt to the commoditization of their primary business.”); K. Higgins, Intelligence at the Network Edge, Network World at 41 (Aug. 21, 2000) (“customers . . . increasingly regard high-speed Internet access as a commodity. To compete successfully, DSL service providers must differentiate themselves by offering a range of value-added services, including multiline, toll-quality voice service; VPNs; frame relay; videostreaming; and emerging productivity and entertainment applications.”). 56 R. King, Run Silent; Run Deep, Tele.com at 70 (Apr. 1998) (quoting Covad’s chairman stating that reliance on ISP important in order “to be able to roll the service out quickly and get the maximum amount of volume on our service that we can.”); Rhythms NetConnections, Form 10-K405 at 7 (SEC filed Mar. 30, 2000) (relying on an ISP will “increase[] volume and reduce[] costs by serving multiple resellers and leveraging their selling efforts.”); NorthPoint Communications Group, Form 10-K405 (SEC filed Mar. 30, 2000) (relying on ISPs would “enabl[e] [its] sales force to focus on prospective high-volume wholesale customers; amortize the cost of [its] fixed capital expenses over large base of end users more rapidly; minimize [its] end user support costs; and achieve a nationwide presence more quickly.”). 57 An additional 18 traditional CLECs also began offering DSL services during this period.
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their business models and strategies were “unproven”58 and had not been “validated . . . in the market.”59
Table 4. Operating Statistics for Public DLECs at Time of IPO Date of IPO Funds Raised Employees Annual Annual DSL Lines in by IPO Revenue Losses Service Choice One 02/16/00 $164M 390 $11.7M $34M 206 Covad 01/22/99 $150M 335 $2.6M $28M 1,948 DSL.net 10/12/99 $50M 146 $184,000 $6.5M 463 Log On America 04/22/99 $25M 13 $760,000 $422,000 n/a Mpower 05/15/98 $63M 145 $3.8M $10.8M 0 Net2000 03/10/00 $212M 485 $28M $39M n/a NAS 06/03/99 $82M 141 $4.8M $2.5M 300 NorthPoint 05/05/99 $386M 423 $931,000 $29M 5,700 Rhythms 04/12/99 $210M 400 $528,000 $36M 650 Sources: See Appendix M.
Then, between March and December 2000, the Internet bubble burst. The nine publicly traded DLECs lost more than 94 percent of their stock-market value. Industry insiders attributed this to the DLECs’ “unsound business models,” their failure to “own the physical layer,” and their decision to “run[] on another firm’s network.”60
The failed DLECs were eventually absorbed by more successful CLECs, often at a bargain price. AT&T and WorldCom acquired the two largest failed DLECs – NorthPoint and Rhythms; several other DLECs were likewise acquired by successful CLECs.61 Significantly, in
58 NorthPoint Communications, Form S-1 (SEC filed Feb. 26, 1999). 59 Rhythms NetConnections, Form S-1 (SEC filed Feb. 16, 1999). 60 L. LaBarba, Who’s Saving Whom?, Telephony (Dec. 18, 2000) (quoting Russ Intravartolo, CEO of ISP wholesaler Starnet: “There is no profitable way into DSL unless you own the physical layer.”); id. (quoting Gary Steele, vice president of product development for PathNet: “What’s going on in the industry may not be consolidation as much as it is the death of unsound business models.”); M. Martin, Caution Flags Flying as CLEC Woes Mount, Network World (Nov. 20, 2000), http://www.nwfusion.com/news/2000/1120clec.html (quoting Current Analysis analyst Jeff Moore: “It’s hard to be profitable when you’re running on another firm’s network.”); Regional DSL Report: Boston, ISP Planet (Dec. 15, 2000), http://www.isp-planet.com/news/dsl_report_boston.html (quoting Vitts CEO and Chairman: The DSL providers “adhere[d] to business plans resembling those of failed dot-com retailers: grow big and fast, no matter the cost of ‘buying’ customers.”); S. Woolley, Highway to Hell, Forbes (Feb. 19, 2001) (“The whole structure made zero sense from an economic standpoint.”). 61 See, e.g., WorldCom Press Release, WorldCom Closes Rhythms Transaction (Dec. 5, 2001) (WorldCom acquired the assets of Rhythms NetConnections for $31 million. The deal was closed approximately one month in advance, resulting in a more than 20 percent reduction in acquisition cost.); AT&T News Release, AT&T Acquires Assets of NorthPoint Communications (Mar. 22, 2001) (AT&T acquired “substantially all of the assets of NorthPoint Communications” for approximately $135 million. “We are delighted to be acquiring NorthPoint’s DSL assets,” said Robert M. Aquilina, co-president of AT&T Consumer. “They will help us in our efforts to move aggressively to bring the full benefits of DSL to consumers and businesses. These benefits include high-speed Internet access, local and long distance calling, and exciting broadband services, including virtual private networks, among other possibilities, in the future.”); Cavalier Telephone Press Release, Cavalier Telephone Completes Purchase of Net2000 Communications V-17
some of these cases, the acquiring CLEC took only the assets of the failed DLEC – primarily collocation space – not its customers.62 If they had viewed “rapid” and “ubiquitous” entry as the keys to the competitive success, the acquiring companies would presumably have done just the opposite.
C. Anti-Competitive Impacts of Expanding UNEs into Competitive Markets.
While the unbundling regime was intended to promote competition for local exchange services,63 both interexchange carriers and wireless carriers have demanded that ILECs also unbundle the inputs used in the provision of long distance and wireless services. These complementary markets are already competitive in their own right. Extending unbundling into these markets is, therefore, not only unnecessary to assure continued competition in those markets, but also likely to undermine the competitive supply of facilities that already has emerged for the local inputs in these markets.
1. Conversion of Special Access Circuits to UNEs.
“Special access” is the name given to “a variety of services and facilities which constitute the local portion of certain interstate telecommunications lines.”64 Special access “primarily involves the provisioning of so-called ‘private lines,’ that is, facilities or network transmission capacity dedicated to the use of an individual customer.”65 These dedicated facilities typically “run directly between the end user and the [interexchange carrier’s] point of presence (POP),”66 or directly between two end-user locations. When ILECs provide special access circuits to interexchange carriers, the ILECs must typically build those circuits from the ground up, using a combination of local loops and interoffice transport.
The customers for special access “are IXCs and large businesses, not residential or small business end users.”67 In fact, between 78 and 89 percent of the special access revenue earned
(Jan. 21, 2002) (Cavalier Telephone acquired the assets and customer lines of Net2000 in Virginia, Maryland, and Washington, D.C.; Broadview will acquire Net2000’s assets in New York and Boston). 62 See, e.g., J. Borland, AT&T Buys NorthPoint Assets, CNET News.com (Mar. 22, 2001), http://news.com.com/2100-1033-254629.html?legacy=cnet (“AT&T is not taking over NorthPoint’s customers along with the network.”). 63 UNE Remand Order ¶ 5 (“We continue to believe that the ability of requesting carriers to use unbundled network elements, including various combinations of unbundled network elements, is integral to achieving Congress’ objective of promoting rapid competition to all consumers in the local telecommunications market.”); id. ¶ 9 (“The unbundling standards we adopt in this Order [] seek to encourage the rapid introduction of competition in all markets.”). 64 Investigation of Special Access Tariffs of Local Exchange Carriers, 8 FCC Rcd 4712, ¶ 2 (1993). 65 Id. 66 Pricing Flexibility Order ¶ 8. 67 Pricing Flexibility Order ¶ 142. See also WorldCom v. FCC, 238 F.3d. 449, 453 (D.C. Cir. 2001) (“Most users of special access services are companies with high call volumes.”); Corrected Brief for Federal Communications Commission at 4, WorldCom v. FCC, No. 99-1395, et al. (D.C. Cir. filed Sept. 12, 2000) (“Because special access services employ dedicated facilities, special access is typically used by IXCs and large businesses with high traffic volumes.”); Brief of MCI WorldCom, Petitioners and Supporting Intervenors at 3-4, WorldCom v. FCC, No. 99-1395, et al. (D.C. Cir. filed Sept. 8, 2000) (“Special access, used generally by business customers who have a high volume of V-18
by BellSouth, Qwest, SBC, and Verizon is generated from DS-1 circuits or above (e.g., DS-3, OC-3).68 And as the Commission has recognized, DS-1 circuits “are primarily used by business customers.”69
The largest purchasers of special access service are interexchange carriers, which use special access to transport large volumes of traffic to and from their largest business customers.70 Between 56 and 76 percent of the special access revenue earned by BellSouth, Qwest, SBC, and Verizon is generated by interexchange carriers. The Commission has noted that long distance carriers “typically provide resold special access and private line services as part of toll service operations.”71
Special access traffic is also highly concentrated, geographically. In each of the BOC regions, the vast majority of special access revenue is generated in a very small minority of wire centers.72
The special access market is already highly competitive. It was among the first to be opened to competition, and it has attracted large numbers of competitors because of the extremely large traffic volumes that it involves. The only economic argument for permitting the
calls, is accomplished ‘via a private, dedicated line…running from the customer to the IXC’ . . . By contrast, switched access connections are generally used by residential customers and other customers with lower traffic volumes.”) (internal citations omitted). 68 USTA, Competition for Special Access Service, High-Capacity Loops, and Interoffice Transport, CC Docket No. 96-98, at 2 & Table 1 (FCC filed Apr. 5, 2001). 69 See, e.g., Second Advanced Services Report ¶ 99. 70 The big three interexchange carriers are not only the largest purchasers of special access service from incumbent LECs, but also major self-suppliers of special access. AT&T and WorldCom, for example, each has local facilities in approximately 100 markets that likely are used to provide special access services. See NPRG CLEC Report 2002, 15th ed., Ch. 6 – WorldCom at 13, 18 & AT&T at 19, 24. Sprint has stated that it is deploying local fiber rings in “20 major U.S. markets” that allow “improved access economics,” and enable Sprint “to significantly reduce its special access costs.” Sprint News Release, Sprint Announces Financial Targets and Growth Strategies (Nov. 3, 2000). Other long distance providers – including Williams, Level 3, and Global Crossing – likewise have extensive local facilities that they use to self-provide special access services. See, e.g., C. Grice, Williams to Expand High-Speed Network into 50 Cities, News.com (Feb. 10, 2000), http://news.cnet.com/news/0-1004-200-1546995.html?tag=st (Williams “expects to spend $421 million over three years in order to link its proposed 33,000-mile fiber-optic ‘backbone’ network directly to business customers in the nation’s largest cities.”); Level 3 Communications, The Level 3 Network, http://www.level3.com/673.html (Level 3 has 57 markets in service and almost 16,000 miles of conduit in North America); Global Crossing Press Release, Global Crossing Reports 2000 Pro Forma Cash Revenue up 36%, Recurring Adjusted EBITDA up 54% from 1999 (Feb. 14, 2001) (in 2000, Global Crossing completed metro rings in 10 cities in the United States: New York, Philadelphia, Washington D.C., Atlanta, Miami, Dallas, Chicago, San Francisco, San Jose, and Los Angeles). 71 FCC, Local Telephone Competition at the New Millennium at Table 6, note **** (Aug. 2000). 72 More than 80 percent of SBC’s special access revenues are generated in less than 25 percent of the wire centers in which it is providing special access. In Verizon’s region, more than 80 percent of special access revenues are generated from about 20 percent of Verizon’s total wire centers. In Qwest’s region, more than 60 percent of special access revenues are generated from 11 percent of Qwest’s total wire centers. In BellSouth’s region, 91 percent of special access revenues are generated from 20 percent of BellSouth’s total wire centers. USTA, Competition for Special Access Service, High-Capacity Loops, and Interoffice Transport, CC Docket No. 96-98, at 3 (FCC filed Apr. 5, 2001).
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conversion of special access circuits into UNEs is that it would supposedly reduce the costs of the inputs that interexchange carriers use in the provision of long distance services. But as the Commission has recognized, the long distance market already is competitive for large business customers that are the primary end-users served with special access circuits.73 Any regulatory action that merely reduces the prices that one of the competitive suppliers of special access may charge is, therefore, unnecessary to promote long distance competition.
Any such action would devalue the assets of other competitive suppliers in this market. CLECs as a group are more significant suppliers of special access service than basic local exchange service. As the Commission has found, “the revenues of competitive LECs come primarily from special access and local private line services.”74 CLECs now account for between 28 and 39 percent of all special access revenue, see Appendix L, which is significantly larger than their share of the local exchange market as a whole.75 CLECs have obtained fiber- based collocation in wire centers that contain a significant share of BOC special access revenues.76
2. Conversion of Transmission Services for Wireless Carriers.
Some wireless carriers suggest that CMRS base stations are equivalent to ILEC end offices, and that wireless carriers are therefore entitled to buy “interoffice transport,” at UNE rates, between various points on their networks.
Wireless carriers clearly do not need access to transport UNEs to compete in wireless markets themselves. The 1996 Act authorized ILEC wireless affiliates to enter long-distance markets immediately, without waiting for any unbundling or section 271 checklist approval by their wireline affiliates.77 As the Commission’s sixth annual report (“Sixth CMRS Report”) on competition in Commercial Mobile Radio Services (CMRS) concluded in December 2001, U.S. wireless markets are robustly competitive, and growing more so year by year.78 While ILEC
73 See Revisions to Price Cap Rules for AT&T Corp., Report and Order, 10 FCC Rcd 3009, ¶¶ 16-18 (1995); see also Motion of AT&T Corp. to be Reclassified as a Non-Dominant Carrier, Order, 11 FCC Rcd 3271, ¶¶ 88-90 (1995). 74 See, e.g., Promotion of Competitive Networks in Local Telecommunications Markets, First Report and Order and Further Notice of Proposed Rulemaking in WT Docket No. 99-217, Fifth Report and Order and Memorandum Opinion and Order in CC Docket No. 96-98, and Fourth Report and Order and Memorandum Opinion and Order in CC Docket No. 88-57, 15 FCC Rcd 22983, ¶ 24 (2000). 75 See Section I.D. 76 See USTA, Competition for Special Access Service, High-Capacity Loops, and Interoffice Transport, CC Docket No. 96-98, at 6-7 (FCC filed Apr. 5, 2001) (In 183 of the 320 MSAs served by BellSouth, Qwest, SBC, and Verizon, one or more fiber based collocation arrangements existed in wire centers that cover at least 30 percent of the incumbent LECs’ special access revenues in those MSAs. In 154 of these MSAs, one or more collocation arrangements exist in wire centers that cover at least 65 percent of the incumbent LEC’s special access revenues in those MSAs.). 77 47 U.S.C. § 271(g)(3). 78 See, e.g., Sixth CMRS Report 4-5 (“In the year 2000, the CMRS industry continued to experience increased competition and innovation as evidenced by lower prices for consumers and increased diversity of service offerings.”). The Commission cited that the “continued downward price trends, churn, and continued expansion of mobile networks
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affiliates rank as robust competitors in wireless markets, unaffiliated wireless carriers are more than holding their own. Approximately 40 percent of the wireless market is served by carriers that are not affiliated with any ILEC.79
Wireless networks consist of four basic tiers. See Figure 4.80 The first three tiers define the wireless tier of the wireless carrier’s network; the fourth tier both switches wireless calls and hands them off to and from the wireline network.81 All of the true switching is performed at the fourth level.
Figure 4. CDMA Network Configuration
Cell Site (Base Station) Cell Site (Base Station)
CDMA Base Station Cell Site Controller (Base Station)
Mobile
ATM Link Switching Link to to Other Center Public UNE Proposed by CDMA Switched Wireless Carriers Networks Telephone Current UNE Network
The base station is not a switch – its purpose is to allocate a shared resource – wireless bandwidth – among multiple users of the network who aren’t all using their wireless phones at the same time. It is the mobile switching center – not the base station itself – that orchestrates the intra-switch hand off when a user moves away from base station A and toward base station B. And likewise for the hand-off required when the user moves on toward a more distant base station C, which is connected to an entirely different switch. The switches themselves are linked to an ATM network that is there to support these “soft,” inter-switch handoffs of live calls. The base station plays no more role in orchestrating the hand off than the wireless handset does – all of these tiers of the network remain under the direction and control of the switch. And in any
into new and existing markets demonstrate a high level of competition for mobile telephony customers. . . . Most carriers report churn rates between 1.5 percent and 3 percent per month. . . . According to one recent survey, almost one in five wireless subscribers have switched carriers in the past year.” Sixth CMRS Report at 21, 23. 79 See Legg Mason Wireless Industry Scorecard at Exh. 8 (estimated market share as of 3Q 2001). 80 See Nortel Networks, Products and Services, CDMA Networks, http://www.nortelnetworks.com/products/ 01/cdma/index.html#. 81 See Nortel Networks, The DMS-100 Wireless System at 3, Document No. 50171.16/10-97 Issue 1.
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event, the hand-offs themselves are not equivalent to switching; they occur to support efficient use of radio spectrum in a cellular architecture network, not the routing of calls between end- users.
3. Conversion of Broadband Services for Information Service Providers.
The provision of information services is highly competitive, and has been deregulated for more than 30 years. While information services providers sometimes use parts of the local exchange network to provide service to end users, they do so by obtaining tariffed services from ILECs. The 1996 Act makes clear that UNEs cannot be used to provide an information service.82
CLECs have nonetheless attempted to insert themselves between ILECs and information services providers by converting tariffed customer services into UNE-centered services. Various CLECs have obtained UNEs to provide connections between end-user customers and those customers’ ISPs. This is what data CLECs like Covad do with respect to broadband Internet access. The CLEC in this scenario is typically little more than a regulatory fiction – a device to use a particular regulatory classification to obtain UNE-based “carrier” connections and prices lower than those available to mere “customers.” The CLEC adds little if any value of its own.
The extension of UNEs into the information services realm is surely not necessary to promote competition for these services. Competition has evolved rapidly without such UNEs. For example, there are now more than 7,000 providers of narrowband Internet access, and the Bell companies collectively provide service to fewer than 6 percent of the subscribers to these services.83 Nor is the extension of UNEs to serve ISPs necessary to promote competition in the broadband market. As discussed in Section IV.C, the provision of broadband services is already highly competitive.
D. Facilities-Based Investment in New Broadband Infrastructure.
The “widespread deployment of broadband infrastructure has become the central communications policy objective of the day.” This will require “the complete or near-complete replacement of copper lines with end-to-end fiber optic transmission facilities.”84 To promote the objective, “broadband services should exist in a minimal regulatory environment that promotes investment and innovation in a competitive market.”85
Manufacturers of computers and other types of hardware that use bandwidth are all but unanimous in their view that – as Intel CEO Craig Barrett puts it, “broadband” only “gets exciting when you get to 5 megabits per second or even 100 mbps.”86 What ranks as
82 See 47 U.S.C. § 251(c)(3). 83 See P. Fusco, Top U.S. ISPs by Subscriber: 2001 Year End, ISP-Planet.com (Feb. 11, 2002), http://www.isp-planet.com/research/rankings/usa.html. 84 Appropriate Framework for Broadband Access to the Internet over Wireline Facilities, Notice of Proposed Rulemaking, 17 FCC Rcd 3019, ¶¶ 1, 12 (2002). 85 Id. ¶ 5. 86 J. Shiver, Intel CEO Makes Case for Broadband Aid, L.A. Times (Jan. 28, 2002).
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“broadband” today “is not sufficient to provide some of the serious content people are interested in.”87 Surveys already confirm that consumers who obtain broadband connections use the Internet more, not less.88 Higher speed connections don’t merely accelerate – and thus shorten – connections – they immediately lead to new uses and thus, longer connections.89 As the Commission recognized in its First Advanced Services Report, broadband links become part of a self-reinforcing “virtuous cycle,” in which better performance and lower per-bit price “fuels more demand” – heavier use of existing applications, and, more importantly, “demand for new applications that were not feasible before.”90 “As the cycle gains momentum . . . companies will provide new applications and services for broadband consumers, . . . consumers will demand broadband, and the virtuous cycle will accelerate.”91 See Table 5.
87 Id. As Intel has stressed, “the true benefits of broadband will require faster transmission speeds” – “at only 200 kbps, ‘advanced services’ are not capable of providing adequate transmission speeds for video.” Comments of Intel Corp. at 5, Inquiry Concerning the Deployment of Advanced Telecommunications Capability to All Americans in a Reasonable and Timely Fashion, and Possible Steps to Accelerate Such Deployment Pursuant to Section 706 of the Telecommunications Act of 1996, CC Docket No. 98-146 (FCC filed Sept. 24, 2001). “High-definition video requires 19.8 Mbps; DVD-quality video needs almost 4 Mbps; and even television quality requires 750 kbps or more. In fact, ‘many experts set 100 Mbps as the frontier [of the Web’s true potential for] general surfing to streaming high-quality, skip-free digital audio and video, as well as faster upload of graphic images and larger files.’” Id. Corning likewise has suggested that “[a] minimum transmission speed of 10 mbps upstream and downstream should be utilized for the purpose of defining next generation broadband capability. . . . This speed is necessary to allow for the bi-directional transmission of audio, data at 10 base-T Ethernet speeds, and compressed full motion video.” Comments of Corning Inc., Deployment of Broadband Networks and Advanced Telecommunications, Docket No. 011109273-1273-01 (NTIA filed Dec. 19, 2001). But Corning stressed that “10 mbps is a minimal level of transmission,” that the range really extends from 10 mbps to 1 Gbps. Id. Corning senior vice president Timothy Reagan told the House Energy and Commerce Committee that “[i]f you think that Americans will need access to information in all its forms – audio, video, and data – it is easy . . . to see that a capability in excess of 22 [Mbps] downstream and 10 [Mbps] upstream is ideal.” Timothy Regan, Senior Vice President, Corning Inc., prepared witness testimony before the House Energy and Commerce Committee, Washington, D.C. (Apr. 25, 2001). 88 See, e.g., Broadband 2001 at Charts 16 and 17 (as broadband users, survey participants spent on average 21.4 hours per month online, as compared to 15.9 hours with a narrowband connection. These same users also spent more time per session (32 minutes vs. 21 minutes), spent more days online (18 vs. 17) and viewed more pages per month (1,828 vs. 1,561)); Jupiter Media Metrix Press Release, Over 40 Percent of US Online Households to Connect Via Broadband by 2006, Reports Jupiter Media Metrix (Oct. 17, 2001) (“Broadband consumers continue to use their connections more intensively than narrowband consumers do…”). 89 According to a Broadband Watch study, customers are using broadband to engage in online activities such as shopping online (95 percent), e-mailing photos (76 percent), downloading streaming video (64 percent), downloading MP3s (61 percent), telecommuting (60 percent), creating Web pages (49 percent) and playing games (47 percent). Respondents also reported that with DSL, they are much more likely to engage in these higher-bandwidth activities: downloading MP3s: 61 percent with DSL vs. 35 percent with dial-up; downloading video: 64 percent with DSL vs. 36 percent with dial-up; and e-mailing photos: 76 percent with DSL vs. 62 percent with dial-up. See Survey Says: DSL Users “Addicted” to Broadband, Bus. Wire (Apr. 3, 2001). See also Jupiter Media Metrix Press Release, Over 40 Percent of US Online Households to Connect Via Broadband by 2006, Reports Jupiter Media Metrix (Oct. 17, 2001) (“Broadband users are more likely than dial-up users are to download music (46 percent of broadband users, 26 percent of dial-up users), listen to music (48 percent and 30 percent, respectively) and watch video (36 percent and 18 percent, respectively). . . . [M]ore broadband consumers conduct personal banking (48 percent and 30 percent, respectively) and stock-related activities online (35 percent and 23 percent, respectively) than dial-up consumers do.”). 90 First Advanced Services Report ¶ 95. 91 First Advanced Services Report ¶ 96.
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Table 5. Emerging Broadband Applications Application Minimum Speed Next-Generation Game 200 kbps “You need to have a broadband connection . . . to use the Xbox online Consoles service.” (e.g., Microsoft Xbox) “Broadband access makes possible an explosion of multiplayer games.” Online Gaming 200 kbps “As broadband connections become more standard, the online gaming industry is poised to deliver gaming experiences that are more enjoyable and exciting than anything we have seen so far.” Downloading Music 200 kbps “Most MP3 files are between 2MB and 5MB in size. Downloading that much data through a narrowband pipe is horribly tedious, especially if you're trying to build an extensive music library on your hard drive. But with cable, DSL, or satellite, the tunes reach your hard drive in a relative flash.” Internet Radio 200 kbps “Though [Internet radio] is possible with a dialup connection, it doesn’t work so well because the signal often gets clogged in the narrow pipe. But with broadband, the music or talk usually reaches your ears as it was originally sung, played, or spoken.” Telemedicine – 384 kbps “The majority of [distance] diagnoses could be determined using [a] Distance Diagnosis 384 kbps link, with slight improvement when the bandwidth was increased to 1 mbps.” Distance Learning 384 kbps “H.320 [the lowest speed distance-learning standard] provides high- quality images at any speed from 384 Kbps and up.” Video-on-Demand 500 kbps “[V]ideo-on-demand will remain out of reach for most U.S. (e.g., Microsoft/ households in the near future, including all homes using dial-up CinemaNow’s PatchBay) internet access and even the vast majority of broadband households.” Streaming Video 600 kbps “[A] minimum 600-Kbps and maximum 800-Kbps video stream to each modem [is] enough to provide each user half a computer screen of ‘TV-quality’ video synched with its audio at all times.” Full-Length Video 1 Mbps “Downloading a full-length feature over a fast broadband connection Downloads at 1 mebabit per second (Mbps) takes about 30 minutes. Over a slow broadband connection of 128 kilobits per second (Kbps), it could take hours.” Videoconferencing 1.5 Mbps “The target for videoconferencing is 30 fps (broadcast quality) but requires bandwidth in the range of 1.5 mbps.” Telesurgery 10 Mbps For a recent telesurgery by a doctor in New York on a patient in France, France Telecom “needed to guarantee 10 Mbps and continuous transmission delays of less than 200 milliseconds, on both inbound and outbound links.” Sources: See Appendix M.
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Figure 5. Increase in Speed/Bandwidth of Various Technologies Processor Speed (MHz) PC Bus Speed (MHz) Hard Drive Capacity (MB) Floppy Drive Capacity (MB) Office LAN Transmission Speed (Mbps)
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Years After Introduction of Technology
Sources: See Appendix M.
Figure 6. Internet Backbone Traffic Growth
Source: Gilder Technology Report. See Appendix M.
From the consumer’s perspective, demand for bandwidth – raw digital capacity and speed – has been rising very fast for the last decade – just as demand for speed and capacity in all the hardware that links up to the digital networks as been rising inexorably for the past two decades. See Figures 5 & 6. What ranks as “broad” today no longer will a few years hence. Most of the applications that will generate data traffic five years hence aren’t running today, at least not in any way comparable to what they will become. Most of the users of “broadband services” today aren’t yet using those services for what they will be using them for in the fairly near future. Most of today’s “broadband” infrastructure, both wired and wireless, will have to be upgraded again and again, indefinitely into the future, to meet the continuous rise in demand.
Many residential applications are now emerging, from high-speed games to telecommuting to telemedicine, that will push residential consumers toward symmetric broadband services. As the chief of the Commission’s Media Bureau recently observed, “current generation ‘broadband’ networks cannot support . . . killer apps, the predecessors of which are
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staring us right in the face.”92 Such applications will require “next generation of broadband network – one that presumably will be symmetrical, or nearly so, and capable of delivering perhaps ten megabits per second.”93
As the Commission itself recently concluded, much of the copper distribution plant will have to be replaced with fiber.94 One analyst estimates that “modernizing our wireline access infrastructure will likely cost over $200 billion from start to finish,” and that this investment will have to be made “without a firm grasp of what services will be demanded and at what price they will be purchased.”95
Wireless broadband services are coming, too. A number of U.S. CMRS carriers have already deployed 2.5G96 services which allow users to access the Internet at speeds up to 144 kbps, a significant improvement over widely deployed 2G services, with top speeds around 10 kbps.97 3G networks will be needed for true broadband.98 Although the FCC has yet to allocate additional spectrum specifically for 3G wireless services, a number of companies already are in the process of deploying 3G networks over their existing spectrum. Verizon Wireless recently launched its 3G service in markets covering one-third of the company’s national footprint.99
92 W. Kenneth Ferree, Chief, Cable Services Bureau, FCC, How Do You Build the Information Superhighway?, remarks at the Broadband Outlook 2002 Conference (Jan. 23, 2002). 93 Id. 94 See Appropriate Framework for Broadband Access to the Internet over Wireline Facilities, Notice of Proposed Rulemaking, ¶ 12, CC Docket No. 02-33, FCC 02-42 (rel. Feb. 15, 2002) (“[t]he logical technological evolution of the network is the complete or near-complete replacement of copper lines with end-to-end fiber optic transmission facilities.”); see also I. Burgess, Credit Suisse First Boston, Investext Rpt. No. 2989479, European Telecom Equipment Weekly Update - Industry Report at *4 (Nov. 12, 1999) (“Ultimately the limitations of copper cable ensure that the economic solution is to push fibre deeper and deeper into the network, closer and closer to the user.”); M. Suydam, Passive Aggressive, CommVerge at 40 (May 1, 2001) (“[Passive Optical Networking] is obviously much better than copper. While DSL is hot today, how long will that last? Eventually, everything will go into fiber.”) (quoting Dong Liu, strategic marketing manager for networking and interface products, Agere Systems). 95 Douglas Ashton, Bear Stearns and Co., prepared witness testimony before the House Energy and Commerce Committee, Washington, D.C. (Apr. 25, 2001). 96 See Sixth CMRS Report at 48 (“the term 2.5G is used to describe the interim technologies that carriers will use while migrating from their current 2G technologies in order to offer mobile data services at higher speeds.”) 97 Carriers who have deployed 2.5G services include VoiceStream, Cingular Wireless, and AT&T Wireless. See Legg Mason Wireless Industry Scorecard at 28; 3G Newsroom.com, What Is 3G?, http://www.3gnewsroom.com/ html/what_is_3g/index.shtml (updated Nov. 18, 2001). 98 See, e.g., J. Haring, H. Shooshan, and K. Pehrsson, Strategic Policy Research, White Paper on Elimination of the Spectrum Cap at 6 (Apr. 12, 2001) attached to Comments of Cingular Wireless LLC in 2000 Biennial Review Spectrum Aggregation Limits for Commercial Mobile Radio Services, WT Docket No. 01-14 (FCC filed Apr. 13, 2001) (“3G services will provide the advantages of allowing internet browsing on the move, and will be ‘always on’ – i.e., no need to establish a network connection each time the user wants to receive e-mail or surf the web.”). 99 Verizon Wireless Press Release, Verizon Wireless Launches Nation’s First Major Advanced Wireless Network: The Verizon Wireless Express Network (Jan. 28, 2002); Verizon Wireless Press Release, Verizon Wireless Introduces Express Network to Key U.S. Cities in the Midwest, South, Northeast and the Pacific Northwest (Apr. 2, 2002).
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Sprint PCS is expected to follow within the first half of 2002.100 Analysts predict that 3G networks will be widely deployed by 2004 or 2005.101
The Commission also has recently taken the first steps to “pave the way for new types of products incorporating ultra-wideband (UWB) technology” 102 – devices that “can operate using spectrum occupied by existing radio services without causing interference,”103 and to explore the introduction of “software defined radio” (SDR) technology that could allow a single device to be quickly reprogrammed to transmit and receive on any frequency within a wide range using virtually any transmission format.104 There also are a host of other technologies currently under development that will be capable of provisioning wireless broadband services. These include Digital SMR, 2 GHz MSS satellite systems, L-Band satellites, and Big LEO satellites.
The strongest incentive 3G carriers and other wireless carriers have today to accelerate the roll out of their broadband wireless services is to capture from incumbent cable operators and ILECs a share of the profitable ($40-$50 per month) broadband subscription fees. A UNE policy that promotes uneconomic competition over the high-frequency portion of the ILEC loop, based on excessively discounted TELRIC prices, will surely depress investment in the high-frequency portions of the airwaves themselves.
Finally, the Commission has recognized that fixed wireless access offers “a replacement for the ‘last mile’ of copper wire.”105 Recent advancements in fixed wireless technologies are expected to “cause a spur in service provider deployments.”106 In particular, Non-Line-of-Sight
100 See B. Chamy, VoiceStream Launches New Phone Network, CNET News.com (Nov. 14, 2001), http://news.com.com/2100-1033-275853.html?; see also Sixth CMRS Report at App. D, Tables 1 & 2 (showing the various 3G contracts and tests/trials already underway in the U.S.). 101 See, e.g., IDC Wireless Displacement Report at 20 (By the 2003-2004 timeframe, 2.5G and 3G end-user terminals . . . are expected to be available in mass market quantities.”); P. Jarich and R. Haley, Strategis Group, Fixed Wireless: The Emerging Vendor Landscape at 208 (Nov. 2001) (“U.S. carriers are planning to deploy high-speed mobile networks as early as year-end 2001…. the 2004-2005 timeframe is seen to be pivotal for the development of the 3G market.”); T. Robillard, Salomon Smith Barney, Investext Rpt. No. 2421674, 3G Odyssey: Infrastructure the Opportunity; Timing the Risk – Industry Report at *1 (Jan. 3, 2001) (“We believe 2G capacity driven spending will represent majority of [revenues] in 01 and 02 while 3G should add to sales and is unlikely to represent majority of [infrastructure revenues] until late 03/early 04.”); F. Marsala, Robertson Stephens, Investext Rpt. No. 8245695, Implications of Cingular’s Technology Announcement – Industry Report at *1 (Oct. 31, 2001) (“[AT&T Wireless] currently plans to deploy third-generation W-CDMA (also called UMTS) beginning in 2003”). 102 Revision of Part 15 of the Commission’s Rules Regarding Ultra-Wideband Transmission Systems, Public Notice, 15 FCC Rcd 12086 (2000). 103 FCC News Release, New Public Safety Applications and Broadband Internet Access Among Uses Envisioned by FCC Authorization of Ultra-Wideband Technology (Feb. 14, 2002); id. (these devices will permit “scarce spectrum resources to be used more efficiently.”). 104 See Inquiry Regarding Software Defined Radios, Notice of Inquiry, 15 FCC Rcd 5930 (2000); Authorization and Use of Software Defined Radios, First Report and Order, 16 FCC Rcd 17373 (2001). 105 Third CMRS Report, App. F at F-1. 106 See Yankee Group Fiber and Fixed Wireless Report at 13; M. Helgeson, Dain Rauscher Wessels, Broadband Wireless: The Worldwide Assessment at 4 (May 17, 2001) (“With NLOS we believe at least 25% more customers can be served within the same geographical footprint. We further believe that this could mean the difference in convincing service providers to put their money into deploying the technology en masse.”); C. Riggle, Next- Generation NLOS Fixed Wireless – An NLOS Case Study, Broadband Wireless Online (Sept. 2001), V-27
technologies have been developed, which obviates the need for an unobstructed path between a fixed wireless transmitter and an end-user premises.107 In addition, “[t]he incorporation of IP- based telephony capabilities in second-generation NLOS equipment will allow MMDS providers to incorporate voice applications in their service mix.”108 This is expected to prompt fixed wireless providers “to target the residential end users, thereby increasing fixed wireless availability and hence subscriber base.”109
The Commission also has recognized that the new broadband infrastructure, both wired and wireless, will be rolled out incrementally. Network deployments are “complex and time- consuming projects that require enormous capital expenditures, a skilled labor-force, and available supply of advanced equipment.”110 As a result, even incumbent network operators “cannot upgrade all of their systems simultaneously,” but instead “upgrades are a multiyear and multiphase endeavor, whereby the operator upgrades certain systems and offers new services on an incremental basis.”111 See, e.g., Figure 7.
Figure 7. Cable Network Upgrades* Cable Homes Passed by High Speed Access Network Upgraded for Two-Way Communications 100% Network Upgraded to 550 MHz 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% 1994 1995 1996 1997 1998 1999 2000 2001 *Shaded columns represent estimated status of upgrades. Sources: See Appendix M.
http://www.shorecliffcommunications.com/magazine/volume.asp?vol=20&story=182 (“[W]ith the recent availability of NLOS wireless solutions, MMDS carriers have a renewed competitive opportunity. MMDS carriers can deploy their networks faster and thus are positioned to capture market share from cable and DSL access providers.”); B. Harter, Is Market-Changing BWA Technology in Sight?, Broadband Week (May 7, 2001), http://www.broadbandweek.com/news/010507/010507_wireless_tech.htm. (“A recent [Allied Business Intelligence] report calls NLOS technologies a key component in the growth of multichannel multipoint distribution services-based networks.”). 107 Yankee Group Fiber and Fixed Wireless Report. 108 Id. at 11. 109 Id. at 8. 110 AT&T/MediaOne Order ¶ 150. 111 Id.
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Unfettered competition is almost always the best policy when markets are young, and when technology is evolving quickly.112 And that is certainly the condition of the broadband market today. Most of the market is up for grabs, because 90-plus percent of the technology that will ultimately be used hasn’t yet been built, 90-plus percent of the capital hasn’t yet been committed, and 90-plus percent of the customers aren’t yet being served. And because broadband digital services will ultimately absorb and displace the old, analog voice and video, it is equally true that no player in the market today has any assurance of winning any given share of the vast digital market ahead. An extraordinary transformation in technology is overtaking all the old certainties.
112 See, e.g., Michael Powell, Chairman, FCC, remarks before the National Summit on Broadband Deployment, Washington, D.C. (Oct. 25, 2001) (“The market is the best vehicle designed by mankind for innovation, for technology change and evolution.”); id. (“Clearly, legal restraints can retard deployment of new services.”); Michael Powell, Chairman, FCC, remarks before the Federal Communications Bar Association, Washington, D.C. (June 21, 2001) (“[B]efore 1993, many argued that we should not open up the wireless market. It was thought that two competitors in the cellular market were certainly more than sufficient. Since that market was opened and PCS introduced we have seen a phenomenal explosion in innovative, digital wireless services.”).
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APPENDICES
APPENDIX A. ESTIMATING CLEC LINES
APPENDIX B. CLEC CIRCUIT SWITCHES
APPENDIX C. WIRE CENTERS IN THE TOP 100 MSAS WHERE CLECS HAVE ACQUIRED CUSTOMERS THROUGH PORTED NUMBERS
APPENDIX D. RATE EXCHANGE AREAS IN THE TOP 100 MSAS WHERE CLECS HAVE OBTAINED NXX CODES
APPENDIX E. CLEC PACKET SWITCHES
APPENDIX F. WIRELESS SWITCHES
APPENDIX G. COMPETITIVE COLLOCATION PROVIDERS IN THE TOP 50 MSAS
APPENDIX H. HOT-CUT PERFORMANCE
APPENDIX I. CLECS PROVIDING ATM AND FRAME RELAY
APPENDIX J. ADDITIONAL INFORMATION ON SOFTSWITCHES
APPENDIX K. CLEC NETWORKS BY MSA
APPENDIX L. ESTIMATING CLEC SPECIAL ACCESS MARKET SHARE
APPENDIX M. ADDITIONAL SOURCES (including full citations for short cites used in this report)
APPENDIX A. ESTIMATING CLEC LINES
The FCC’s February 2002 Local Telephone Competition Report includes CLEC line- count figures that are based on counts supplied by the CLECs themselves to the FCC. Those counts do not appear to be accurate, however. There are other significant problems too, but the most important source of inaccuracy is probably that CLECs are either overlooking or misinterpreting the requirement that they convert high-capacity lines into voice-grade-equivalent lines. In contrast, the CLECs do make a clear distinction between lines and “voice-grade equivalents” when they report on the state of their business to investors.
According to the Commission’s recent report, CLECs reported serving a total of 17.3 million lines as of June 30, 2001. The CLECs inform the FCC that they served about half of those lines – 8.6 million lines – in whole or in part over their own facilities, beginning with their own switches.1 The other half were resale or UNE-P lines, switched by the ILEC.
The Bell companies are, of course, in a position to check the UNE-P and resale-line totals directly, and Bell company records confirm that the CLECs’ resale and UNE-P counts are reasonably accurate. But additional Bell company records indicate beyond serious doubt that the estimates of facilities-based lines that the CLECs are supplying to the Commission are much too low. CLECs are in fact serving two to three times as many lines over their own facilities than their reports to the Commission indicate. In total, CLECs served no fewer than 25 million lines, and likely closer to 32 million lines as of year-end 2001, not 17 million.
“Lines” versus “Voice-Grade Equivalent Lines.” The FCC directs CLECs to report “all local exchange service lines and all lines that are used for exchange access services.”2 Carriers must report all “voice-grade equivalent lines,” which are defined as “a line or channel that directly connects an end user to a carrier and allows the end user to originate and terminate local telephone calls on the public switched network.”3 The FCC further directs carriers to:
Count as one voice-grade equivalent line: traditional analog POTS lines, Centrex- CO extensions, and Centrex-CU trunks. Count lines based on how they are charged to the customer rather than how they are physically provisioned . . . Report 8 voice-grade equivalent lines if a customer buys 8 trunks that happen to be provisioned over a DS1 circuit. If a customer buys a DS1 circuit that is
1 CLECs reported serving 5.8 million lines over “CLEC-owned ‘last-mile’ facilities.” FCC Local Competition Report, Feb. 2002 ed. at Table 3. In addition, CLECs reported serving 7.6 million lines through “UNEs,” which includes UNE loops leased from an ILEC and used in combination with a CLEC’s own switch. See id. at 1-2 & nn. 3-4. According to data reported by ILECs, there were 4.8 million “UNEs with switching” provided to CLECs. See id. at Table 4. Subtracting this figure from the 7.6 million lines that CLECs serve through UNES, results in 2.8 million CLEC lines served using ILEC loops but CLEC switching. 2 FCC, Instructions for the Local Competition and Broadband Reporting Form, FCC Form 477 at 5 (of data as of Dec. 31, 2001) (“Form 477 Instructions”). 3 Id. at 5, 6 (emphasis in original).
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provided as a channelized service, report 24 voice-grade lines, even if there is some indication that the customer is only using 8 of the derived lines.4
CLECs certainly know what the term “voice-grade equivalent line” means. They use the term themselves in reports to the investment community, including their reports filed with the Securities Exchange Commission. See Section I, Table 4. In dealing with the FCC, however, some CLECs express concern that complying with the FCC’s instructions would lead to the release of competitively sensitive information.5 As the Commission itself has noted, “the reports of at least some CLECs are not consistent” with its directions, and, as a result, “there may be some need for further clarification and adjustment of the reporting system.”6
E911 Listings: At Least 16 Million Facilities-Based CLEC Lines. As of year-end 2001, CLECs had listed 16 million lines in E911 databases – or almost twice as many as the 8.6 million facilities-based lines they reported to the FCC. This gross discrepancy cannot be attributed to any factor other than gross under-reporting by the CLECs to the FCC.7
For obvious reasons, the E911 databases are maintained with scrupulous care. The databases are maintained on behalf of police and fire departments by the ILECs; their contents are derived from both ILEC and CLEC records. ILECs provide all entries for lines served by the ILECs themselves, and for UNE-P and resale lines served by CLECs. CLECs provide the entries for lines switched by CLEC switches. Once a carrier loses a customer, its E911 listing for that customer is replaced by the listing of the customer’s new carrier, which ensures that the database does not become infected with large numbers of obsolete listings.
Each E911 subscriber listing represents at least one customer access line, but may represent more than a single line. In the case of business customers, for example, a single E911 listing may represent many individual lines, because a carrier does not typically have to create a separate E911 listings for every line served at the same location. A business might, for example, have 100 lines numbered 326-79xx; a single E911 listing would then suffice to link all calls from 326-79xx numbers as originating from the same location. A count of CLEC lines based of E911 listings will therefore understate the number of lines served by CLEC switches.
4 Id. 5 See, e.g., Comments of AT&T Corp. at 17, Local Competition and Broadband Reporting, CC Docket No. 99-301 (FCC filed Dec. 3, 1999) (“There is little information that is guarded more closely by a newly-developing competitor . . . than its subscriber and access line counts.”); Comments of Time Warner Telecom at 6-7, Local Competition and Broadband Reporting, CC Docket No. 99-301 (FCC filed Mar. 19, 2001) (“Much of the data the Commission requests on Form 477 is widely considered proprietary and competitively-sensitive. . . . [f]or example, TWTC routinely seeks confidential treatment of its data on total voice telephone service lines and channels provided to end users.”). 6 FCC Local Competition Report, Feb. 2002 ed. at 1-2, n.3. 7 The CLEC-reported totals in the FCC’s report are understated for other reasons as well. The FCC requires CLECs to provide the number of lines they serve on a state-by-state basis, but only for the states “in which they provide 10,000 or more ‘voice-grade equivalent lines.’” Form 477 Instructions at 1. As the Commission has recognized, “lines as reported by CLECs are understated as a result of th[is] state-specific reporting threshold.” FCC Local Competition Report, Feb. 2002 ed. at 2, n.5. Any confusion with regard to lines versus “voice-grade-equivalent circuits” may of course seriously compound this under-reporting problem. Moreover, the FCC totals are as of June 2001, whereas the totals reported here are for year-end 2001.
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Both the FCC and the Department of Justice have repeatedly relied on E911 listings to estimate CLEC facilities-based lines in section 271 proceedings.8 No CLEC providing service to end-user customers has yet claimed that its facilities-based lines are actually lower than the totals produced by its E911 listings.9 Nor has any CLEC disputed that the E911 methodology undercounts lines served.
Interconnection Trunks: 23 Million Facilities-Based CLEC Lines. CLECs have obtained approximately 9 million interconnection trunks from ILECs. In the reports they file with the FCC, however, the CLECs claim to be serving only 8.6 million lines over their own facilities. It is simply inconceivable that CLECs have obtained roughly one trunk for every line they serve.
CLECs serve a large number of residential and business customers for whom line-to- trunk ratios of between 4:1 and 10:1 are the industry norm. In arriving at the high-end estimate – 23 million facilities-based CLEC lines – presented in this report, the Bell companies used a ratio of 2.75 lines per interconnection trunk. That ratio is based on internal studies that one Bell company (SBC) performed in 1998. That study took a weighted average of the different kinds of customers that CLECs were likely to be serving at that time, and the line-to-trunk ratios they were likely to be using for those different types of customers. The study assumed that 65 percent of CLEC lines were provided to ISPs using a 1:1 line-to-trunk ratio, and that the remaining 35 percent were provided to business customers using a 6:1 line-to-trunk ratio.
Today, CLECs are serving a far higher percentage of non-ISP customers.10 Their average line-to-trunk ratios will therefore be considerably higher today than they were in 1998. Larger CLECs will have higher line-to-trunk ratios too, because large-number statistics make possible much more efficient sharing of trunks. And CLECs are much less likely to maintain inventories of inactive trunks today than they were in 1998. CLEC operations have grown much more efficient over time, and CLECs are now less likely to base day-to-day business decisions on over-optimistic projections of future growth.
For all of these reasons, our trunk-derived estimates of 23-million facilities-based CLEC lines are very conservative. As with the E911-derived estimates, the actual totals may well be two to ten times higher.
8 See, e.g., DOJ Arkansas/Missouri Evaluation at 4, n. 8 (“Estimated market share will vary depending on the methodology used to estimate facilities-based lines. The Department relied on entries in the E-911 database.”); DOJ New York Evaluation at 9; DOJ Kansas/Oklahoma Evaluation at 4, n. 11 & 7, n. 25; DOJ Massachusetts Evaluation at 4; DOJ Pennsylvania Evaluation at 4. 9 On a few occasions (e.g., Sprint in the first Georgia/Louisiana 271 proceeding and WorldCom in the Arkansas/Missouri 271 proceeding), CLECs have claimed that their residential E911 listings were only for test lines, not actual customers, and that they were no longer operating those test lines. While E911 listings are typically removed from the database when a customer modifies or terminates service on a given telephone number (e.g., when the customer switches to another carrier, or the customer’s phone number is transferred to a different address), at any given time a snapshot of the E911 database is taken there may still a few inactive E911 listings in the database. Such listings represent no more than a de minimis fraction of all CLEC listings in the database at any given time. 10 For example, based on E911 listings, CLECs serve approximately 3 million residential subscribers today over their own local switches, which represents between 13 and 19 percent of all lines that CLECs serve with their own switches.
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CLEC Reports to Investors: 156 Million Voice-Grade Equivalent Lines. Twelve CLECs publicly report the numbers of “voice-grade” “DS0” or “access line” “equivalents” they serve. Together they report serving a total of 156 million voice-grade circuits. See Section I, Table 4. In a recent presentation to Lehman Brothers, AT&T President David Dorman stated that AT&T’s local network alone was being used to serve “2.7 M local voice lines,” but “over 30 M DSO equivalents.”11 WorldCom’s most recent 10-K filed with the SEC indicates that it added more than 10 million “domestic local voice grade equivalents” in 2001 alone, bringing its total to more than 76 million.12
11 Dave Dorman, President, AT&T, Presentation Before the Lehman Brothers T3 Telecom, Trends and Technology Conference (Dec. 6, 2001). 12 WorldCom, Inc., Form 10-K (SEC filed Mar. 13, 2002).
A-4
APPENDIX B. CLEC CIRCUIT SWITCHES
This appendix tabulates the circuit switches that CLECs operate. It is based on information contained in Telcordia’s Local Exchange Routing Guide.
This appendix includes the switches owned by CLECs that have declared bankruptcy. Most such CLECs are still operational (and some are now emerging from bankruptcy). Moreover, switches are a sunk investment, so if one company ceases to use its switch it is highly likely that another company will quickly seize the opportunity to do so (and will probably be able to obtain the switch at a fire-sale price). In addition, even though some CLECs may now be experiencing financial troubles, the fact that they were able to deploy so many switches at one time is still highly probative of the ability of CLECs to deploy switches generally. In any event, switches operated by CLECs that have declared bankruptcy (as of March 31, 2002) represent no more than 17 percent of the total counted here.
CLEC Circuit Switches Serving BOC Rate Centers State BOC Type CLEC City Street Region AL BELLSOUTH DMH ALLTEL MONTGOMERY 6925 HALCYON DR AL VERIZON DMH AT&T BIRMINGHAM 2101 6TH AVE N AL BELLSOUTH 4E AT&T BIRMINGHAM 1715 6TH AVE N AL BELLSOUTH 4E AT&T MONTGOMERY 38 WASHINGTON AVE AL BELLSOUTH 5E E.SPIRE BIRMINGHAM 505 20TH ST AL BELLSOUTH 5E E.SPIRE MOBILE 103 DAUPHIN ST AL BELLSOUTH 5E E.SPIRE MONTGOMERY ONE COURT SQUARE AL BELLSOUTH 5E ICG COMMUNICATIONS BIRMINGHAM 2114 1ST AVE N AL BELLSOUTH NT5 INTERMEDIA COMMUNICATIONS BIRMINGHAM 2705 6TH AVE S AL BELLSOUTH DM5 ITC^DELTACOM ANNISTON 2 DELTA DR AL VERIZON DM5 ITC^DELTACOM BIRMINGHAM 900 APPALACHEE ST AL VERIZON DS ITC^DELTACOM HUNTSVILLE 8600 S MEMORIAL PKY AL BELLSOUTH DS ITC^DELTACOM MOBILE 25 BATTLESHIP PKY AL BELLSOUTH DS ITC^DELTACOM MONTGOMERY 10 TALLAPOOSA ST AL BELLSOUTH 5E KMC TELECOM HUNTSVILLE 994 EXPLORER BLVD AL BELLSOUTH 5E KMC TELECOM MONTGOMERY 315 N BAINBRIDGE ST AL BELLSOUTH DS LEVEL 3 BIRMINGHAM 600 18TH ST N AL BELLSOUTH DS NETWORK TELEPH. BIRMINGHAM 1920 OXMOOR RD AL BELLSOUTH 5E NEWSOUTH COMMUNICATIONS BIRMINGHAM 950 22ND ST SUITE 850 AL BELLSOUTH EWSD NEWSOUTH COMMUNICATIONS MOBILE 103 DAUPHIN ST AL BELLSOUTH DS US LEC BIRMINGHAM 600 UNIVERSITY PARK PL AL BELLSOUTH 5E US LEC MOBILE 3100 COTTAGE HILL RD @ BLDG-5 AL BELLSOUTH DMT WEBSHOPPE COMMUNICATIONS ALEXANDER CITY 246 CHURCH ST AR SBC 5E ADELPHIA LITTLE ROCK W 3RD ST & S GAINES ST AR SBC DS ALLTEL FAYETTEVILLE 138 N EAST AVE AR SBC DS ALLTEL FORT SMITH 101 N 13TH ST AR SBC DMH ALLTEL LITTLE ROCK 4001 N RODNEY PARHAM AR SBC 4E AT&T LITTLE ROCK 715 S LOUISIANA ST AR SBC 5E E.SPIRE LITTLE ROCK 124 W CAPITAL AVE AR SBC DMH TRIVERGENT LITTLE ROCK 1519 S BOWMAN RD AR SBC 5E WORLDCOM LITTLE ROCK 323 S CROSS ST AZ QWEST 5ES ADELPHIA PHOENIX 1402 E BUCKEYE RD AZ QWEST 5E ALLEGIANCE TELECOM PHOENIX 120 E VAN BUREN ST AZ QWEST 4E AT&T MESA 1231 W UNIVERSITY DR
B-1
CLEC Circuit Switches Serving BOC Rate Centers State BOC Type CLEC City Street Region AZ QWEST 4E AT&T PHOENIX 211 W MONROE ST AZ QWEST 5ES AT&T PHOENIX 211 W MONROE ST AZ QWEST 5ES AT&T PHOENIX 2730 E CAMELBACK RD AZ QWEST 4E AT&T TUCSON 126 E ALAMEDA ST AZ QWEST DM5 COX CHANDLER 100 N 79TH ST AZ QWEST DM5 COX PHOENIX 6610 W VAN BUREN ST AZ QWEST 5ES E.SPIRE TUCSON 33 N NORTH STONE AVE AZ QWEST DMS1/200 ELECTRIC LIGHTWAVE PHOENIX 313 N 3RD AVE AZ QWEST DMS100 ESCHELON PHOENIX 2600 N CENTRAL AVE AZ QWEST NT5 GLOBAL CROSSING PHOENIX 429 S 6TH DR AZ QWEST DS GREAT WEST SVCS CHANDLER 700 N CORONADO ST AZ QWEST NT5 INTERMEDIA COMMUNICATIONS PHOENIX 3115 N 3RD AVE AZ QWEST DS LEVEL 3 PHOENIX 811 S 16TH ST AZ QWEST DS LEVEL 3 TUCSON 210 W ELM ST AZ QWEST DS MCLEODUSA PHOENIX 1710 E GRANT ST AZ QWEST DS MOUNTAIN TELECOM SCOTTSDALE 10190 E MCKELLIPS RD AZ QWEST DMS100 NORTH COUNTY PHOENIX 1609 N 12TH ST COMMUNICATIONS AZ QWEST DMS100 NORTH COUNTY PHOENIX 1220 E WASHINGTON ST COMMUNICATIONS AZ QWEST DMS100 NORTH COUNTY TUCSON 177 N CHURCH AVE COMMUNICATIONS AZ QWEST NT5 SADDLEBACK COMMUNICATIONS SCOTTSDALE 10190 E MCKELLIPS RD COMPANY AZ QWEST NT5 TELIGENT TEMPE 7850 S HARDY DR AZ QWEST DM5 TIME WARNER TELECOM PHOENIX 3220 N 3RD ST AZ QWEST DM5 TIME WARNER TELECOM TUCSON 3836 S EVANS BLVD AZ QWEST NT5 WORLDCOM PHOENIX 111 W MONROE ST AZ QWEST 5ES WORLDCOM TUCSON 75 E ALAMEDA ST AZ QWEST NT5 XO PHOENIX 3930 E WATKINS ST CA SBC DS ADVANCED TELCOM GROUP CONCORD 2041 EAST ST CA SBC 5E ADVANCED TELCOM GROUP SAN RAFAEL 1009 E ST CA VERIZON 5E ALLEGIANCE TELECOM LOS ANGELES 818 W 7TH ST. SUITE 320 CA SBC 5E ALLEGIANCE TELECOM RANCHO 10995 GOLD CENTER DR CORDOVA CA SBC 5E ALLEGIANCE TELECOM SAN DIEGO 5761 COPLEY DR CA SBC 5E ALLEGIANCE TELECOM SAN FRANCISCO 651 BRANNAN STREET, 3RD FLOOR CA VERIZON 5E ALLEGIANCE TELECOM SANTA ANA 1251 E DYER RD CA SBC 5E2 ALLEGIANCE TELECOM SUNNYVALE 677 PALOMAR AVE CA SBC DS ARRIVAL COMMUNICATIONS BAKERSFIELD 1800 19TH ST CA VERIZON 5E AT&T ANAHEIM 217 N LEMON ST CA SBC 4E AT&T ANAHEIM 217 N LEMON ST CA SBC 4E AT&T DUNNIGAN INTER YOLO CNTY CA SBC 5E AT&T DUNNIGAN INTER YOLO COUNTY & ROADS 6 AND 86 CA SBC 4E AT&T GARDENA 17200 S VERMONT AVE CA VERIZON 5E AT&T LOS ANGELES 700 S FLOWER ST CA SBC 4E AT&T LOS ANGELES 420 S GRAND AVE CA SBC NT5 AT&T LOS ANGELES 420 S GRAND AVE CA SBC 5E AT&T MOJAVE N-O HWY 58 & 9 MI E-O MOJAVE INDEX D CA SBC 4E AT&T OAKLAND 1601 FRANKLIN ST
B-2
CLEC Circuit Switches Serving BOC Rate Centers State BOC Type CLEC City Street Region CA SBC NT5 AT&T OAKLAND 1601 FRANKLIN ST CA SBC 5E AT&T OAKLAND 344 20TH ST CA SBC 5E AT&T OAKLAND 1587 FRANKLIN ST CA VERIZON 4E AT&T OXNARD 1050 S C ST CA VERIZON 5E AT&T SACRAMENTO 603 S ST CA SBC 4E AT&T SACRAMENTO 1407-11-23 J ST CA VERIZON 4E AT&T SAN BERNARDINO 455 2ND ST CA SBC 5E AT&T SAN BERNARDINO 455 W 2ND ST CA SBC 5E AT&T SAN DIEGO 5464 MOREHOUSE DR CA SBC NT5 AT&T SAN DIEGO 650 ROBINSON AVE CA SBC 4E AT&T SAN DIEGO 650 ROBINSON AVE CA VERIZON 5E AT&T SAN FRANCISCO 1 BUSH ST CA VERIZON NT5 AT&T SAN FRANCISCO 360 SPEAR ST CA SBC 5E AT&T SAN FRANCISCO 555 PINE ST CA SBC 4E AT&T SAN FRANCISCO 611 FOLSOM ST CA SBC 5E AT&T SAN FRANCISCO 360 SPEAR ST CA VERIZON NT5 AT&T SAN JOSE 95 ALMADEN AVE CA SBC 4E AT&T SAN JOSE 95 ALMADEN AV CA SBC 5E AT&T SAN JOSE 95 ALMADEN AV CA VERIZON 5E AT&T SHERMAN OAKS 14800 VENTURA BLVD CA SBC 4E AT&T SHERMAN OAKS 14800 VENTURA BLVD CA SBC 5E AT&T SHERMAN OAKS 14800 VENTURA BLVD CA SBC 4E AT&T STOCKTON 344 N HUNTER ST CA SBC 5E AT&T STOCKTON 345 N SAN JOAQUIN AV CA SBC D12 CITIZENS ELK GROVE 820 ELK GROVE FLORIN RD CA VERIZON 5E COX ALISO VEIJO 17 JOURNEY ST CA SBC D12 COX EL CAJON 1175 N. CUYAMUCA ST. CA SBC DMS COX RANCHO SANTA 29947 AVENIDA DE LAS MARGARITA BANDERAS CA SBC D12 COX SAN DIEGO 1441 EUCLID AVE CA SBC D12 ELECTRIC LIGHTWAVE RANCHO 3224 LUYUNG DR. CORDOVA CA VERIZON NT5 FIRST WORLD COMMUNICATIONS ANAHEIM 1520 S LEWIS ST CA VERIZON NT5 FOCAL COMMUNICATIONS LOS ANGELES 1200 W 7TH ST CA VERIZON DM5 FOCAL COMMUNICATIONS SAN FRANCISCO 650 TOWNSEND ST CA SBC NT5 FOCAL COMMUNICATIONS SAN JOSE 1741 TECHNOLOGY DR CA VERIZON DS GLOBAL CROSSING ANAHEIM 2461 W LA PALMA AVE 2ND FLR CA SBC NT5 GLOBAL CROSSING CALIFORNIA SAN DIEGO CA SBC NT5 GLOBAL CROSSING SACRAMENTO 1303 J ST CA VERIZON 5E ICG COMMUNICATIONS ALHAMBRA 2300 W VALLEY BLVD CA SBC 5E ICG COMMUNICATIONS IRVINE 2968 WHITE RD., SUITE 200 CA VERIZON 5E ICG COMMUNICATIONS LAKEWOOD 4007 PARAMOUNT BLVD CA VERIZON 5E ICG COMMUNICATIONS LOS ANGELES 1905 ARMACOST AVE CA SBC 5E2 ICG COMMUNICATIONS LOS ANGELES 600 W 7TH ST CA SBC 5E2 ICG COMMUNICATIONS MILPITAS 1175 MONTAGUE EXPRESSWAY CA SBC 5E ICG COMMUNICATIONS OAKLAND 180 GRAND AVE CA VERIZON 5E ICG COMMUNICATIONS ONTARIO 1471 VALENCIA PL CA SBC 5E ICG COMMUNICATIONS SACRAMENTO 1414 K ST CA SBC 5E ICG COMMUNICATIONS SACRAMENTO 770 L ST CA SBC 5E ICG COMMUNICATIONS SAN DIEGO 8951 COMPLEX DR CA SBC 5E ICG COMMUNICATIONS SAN FRANCISCO 620 3RD ST
B-3
CLEC Circuit Switches Serving BOC Rate Centers State BOC Type CLEC City Street Region CA VERIZON 5E ICG COMMUNICATIONS SAN JOSE 190 PARK CENTER PLAZA CA SBC 5E KCINDUR COMM SAN LUIS OBISPO 872 MORRO ST CA SBC DS LEVEL 3 FRESNO 305 W NAPA AVE CA SBC DS LEVEL 3 WEST 1075 TRIANGLE CT SACRAMENTO CA VERIZON DMS MPOWER BELLFLOWER 16730 BELLFLOWER BLVD CA SBC DS MPOWER EMERYVILLE 1400 65TH ST CA SBC NT5 MPOWER LA MESA 4695 PALM AVE CA VERIZON DMS MPOWER POMONA 362 E 4TH ST CA SBC DS MPOWER SACRAMENTO 9332 TECH CENTER DR CA SBC NT5 MPOWER SAN JOSE 560 CHARCOT AVE CA VERIZON DM5 NET-TEL CORP. LOS ANGELES 530 W 6TH ST CA SBC NT5 NET-TEL CORP. SAN FRANCISCO 200 PAUL AVE CA VERIZON DMH NORTH COUNTY LOS ANGELES 624 SOUTH GRAND COMMUNICATIONS CA SBC DMH NORTH COUNTY SACRAMENTO 926 J ST COMMUNICATIONS CA SBC DMH NORTH COUNTY SAN DIEGO 4008 TAYLOR ST COMMUNICATIONS CA VERIZON DMH NORTH COUNTY SAN FRANCISCO 98 BATTERY ST COMMUNICATIONS CA VERIZON VCD PAETEC LOS ANGELES 530 W 6TH ST CA VERIZON NT5 POINTE COMM INC EL MONTE 11025 VALLEY BLVD CA SBC NT5 POINTE COMM INC SAN DIEGO 3949 RUFFIN RD CA SBC 5E RCN CARSON 1059 E BEDMAR ST CA SBC 5E RCN SAN FRANCISCO 200 PAUL AVE CA SBC D12 SIERRA TELEPHONE CO. OAKHURST 41950 ROAD 426 CA SBC 5E SUREWEST COMMUNICATIONS ROSEVILLE 224 LINCOLN ST CA VERIZON NT5 TELIGENT LOS ANGELES 1200 W 7TH ST CA SBC NT5 TELIGENT OAKLAND 1111 BROADWAY CA SBC DS TIME WARNER TELECOM BAKERSFIELD 1918 M ST CA SBC DM5 TIME WARNER TELECOM FRESNO 7576 N DEL MAR AVE CA SBC 5ESS TIME WARNER TELECOM IRVINE 7 MASON CA VERIZON DM5 TIME WARNER TELECOM LOS ANGELES 3700 WILSHIRE BLVD CA VERIZON DM5 TIME WARNER TELECOM RIVERSIDE 1110 PALMYRITA AVE CA SBC 5E TIME WARNER TELECOM SAN DIEGO 8925 WARE CT CA SBC DMS TIME WARNER TELECOM SAN DIEGO 1125 NINTH ST CA VERIZON DM5 TIME WARNER TELECOM SAN FRANCISCO 501 2ND ST CA VERIZON DM5 TIME WARNER TELECOM SAN LUIS OBISPO 3050 BROAD ST CA VERIZON DMS TIME WARNER TELECOM WALNUT CREEK 1340 TREAT BLVD CA VERIZON 5E U.S. TELEPACIFIC LOS ANGELES 800 W 6TH ST SUITE 300 3RD FLOOR CA SBC 5E U.S. TELEPACIFIC SAN DIEGO 6134 NANCY RIDGE DR CA SBC 5E U.S. TELEPACIFIC SAN JOSE 55 NICHOLSON LN CA SBC DM5 URJET BACKBONE NETWORK LOS ANGELES 624 S GRAND AVE 11TH FLOOR CA SBC 5E WESTERN INTEGRATED NORTH 5411 LUCE AVE NETWORKS HIGHLANDS CA VERIZON DE4 WORLDCOM ANAHEIM 905 EAST DISCOVERY LANE CA SBC 5E WORLDCOM BAKERSFIELD 1415 18TH ST CA SBC 5E WORLDCOM BAKERSFIELD 1415 18TH ST CA SBC 5E WORLDCOM FRESNO 1315 VAN NESS AVE CA SBC 5E WORLDCOM FRESNO 1315 VAN NESS
B-4
CLEC Circuit Switches Serving BOC Rate Centers State BOC Type CLEC City Street Region CA SBC DMH WORLDCOM HAYWARD 21350 CABOT BLVD CA VERIZON NT5 WORLDCOM IRVINE 17642 ARMSTRONG AVE CA VERIZON DE4 WORLDCOM LOS ANGELES 609 W 7TH AVE CA SBC AXT WORLDCOM LOS ANGELES 1149 S BROADWAY ST CA SBC AXT WORLDCOM LOS ANGELES 1149 SOUTH BROADWAY CA SBC 5E WORLDCOM REDWOOD CITY 2700 SPRING ST CA SBC DE4 WORLDCOM SAN DIEGO 707 BROADWAY CA SBC NT5 WORLDCOM SAN DIEGO 8806 COMPLEX DR CA SBC DMH WORLDCOM SAN DIEGO 8806 COMPLEX DR CA VERIZON DE4 WORLDCOM SAN FRANCISCO 274 BRANNAN ST CA SBC AXT WORLDCOM SAN FRANCISCO 525 MARKET ST CA SBC AXT WORLDCOM SAN FRANCISCO 525 MARKET ST CA SBC NT5 WORLDCOM SAN JOSE 611 RIVER OAKS PKY CA SBC 5E WORLDCOM STOCKTON 400 E MAIN ST CA SBC 5E WORLDCOM SUNNYVALE 464 OAKMEAD PKY CA SBC 5E WORLDCOM WEST 2820 KOVR DR SACRAMENTO CA SBC NT5 XO FREMONT 855 MISSION CT CA VERIZON DMS XO LONG BEACH 200 PINE AVE CA SBC DS XO LONG BEACH 200 PINE AVE CA SBC DMS XO LOS ANGELES 624 S GRAND CA SBC DMS XO LOS ANGELES 624 S GRAND CA SBC DM5 XO ROSEVILLE 1390 LEAD HILL BLVD CA SBC DMS XO SAN DIEGO 5771 COPLEY DR CA VERIZON NT5 XO SANTA ANA 1924 E DEERE AVE CA SBC DMS XO SANTA ANA 1924 E DEERE AVE CA SBC DMS XO SANTA ANA 1924 E DEERE AVE CT SBC DS ADVANCED TELCOM GROUP STAMFORD 76 PROGRESS DR CT SBC 5E AT&T BRIDGEPORT 522 FAIRFIELD AVE CT SBC NT5 AT&T CHESHIRE 751 HIGGINS RD CT SBC DMS AT&T HARTFORD 153 MARKET ST CT SBC 4E AT&T NEW HAVEN 310 ORANGE ST CT SBC NT5 AT&T STAMFORD 76 PROGRESS DR CT SBC 5E CABLEVISION LIGHTPATH NORWALK 28 CROSS ST CT SBC DS CHOICE ONE HARTFORD NORTHEAST PLZ TOWER 2 CT SBC 5E CONVERSENT NEW HAVEN 300 GEORGE ST CT SBC D12 COX MANCHESTER 170 UTOPIA RD CT SBC NT5 GLOBAL CROSSING STAMFORD 114 STILLWATER CT SBC D12 WORLDCOM HARTFORD 242 TRUMBULL ST CT SBC 5E WORLDCOM HARTFORD MAIN ST & GOLD ST CT SBC AXT WORLDCOM HARTFORD 185 ASYLUM ST CT SBC AXT WORLDCOM HARTFORD 185 ASYLUM ST @ SEE ALSO CITY PLACE CT SBC 5E WORLDCOM STAMFORD 1351 WASHINGTON BLVD CT SBC AXT WORLDCOM STAMFORD 3 LANDMARK SQ DC VERIZON 5E ALLEGIANCE TELECOM WASHINGTON 1120 VERMONT AVE NW DC VERIZON 5E ARBROS WASHINGTON 1201 L ST NW DC VERIZON 5E AT&T WASHINGTON 725 13TH ST. DC VERIZON 4E AT&T WASHINGTON 30 E ST SW DC VERIZON DMH AT&T WASHINGTON 1331 F ST NW DC VERIZON NT5 FOCAL COMMUNICATIONS WASHINGTON 1120 VERMONT AVE NW
B-5
CLEC Circuit Switches Serving BOC Rate Centers State BOC Type CLEC City Street Region DC VERIZON NT5 GLOBAL CROSSING WASHINGTON 1220 L ST N.W. DC VERIZON DM5 NET2000 WASHINGTON 1275 K ST DC VERIZON NT5 TELIGENT WASHINGTON 1120 VERMONT AVE NW DC VERIZON NT5 WORLDCOM WASHINGTON 120 INGRAHAM ST NE DC VERIZON 5E WINSTAR WASHINGTON 1850 M ST NW DC VERIZON VCD WINSTAR WASHINGTON 1850 M ST NW DC VERIZON DMS XO WASHINGTON 4301 CONNECTICUT AVE NW DE VERIZON DMH CAVALIER TELEPHONE NEWARK 500 N WAKEFIELD DR FL BELLSOUTH 5E ADELPHIA JACKSONVILLE 6263 PHILLIPS HWY FL BELLSOUTH 5E ADELPHIA TAMARAC 2121 W PROSPECT RD FL VERIZON 5E ALLEGIANCE TELECOM TAMPA 8230 E BROADWAY AVE FL BELLSOUTH 5E ALLTEL JACKSONVILLE 601 RIVERSIDE AVE FL BELLSOUTH 4E AT&T FORT 1352 NW 40TH AVE LAUDERDALE FL BELLSOUTH 5E AT&T FORT 1340 NW N.W. 40TH AVE LAUDERDALE FL VERIZON 5E AT&T JACKSONVILLE 424 PEARL ST FL BELLSOUTH 4E AT&T JACKSONVILLE 424 PEARL ST FL BELLSOUTH 5E AT&T JACKSONVILLE 424 N PEARL ST FL BELLSOUTH NT5 AT&T JACKSONVILLE 424 N PEARL ST FL BELLSOUTH 5E AT&T JACKSONVILLE 5934 RICHARD RD FL BELLSOUTH 4E AT&T OJUS 460 NE 215 ST FL BELLSOUTH NT5 AT&T OJUS 460 NE 215TH ST FL BELLSOUTH 4E AT&T ORLANDO 45 N MAGNOLIA AVE FL BELLSOUTH 5E AT&T ORLANDO 45 N MAGNOLIA AVE FL BELLSOUTH 5E AT&T ORLANDO 1151 N KELLER RD FL BELLSOUTH 5E AT&T POMPANO BEACH 141 NW 16TH ST FL VERIZON 4E AT&T TAMPA 2261 MASSARO BLVD FL VERIZON 5E AT&T TAMPA 6015 BENJAMIN RD FL BELLSOUTH 4E AT&T WEST PALM 325 GARDENIA ST BEACH FL BELLSOUTH 5E AT&T WEST PALM 3700 RCA BLVDAVE BEACH FL BELLSOUTH VCD BTI JACKSONVILLE 121 W FORSYTH ST SUITE 100 FL BELLSOUTH 5E BTI ORLANDO 201 S ORANGE AVE FL BELLSOUTH 5E BTI ORLANDO 201 S ORANGE AVE FL VERIZON VCD BTI TAMPA 400 N TAMPA ST FL BELLSOUTH 5E E.SPIRE FORT 100 NE 3RD AVE LAUDERDALE FL BELLSOUTH 5E E.SPIRE JACKSONVILLE 200 W FORSYTH ST FL VERIZON 5EH E.SPIRE TAMPA 111 MADISON ST FL BELLSOUTH 5E EAGLE COMMUNICATIONS MIAMI 1 NE 1ST ST FL BELLSOUTH NT5 FLORIDA DIGITAL NETWORK FORT 200 N ANDREWS AVE LAUDERDALE FL BELLSOUTH NT5 FLORIDA DIGITAL NETWORK GAINESVILLE 400 SW 2ND AVE FL BELLSOUTH NT5 FLORIDA DIGITAL NETWORK JACKSONVILLE 3986 BLVD CENTER DR FL BELLSOUTH NT5 FLORIDA DIGITAL NETWORK ORLANDO 390 N ORANGE AVE FL BELLSOUTH NT5 FLORIDA DIGITAL NETWORK PORT ORANGE 829 ORANGE AVE FL VERIZON NT5 FLORIDA DIGITAL NETWORK TAMPA 610 E ZACK ST FL VERIZON DMH FLORIDA DIGITAL NETWORK TAMPA 655 N FRANKLIN ST FL BELLSOUTH NT5 FOCAL COMMUNICATIONS MIAMI 701 BRICKELL AVE FL VERIZON NT5 GLOBAL CROSSING TAMPA 400 N TAMPA ST
B-6
CLEC Circuit Switches Serving BOC Rate Centers State BOC Type CLEC City Street Region FL BELLSOUTH NT5 GLOBAL NAPS MIAMI 100 S BISCAYNE BLVD FL BELLSOUTH DMS IDS TELECOM MIAMI 1080 NW 163RD DR FL BELLSOUTH VCD INTERLOOP INC MIAMI 15590 NW 15TH AVE FL VERIZON 5E INTERLOOP INC TAMPA 3403 ORIENT RD FL BELLSOUTH NT5 INTERMEDIA COMMUNICATIONS JACKSONVILLE 7020 A C SKINNER PKY FL BELLSOUTH DMS INTERMEDIA COMMUNICATIONS MIAMI 1907 NW 87TH ST FL BELLSOUTH NT5 INTERMEDIA COMMUNICATIONS ORLANDO 100 W LUCERNE CIR FL BELLSOUTH NT5 INTERMEDIA COMMUNICATIONS ORLANDO 111 N ORANGE AVE FL VERIZON DMT INTERMEDIA COMMUNICATIONS TAMPA 3502 QUEEN PALM DR FL BELLSOUTH DS ITC^DELTACOM DAYTONA BEACH 268 N RIDGEWOOD AVE FL BELLSOUTH DS ITC^DELTACOM JACKSONVILLE 421 W CHURCH ST FL BELLSOUTH DS ITC^DELTACOM OCALA 2909 SE 36TH AVE FL BELLSOUTH DS ITC^DELTACOM ORLANDO 201 S ORANGE AVENUE FL BELLSOUTH DS ITC^DELTACOM PANAMA CITY 1795 INDUSTRIAL DR FL BELLSOUTH DMS ITC^DELTACOM PENSACOLA 100 N Q ST FL VERIZON DS ITC^DELTACOM TAMPA 655 N FRANKLIN ST FL BELLSOUTH DS ITC^DELTACOM WEST PALM 1475 CENTREPARK BLVD BEACH FL VERIZON 5E KMC TELECOM CLEARWATER 12690 44TH ST N FL BELLSOUTH 5E KMC TELECOM ENSLEY 7891 SEARS BLVD FL BELLSOUTH 5E KMC TELECOM HOLLY HILL 1640 STATE AV FL BELLSOUTH 5E KMC TELECOM PALM BAY 2300 COMMERCE PARK DR NE FL VERIZON 5E KMC TELECOM SARASOTA 6288 TOWER LN FL BELLSOUTH DS LEVEL 3 JACKSONVILLE 4814 PHILLIPS HWY FL BELLSOUTH EWSD METTEL MIAMI 100 N BISCAYNE BLVD FL BELLSOUTH NT5 MPOWER FORT 201 NE 24TH ST LAUDERDALE FL VERIZON NT5 MPOWER TAMPA 655 N FRANKLIN ST FL BELLSOUTH 5E NETWORK PLUS MIAMI 100 NE 80TH TER FL BELLSOUTH DS NETWORK TELEPH. PENSACOLA 30 W BELMONT ST FL BELLSOUTH DCO NEW MILLENNIUM MIAMI 100 N BISCAYNE BLVD TELECOMMUNICATIONS INC. FL BELLSOUTH EWSD NEWSOUTH COMMUNICATIONS DESTIN 185 STAHLMAN AVE FL VERIZON 5E NEWSOUTH COMMUNICATIONS WINTER HAVEN 200 AVE B FL BELLSOUTH EWSD ORLANDO TELEPHONE ORLANDO 4558 35TH ST FL BELLSOUTH VCD PAETEC MIAMI 100 N BISCAYNE BLVD FL BELLSOUTH NT5 POINTE COMM INC MIAMI 99 S. E. 5TH STREET FL BELLSOUTH 5E SPRINT ORLANDO 200 E ROBINSON ST FL BELLSOUTH NT5 TELIGENT EATONVILLE 250 RIO DR FL BELLSOUTH 5E TIME WARNER TELECOM MAITLAND 2251 LUCIEN WAY FL BELLSOUTH 5E TIME WARNER TELECOM ORLANDO 7003 PRESIDENTS DR FL BELLSOUTH DMH TRIVERGENT MIAMI 18504 NE 5TH AVE FL VERIZON NT5 URBAN MEDIA LONG DISTANCE TAMPA 7808 WOODLAND CENTER BLVD FL BELLSOUTH 5E US LEC JACKSONVILLE 6410 SOUTHPOINT PKY FL BELLSOUTH VCD US LEC MIAMI 5301 BLUE LAGOON DR FL BELLSOUTH 5E US LEC PALM BEACH 7121 FAIRWAY DR GARDENS FL VERIZON 5E US LEC TAMPA 400 N TAMPA ST FL BELLSOUTH 5E WINSTAR MIAMI 150 SE 2ND AVE FL BELLSOUTH 5E WINSTAR ORLANDO 201 S ORANGE AVENUE FL VERIZON VCD WINSTAR TAMPA 4200 W CYPESS ST FL BELLSOUTH DE4 WORLDCOM MIAMI 150 SE 2ND AVE
B-7
CLEC Circuit Switches Serving BOC Rate Centers State BOC Type CLEC City Street Region FL BELLSOUTH 5E WORLDCOM MIAMI 8830 NW 18TH TER FL BELLSOUTH DE4 WORLDCOM MIAMI 150 SE 2ND AVE FL BELLSOUTH DE4 WORLDCOM ORLANDO 250 S. ORANGE AVE FL BELLSOUTH DMH WORLDCOM ORLANDO 400 LK DESTINY RD FL BELLSOUTH DE4 WORLDCOM POMPANO BEACH 599 SW 16TH TER FL BELLSOUTH DE4 WORLDCOM POMPANO BEACH 599 SW 16TH TER FL VERIZON DE4 WORLDCOM TAMPA 1000 NORTH ASHLEY DR. 9TH FL FL VERIZON DMH WORLDCOM TAMPA 8212 WOODLAND CENTER BLVD FL BELLSOUTH DMS XO MIAMI 16565 B NW 15TH ST FL VERIZON DM5 XO TAMPA 5904A HAMPTON OAKS PKY GA BELLSOUTH 5E ADELPHIA ATLANTA 953 DONNELLY AVE SW GA BELLSOUTH 5E ALLEGIANCE TELECOM ATLANTA 55 MARIETTA ST NW GA BELLSOUTH DMS ALLTEL AUGUSTA 1490 ELLIS ST GA BELLSOUTH DMH ALLTEL RINCON ONE BLOCK OFF HWY 21 GA BELLSOUTH 4E AT&T ATLANTA 3003 S COBB PKWY GA BELLSOUTH 4E AT&T ATLANTA 51 PEACHTREE CENTER AVE NE GA BELLSOUTH 5E AT&T ATLANTA 51 PEACHTREE CENTER AVE NE GA BELLSOUTH NT5 AT&T ATLANTA 51 PEACHTREE CENTER AVE NE GA BELLSOUTH 4E AT&T MACON 1030 GEORGIA AVE GA BELLSOUTH 5E AT&T MACON 1030 GEORGIA AVE GA BELLSOUTH 4E AT&T MONTICELLO 266 E GREEN ST GA BELLSOUTH DMH AT&T NORCROSS 5060 AVALON RIDGE PKY GA BELLSOUTH 5E AT&T STONE MOUNTAIN 4545 STONEGATE INDUSTRIAL BLVD GA BELLSOUTH 5E BTI ATLANTA 55 PARK PL NE GA BELLSOUTH DS COMM SOUTH COS HAWKINSVILLE BROAD ST GA BELLSOUTH EWS DARIEN COMMUNICATIONS DARIEN 1011 NORTHWAY ST GA BELLSOUTH 5E E.SPIRE ATLANTA 2 RAVINIA DR NE GA BELLSOUTH 5E E.SPIRE COLUMBUS 1044 FRONT ST GA BELLSOUTH NT5 FOCAL COMMUNICATIONS ATLANTA 250 WILLIAMS ST NW GA BELLSOUTH NT5 GLOBAL CROSSING ATLANTA 250 WILLIAMS ST GA BELLSOUTH 5E ICG COMMUNICATIONS CHAMBLEE 30 PERIMETER PARK DR GA BELLSOUTH NT5 INTERMEDIA COMMUNICATIONS ATLANTA 360 INTERSTATE NORTH PKY NW GA BELLSOUTH DS ITC^DELTACOM ATHENS 125 REESE ST GA BELLSOUTH DS ITC^DELTACOM ATLANTA 55 PARK PL NE GA BELLSOUTH DS ITC^DELTACOM AUGUSTA 301 15TH ST GA BELLSOUTH DS ITC^DELTACOM MACON 160 STATE ST GA BELLSOUTH DS ITC^DELTACOM SAVANNAH 1315 BULL ST GA BELLSOUTH 5E KMC TELECOM AUGUSTA 419 11TH ST GA BELLSOUTH 5E KMC TELECOM SAVANNAH 81 ROSS RD GA BELLSOUTH DS LECSTAR ALBANY 304 PINE AVE GA BELLSOUTH 5E LECSTAR AUGUSTA 937 GREENE ST GA BELLSOUTH DS LECSTAR MACON 787 CHERRY ST GA BELLSOUTH 5E LECSTAR SAVANNAH 1300 BULL ST GA BELLSOUTH EWS LIGHTSOURCE TELECOM ROSWELL 1940 OLD ALABAMA RD GA BELLSOUTH NT5 MPOWER ATLANTA 1593 NORTHEAST EXPY NE GA BELLSOUTH NT5 NET-TEL CORP. ATLANTA 250 WILLIAMS ST NW GA BELLSOUTH 5E NETWORK PLUS NORCROSS 3190 REPS MILLER RD NW GA BELLSOUTH DS NETWORK TELEPH. ATLANTA 2700 NE EXPRESSWAY ACCESS RD NE @ BLDG-B GA BELLSOUTH NT5 TELIGENT ATLANTA 55 MARIETTA ST
B-8
CLEC Circuit Switches Serving BOC Rate Centers State BOC Type CLEC City Street Region GA BELLSOUTH DS TOUCHTONE COMMUNICATIONS VALDOSTA 501 NORTH TOOMBS GA BELLSOUTH DS TRIVERGENT ATLANTA 3423 PIEDMONT RD NE GA BELLSOUTH 5E US LEC ATLANTA 2 CONCOURSE PKY NE GA BELLSOUTH 5E WINSTAR ATLANTA 34 PEACHTREE ST NW GA BELLSOUTH VCD WINSTAR ATLANTA 34 PEACHTREE ST GA BELLSOUTH AXT WORLDCOM ATLANTA 250 WILLIAMS ST NW GA BELLSOUTH DMH WORLDCOM ATLANTA 250 WILLIAMS ST NW GA BELLSOUTH DE4 WORLDCOM MARIETTA 1176 FRANKLIN ST GA BELLSOUTH DM5 XO SMYRNA 4000 HIGHLANDS PKY SE HI VERIZON DM5 TIME WARNER TELECOM HONOLULU 737 BISHOP ST IA QWEST 4E AT&T DES MOINES 925 HIGH IA QWEST 5ES AT&T DES MOINES 925 HIGH IA QWEST DMS10 CASCADE TELEPHONE CO. CASCADE 108 FILLMORE ST SE IA QWEST DMS1/200 FIBER COM SIOUX CITY 901 STEUBEN ST IA QWEST DMS10 GLOBAL CROSSING OAKLAND 505 LINDEN ST IA QWEST DMS100 HICKORYTECH URBANDALE 2859 99TH ST IA QWEST DMS1/200 IOWA NETWORK SERVICES, INC. DES MOINES 312 8TH ST IA QWEST DMS10 IOWA TELECOM OXFORD 116 PRARIE IA QWEST GT5 IOWA TELECOM REDFIELD 1111 THOMAS ST IA QWEST NT5 MCLEODUSA DAVENPORT 5617 W LOCUST ST IA QWEST DS MCLEODUSA DES MOINES 3540 SW 61ST ST ID QWEST DS CTC COMMUNICATIONS BOISE 5883 W DRY CREEK RD ID QWEST DSS ELECTRIC LIGHTWAVE BOISE 10452 EMERALD ST ID QWEST DS MCLEODUSA BOISE 314 S 6TH ST ID QWEST EWSD TIME WARNER TELECOM BOISE 199 N CAPITOL BLVD IL SBC DS ADELPHIA CHICAGO 601 W POLK ST IL SBC 5E ALLEGIANCE TELECOM CHICAGO 140 S DEARBORN IL VERIZON 5E AT&T CHICAGO 717 S WELLS ST IL SBC 4E AT&T CHICAGO 85 W CONGRESS PKY IL SBC NT5 AT&T CHICAGO 85 W CONGRESS PKY IL SBC DS AT&T CHICAGO 85 W CONGRESS PKY IL SBC 5E AT&T CHICAGO 10 S CANAL ST IL SBC 4E AT&T CHICAGO 10 S CANAL ST IL SBC 5E AT&T GLENVIEW 1900 PICKWICK IL SBC DS AT&T LISLE 4513 WESTERN AVE IL SBC 4E AT&T OAK BROOK 1000 COMMERCE DR IL SBC 5E AT&T OAK BROOK 1000 COMMERCE DR IL SBC 5E AT&T ROLLING 3820 GOLF RD MEADOWS IL SBC 5E CHOICE ONE MACHESNEY PARK 9934 N ALPINE RD IL SBC NT5 CORE COMMUNICATIONS CHICAGO 65 E WACKER PL IL SBC DS ELEC STERLING 2 EAST 3RD ST. IL SBC DMH FOCAL COMMUNICATIONS CHICAGO 200 N LA SALLE ST IL SBC DMH FOCAL COMMUNICATIONS ELK GROVE 1305 E ALGONQUIN RD TOWNSHIP IL SBC NT5 GLOBAL CROSSING CHICAGO 101 N. WACKER DR. SUITE 310 IL SBC DCO GLOBAL CROSSING POCAHONTAS MIDLAND TEL CO IL SBC DMS GLOBALCOM CHICAGO 520 S. FEDERAL IL SBC 5E2 ICG COMMUNICATIONS CHICAGO 717 S WELLS ST IL SBC NT5 INTERMEDIA COMMUNICATIONS CHICAGO 205 N MICHIGAN AVE IL SBC NT5 MADISON RIVER PEKIN 416 MARGARET ST
B-9
CLEC Circuit Switches Serving BOC Rate Centers State BOC Type CLEC City Street Region IL SBC 5E MCLEODUSA CHICAGO 427 S LA SALLE ST IL SBC NT5 MCLEODUSA SPRINGFIELD 528 S 5TH ST IL SBC NT5 MPOWER WHEELING 31 N WOLF IL SBC NT5 NET-TEL CORP. CHICAGO 717 S WELLS ST IL SBC 5E PAETEC CHICAGO 600 S FEDERAL ST IL VERIZON NT5 RCN CHICAGO 350 N ORLEANS ST IL SBC DS TDS VERNON HILLS 50 LAKEVIEW PKY IL SBC NT5 TELIGENT CHICAGO 111 N CANAL ST IL SBC NT5 WORLDCOM BENSENVILLE 602 N YORK RD IL SBC AXT WORLDCOM CHICAGO 800 S WELLS ST IL SBC NT5 WORLDCOM CHICAGO 550 W JACKSON IL SBC AXT WORLDCOM CHICAGO 800 S WELLS ST IL SBC DMH WORLDCOM ELK GROVE 955 ARTHUR AVE VILLAGE IL SBC NT5 XO CHICAGO 303 E WACKER DR IL SBC NT5 XO WOOD DALE 711 N EDGEWOOD AVE IN VERIZON 5EH AT&T EVANSVILLE 133-135 NW 5TH ST IN SBC 5E AT&T INDIANAPOLIS 112 W NORTH ST IN SBC DMH AT&T INDIANAPOLIS 711 WEST HENRY ST IN SBC VCD CHOICE ONE BLOOMINGTON 2599 W VERNAL PIKE TOWNSHIP IN VERIZON 5E CHOICE ONE FORT WAYNE 2730 E COLISEUM BLVD IN VERIZON 5E CHOICE ONE INDIANAPOLIS 701 W HENRY ST IN SBC VCD CHOICE ONE KNIGHT TOWNSHIP 5727 OLD BOONVILLE HWY IN SBC 5E CHOICE ONE MISHAWAKA 221 RED COACH DR IN SBC DE5 DIVERSIFIED COMMUNICATIONS MCCORDSVILLE 6061 W. PENDLETON PIKE, RD. 67 INC IN SBC DS FBN INDIANA MICHIGAN CITY 724 FRANKLIN ST IN SBC NT5 GLOBAL CROSSING INDIANAPOLIS 700 HENRY ST IN SBC DM5 GOLDEN HARBOR INDIANAPOLIS 800 OLIVER AVE IN VERIZON EWSD INDIGITAL FORT WAYNE 5312 WEST WASHINGTON CENTER ROAD IN SBC NT5 INTERMEDIA COMMUNICATIONS INDIANAPOLIS 550 KENTUCKY AV IN VERIZON 5E KMC TELECOM FORT WAYNE 1710 DIRECTORS ROW IN SBC DS LEVEL 3 INDIANAPOLIS 1902 S EAST ST IN SBC DS MCLEODUSA FISHERS 7998 CENTERPOINT DR IN SBC 5EH MICHIANA METRONET FRANKFORT 257 W CLINTON ST IN SBC DMT MICHIANA METRONET HARTFORD CITY 218 W FRANKLIN ST IN SBC D12 TELIGENT INDIANAPOLIS 5739 W MINNESOTA ST IN VERIZON 5E TIME WARNER TELECOM INDIANAPOLIS 1465 GENT AVE IN SBC NT5 TOTALINK EVANSVILLE 1301 W LLOYD EXPY IN SBC DMH TRIVERGENT INDIANAPOLIS 701 W HENRY ST IN SBC DMH WESTEL ANDERSON 121 E 11 ST IN SBC DMH WORLDCOM INDIANAPOLIS 6835 HILLSDALE CT KS SBC 5E ADELPHIA WICHITA 266 N MAIN KS SBC 5E AT&T KANSAS CITY 7400 JOHNSON DR KS SBC 4E AT&T WICHITA 154 N BROADWAY ST KS SBC 5E BIRCH TELECOM WICHITA 3450 N ROCK RD KS SBC 5E EVEREST CONNECTIONS LENEXA 9669 LACKMAN RD KS SBC NT5 IONEX TELECOMMUNICATIONS WICHITA 8201 E 34TH ST N INC. KS SBC 5E KMC TELECOM TOPEKA 2444 SE LAKEWOOD BLVD
B-10
CLEC Circuit Switches Serving BOC Rate Centers State BOC Type CLEC City Street Region KS SBC DMT RTSC COMMUNICATIONS LENORA LENORA KS SBC DMT RTSC COMMUNICATIONS VICTORIA VICTORIA KS KS SBC DMH TRIVERGENT LENEXA 7945 BOND ST KS SBC DMH TRIVERGENT WICHITA 8200 E 34 CIR N KS SBC NT5 WORLDNET, LLC DBA SU LAWRENCE 644 NEW HAMPSHIRE ST KY BELLSOUTH 5E ADELPHIA LOUISVILLE 962 S 3RD ST KY BELLSOUTH 4E AT&T LOUISVILLE 521 W CHESTNUT ST KY BELLSOUTH DMS AT&T LOUISVILLE 521 W CHESTNUT ST KY BELLSOUTH NT5 AT&T LOUISVILLE 521 W CHESTNUT ST KY BELLSOUTH 5E E.SPIRE LOUISVILLE 462 S 4TH ST KY BELLSOUTH 5E E-TEL MURRAY 401 OLIVE ST KY BELLSOUTH 5E ICG COMMUNICATIONS LOUISVILLE 332 W BROADWAY ST KY BELLSOUTH DS LEVEL 3 LOUISVILLE 848 S 8TH ST KY VERIZON D12 MIKROTEC COMMUNICATIONS LEXINGTON 1001 WINCHESTER RD KY VERIZON POI NEWSOUTH COMMUNICATIONS LEXINGTON 151 S MARTIN LUTHER KING BLVD KY VERIZON D12 TOUCHTONE COMMUNICATIONS LEXINGTON 250 W MAIN ST KY BELLSOUTH DS TOUCHTONE COMMUNICATIONS PADUCAH 1158 JEFFERSON ST KY BELLSOUTH 5E US LEC LOUISVILLE 9780 ORMSBY STATION RD KY BELLSOUTH DS VISION PADUCAH 923 WASHINGTON ST LA BELLSOUTH 5E ADELPHIA BATON ROUGE 301 MAIN ST LA BELLSOUTH D12 ADVANCED TELCOM GROUP BATON ROUGE 620 FLORIDA ST LA BELLSOUTH 4E AT&T BATON ROUGE 333 N 6TH ST LA BELLSOUTH 4E AT&T NEW ORLEANS 840 POYDRAS/520 BARONNE LA BELLSOUTH DS CENTURYTEL INC SHREVEPORT 406 COTTON ST LA BELLSOUTH VCD COLUMBIA TELECOMM NEW ORLEANS 1340 POYDRAS ST LA BELLSOUTH NT5 COX HARAHAN 338 EDWARDS AVE LA BELLSOUTH DMT CP-TEL NETWORK SERVICES, INC. NATCHITOCHES 5909 HWY 1 BYPASS LA BELLSOUTH 5E E.SPIRE NEW ORLEANS 1250 POYDRAS AVE LA BELLSOUTH DM5 INTERMEDIA COMMUNICATIONS SHREVEPORT 724 MCNEIL ST LA BELLSOUTH DS ITC^DELTACOM BATON ROUGE 446 NORTH BLVD LA BELLSOUTH DS ITC^DELTACOM LAKE CHARLES 902 RAILROAD AVE LA BELLSOUTH DS ITC^DELTACOM MONROE 117 HART ST LA BELLSOUTH DS ITC^DELTACOM NEW ORLEANS 639 LOYOLA AVE LA BELLSOUTH DS ITC^DELTACOM SCOTT 220 RUE BON SECOURS LA BELLSOUTH DS ITC^DELTACOM SHREVEPORT 724 MCNEIL ST LA BELLSOUTH 5E KMC TELECOM BATON ROUGE 5758 ESSEN LN LA BELLSOUTH 5E KMC TELECOM MONROE 1908 PINE ST LA BELLSOUTH 5E KMC TELECOM SHREVEPORT 506 CADDO ST LA BELLSOUTH DS LEVEL 3 METAIRIE 3220 LAUSAT ST LA BELLSOUTH DS LOUISIANA COMPETITIVE KAPLAN KAPLAN LN TELECOMMUNICATIONS, INC. LA BELLSOUTH D12 MADISON RIVER NEW ORLEANS 1650 POYDRAS ST LA BELLSOUTH NT5 MCLEODUSA LAFAYETTE 201 W VERMILLION ST LA BELLSOUTH DS NETWORK TELEPH. BATON ROUGE 566 LOBDELL AVE LA BELLSOUTH DS NETWORK TELEPH. LAFAYETTE 110 CENTRAL ST LA BELLSOUTH DS NETWORK TELEPH. NEW ORLEANS 115 GRUNER RD LA BELLSOUTH DS NETWORK TELEPH. SHREVEPORT 602 CROCKETT ST LA BELLSOUTH EWSD NEWSOUTH COMMUNICATIONS METAIRIE 1008 L AND A RD LA BELLSOUTH 5E RESERVE LONG DIST RESERVE 100 RTC DRIVE LA BELLSOUTH DS STRATOS TELECOM, INC. MORGAN CITY 1750 YOUNGS RD
B-11
CLEC Circuit Switches Serving BOC Rate Centers State BOC Type CLEC City Street Region LA BELLSOUTH DMH STRATOS TELECOM, INC. NEW ORLEANS 701 POYDRAS ST LA BELLSOUTH DS STRATOS TELECOM, INC. VENICE 523 JUMP BASIN RD @ WREHSE ON SHELL DOCK LA BELLSOUTH VCD XSPEDIUS CORP. LAKE CHARLES 844 RYAN ST MA VERIZON DS ADELPHIA SOMERVILLE 70 INNERBELT RD MA VERIZON 5E ALLEGIANCE TELECOM BOSTON 451 D ST MA VERIZON 5E AT&T BOSTON 230 CONGRESS ST MA VERIZON NT5 AT&T BOSTON 451 D ST MA VERIZON 4E AT&T CAMBRIDGE 250 BENT ST MA VERIZON 5E AT&T CAMBRIDGE 250 BENT ST MA VERIZON 5E AT&T FOXBORO 85 E. BELCHER RD MA VERIZON 5E AT&T FRAMINGHAM 825 WAVERLY STREET MA VERIZON 5E AT&T FRAMINGHAM 825 WAVERLY STREET MA VERIZON 5E AT&T LOWELL 12 WASHER ST MA VERIZON 5E AT&T MARLBORO 19 BRIGHAM ST MA VERIZON 5E AT&T NEEDHAM 95 WEXFORD ST MA VERIZON 4E AT&T SPRINGFIELD 351 BRIDGE ST MA VERIZON 4E AT&T WORCESTER 175 MAIN ST MA VERIZON NT5 BROADVIEW CHARLESTOWN 500 RUTHERFORD AVE SUITE 202 MA VERIZON 5E CHOICE ONE SPRINGFIELD 1 FEDERAL ST - BUILDING 111-3 MA VERIZON 5E CHOICE ONE WORCESTER 474 MAIN ST MA VERIZON DCO COMAV FRAMINGHAM 111 SPEEN ST MA VERIZON 5E CONVERSENT WORCESTER 90 WASHINGTON ST MA VERIZON 5E CORE COMMUNICATIONS BOSTON 451 D ST MA VERIZON NT5 FOCAL COMMUNICATIONS CAMBRIDGE ONE MAIN ST MA VERIZON NT5 GLOBAL CROSSING BOSTON 230 CONGRESS ST MA VERIZON NT5 GLOBAL CROSSING WESTFIELD 8 WILLIAMS WAY MA VERIZON NT5 INTERMEDIA COMMUNICATIONS CAMBRIDGE 179 5TH ST MA VERIZON DMS LIGHTSHIP TELECOM WORCESTER 44 FRONT ST MA VERIZON DMH NECLEC LLC SPRINGFIELD 167 MARKET PL. MA VERIZON NT5 NET2000 CHARLESTOWN 500 RUTHERFORD AVE MA VERIZON 5E NETWORK PLUS CAMBRIDGE 185 BENT ST MA VERIZON DS NORFOLK COUNTY COMM FRANKLIN 13 MAIN ST MA VERIZON 5E PAETEC BOSTON 230 CONGRESS ST MA VERIZON 5E RCN SOUTH BOSTON 105 W 1ST ST MA VERIZON DMT RICHMOND CONNECTIONS RICHMOND CANAAN RD & RICHMOND RD MA VERIZON NT5 TELIGENT CHARLESTOWN 500 RUTHERFORD AVE MA VERIZON 5E WINSTAR BOSTON 99 SUMMER ST MA VERIZON NT5 WORLDCOM ACTON 31 NAGOG PARK MA VERIZON NT5 WORLDCOM BOSTON 800 BOYLSTON ST MA VERIZON DMH WORLDCOM CAMBRIDGE 300 BENT ST MA VERIZON 5EH WORLDCOM SPRINGFIELD 1 FEDERAL ST MA VERIZON AXT WORLDCOM WALTHAM 580 WINTER ST MA VERIZON NT5 XO CAMBRIDGE 89 FULKERSON ST MD VERIZON 5E ADELPHIA BALTIMORE 300 W LEXINGTON ST MD VERIZON 5EH ADVANCED TELCOM GROUP ROCKVILLE 515 DOVER RD MD VERIZON 5E ALLEGIANCE TELECOM BALTIMORE 100 S CHARLES ST MD VERIZON 5E AT&T BALTIMORE 323 N CHARLES ST MD VERIZON DMH AT&T BALTIMORE 25 S CHARLES ST MD VERIZON NT5 AT&T COLUMBIA 9151 RUMSEY RD MD VERIZON 4E AT&T MONROVIA 11026 FINGERBOARD RD
B-12
CLEC Circuit Switches Serving BOC Rate Centers State BOC Type CLEC City Street Region MD VERIZON VCD BROADSTREET LINTHICUM 989 CORPORATE BLVD HEIGHTS MD VERIZON DMH CAVALIER TELEPHONE SALISBURY 128 E CHURCH ST MD VERIZON NT5 COMCAST BALTIMORE 8031 CORPORATE DR MD VERIZON DMH CORE COMMUNICATIONS BALTIMORE 200 E LEXINGTON ST MD VERIZON 5E E.SPIRE LAUREL 14405 LAUREL PL MD VERIZON NT5 GLOBAL CROSSING BALTIMORE 1628 ST PAUL ST MD VERIZON 5E KMC TELECOM IJAMSVILLE 3005 BIG WOODS RD MD VERIZON DM5 NET2000 BALTIMORE 300 W LEXINGTON ST MD VERIZON 5E RCN LANHAM 10000 DEREKWOOD LN MD VERIZON 5E WINSTAR BALTIMORE 201 N CHARLES ST MD VERIZON NT5 WORLDCOM BALTIMORE 111 MARKET PL MD VERIZON DMH WORLDCOM BALTIMORE 900 FLEET ST ME VERIZON DMT CRC COMMUNICATIONS PORTLAND 92 OAK ST ME VERIZON EWSD FAIRPOINT FRYEBURG 9 MI E OF CONWAY NH ME VERIZON DMT LIGHTSHIP TELECOM PORTLAND 1 CITY CTR ME VERIZON DCO LINCOLNVILLE DAMARISCOTTA 18 MI E OF BATH COMMUNICATIONS ME VERIZON DMT MID-MAINE COMMUNICATIONS KENDUSKEAG 646 KENDUSKEAG RD ME VERIZON DS OXFORD NETWORKS NORWAY 27 FAIR ST ME VERIZON 5E WORLDCOM PORTLAND 380 CUMBERLAND(NYNEX) AVE MI SBC 5E ADELPHIA SOUTHFIELD 21355 MELROSE ST MI SBC 5E ALLEGIANCE TELECOM SOUTHFIELD 21455 MELROSE ST MI VERIZON NT5 AT&T DETROIT 445 STATE ST MI SBC 4E AT&T PLYMOUTH 1316 W ANN ARBOR RD MI SBC 5E AT&T PLYMOUTH 1316 ANN ARBOR RD W MI VERIZON 5E AT&T SOUTHFIELD 1000 TOWN CENTER DR MI SBC DMT BARAGA TELEPHONE COM BARAGA 204 STATE ST MI SBC 5E CENTURYTEL INC GRAND RAPIDS 5005 STARR ST SE MI SBC 5E CHOICE ONE ANN ARBOR 220 E HURON ST MI SBC 5E CHOICE ONE PORTAGE 4750 COMMERCIAL AVE MI VERIZON 5E COMCAST WESTLAND 38205 N EXECUTIVE DR MI SBC NT5 CORE COMMUNICATIONS TROY 1179 MAPLELAWN DR MI SBC 5E CTS TELECOM CLIMAX BOX 103 CLIMAX MI SBC NT5 FOCAL COMMUNICATIONS SOUTHFIELD 23800 W 10 MILE RD MI SBC 5E KMC TELECOM LANSING 240 E SOUTH ST MI SBC 5E KMC TELECOM PITTSFIELD 4575 CONCOURSE DR TOWNSHIP MI SBC DS LEVEL 3 GRAND RAPIDS 209 GRAHAM ST SW MI VERIZON 5E MCLEODUSA FLINT 4074 S LINDEN RD MI VERIZON 5E MCLEODUSA FLINT G 4074 S LINDEN RD MI SBC DS MPOWER SOUTHFIELD 300 GALLERIA OFFICECENTRE MI SBC NT5 NET-TEL CORP. SOUTHFIELD 21355 MELROSE ST MI VERIZON 5E TC3 TELECOM ADRIAN 1114F S WINTER ST MI SBC DS TDS LANSING 5643 ENTERPRISE DR MI SBC DS TDS PLYMOUTH 45053 FIVE MILE RD MI SBC EWSD TDS WYOMING 1575 GEZON PKWY SW MI SBC NT5 TELIGENT SOUTHFIELD 2100 MELROSE MI SBC NT5 TELIGENT SOUTHFIELD 2100 MELROSE MI SBC DMH WORLDCOM GRAND RAPIDS 2855 OAK INDUSTRIAL DR NE MI SBC DMS WORLDCOM LANSING 5688 W GRAND RIVER AVE
B-13
CLEC Circuit Switches Serving BOC Rate Centers State BOC Type CLEC City Street Region MI SBC AXT WORLDCOM SOUTHFIELD 21500 MELROSE AVE MI SBC DMH WORLDCOM SOUTHFIELD 21500 MELROSE AVE MI SBC AXT WORLDCOM SOUTHFIELD 21500 MELROSE AVE MI SBC DMS WORLDCOM TRAVERSE CITY 133 E STATE ST MI VERIZON DM5 XO SOUTHFIELD 21555 MELROSE AVENUE BLDG 8 MN QWEST 5E ALLEGIANCE TELECOM MINNEAPOLIS 250 MARQUETTE AVE MN QWEST 5ES AT&T MINNEAPOLIS 511 11TH AVE S MN QWEST 4E AT&T MINNEAPOLIS 200 S 5TH ST MN QWEST 4E AT&T MINNEAPOLIS 200 S 5TH ST MN QWEST 5ES AT&T ROSEVILLE 2611 FAIRVIEW AVE N MN QWEST DMS1/200 ESCHELON MINNEAPOLIS 511 11TH AVE S MN QWEST NT5 FOCAL COMMUNICATIONS MINNEAPOLIS 222 S 9TH ST MN QWEST DMS1/200 GLOBAL CROSSING APPLE VALLEY 109 GARDEN VIEW DR MN QWEST NT5 GLOBAL CROSSING MINNEAPOLIS 511 11TH AVE S MN QWEST EWSD INTEGRA TELECOM LAKE 55372 PRIOR MN QWEST 5ES INTEGRA TELECOM LAKE 55372 PRIOR MN QWEST NT5 INTEGRA TELECOM ST CLOUD 26 6TH AVE N MN QWEST NT5 INTERMEDIA COMMUNICATIONS MINNEAPOLIS 511 11TH AVE S MN QWEST 5ES KMC TELECOM GOLDEN VALLEY 730 BOONE AVE N MN QWEST DS LEVEL 3 MINNEAPOLIS 511 11TH AVE S MN QWEST 5ES MCLEODUSA MINNEAPOLIS 401 2ND AVE S MN QWEST DMS100 ONVOY PLYMOUTH 10300 6TH AVE N MN QWEST DMS1/200 TELIGENT EAGAN 3030 LEXINGTON AVE MN QWEST DS TIME WARNER TELECOM MINNETONKA 5480 FELTL RD MN QWEST DMS100 VAL-ED JOINT VENTURE LLP MOORHEAD 702 MAIN AVE MN QWEST DMS10 VAL-ED JOINT VENTURE LLP MOORHEAD 702 MAIN AVE MN QWEST 5ES WHLINK ANNANDALE 110 OAK AVE N MN QWEST VCD WINSTAR MINNEAPOLIS 608 2ND AVE S MN QWEST 5ES WORLDCOM MINNEAPOLIS 511 11TH AVE S MN QWEST NT5 WORLDCOM MINNEAPOLIS 331 2ND AVE S MN QWEST 5ES WORLDCOM ST PAUL 333 SIBLEY ST MN QWEST DS XO MINNEAPOLIS 1200 WASHINGTON AVE N MO SBC 5E ALLEGIANCE TELECOM ST LOUIS 710 N TUCKER 4TH FLR MO SBC DMS ALLTEL GREENVILLE ALLIED TELEPHONE MO SBC DS ALLTEL SPRINGFIELD 3330 E MONTCLAIR MO SBC DMS ALLTEL VANDALIA ALLIED TEL CO MO VERIZON 5E AT&T CREVE COEUR 11840 BORMAN DR MO SBC 4E AT&T HILLSBORO 8201 HWY 21 MO SBC 4E AT&T KANSAS CITY 1425 OAK TRFY MO SBC 5E AT&T KANSAS CITY 324 E 11TH ST MO SBC 5E AT&T KANSAS CITY 1425 OAK TRFY MO SBC 4E AT&T ST LOUIS 2651 OLIVE MO SBC 5E AT&T ST LOUIS 2651 OLIVE MO SBC 4E AT&T ST.LOUIS 2651 OLIVE MO SBC 5E BIRCH TELECOM KANSAS CITY 324 E 11TH ST MO SBC 5E BIRCH TELECOM MARYLAND 107 WELDON PKY HEIGHTS MO SBC NT5 DIGITAL TELEPORT MARYLAND 11111 DORSETT RD HEIGHTS MO SBC 5E E.SPIRE KANSAS CITY 1100 MAIN ST, CITY CENTER SQUARE
B-14
CLEC Circuit Switches Serving BOC Rate Centers State BOC Type CLEC City Street Region MO SBC NT5 GLOBAL CROSSING KANSAS CITY 1100 MAIN ST CENTER CITY MO SBC NT5 INTERMEDIA COMMUNICATIONS ST LOUIS 1445 N WARSON RD MO SBC DS LEVEL 3 KANSAS CITY 1100 WALNUT MO SBC DS MCLEODUSA KANSAS CITY 1201 TROOST AVE MO SBC DM5 MCLEODUSA SPRINGFIELD 331 PARK CENTRAL E MO SBC NT5 MCLEODUSA ST LOUIS 210 N TUCKER BLVD MO SBC NT5 MPOWER ST LOUIS 11756 BORMAN DR MO SBC DMH ST LOUIS ELECTRONICS HARVESTER 111 TOELLE MO SBC 1AE ST LOUIS ELECTRONICS ST LOUIS 3810 WASHINGTON MO SBC NT5 TELIGENT KANSAS CITY 2501 W PENNWAY ST MO SBC DMH TRIVERGENT OLIVETTE 10405 BAUR BLVD MO SBC DMH TRIVERGENT SPRINGFIELD 1521-1527 E LARK ST MO SBC 5E WORLDCOM KANSAS CITY 324 E 11TH ST MO SBC AXT WORLDCOM MERILYN 11636 LACKLAND RD MO SBC 5E WORLDCOM SPRINGFIELD 940 E TRAFFICWAY ST MO SBC AXT WORLDCOM ST LOUIS 11636 LACKLAND RD MO SBC NT5 XO MARYLAND 2020 WESTPORT CENTER DR HEIGHTS MS BELLSOUTH 5E ADELPHIA JACKSON 142 LEFLEUR SQUARE RD MS BELLSOUTH 4E AT&T JACKSON 210 E PEARL ST MS BELLSOUTH DS AT&T JACKSON 210 E PEARL ST MS BELLSOUTH NT5 CGI JACKSON 700 S WEST ST RM 203 MS BELLSOUTH DS DIXIENET COMMUNICATIONS RIPLEY 301 N MAIN ST MS BELLSOUTH DMT GULFPINES COMMUNICATIONS HATTIESBURG 200 FOXGATE AVE MS BELLSOUTH DS ITC^DELTACOM GULFPORT 2221 17TH ST MS BELLSOUTH DS ITC^DELTACOM JACKSON 125 S CONGRESS ST MS BELLSOUTH 5E KMC TELECOM GULFPORT 277 DEBUYS RD MS BELLSOUTH DS NETWORK TELEPH. JACKSON 209 E CAPITOL ST MS BELLSOUTH 5E WORLDCOM JACKSON 317 E CAPITOL ST MS BELLSOUTH 5E XSPEDIUS CORP. JACKSON 108 BUSINESS PARK DR MT QWEST VCD AVISTA COMMUNICATIONS BILLINGS 210 N 29TH ST NC BELLSOUTH 5E ADELPHIA CHARLOTTE 1027 N CHURCH ST NC BELLSOUTH DMH ALLTEL GARNER 3651 JUNCTION BLVD NC BELLSOUTH DMH ALLTEL GREENSBORO 111 W FLORIDA ST NC BELLSOUTH DMH ALLTEL MATTHEWS 131 W MATTHEWS ST NC BELLSOUTH 4E AT&T CHARLOTTE 208 N CALDWELL ST NC BELLSOUTH 5E AT&T CHARLOTTE 208 N CALDWELL ST NC BELLSOUTH DMH AT&T CHARLOTTE 200 S COLLEGE ST NC BELLSOUTH 4E AT&T DURHAM CHIN PAGE RD NC BELLSOUTH 4E AT&T GREENSBORO 100 S EUGENE ST NC BELLSOUTH NT5 AT&T GREENSBORO 100 S EUGENE ST NC VERIZON NT5 AT&T RALEIGH 128 W HARGETT ST (121 W MORGAN ST) NC BELLSOUTH 5E BTI CHARLOTTE 701 E TRADE ST NC BELLSOUTH 5E BTI GREENSBORO 105 CREEK RIDGE RD NC BELLSOUTH 5E BTI RALEIGH 2111 HARROD ST NC BELLSOUTH 5E BTI WILMINGTON 3255 BURNT MILL DR NC BELLSOUTH 5E CONNECT COMMUNICATIONS CHARLOTTE 401 S COLLEGE ST NC VERIZON DM5 CTC COMMUNICATIONS CHARLOTTE 401 S COLLEGE ST NC VERIZON 5E ICG COMMUNICATIONS CHARLOTTE 401 S COLLEGE ST NC BELLSOUTH NT5 INTERMEDIA COMMUNICATIONS CHARLOTTE 9400-A SOUTHERN PINES BLVD.
B-15
CLEC Circuit Switches Serving BOC Rate Centers State BOC Type CLEC City Street Region NC BELLSOUTH DM5 INTERMEDIA COMMUNICATIONS DURHAM 5400 S. MIAMI BLVD. SUITE #124 NC VERIZON DS ITC^DELTACOM ASHEVILLE 24 O HENRY AVE NC BELLSOUTH DS ITC^DELTACOM CHARLOTTE 401 S COLLEGE ST NC VERIZON DS ITC^DELTACOM DURHAM 2003 E USHWY 54 NC BELLSOUTH DS ITC^DELTACOM GREENSBORO 301 S ELM ST NC BELLSOUTH DS ITC^DELTACOM RALEIGH 213 N HARRINGTON ST NC BELLSOUTH DS ITC^DELTACOM WILMINGTON 4428A S COLLEGE RD NC BELLSOUTH 5E KMC TELECOM GREENSBORO 2423 BINFORD ST NC BELLSOUTH 5E KMC TELECOM WINSTON-SALEM 133 HICKS ST NC VERIZON DS LEVEL 3 CHARLOTTE 4021 ROSE LAKE DR NC BELLSOUTH DS LEVEL 3 GREENSBORO 105 CREEK RIDGE RD NC VERIZON DS LEVEL 3 RALEIGH 5301 DEPARTURE DR NC BELLSOUTH NT5 MADISON RIVER MEBANE 109 W WASHINGTON ST NC VERIZON NT5 MADISON RIVER MORRISVILLE 5150 MCCRIMMON PKY NC BELLSOUTH DS MPOWER CHARLOTTE 3101 YORKMONT NC BELLSOUTH DS NETWORK TELEPH. CHARLOTTE 208 N CALDWELL ST NC BELLSOUTH DMH TELIGENT CHARLOTTE 3101 INTERNATIONAL AIRPORT DR NC BELLSOUTH 5E TIME WARNER TELECOM CHARLOTTE 1500 N SHARON AMITY RD NC BELLSOUTH 5E TIME WARNER TELECOM DURHAM 924 ELLIS RD NC BELLSOUTH 5E TIME WARNER TELECOM GREENSBORO 496 GALLIMORE DAIRY RD NC BELLSOUTH DMH TRIVERGENT GREENSBORO 100 N GREENE ST NC VERIZON 5E US LEC CHARLOTTE 222 S CALDWELL ST NC BELLSOUTH 5E US LEC GREENSBORO 301 S ELM ST NC VERIZON 5E US LEC RALEIGH 2201 BRENTWOOD RD NC BELLSOUTH 5E WINSTAR CHARLOTTE 200 S COLLEGE ST NC VERIZON NT5 WORLDCOM MORRISVILLE 1500 PERIMETER PARK DR NC BELLSOUTH 5E XSPEDIUS CORP. GREENSBORO 1801 STANLEY RD ND QWEST EWSD IDEAONE FARGO 3239 39TH ST SW ND QWEST DMS10 INTER - COMMUNITY TELEPHONE BUFFALO INTERCOMMUNITY TEL CO CO. ND QWEST 5ES MCLEODUSA FARGO 2911 FIECHTNER DR ND QWEST 5ES WESTERN CLEC CORPORATION WEST FARGO 1447 44TH ST NW NE QWEST NT5 ALLTEL OMAHA 10630 BURT NE QWEST DMS10 ARLINGTON TELEPHONE CO. ARLINGTON 615 W DODGE INDEP CO NE QWEST 4E AT&T OMAHA 118 S 19TH ST NE QWEST 5ES AT&T OMAHA 118 S 19TH ST NE QWEST 4E AT&T OMAHA 4015 S 132ND ST NE QWEST 5ES AT&T OMAHA 2505 S 72ND ST NE QWEST DMS1/200 COX OMAHA 11505 W DODGE RD NE QWEST DMS1/200 COX OMAHA 11505 W DODGE RD NE QWEST DS LEVEL 3 BELLEVUE 1514 CHANDLER RD NE QWEST DS MCLEODUSA OMAHA 1721 ST MARYS AVE NE QWEST DCO NORTHEAST NEBRASKA JACKSON 1 BLK N OF HWY 20 TELEPHONE CO. NH VERIZON 4E AT&T MANCHESTER 25 CONCORD ST NH VERIZON D12 BAYRING PORTSMOUTH 11 MANCHESTER SQ NH VERIZON 5E CHOICE ONE MANCHESTER 25 SUNDIAL AVE NH VERIZON 5E CONVERSENT NASHUA 145 TEMPLE ST NH VERIZON EWSD FAIRPOINT MANCHESTER 1 SUNDIAL AVE NH VERIZON DMT LIGHTSHIP TELECOM MANCHESTER 55 BRIDGE ST
B-16
CLEC Circuit Switches Serving BOC Rate Centers State BOC Type CLEC City Street Region NH VERIZON 5E WORLDCOM MANCHESTER 1100 ELM ST NH VERIZON 5EH WORLDCOM NASHUA 97 MAIN ST NJ VERIZON 5E ADELPHIA PISCATAWAY 225 OLD NEW BRUNSWICK RD NJ VERIZON DS ADVANCED TELCOM GROUP HAMILTON 3575 QUAKERBRIDGE RD TOWNSHIP (MERCER) NJ VERIZON 4E AT&T CAMDEN 12 N 7TH ST NJ VERIZON NT5 AT&T CAMDEN 12 N 7TH ST NJ VERIZON 5E AT&T CEDAR KNOLLS 88 HORSE HILL RD NJ VERIZON 4E AT&T FREEHOLD 175 W MAIN ST NJ VERIZON 4E AT&T HAMILTON 1300 WHITE HORSE-HMLTN SQ SQUARE NJ VERIZON NT5 AT&T NEWARK 95 WILLIAM ST NJ VERIZON 5E AT&T NEWARK 95 WILLIAM ST NJ VERIZON 4E AT&T ROCHELLE PARK 75 W PASSAIC ST NJ VERIZON NT5 AT&T ROCHELLE PARK 75 W PASSAIC ST NJ VERIZON NT5 COMCAST MOORESTOWN 650 CENTERTON RD (BURLINGTON) NJ VERIZON NT5 FOCAL COMMUNICATIONS JERSEY CITY 287-309 @WASHINGTON ST NJ VERIZON NT5 GLOBAL CROSSING NEWARK 1085 RAYMOND BLVD NJ VERIZON NT5 GLOBAL NAPS NEWARK 744 BROAD ST NJ VERIZON DS LEVEL 3 PRINCETON 211 COLLEGE RD E NJ VERIZON EN4 LEVEL 3 WEEHAWKEN 300 BOULEVARD E NJ VERIZON 5E RCN NUTLEY 65 RIVER RD NJ VERIZON 5E SNIP LINK PENNSAUKEN 100A TWINBRIDGE DR NJ VERIZON NT5 TELIGENT TRENTON 50 W STATE ST NJ VERIZON DS WINSTAR NEWARK 165 HALSEY ST NJ VERIZON 5E WINSTAR NEWARK 95 WILLIAM ST NJ VERIZON 5E WINSTAR NEW BRUNSWICK 18 PATTERSON ST NJ VERIZON AXT WORLDCOM JERSEY CITY 101 HUDSON ST NJ VERIZON DMH WORLDCOM LAUREL SPRINGS 29-35 BROADWAY AVE NJ VERIZON NT5 WORLDCOM NEW BRUNSWICK 23 HOME NEWS ROW NJ VERIZON DMS WORLDCOM NEWARK 131 MARKET ST NJ VERIZON NT5 XO NEWARK 165 HALSEY ST NM QWEST 4E AT&T ALBUQUERQUE 111 3RD ST NW NM QWEST 5ES E.SPIRE ALBUQUERQUE 201 3RD ST NW NM QWEST DS LEVEL 3 ALBUQUERQUE 104 GOLD AVE SE NM QWEST DS MCLEODUSA ALBUQUERQUE 505 MARQUETTE AVE NW NM QWEST DM5 TIME WARNER TELECOM ALBUQUERQUE 3830 SINGER BLVD NE NM QWEST 5ES WORLDCOM ALBUQUERQUE 422 GOLD AVE SW NV SBC DS ADVANCED TELCOM GROUP RENO STE 630 NV SBC 4E AT&T RENO 10 N CENTER ST NV SBC DMT LIBERTY TELECOM RENO 200 SOUTH VIRGINIA STREET NV SBC 5E WORLDCOM RENO 200 S VIRGINIA ST NY VERIZON 5E ADELPHIA BUFFALO 101 LASALLE AVE NY VERIZON 5E ADELPHIA SYRACUSE 6007 FAIRLAKES RD NY VERIZON 5E ALLEGIANCE TELECOM NEW YORK 111 8TH AVENUE 14TH FLOOR NY VERIZON 5E ALLEGIANCE TELECOM NEW YORK 60 HUDSON ST NY VERIZON 5E AT&T ALBANY 158 STATE ST. NY VERIZON 4E AT&T BUFFALO 65 FRANKLIN ST NY VERIZON 5E AT&T BUFFALO 325 DELAWARE AVE NY VERIZON NT5 AT&T HUNTINGTON 1444 E JERICHO TPKE
B-17
CLEC Circuit Switches Serving BOC Rate Centers State BOC Type CLEC City Street Region NY VERIZON 5E AT&T MANHATTAN 811 10TH AVE NY VERIZON 4E AT&T MANHATTAN 811 10TH AVE NY VERIZON 4E AT&T MANHATTAN 33 THOMAS ST NY VERIZON NT5 AT&T MANHATTAN 33 THOMAS ST NY VERIZON 5E AT&T MANHATTAN 67 BROAD ST NY VERIZON 5E AT&T MANHATTAN 1 WORLD FINANCIAL (TOWER B) CTR NY VERIZON 5E AT&T MANHATTAN 250 VESEY ST NY VERIZON 5E AT&T MANHATTAN 216 E 45TH ST NY VERIZON 5E AT&T MANHATTAN 33 THOMAS ST NY VERIZON 5E AT&T QUEENS 9403 QUEENS BLVD NY VERIZON 4E AT&T SYRACUSE 201 S STATE ST NY VERIZON NT5 AT&T WHITE PLAINS 400 HAMILTON AVE. NY VERIZON 4E AT&T WHITE PLAINS 360 HAMILTON AVE NY VERIZON NT5 BROADVIEW QUEENS 3718 NORTHERN BLVD NY VERIZON NT5 BROADVIEW SYRACUSE 224 HARRISON ST NY VERIZON 5E CABLEVISION LIGHTPATH BETHPAGE 1111 STEWART AVE NY VERIZON 5E CABLEVISION LIGHTPATH HICKSVILLE 111 NEW SOUTH RD NY VERIZON 5E CABLEVISION LIGHTPATH WHITE PLAINS 151 FULTON AVE NY VERIZON 5E CHOICE ONE ALBANY 80 STATE ST NY VERIZON 5E CHOICE ONE BUFFALO 350 MAIN ST NY VERIZON 5E CHOICE ONE SYRACUSE 110 W FAYETTE ST NY VERIZON EWSD COMAV BROOKLYN 25 CHAPEL ST NY VERIZON 5E CONVERSENT MELVILLE 201 OLD COUNTRY RD NY VERIZON 5E CORE COMMUNICATIONS MANHATTAN 67 BROAD ST NY VERIZON DMH CTSI SYRACUSE 201 S STATE ST NY VERIZON 5E E.SPIRE NEW YORK 75 BROAD STREET 3RD FLOOR NY VERIZON 5E EAGLE COMMUNICATIONS MANHATTAN 60 E 56TH ST NY VERIZON 5E EAGLE COMMUNICATIONS MANHATTAN 601 W 26TH ST NY VERIZON D12 FAIRPOINT CHATHAM 19 RAILROAD AV NY VERIZON NT5 FOCAL COMMUNICATIONS MANHATTAN 325 HUDSON ST NY VERIZON NT5 GLOBAL CROSSING ALBANY 11 N PAERL ST SUITE 2000 NY VERIZON NT5 GLOBAL NAPS MANHATTAN 1 FINANCIAL SQ NY VERIZON DS ICG COMMUNICATIONS MANHATTAN 67 BROAD ST NY VERIZON NT5 INTERMEDIA COMMUNICATIONS MANHATTAN 160 W BROADWAY NY VERIZON DM5 INTERNATIONAL TELCOM MANHATTAN 160 W BROADWAY NY VERIZON DS LEVEL 3 ALBANY 314 N PEARL ST NY VERIZON DS LEVEL 3 BUFFALO 240 SCOTT ST NY VERIZON DCO METROPOLITAN MANHATTAN 67 BROAD ST TELECOMMUNICATIONS NY VERIZON DE4 METTEL HEMPSTEAD 875 MERRICK AVE NY VERIZON D12 MIDHUDSON_COMM ALBANY 11 N PEARL ST NY VERIZON DMS10 NECLEC LLC NEW YORK CITY 32 OLD SLIP 4TH FLOOR NY VERIZON NT5 NET2000 MANHATTAN 325 HUDSON ST NY VERIZON DM5 NET-TEL CORP. MANHATTAN 67 BROAD ST NY VERIZON NT5 NORTHLAND NETWORKS SYRACUSE 500 S SALINA ST NY VERIZON MFS NORTHLAND NETWORKS UTICA 258 GENESEE ST NY VERIZON VCD PAETEC ALBANY 1 COMMERCE PLZ NY VERIZON 5E PAETEC MANHATTAN 111 8TH AVE. NY VERIZON 5E RCN MANHATTAN 333 W. HOUSTON ST NY VERIZON 5E RCN QUEENS 3316 WOODSIDE AVE
B-18
CLEC Circuit Switches Serving BOC Rate Centers State BOC Type CLEC City Street Region NY VERIZON NT5 TELIGENT MANHATTAN 111 8TH AVE NY VERIZON NT5 THOUSAND ISLANDS WATERTOWN 130 PARK PL COMMUNICATIONS NY VERIZON 5E TIME WARNER TELECOM COLONIE 10 AIRLINE DR NY VERIZON DMT WARWICK VALLEY TELEPHONE MIDDLETOWN 24 JOHN ST COMPANY NY VERIZON DS WESTELCOM NETWORKS PLATTSBURGH 24 MARGARET ST NY VERIZON AXT WORLDCOM BUFFALO 325 DELAWARE - 1ST F NY VERIZON 5E WORLDCOM BUFFALO 325 DELAWARE AVE NY VERIZON DMH WORLDCOM GARDEN CITY 845 STEWART AVE NY VERIZON DMS WORLDCOM NEW YORK 111 8TH AVE NY VERIZON AXT WORLDCOM NEW YORK 111 8TH AVE NY VERIZON NT5 WORLDCOM NEW YORK 560 WASHINGTON ST NY VERIZON NT5 WORLDCOM NEW YORK 60 HUDSON ST NY VERIZON 5E WORLDCOM WESTBURY 48 SWALM ST (NASSAU) NY VERIZON 5E WORLDCOM WHITE PLAINS 20 CHURCH ST @ MAIN ST NY VERIZON NT5 XO MANHATTAN 111 8TH AVE NY VERIZON DMS XO NEW YORK 75 BROAD ST OH SBC 5E2 ALLEGIANCE TELECOM CLEVELAND 1505 ROCKWELL AVE OH SBC 5E ALLTEL MONCLOVA 3530 BRIARFIELD BLVD TOWNSHIP OH SBC 4E AT&T CINCINNATI 229 W 7TH ST OH SBC NT5 AT&T CINCINNATI 358 GEST ST OH SBC 5E AT&T COLUMBUS 111 N 4TH ST OH SBC NT5 AT&T COLUMBUS 10 W BROAD ST OH SBC 5E AT&T COLUMBUS 111 N 4TH ST OH SBC DMH AT&T INDEPENDENCE 7555 E PLEASANT VALLEY RD OH VERIZON VCD BUCKEYE TELESYSTEM TOLEDO 4818 ANGOLA RD OH SBC 5E CABLEVISION LIGHTPATH STRONGSVILLE 8179 DOW CIR OH SBC DS CHOICE ONE AKRON 600 S MAIN ST OH SBC DS CHOICE ONE COLUMBUS 10 W BROAD ST OH SBC DS CHOICE ONE DAYTON 111 W 1ST ST OH SBC DM5 CORE COMMUNICATIONS GARFIELD 15166 NEO PKY HEIGHTS OH SBC DM5 CORE COMMUNICATIONS WORTHINGTON 575 SCHERERS CT OH SBC NT5 FOCAL COMMUNICATIONS CLEVELAND 1228 EUCLID AVE OH SBC NT5 GLOBAL CROSSING CLEVELAND 1621 EUCLID AVE, SUITE 620 OH SBC 5E2 ICG COMMUNICATIONS AKRON 520 S MAIN ST #2435 OH SBC 5E ICG COMMUNICATIONS CINCINNATI 105 E 4TH ST OH SBC 5E ICG COMMUNICATIONS CLEVELAND 1554 HAMILTON AVE OH SBC 5E ICG COMMUNICATIONS COLUMBUS 266 N 5TH ST OH SBC 5E ICG COMMUNICATIONS DAYTON 1 FIRST NATIONAL PLZ OH SBC 5E ICG COMMUNICATIONS GARFIELD 15467 NEO PKY HEIGHTS OH SBC 5E ICG COMMUNICATIONS WORTHINGTON 6185 HUNTLEY RD OH SBC DMS INTERMEDIA COMMUNICATIONS CINCINNATI 150 E 4TH ST OH SBC NT5 INTERMEDIA COMMUNICATIONS CLEVELAND 1228 EUCLID AVE OH SBC 5E KMC TELECOM AKRON 175 TARBELL ST OH SBC 5E KMC TELECOM MORAINE 2870 SELLARS RD OH SBC 5E KMC TELECOM TOLEDO 6 CITY PARK AVE OH SBC DS LEVEL 3 AKRON 1 CASCADE PLZ
B-19
CLEC Circuit Switches Serving BOC Rate Centers State BOC Type CLEC City Street Region OH SBC DS LEVEL 3 CLEVELAND 4000 CHESTER AVE OH SBC DS LEVEL 3 COLUMBUS 428 REYNOLDS AVE OH SBC DS LEVEL 3 DAYTON 732 GERMANTOWN ST OH SBC DS MCLEODUSA CLEVELAND 1625 ROCKWELL AVE OH SBC 5E MCLEODUSA COLUMBUS 211 N GRANT AVE OH SBC DS MCLEODUSA DAYTON 1 FIRST NATIONAL PLZ OH SBC DS MPOWER CLEVELAND 1 EATON CTR OH SBC DS MPOWER COLUMBUS 180 E BROAD ST OH SBC D12 SPRINT LEBANON 20 N MECHANIC ST OH SBC NT5 TELIGENT GARFIELD 15248 NEO PKY HEIGHTS OH SBC 5E TIME WARNER TELECOM BLUE ASH 11252 CORNELL PARK DR OH SBC DS TIME WARNER TELECOM CINCINNATI 9490 MERIDIAN WAY OH SBC 5E TIME WARNER TELECOM COLUMBUS 1125 CHAMBERS RD OH SBC DS TIME WARNER TELECOM DAYTON 1 S MAIN ST OH SBC DMH TRIVERGENT AKRON 388 S MAIN ST OH SBC DMH TRIVERGENT CINCINNATI 344 GEST ST OH SBC NT5 WORLDCOM CINCINNATI 312 PLUM ST OH SBC DE4 WORLDCOM CLEVELAND 1621 EUCLID AVE OH SBC DMH WORLDCOM CLEVELAND 1150 W 3RD ST OH SBC DMS WORLDCOM TOLEDO 26 N 11TH ST OH SBC NT5 XO CLEVELAND 815 SUPERIOR AVE NE OH SBC NT5 XO COLUMBUS 10 W BROAD ST OK SBC 4E AT&T OKLAHOMA CITY 121 DEAN A MCGEE OK SBC 5E AT&T OKLAHOMA CITY 111 DEAN A MCGEE OK SBC 4E AT&T TULSA 509 S DETROIT OK SBC NT5 COX OKLAHOMA CITY 2312 N W 10TH ST OK SBC 5E E.SPIRE TULSA 100 W 5TH ST OK SBC DS HARVEST TELECOM TULSA 2488 E 81ST ST OK SBC DS INVENTIVE TECHNOLOGY CLINTON 817 AVANT AVE OK SBC DS LEVEL 3 OKLAHOMA CITY 100 SE 8TH OK SBC DS LEVEL 3 TULSA 16719 E ADMIRAL PLACE OK SBC NT5 LOGIX COMMUNICATIONS OKLAHOMA CITY 100 W PARK AVE OK SBC D12 LOGIX COMMUNICATIONS TULSA 610 S MAIN ST OK SBC NT5 MCLEODUSA OKLAHOMA CITY 815 N BROADWAY OK SBC DS PIONEER LONG DISTANCE ENID 225 W CHESTNUT AVE OK SBC DS PIONEER LONG DISTANCE FAIRVIEW 110 S 7TH ST OK SBC DMT SURE-TEL STILLWATER 504 S MAIN ST OK SBC DMH TRIVERGENT TULSA 1437 S BOULDER AVE, SUITE 130 OK SBC 5E WORLDCOM OKLAHOMA CITY 101 W PARK AVE OK SBC 5E WORLDCOM TULSA 4500 S 129TH EAST AVE OR VERIZON DS ADVANCED TELCOM GROUP PORTLAND 810 SE BELMONT ST OR QWEST VCD ADVANCED TELCOM GROUP SALEM 198 COMMERCIAL ST SE OR QWEST 5E ALLEGIANCE TELECOM TIGARD 10575 SW CASCADE AVE OR QWEST 5ES AT&T EUGENE 1515 WESTEC DR OR VERIZON 4E AT&T PORTLAND 819 SW OAK ST OR VERIZON NT5 AT&T PORTLAND 819 SW OAK ST OR VERIZON 5E AT&T TIGARD 10340 SW NIMBUS AVE OR QWEST 5ES BEAVER CREEK TELEPHONE CO BEAVER CREEK BEAVER CREEK OR QWEST DMS10 CENTURYTEL INC AURORA TEL UTILITIES AURORA OR VERIZON DMH ELECTRIC LIGHTWAVE PORTLAND 6038 NE 78TH CT
B-20
CLEC Circuit Switches Serving BOC Rate Centers State BOC Type CLEC City Street Region OR VERIZON D12 ESCHELON PORTLAND 921 SW WASHINGTON SUITE 410 OR QWEST DMS10 GERVAIS TELEPHONE CO. DBA GERVAIS GERVAIS DATAVISION COMM OR VERIZON DS GREAT WEST SVCS BEAVERTON 20700 NW TRAIL WALK OR VERIZON 5E INTEGRA TELECOM BEAVERTON 10870 SW BARNES RD OR VERIZON DMS INTERNATIONAL TELCOM PORTLAND 6058 NE 78TH CT OR VERIZON DS LEVEL 3 PORTLAND 1335 NW NORTHRUP ST OR VERIZON DS MCLEODUSA PORTLAND 926 NW 13TH AVE OR VERIZON DMH NORTH COUNTY PORTLAND 921 SW WASHINGTON COMMUNICATIONS OR VERIZON D12 NORTH SANTIAM STAYTON STAYTON COMMUNICATIONS OR QWEST 5ES RIO COMMUNICATIONS INC EUGENE 151 W 7TH AVE OR QWEST DS RIO COMMUNICATIONS INC MEDFORD 502 N CENTRAL AVE OR QWEST DMS1/200 SPRINT SHERIDAN 233 SE SAMPSON OR QWEST DCO ST. PAUL COOPERATIVE ST PAUL SAINT PAUL TELEPHONE ASSOCIATION OR VERIZON DM5 TIME WARNER TELECOM PORTLAND 520 SW 6TH AVE OR VERIZON DS WINSTAR PORTLAND 6132 NE 112TH AVE OR VERIZON NT5 WORLDCOM PORTLAND 425 SW WASHINGTON ST OR VERIZON AXT WORLDCOM PORTLAND 851 SW 6TH AVE OR QWEST DS XO BEAVERTON 9000 SW NIMBUS AVE PA VERIZON 5E ADELPHIA HARRISBURG 1037 N 7TH ST PA VERIZON 5E ADELPHIA PHILADELPHIA 3020-3040 MARKET ST PA VERIZON 5E ADELPHIA PITTSBURGH 200 TECHNOLOGY DR PA VERIZON 5E ADELPHIA PITTSTON 1180 SATHERS DR PA VERIZON 5E ADELPHIA STATE COLLEGE 101 INNOVATIONS BLVD PA VERIZON 5E ADELPHIA YORK 140 W MARKET ST PA VERIZON 5E ALLEGIANCE TELECOM PHILADELPHIA 401 N BROAD ST PA VERIZON 5E ARBROS PHILADELPHIA 401 N BROAD ST PA VERIZON 4E AT&T HARRISBURG 210 PINE ST PA VERIZON NT5 AT&T PHILADELPHIA 500 S 27TH ST. PA VERIZON 4E AT&T PHILADELPHIA 500 S TWENTY-SEVENTH ST PA VERIZON 5E AT&T PITTSBURG 635 GRANT ST. PA VERIZON 4E AT&T PITTSBURGH 635 GRANT ST PA VERIZON 5E AT&T PITTSBURGH 2500 ALLEGHENY CTR MALL PA VERIZON 5E AT&T WAYNE 60 WEST AVE PA VERIZON VCD BROADSTREET CARNEGIE 500 NOBLESTOWN RD PA VERIZON NT5 BROADVIEW HORSHAM 400 HORSHAM RD PA VERIZON 5E CAVALIER TELEPHONE WARMINSTER 965 THOMAS DR PA VERIZON DS CHOICE ONE ALLENTOWN 7150 WINDSOR DR PA VERIZON DS CHOICE ONE HARRISBURG 301 CHESTNUT ST PA VERIZON 5E CHOICE ONE PITTSBURGH 650 SMITHFIELD ST PA VERIZON DS CHOICE ONE WILKES-BARRE 1090 HANOVER ST PA VERIZON DMS CORECOMM (ATX) PHILADELPHIA 200 S 24TH ST PA VERIZON NT5 CORECOMM (ATX) PHILADELPHIA 200 S 24TH ST PA VERIZON D12 CTSI DALLAS 100 LAKE ST PA VERIZON NT5 CTSI HARRISBURG 31 S 31ST ST PA VERIZON DMH CTSI LEESPORT 203 N CENTRE AV PA VERIZON D12 D&E LITITZ 19 S CEDAR ST PA VERIZON 5E E.SPIRE PHILADELPHIA 401 N BROAD ST PA VERIZON 5E EAGLE COMMUNICATIONS PHILADELPHIA 401 SOUTH BROAD ST.
B-21
CLEC Circuit Switches Serving BOC Rate Centers State BOC Type CLEC City Street Region PA VERIZON NT5 FOCAL COMMUNICATIONS NORRISTOWN 1000 FORGE (BLDG C) AVE PA VERIZON NT5 FOCAL COMMUNICATIONS PHILADELPHIA 701 MARKET ST PA VERIZON NT5 INTERMEDIA COMMUNICATIONS PHILADELPHIA 401 N BROAD ST PA VERIZON NT5 INTERMEDIA COMMUNICATIONS PITTSBURGH 1400 PENN AVE PA VERIZON DS LEVEL 3 PITTSBURGH 143 S 25TH ST PA VERIZON 5E METTEL PHILADELPHIA 401 N BROAD ST PA VERIZON NT5 NET2000 PHILADELPHIA 401 N BROAD ST PA VERIZON D12 PENN TELECOM, INC. GIBSONIA 4008 GIBSONIA RD PA VERIZON 5E RCN LOWER 1000 ADAMS AVE PROVIDENCE TOWNSHIP PA VERIZON 5E RCN NORTHAMPTON 5508 NOR BATH BLVD PA VERIZON NT5 TELIGENT PHILADELPHIA 401 N BROAD ST PA VERIZON 5E US LEC PHILADELPHIA 401 N BROAD ST PA VERIZON 5E US LEC PITTSBURGH ALLEGHENY CTR MALL PA VERIZON VCD WINSTAR PHILADELPHIA 1101 MARKET ST PA VERIZON DS WINSTAR PITTSBURGH 707 GRANT ST PA VERIZON DMH WORLDCOM KING OF PRUSSIA 630 CLARK AVE PA VERIZON DE5 WORLDCOM PHILADELPHIA 401 N. BROAD ST PA VERIZON DE5 WORLDCOM PHILADELPHIA 401 N. BROAD ST PA VERIZON DMH WORLDCOM PITTSBURGH 2990 SASSAFRAS WAY PA VERIZON NT5 XO ALLENTOWN 974 MARCON BLVD PA VERIZON DMH XO HARRISBURG 991 PEIFFERS LN PA VERIZON NT5 XO PHILADELPHIA 2400 MARKET ST RI VERIZON NT5 AT&T PROVIDENCE RI 275 PROMENADE ST. RI VERIZON 5E CHOICE ONE PROVIDENCE 121 S MAIN ST RI VERIZON 5E CONVERSENT PROVIDENCE 935 WESTMINSTER ST RI VERIZON DMS COX WEST WARWICK 11 JAMES P MURPHY IND HWY RI VERIZON DM5 INTERNATIONAL TELCOM PROVIDENCE 304 CARPENTER ST RI VERIZON DMS5 NECLEC LLC NEWPORT 17 GOODWIN ST RI VERIZON 5E WORLDCOM PROVIDENCE 8 PARSONAGE ST SC BELLSOUTH DS ALLTEL LEXINGTON 106 N CHURCH ST SC BELLSOUTH DMH ALLTEL NORTH 4920 APPIAN WAY CHARLESTON SC BELLSOUTH 4E AT&T COLUMBIA 1645 HAMPTON ST SC BELLSOUTH 5E AT&T COLUMBIA 1645 HAMPTON ST SC BELLSOUTH 5E BTI CHARLESTON 176 GROGHAN SPUR RD SC BELLSOUTH VCD BTI COLUMBIA 1401 MAIN ST SC BELLSOUTH VCD BTI GREENVILLE 301 N MAIN ST SC BELLSOUTH DS DANIEL ISLAND MEDIA COMPANY CHARLESTON 1350 DANIEL ISLAND DR SC BELLSOUTH 5E E.SPIRE COLUMBIA 1401 MAIN ST SC BELLSOUTH 5E E.SPIRE GREENVILLE 218 COLLEGE ST SC VERIZON EWSD HTC COMMUNICATIONS COLLINS CREEK HWY 707 SC BELLSOUTH DS ITC^DELTACOM CHARLESTON 1 CHARLOTTE ST & CONCORD ST SC BELLSOUTH DS ITC^DELTACOM COLUMBIA 1426 MAIN ST SC BELLSOUTH DS ITC^DELTACOM GREENVILLE 325 W MCBEE AVE SC BELLSOUTH 5E KMC TELECOM COLUMBIA 3770 LUCIUS RD SC BELLSOUTH 5E KMC TELECOM NORTH 3310 MADONNA ST CHARLESTON SC BELLSOUTH 5E KMC TELECOM SPARTANBURG 110 OLD LOWE RD SC BELLSOUTH DS LEVEL 3 GREENVILLE 301 N MAIN ST SC VERIZON 5E NEWSOUTH COMMUNICATIONS GREENVILLE 5 DUNCAN ST
B-22
CLEC Circuit Switches Serving BOC Rate Centers State BOC Type CLEC City Street Region SC BELLSOUTH NT5 SOUTH CAROLINA NET COLUMBIA 1426 MAIN ST SD QWEST NT5 BLACK HILLS FIBERCOM RAPID CITY 809 DEADWOOD AVE SD QWEST DMS10 EAST PLAINS TELECOM, INC. HUDSON HUDSON @ HUDSON CO SD QWEST DM5 MIDCO COMM SIOUX FALLS 410 S PHILLIPS AVE SD QWEST DCO SIOUX VALLEY TELEPHONE CO. HUMBOLDT > BLK W OF BANK SD QWEST DMS100 SOUTH DAKOTA NETWORK SIOUX FALLS 2900 W 10TH ST METRO TN BELLSOUTH 5E ADELPHIA NASHVILLE 2530 PERIMETER PLACE DR TN BELLSOUTH DMH AT&T CHATTANOOGA 611 CHESTNUT ST TN BELLSOUTH DMH AT&T KNOXVILLE 900 S GAY ST TN BELLSOUTH 4E AT&T KNOXVILLE 410 MAGNOLIA AVE / 439 DEPOT ST TN BELLSOUTH 4E AT&T MEMPHIS 231 COURT TN BELLSOUTH DMH AT&T NASHVILLE 49 MUSIC SQUARE W TN BELLSOUTH 4E AT&T NASHVILLE 185 2ND AVE N TN BELLSOUTH 5E BTI KNOXVILLE TWO CENTRE SQ TN BELLSOUTH 5E BTI NASHVILLE 150 4TH AVE N TN BELLSOUTH DMS ELECTRIC POWER BOARD OF CHATTANOOGA 110 N GREENWOOD AVE CHATANOOGA TN BELLSOUTH 5E ICG COMMUNICATIONS NASHVILLE 315 DEADERICK ST TN BELLSOUTH NT5 INTERMEDIA COMMUNICATIONS MEMPHIS 3042 DIRECTORS ROW TN BELLSOUTH NT5 INTERMEDIA COMMUNICATIONS NASHVILLE 100 FRANKLIN ST TN BELLSOUTH DS ITC^DELTACOM CHATTANOOGA 1329 SLAYTON ST TN BELLSOUTH DS ITC^DELTACOM KNOXVILLE 5490 CENTRAL AVENUE PIKE TN BELLSOUTH DS ITC^DELTACOM MEMPHIS 201 COURT AVE TN BELLSOUTH NT5 ITC^DELTACOM NASHVILLE 1301 4TH AVE S TN BELLSOUTH 5E KMC TELECOM CHATTANOOGA 1120 E 16TH ST TN BELLSOUTH DS LEVEL 3 MEMPHIS 3993 CROWFARM TN BELLSOUTH DS LEVEL 3 NASHVILLE 2990 SIDCO DR TN BELLSOUTH DS NETWORK TELEPH. MEMPHIS 201 COURT AVE TN BELLSOUTH DS NETWORK TELEPH. NASHVILLE 185 2ND AVE N TN BELLSOUTH 5E NEWSOUTH COMMUNICATIONS NASHVILLE 505 FESSLERS LN TN BELLSOUTH 5E TIME WARNER TELECOM MEMPHIS 5450 WINCHESTER RD TN BELLSOUTH DMH TRIVERGENT NASHVILLE 940 3RD AVE N TN BELLSOUTH 5E US LEC KNOXVILLE 800 S GAY ST TN BELLSOUTH VCD US LEC MEMPHIS 6625 LENOX PARK DR TN BELLSOUTH 5E WORLDCOM KNOXVILLE 406 UNION AVE SW TN BELLSOUTH NT5 WORLDCOM MEMPHIS 240 S. HOLLYWOOD TN BELLSOUTH NT5 XO MEMPHIS 5127 TRUSE TN BELLSOUTH NT5 XO NASHVILLE 101 MOLLOY ST TN BELLSOUTH 5E XSPEDIUS CORP. MEMPHIS 8110 CORDOVA RD TN BELLSOUTH 5E XSPEDIUS CORP. NASHVILLE 535 MAINSTREAM DR TX SBC DM5 ADDISON CLEC NETWORK DALLAS 5757 ALPHA RD TX SBC 5E ADELPHIA HOUSTON 2300 LYONS RD TX SBC 5E ALLEGIANCE TELECOM AUSTIN 11400 BURNET RD @ BUILDING 5 TX VERIZON 5E ALLEGIANCE TELECOM DALLAS 1950 N STEMMONS FWY TX SBC 5E ALLEGIANCE TELECOM HOUSTON 1301 FANNIN ST TX SBC 5E ALLEGIANCE TELECOM SAN ANTONIO 5308 DISTRIBUTION DR TX SBC NT5 AMERICAN LIGHTWAVE HOUSTON 1415 LOUISIANA ST COMMUNICATIONS, INC. TX SBC NT5 AMERICAN TELCO DALLAS 1950 N STEMMONS FWY TX SBC DMS AMERICAN TELCO FORT WORTH 810 HOUSTON ST
B-23
CLEC Circuit Switches Serving BOC Rate Centers State BOC Type CLEC City Street Region TX SBC DS AMERICAN TELCO HOUSTON 1415 LOUISIANA FLOOR D ROOM 2 TX SBC DCO AMERICAN TELCO SAN ANTONIO 301 BROADWAY, SUITE 386 TX SBC 4E AT&T ADAMS 13900 CR 22 TX SBC 5E AT&T ADAMS 12300 CR 22 TX SBC 4E AT&T ANY TOWN ANY ST TX VERIZON NT5 AT&T AUSTIN 120 W 9TH TX SBC 4E AT&T AUSTIN 915 COLORADO ST TX VERIZON DMH AT&T DALLAS 13601 PRESTON- ANNEX TOWER RD TX VERIZON 4E AT&T DALLAS 4100 BRYAN ST TX VERIZON 5E AT&T DALLAS 4100 BRYAN ST TX VERIZON NT5 AT&T DALLAS 4100 BRYAN ST TX SBC 5E AT&T DALLAS 4100 BRYAN ST TX SBC 4E AT&T DALLAS 4100 BRYAN ST TX SBC 5E AT&T DALLAS 4100 BRYAN ST TX SBC 4E AT&T FORT WORTH 1116 HOUSTON ST TX VERIZON DMH AT&T HOUSTON 1301 FANNIN SUITE 1290 TX SBC 4E AT&T HOUSTON 1407 JEFFERSON ST TX SBC 4E AT&T HOUSTON 1407 JEFFERSON ST TX SBC DS AT&T HOUSTON 1407 JEFFERSON ST TX SBC 5E AT&T HOUSTON 1407 JEFFERSON TX SBC 4E AT&T MIDLAND 410 W MISSOURI AVE TX SBC 4E AT&T SAN ANTONIO 105 AUDITORIUM CIR TX SBC NT5 AT&T SAN ANTONIO 105 AUDITORIUM CIR TX SBC 5E AT&T SEGUIN RTE 2 BOX 400 TX VERIZON 5E ATS TELECOMMUNICATIONS KYLE 168 KIRKHAM CIR SYSTEMS, INC D/B/A ATS TX SBC 5E BAY STAR SATELLITE P HOUSTON 4112 MANGUM RD TX VERIZON DCO CENTRAL TEXAS SAN ANGELO 100 STRAWN RD COMMUNICATIONS TX VERIZON VCD COSERV DALLAS 1950 N STEMMONS FWY TX SBC D12 COSERV FRISCO 3966 PARKWOOD BLVD TX SBC DS CYPRESS TELECOMMUNICATIONS HOUSTON 777 WALKER ST #C190 CORPORATION TX SBC 5E E.SPIRE AUSTIN 816 CONGRESS AVE TX SBC 5E E.SPIRE DALLAS 2323 BRYAN ST TX SBC 5E E.SPIRE EL PASO 201 E MAIN TX SBC 5E E.SPIRE FORT WORTH 309 W 7TH ST TX SBC 5E E.SPIRE SAN ANTONIO 323 BROADWAY TX SBC DMT FEC COMMUNICATIONS ROYSE CITY 2884 BLACKLAND RD TX VERIZON DMH FOCAL COMMUNICATIONS DALLAS 1950 N STEMMONS FWY TX VERIZON NT5 FOCAL COMMUNICATIONS HOUSTON 5959 CORPORATE DR TX VERIZON 5E FORT BEND TELCO KATY 1400 AVE A TX SBC DS GCEC TECHNOLOGIES SHERMAN 217 N WALNUT ST TX VERIZON NT5 GLOBAL CROSSING DALLAS 2323 BRYAN STREET SUITE 900 TX SBC DM5 GRANDE COMMUNICATIONS DALLAS 2323 BRYAN ST NETWORKS TX SBC 5E ICG COMMUNICATIONS AUSTIN 114 W 7TH ST TX SBC 5E ICG COMMUNICATIONS CORPUS CHRISTI 539 N CARANCAHUA ST TX VERIZON 5E ICG COMMUNICATIONS DALLAS 717 N HARWOOD ST TX VERIZON 5E ICG COMMUNICATIONS HOUSTON 2100 W LOOP S
B-24
CLEC Circuit Switches Serving BOC Rate Centers State BOC Type CLEC City Street Region TX SBC 5E ICG COMMUNICATIONS SAN ANTONIO 703 URBAN LOOP TX SBC NT5 INTERMEDIA COMMUNICATIONS DALLAS 2323 BRYAN ST TX SBC NT5 INTERMEDIA COMMUNICATIONS HOUSTON 1301 FANNIN ST TX VERIZON 5E IONEX TELECOMMUNICATIONS DALLAS 1201 MAIN ST INC. TX SBC 5E IONEX TELECOMMUNICATIONS HOUSTON 5433 WESTHEIMER RD INC. TX SBC DS ITC^DELTACOM AUSTIN 8201 E RIVERSIDE DR TX SBC DS ITC^DELTACOM DALLAS 2020 LIVE OAK ST TX SBC DS ITC^DELTACOM HOUSTON 12075 NORTH FWY TX SBC 5E KMC TELECOM CORPUS CHRISTI 5337 BEAR LN TX SBC 5E KMC TELECOM LONGVIEW 303 W HARRISON RD TX SBC DMH KO COMMUNICATIONS DB GREENVILLE 2702 WESLEY TX SBC DMH KO COMMUNICATIONS DB MOUNT PLEASANT 407 N. VAN BUREN TX SBC 5E KO COMMUNICATIONS DB MT. PLEASANT 2605 WEST FERGUSON RD TX VERIZON DS LEVEL 3 AUSTIN 4207 SMITH SCHOOL RD @ 78744 TX SBC DS LEVEL 3 SAN ANTONIO 5130 SERVICE CENTER DR TX SBC DMT LOGIX COMMUNICATIONS AMARILLO 203 W 8TH AVE TX SBC NT5 LOGIX COMMUNICATIONS AUSTIN 210 BARTON SPRINGS RD TX SBC NT5 LOGIX COMMUNICATIONS HOUSTON 1415 LOUISIANA ST TX SBC DMH LOGIX COMMUNICATIONS SAN ANTONIO 106 S ST MARYS TX SBC DS MCLEODUSA AUSTIN 1011 SAN JACINTO BLVD TX VERIZON DM5 MCLEODUSA DALLAS 600 N PEARL SOUTH TOWER TX SBC DM5 MCLEODUSA HOUSTON 12017 NORTH FWY TX VERIZON DM5 MCLEODUSA MCALLEN 900-1/2 BEECH AVE TX SBC DM5 MCLEODUSA SAN ANTONIO 106 S ST MARYS ST SUITE 210 TX SBC DMT MCLEODUSA VICTORIA 116 N MAIN ST TX VERIZON DMT MILLENIUM KELLER 4700 KELLER HICKS RD TX SBC DS MPOWER DALLAS 1950 N STEMMONS FWY TX SBC DS MPOWER HOUSTON 5959 CORPORATE DR TX VERIZON NT5 NET-TEL CORP. ADDISON 16200 ADDISON RD TX VERIZON DCO NORTEX TELECOM DENTON 3400 SUNDOWN BLVD TX SBC 5E NTS COMMUNICATIONS, INC. ABILENE 500 CHESTNUT ST STE. 936 TX SBC 5E2 NTS COMMUNICATIONS, INC. AMARILLO 208 W 8TH AVE TX SBC 5E NTS COMMUNICATIONS, INC. LUBBOCK 1220 BROADWAY, STE. 200 TX SBC 5E NTS COMMUNICATIONS, INC. MIDLAND 415 W WALL ST TX SBC 5E NTS COMMUNICATIONS, INC. ODESSA 3801 DAWN AVE TX VERIZON 5E OPTEL DALLAS 3228 HALIFAX ST TX VERIZON 5E OPTEL HOUSTON 10300 WESTOFFICE DR TX SBC DS PATHWAY COM-TEL, INC. BURLESON 3101 OLD STATE HWY 174 TX SBC 5E RELIANT ENERGY HOUSTON 1111 LOUISIANA ST COMMUNICATIONS, INC. TX SBC EWSD TAYLOR AUSTIN 800 BRAZOS ST TX SBC EWSD TAYLOR DALLAS 13601 PRESTON RT 78 TELEPORT TX SBC EWSD TAYLOR HOUSTON 1770 ST JAMES PL TX SBC EWSD TAYLOR SAN ANTONIO 100 TAYLOR TX SBC DMT TECH TEL LUBBOCK 3302 QUAKER AVE TX VERIZON NT5 TELIGENT DALLAS 1950 N STEMMONS FWY TX VERIZON NT5 TELIGENT HOUSTON 1301 FANNIN ST TX SBC NT5 TELIGENT SAN ANTONIO 8500 VICAR DR TX SBC 5E TEXACOM CORPORATION HOUSTON 1200 CLAY ST
B-25
CLEC Circuit Switches Serving BOC Rate Centers State BOC Type CLEC City Street Region TX SBC 5E TIME WARNER TELECOM AUSTIN 12012 N MOPAC EXPY TX SBC 5E TIME WARNER TELECOM AUSTIN 3012 MONTOPOLIS DR TX VERIZON 5E TIME WARNER TELECOM DALLAS 1100 REGAL ROW TX VERIZON EWSD TIME WARNER TELECOM HOUSTON 2900 WESLAYAN ST TX SBC 5E TIME WARNER TELECOM HOUSTON 8495 TIDWELL RD TX SBC 5E TIME WARNER TELECOM SAN ANTONIO 301 BROADWAY TX SBC DS TXU COMMUNICATIONS CONROE 411 W PHILLIP TX SBC NT5 TXU COMMUNICATIONS DALLAS 400 S.AKARD TX SBC DS TXU COMMUNICATIONS LUFKIN 321 N 1ST ST TX SBC NT5 TXU COMMUNICATIONS ROUND ROCK 214 FRONTIER TRL TX SBC DS WALLER CREEK AUSTIN 306 SAN JACINTO BLVD COMMUNICATIONS TX SBC 5E WESTERN INTEGRATED DALLAS 2229 COCKRELL AVE NETWORKS TX SBC 5E WES-TEX TELECOMMUNICATIONS BIG SPRING 801 RUNNELS TX SBC EWSD WES-TEX TELECOMMUNICATIONS BIG SPRING 711 SCURRY ST TX SBC NT5 WORLDCOM AUSTIN 2525 RIDGEPOINT DR TX SBC AXT WORLDCOM DALLAS 1950 STEMMONS FWY TX SBC AXT WORLDCOM DALLAS 1950 STEMMONS TX SBC DMH WORLDCOM HOUSTON 1001 TEXAS TX SBC NT5 WORLDCOM HOUSTON 1701 LYONS AVE TX SBC DMS WORLDCOM HOUSTON 1701 LYONS AVE TX VERIZON NT5 WORLDCOM IRVING 2477 GATEWAY DR TX VERIZON NT5 WORLDCOM RICHARDSON 400 INTERNATIONAL PKWY 2ND FL EAST TX VERIZON NT5 WORLDCOM SAN ANTIONIO 222 ROTARY TX SBC NT5 WORLDCOM SAN ANTONIO 700 N ST MARY'S TX SBC DS XO AUSTIN 2100 S IH35 TX SBC DMS XO DALLAS 1300 MOCKINGBIRD LN TX SBC DM5 XO HOUSTON 2401 PORTSMOUTH TX SBC DS XO SAN ANTONIO 6550 FIRST PARK TEN BLVD UT QWEST 4E AT&T SALT LAKE CITY 70 S STATE UT QWEST 5ES AT&T SALT LAKE CITY 70 S STATE UT QWEST DMS100 AT&T WEST VALLEY 2440 S 1070 W CITY UT QWEST DMS1/200 ELECTRIC LIGHTWAVE SALT LAKE CITY 265 E 100TH S UT QWEST DMS100 ESCHELON SALT LAKE CITY 215 S STATE ST UT QWEST 5E ICG COMMUNICATIONS WEST VALLEY 2342 PRESIDENTS DR CITY UT QWEST 5ES INTEGRA TELECOM SALT LAKE CITY 3676 CALIFORNIA AVE UT QWEST DS LEVEL 3 SALT LAKE CITY 572 S DELONG ST UT QWEST DS MCLEODUSA SALT LAKE CITY 40 E 100 S UT QWEST DS WINSTAR SALT LAKE CITY 161 REGENT ST UT QWEST NT5 WORLDCOM SALT LAKE CITY 175 S WEST TEMPLE UT QWEST DMS100 XO SALT LAKE CITY 118 S 1000 W VA VERIZON 5E ADELPHIA NORFOLK 2600 ELTHAM AVE VA VERIZON DMH ALLTEL CHESAPEAKE 811 INDUSTRIAL AVE VA VERIZON DMH ALLTEL RICHMOND 2501 GOODES BRIDGE RD VA VERIZON 4E AT&T ARLINGTON 900 S WALTER REED DR VA VERIZON NT5 AT&T FREDERICKSBURG 901 PRINCE EDWARD ST VA VERIZON 4E AT&T NORFOLK 120-36 W BUTE ST VA VERIZON 5E AT&T RICHMOND 703 E GRACE ST
B-26
CLEC Circuit Switches Serving BOC Rate Centers State BOC Type CLEC City Street Region VA VERIZON 4E AT&T RICHMOND 2510 TURNER RD VA VERIZON 5E AT&T RICHMOND 5401 STAPLES MILLS RD VA VERIZON VCD BROADSTREET CHESAPEAKE 510 INDEPENDENCE PARKWAY VA VERIZON VCD BROADSTREET GLENALLEN 4206 PARK PLACE CT VA VERIZON VCD BROADSTREET ROANOKE 5305 VALLEYPARK DR VA VERIZON 5E CAVALIER TELEPHONE HERNDON 360 HERNDON PKY VA VERIZON 5E CAVALIER TELEPHONE NORFOLK 1319 INGLESIDE RD VA VERIZON 5E CAVALIER TELEPHONE RICHMOND 2134 W LABURNUM AVE VA VERIZON DS COX NEWPORT NEWS 179 LOUISE DR VA VERIZON NT5 GLOBAL NAPS RESTON 12347 SUNRISE VALLEY DR VA VERIZON 5E ICG COMMUNICATIONS VIENNA 8504 TYCO RD VA VERIZON NT5 INTERMEDIA COMMUNICATIONS FAIRFAX 2720-D PROSPERITY AVE VA VERIZON 5E KMC TELECOM PORTSMOUTH 969 BROAD ST VA VERIZON 5E KMC TELECOM ROANOKE 2151 HOLLINS RD NE VA VERIZON DM5 NET2000 RICHMOND 701 E CARY ST VA VERIZON 5E PAETEC STERLING 22685 HOLIDAY PARK DR VA VERIZON NT5 PICUS COMMUNICATIONS NORFOLK 370 WORLD TRADE CTR VA VERIZON DCO TIDALWAVE TELEPHONE FAIRFAX 14101 PARKE LONG CT VA VERIZON NT5 URBAN MEDIA LONG DISTANCE HERNDON 470 SPRINGPARK PL VA VERIZON 5E US LEC RICHMOND 7401 BEAUFONT SPRINGS DR VA VERIZON 5E US LEC TYSONS CORNER 7901 JONES BRANCH DR VA VERIZON 5E US LEC VIRGINIA BEACH 477 VIKING DR VA VERIZON DMH WORLDCOM RESTON 12379 SUNRISE VALLEY DR VT VERIZON 5E ADELPHIA SOUTH 102 KIMBALL AVE BURLINGTON VT VERIZON DMT LIGHTSHIP TELECOM BURLINGTON 7 BURLINGTON SQ VT VERIZON EWSD SOVERNET WINOOSKI 276 E ALLEN ST WA VERIZON 5E ADELPHIA BELLEVUE 13410 NE 16TH ST WA VERIZON DS ADVANCED TELCOM GROUP EVERETT 2939 COLBY AVE WA QWEST VCD ADVANCED TELCOM GROUP TACOMA 1124 BROADWAY WA QWEST VCD ADVANCED TELCOM GROUP YAKIMA 15 W YAKIMA AVE WA VERIZON 5E ALLEGIANCE TELECOM SEATTLE 1100 2ND AVE 1ST FLOOR WA VERIZON 5E AT&T REDMOND 11241 WILLOWS RD WA VERIZON 5E AT&T SEATTLE 1122 3RD AVE WA QWEST 4E AT&T SEATTLE 1122 3RD AVE WA VERIZON 5E AT&T SEATTLE 1215 4TH AVE WA VERIZON 5E AT&T SEATTLE 1122 3RD AVE WA QWEST 4E AT&T SPOKANE 501 W 2ND AVE WA VERIZON 4E AT&T TACOMA 757 S FAWCETT AVE WA QWEST 5ES AT&T TACOMA 757 S FAWCETT AVE WA QWEST DMS100 AT&T TACOMA 2324 PACIFIC AVE WA QWEST 5ES AVISTA COMMUNICATIONS SPOKANE 118 N STEVENS ST WA QWEST DMS100 CENTURYTEL INC GIG HARBOR GIG HARBOR WA WA VERIZON VCD COMPUTERS 5, INC. DBA: LOCAL WENATCHEE 215 YAKIMA ST TEL WA VERIZON D12 ELECTRIC LIGHTWAVE SEATTLE 1218 3RD AVE RM.410 WA VERIZON D12 ELECTRIC LIGHTWAVE TUKWILA 13705 GATEWAY DR WA QWEST DMS1/200 ELECTRIC LIGHTWAVE VANCOUVER 4400 NE 77TH AVE WA VERIZON NT5 ESCHELON SEATTLE 1200 3RD AVE WA VERIZON NT5 FOCAL COMMUNICATIONS SEATTLE 1511 6TH AVE WA VERIZON NT5 GLOBAL CROSSING SEATTLE 2001 6TH AVE SUITE 1605
B-27
CLEC Circuit Switches Serving BOC Rate Centers State BOC Type CLEC City Street Region WA VERIZON DS GREAT WEST SVCS BELLEVUE 10001 NE 1ST ST WA QWEST DS ICG COMMUNICATIONS TUKWILA 12201 TUKWILA INTERNATIONAL BLVD WA VERIZON 5E INTEGRA TELECOM KENT 20435 72ND AVE S WA VERIZON DMS INTERNATIONAL TELCOM SEATTLE 417 2ND AVE W WA VERIZON DM5 INTERNATIONAL TELCOM SPOKANE 9515 E 1ST AVE WA QWEST DM5 MARATHON COMMUNICATIONS, SEATTLE 417 2ND AVE W INC. WA QWEST DM5 MCLEODUSA SPOKANE 627 E SPRAGUE AVE WA VERIZON DS MCLEODUSA TUKWILA 3311 S 120TH PL WA QWEST 5ES RAINIER CABLE EATONVILLE 5228 TANWAX BLVD WA VERIZON NT5 TELIGENT SEATTLE 1551 EASTLAKE AVE WA QWEST EWSD TIME WARNER TELECOM SPOKANE 601 W MAIN AVE WA VERIZON VCD WINSTAR SEATTLE 1000 2ND AVE WA QWEST AXE10 WORLDCOM KIRKLAND 11311 NE 120TH ST WA VERIZON 5E WORLDCOM KIRKLAND 11311 NE 120TH ST WA VERIZON NT5 WORLDCOM SEATTLE 2001 6TH WA VERIZON DMS XO SEATTLE 1000 DENNY WAY WA QWEST DMS1/200 XO SPOKANE 155 SOUTH STEVENS ST WI SBC 5E AT&T MADISON 315 W MIFFLIN ST WI VERIZON 5E AT&T WEST ALLIS 2152 S 114TH ST WI SBC 5E CHOICE ONE APPLETON 10 COLLEGE AVE WI SBC 5E CHOICE ONE MADISON 222 W WASHINGTON AVE WI SBC 5E CHOICE ONE MILWAUKEE 744 N 4TH ST WI SBC NT5 GLOBAL CROSSING GREEN BAY 2020 ANGIE AVE WI SBC 5E KMC TELECOM MADISON 714 MARKET PL WI SBC DS LEVEL 3 MILWAUKEE 411 E WISCONSIN AVE WI SBC DS MCLEODUSA GREEN BAY 314 N DANZ AVE WI SBC DS MCLEODUSA MADISON 1858 WRIGHT ST WI SBC VCD MCLEODUSA MILWAUKEE 731 N JACKSON ST WI SBC DMH NET LEC INC GREEN BAY 1046 GRAY CT WI SBC DMH NORTHERN TELEPHONE & DATA OSHKOSH 144 HIGH AVE CORP WI SBC EWSD TDS APPLETON 10 COLLEGE AVE WI SBC DMH TDS MADISON 6416 SCHROEDER RD WI SBC EWSD TDS MADISON 3330 UNIVERSITY AVE WI SBC EWSD TDS NEW BERLIN 2885 S 166TH ST WI SBC DS TIME WARNER TELECOM BROOKFIELD 3235 INTERTECH DR WI SBC 5E TIME WARNER TELECOM MILWAUKEE 1710 N 6TH ST WI SBC DE4 WORLDCOM MILWAUKEE 330 E WELLS ST WV VERIZON 4E AT&T CHARLESTON 816 LEE ST E WV VERIZON NT5 CTSI CHARLESTON 233 VIRGINIA ST E WV VERIZON DMH CTSI NITRO 2006 20TH ST WV VERIZON 5E FIBERNET CHARLESTON 211 BROAD ST WV VERIZON DMH NORTH COUNTY CHARLESTON 405 CAPITOL ST COMMUNICATIONS WV VERIZON 5E NTELOS CHARLESTON 500 SUMMERS ST WV VERIZON EWSD STRATUS WAVE COMM WHEELING 1025 MAIN ST
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APPENDIX C. WIRE CENTERS IN THE TOP 100 MSAS WHERE CLECS HAVE ACQUIRED CUSTOMERS THROUGH PORTED NUMBERS
Wire Centers in the Top 100 MSAs Where CLECs Have Acquired Customers Through Ported Numbers Percentage of Wire Centers Served by: Percentage of BOC Switched Access Lines in Wire Centers Served by: 1 or 2 or 3 or 4 or 1 or more CLEC switch 2 or more 3 or more 4 or more more more more more Bus. Res. Tot. Bus. Res. Tot. Bus. Res. Tot. Bus. Res. Tot. CLEC MSA switch 1. Los Angeles-Long Beach, 92 91 88 86 99 100 99 99 99 99 99 99 99 99 98 98 CA PMSA 2. New York, NY PMSA 95 86 79 73 99 99 99 97 97 97 97 95 96 95 91 92 3. Chicago, IL PMSA 89 82 77 69 98 99 98 97 96 96 95 94 94 92 89 91 4. Philadelphia, PA-NJ PMSA 95 88 81 75 100 99 99 99 97 97 98 95 96 97 93 94 5. Washington, DC-MD-VA- 63 53 50 47 91 89 90 89 83 86 88 80 84 86 76 81 WV PMSA 6. Detroit, MI PMSA 92 79 70 61 98 99 98 96 94 95 94 91 92 90 84 87 7. Houston, TX PMSA 90 74 68 64 98 97 97 96 93 94 95 89 91 93 86 89 8. Atlanta, GA MSA 80 73 67 66 98 99 99 97 97 97 95 94 94 95 93 94 9. Dallas, TX PMSA 93 81 71 62 100 99 99 98 95 97 96 91 93 93 85 88 10. Boston, MA-NH PMSA 97 93 86 78 100 99 99 99 97 98 98 95 96 97 92 95 11. Riverside-San Bernardino, Included in Los Angeles-Long Beach, CA PMSA CA PMSA 12. Phoenix-Mesa, AZ MSA 78 69 66 61 99 98 98 98 97 97 98 96 97 97 92 93 13. San Diego, CA MSA 86 78 73 71 99 98 98 98 97 98 97 93 95 96 93 94 14. Minneapolis-St. Paul, MN- 91 88 83 78 100 99 99 99 97 98 99 95 97 98 94 95 WI MSA 15. Orange County, CA PMSA Included in Los Angeles-Long Beach, CA PMSA 16. Nassau-Suffolk, NY PMSA 98 96 92 84 100 100 100 99 99 99 99 98 98 97 93 94 17. St. Louis, MO-IL MSA 66 45 39 36 94 91 92 83 77 79 80 72 75 79 70 73 18. Baltimore, MD PMSA 88 74 69 64 99 98 98 95 90 92 94 87 89 92 84 87 19. Oakland, CA PMSA Included in San Francisco, CA PMSA 20. Seattle-Bellevue-Everett, 100 96 96 88 100 100 100 99 98 99 99 98 99 99 96 97 WA PMSA 21. Tampa-St. Petersburg- 33 0 0 0 32 50 47 0 0 0 0 0 0 0 0 0 Clearwater, FL MSA
C-1
Wire Centers in the Top 100 MSAs Where CLECs Have Acquired Customers Through Ported Numbers Percentage of Wire Centers Served by: Percentage of BOC Switched Access Lines in Wire Centers Served by: 1 or 2 or 3 or 4 or 1 or more CLEC switch 2 or more 3 or more 4 or more more more more more Bus. Res. Tot. Bus. Res. Tot. Bus. Res. Tot. Bus. Res. Tot. CLEC MSA switch 22. Pittsburgh, PA MSA 81 74 61 48 99 96 97 97 93 94 93 87 90 90 81 84 23. Cleveland-Lorain-Elyria, 90 88 80 78 99 98 99 99 97 98 98 93 95 97 92 94 OH PMSA 24. Miami, FL PMSA 86 86 83 81 99 99 99 99 99 99 98 98 98 98 97 97 25. Denver, CO PMSA 97 81 81 81 100 100 100 98 96 97 98 96 97 98 96 97 26. Newark, NJ PMSA 95 90 88 83 100 99 99 98 96 97 97 94 95 95 92 93 27. Portland-Vancouver, OR- 90 86 81 81 99 98 98 99 97 98 98 97 97 98 97 97 WA PMSA 28. San Francisco, CA PMSA 84 77 73 67 99 98 98 98 95 96 97 94 95 95 91 93 29. Kansas City, MO-KS MSA 88 85 82 79 99 98 98 99 97 98 98 96 97 97 94 95 30. San Jose, CA PMSA 95 89 84 79 100 100 100 100 100 100 98 94 96 97 91 94 31. Cincinnati, OH-KY-IN 100 50 0 0 100 100 100 35 56 51 0 0 0 0 0 0 PMSA 32. FortWorth-Arlington, TX Included in Dallas, TX PMSA PMSA 33. Orlando, FL MSA 82 82 82 73 99 98 98 99 98 98 99 98 98 89 87 88 34. Sacramento, CA PMSA 78 53 47 47 99 96 97 95 87 91 91 83 86 91 83 86 35. San Antonio, TX MSA 77 70 60 57 99 96 97 98 95 96 93 89 90 92 88 89 36. Las Vegas, NV-AZ MSA Served principally by Sprint 37. Fort Lauderdale, FL PMSA 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 38. Indianapolis, IN MSA 76 61 48 45 98 94 96 94 86 89 90 80 84 89 78 82 39. Norfolk-Virginia Beach- 82 78 76 67 98 96 97 96 93 94 96 93 94 95 89 91 Newport News, VA-NC MSA 40. Milwaukee-Waukesha, WI 100 85 74 65 100 100 100 98 96 97 95 92 93 90 86 87 PMSA 41. Columbus, OH MSA 80 70 67 63 100 99 99 98 96 97 95 93 94 94 89 91 42. Charlotte-Gastonia-Rock 75 64 58 56 97 93 94 94 87 89 92 83 86 91 81 84 Hill, NC-SC MSA 43. Bergen-Passaic, NJ PMSA 96 89 89 81 99 98 99 99 97 98 99 97 98 95 91 93 44. New Orleans, LA MSA 83 52 52 48 99 97 98 95 91 92 95 91 92 95 89 90
C-2
Wire Centers in the Top 100 MSAs Where CLECs Have Acquired Customers Through Ported Numbers Percentage of Wire Centers Served by: Percentage of BOC Switched Access Lines in Wire Centers Served by: 1 or 2 or 3 or 4 or 1 or more CLEC switch 2 or more 3 or more 4 or more more more more more Bus. Res. Tot. Bus. Res. Tot. Bus. Res. Tot. Bus. Res. Tot. CLEC MSA switch 45. Salt Lake City-Ogden, UT 96 92 83 75 100 100 100 100 99 100 99 98 98 98 93 95 MSA 46. Greensboro-Winston Salem- 88 83 71 63 99 97 97 99 96 97 98 92 94 97 87 90 High Point, NC MSA 47. Nashville, TN MSA 73 68 61 59 97 94 95 96 92 93 95 89 91 94 88 90 48. Austin-San Marcos, TX 92 79 75 67 99 98 99 98 96 97 97 95 96 96 91 93 MSA 49. Buffalo-Niagara Falls, NY 80 60 53 48 98 96 96 96 91 92 94 88 90 93 86 88 MSA 50. Middlesex-Somerset- 93 86 82 79 100 99 99 98 96 97 98 95 96 97 93 95 Hunterdon, NJ PMSA 51. Hartford, CT MSA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA 52. Monmouth-Ocean, NJ 76 58 48 33 93 83 86 86 72 76 81 63 69 61 50 53 PMSA 53. Raleigh-Durham-Chapel 94 88 88 81 99 98 98 98 96 97 98 96 97 98 94 95 Hill, NC MSA 54. Memphis, TN-AR-MS 84 72 64 60 99 98 99 95 94 94 91 87 88 90 87 87 MSA 55. Providence-Fall River- 96 79 64 61 100 99 99 98 94 95 95 89 91 94 86 88 Warwick, RI-MA MSA 56. Jacksonville, FL MSA 88 85 76 68 99 97 98 98 97 97 95 91 92 92 84 87 57. Rochester, NY MSA 68 41 18 9 92 86 87 75 60 63 53 36 40 39 25 28 58. Grand Rapids-Muskegon- 82 54 46 36 97 93 95 93 82 86 91 80 85 78 62 69 Holland, MI MSA 59. West Palm Beach-Boca 94 88 88 88 100 100 100 98 98 98 98 98 98 98 98 98 Raton, FL MSA 60. Oklahoma City, OK MSA 84 69 63 53 100 99 99 94 89 91 93 85 88 91 81 85 61. Louisville, KY-IN MSA 85 85 80 80 99 99 99 99 99 99 97 96 97 97 96 97 62. Richmond-Petersburg, VA 73 73 68 65 98 95 96 98 95 96 97 91 93 97 90 93 MSA 63. Dayton-Springfield, OH 70 60 55 50 99 97 97 96 91 92 93 87 89 89 82 84 MSA
C-3
Wire Centers in the Top 100 MSAs Where CLECs Have Acquired Customers Through Ported Numbers Percentage of Wire Centers Served by: Percentage of BOC Switched Access Lines in Wire Centers Served by: 1 or 2 or 3 or 4 or 1 or more CLEC switch 2 or more 3 or more 4 or more more more more more Bus. Res. Tot. Bus. Res. Tot. Bus. Res. Tot. Bus. Res. Tot. CLEC MSA switch 64. Greenville-Spartanburg- 83 55 43 35 98 96 97 91 82 84 86 76 78 74 68 70 Anderson, SC MSA 65. Fresno, CA MSA 43 29 29 24 94 92 93 89 83 85 89 83 85 84 75 78 66. Birmingham, AL MSA 90 68 65 61 99 97 97 94 85 87 93 82 85 92 79 83 67. Albany-Schenectady-Troy, 64 55 41 39 97 92 93 96 90 91 92 83 86 92 81 84 NY MSA 68. Honolulu, HI MSA 85 51 5 0 94 99 96 76 92 82 14 36 22 0 0 0 69. Tucson, AZ MSA 84 68 58 53 100 99 99 98 89 92 95 83 86 94 80 84 70. Tulsa, OK MSA 63 52 44 33 95 90 92 91 80 84 84 76 79 79 64 70 71. Ventura, CA PMSA 67 56 44 44 96 92 93 91 85 87 88 75 79 88 75 79 72. Syracuse, NY MSA 66 51 40 40 96 90 92 94 85 87 91 80 83 91 80 83 73. Tacoma, WA PMSA 80 80 80 67 99 98 98 99 98 98 99 98 98 90 88 89 74. El Paso, TX MSA 69 46 0 0 97 89 92 88 71 77 0 0 0 0 0 0 75. Omaha, NE-IA MSA 86 71 62 62 100 98 99 98 95 96 98 93 95 98 93 95 76. Akron, OH PMSA 85 80 65 45 98 96 97 98 94 95 94 87 89 82 71 74 77. Albuquerque, NM MSA 69 63 56 56 95 88 90 94 84 87 92 80 84 92 80 84 78. Knoxville, TN MSA 68 59 50 41 95 90 92 94 87 89 90 81 83 85 75 77 79. Bakersfield, CA MSA 55 27 23 5 88 88 88 76 68 71 73 64 67 41 13 22 80. Gary, IN PMSA 38 19 0 0 60 53 56 38 32 34 0 0 0 0 0 0 81. Allentown-Bethlehem- 80 65 55 50 94 90 91 93 87 89 90 82 84 87 78 81 Easton, PA MSA 82. Harrisburg-Lebanon- 76 62 52 48 98 95 96 96 90 92 88 85 86 87 80 83 Carlisle, PA MSA 83. Scranton-Wilkes-Barre- 75 71 67 58 98 95 96 98 94 95 95 89 91 86 77 80 Hazleton, PA MSA 84. Toledo, OH MSA 80 73 67 53 98 96 97 94 91 92 90 87 88 81 75 77 85. Youngstown-Warren, OH 50 19 0 0 88 79 81 33 29 30 0 0 0 0 0 0 MSA 86. Baton Rouge, LA MSA 85 65 60 45 99 96 97 95 89 91 94 88 90 88 77 80 87. Sarasota-Bradenton, FL 89 74 68 63 94 97 95 86 92 88 83 91 85 80 90 83 MSA
C-4
Wire Centers in the Top 100 MSAs Where CLECs Have Acquired Customers Through Ported Numbers Percentage of Wire Centers Served by: Percentage of BOC Switched Access Lines in Wire Centers Served by: 1 or 2 or 3 or 4 or 1 or more CLEC switch 2 or more 3 or more 4 or more more more more more Bus. Res. Tot. Bus. Res. Tot. Bus. Res. Tot. Bus. Res. Tot. CLEC MSA switch 88. Wilmington-Newark, DE- 93 93 80 67 100 99 99 100 99 99 98 96 97 96 89 92 MD PMSA 89. Springfield, MA MSA 81 73 58 38 98 95 96 97 94 95 91 85 87 78 70 72 90. Ann Arbor, MI PMSA Included in Detroit, MI PMSA 91. Little Rock-North Little 74 65 43 35 97 92 94 92 86 88 79 64 69 76 57 64 Rock, AR MSA 92. Stockton-Lodi, CA MSA 78 56 0 0 98 97 97 86 81 82 0 0 0 0 0 0 93. Charleston-North 86 86 79 64 98 97 97 98 97 97 98 96 96 95 90 92 Charleston, SC MSA 94. Jersey City, NJ PMSA 100 100 100 80 100 100 100 100 100 100 100 100 100 94 87 90 95. McAllen-Edinburg-Mission, 11 11 0 0 50 24 32 50 24 32 0 0 0 0 0 0 TX MSA 96. Mobile, AL MSA 81 63 56 50 98 96 97 88 81 83 85 74 77 81 68 71 97. Vallejo-Fairfield-Napa, CA 92 62 31 31 100 99 100 93 92 93 69 67 68 69 67 68 PMSA 98. New Haven-Meriden, CT NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA PMSA 99. Columbia, SC MSA 93 87 73 53 99 99 99 98 95 96 96 91 93 93 87 89 100. Wichita, KS MSA 67 52 30 26 99 96 97 94 91 92 87 75 79 86 72 77 Total for Top 100 MSAs 83 73 65 60 98 97 97 96 93 94 93 89 91 91 86 88
C-5
APPENDIX D. RATE EXCHANGE AREAS IN THE TOP 100 MSAS WHERE CLECS HAVE OBTAINED NXX CODES
Rate Exchange Areas in the Top 100 MSAs Where CLECs Have Obtained NXX Codes Percentage of Rate Exchange Areas Served by: 1 or more 2 or more 3 or more 4 or more CLEC switch 1. Los Angeles-Long Beach, CA PMSA 96 86 74 60 2. New York, NY PMSA 96 85 85 66 3. Chicago, IL PMSA 74 57 30 8 4. Philadelphia, PA-NJ PMSA 99 94 94 75 5. Washington, DC-MD-VA-WV PMSA 90 75 75 51 6. Detroit, MI PMSA 88 84 66 48 7. Houston, TX PMSA 81 63 50 38 8. Atlanta, GA MSA 100 80 60 47 9. Dallas, TX PMSA 95 76 53 42 10. Boston, MA-NH PMSA 100 92 92 80 11. Riverside-San Bernardino, CA PMSA Included in Los Angeles-Long Beach, CA PMSA 12. Phoenix-Mesa, AZ MSA 50 31 25 25 13. San Diego, CA MSA 89 77 63 57 14. Minneapolis-St. Paul, MN-WI MSA 100 29 18 14 15. Orange County, CA PMSA Included in Los Angeles-Long Beach, CA PMSA 16. Nassau-Suffolk, NY PMSA 89 74 74 61 17. St. Louis, MO-IL MSA 24 10 6 0 18. Baltimore, MD PMSA 100 94 94 77 19. Oakland, CA PMSA Included in San Francisco, CA PMSA 20. Seattle-Bellevue-Everett, WA PMSA 98 85 73 63 21. Tampa-St. Petersburg-Clearwater, FL MSA 100 88 88 88 22. Pittsburgh, PA MSA 99 77 77 43 23. Cleveland-Lorain-Elyria, OH PMSA 91 83 43 26 24. Miami, FL PMSA 100 100 100 100 25. Denver, CO PMSA 79 50 50 43 26. Newark, NJ PMSA 97 86 86 72 27. Portland-Vancouver, OR-WA PMSA 81 53 42 36 28. San Francisco, CA PMSA 95 90 76 48 29. Kansas City, MO-KS MSA 44 22 17 11 30. San Jose, CA PMSA 91 82 82 73 31. Cincinnati, OH-KY-IN PMSA 50 0 0 0 32. Fort Worth-Arlington, TX PMSA Included in Dallas, TX PMSA 33. Orlando, FL MSA 100 100 100 100 34. Sacramento, CA PMSA 91 55 27 18 35. San Antonio, TX MSA 100 80 60 40 36. Las Vegas, NV-AZ MSA Served principally by Sprint 37. Fort Lauderdale, FL PMSA 100 100 100 100 38. Indianapolis, IN MSA 28 0 0 0 39. Norfolk-Virginia Beach-Newport News, VA-NC MSA 100 75 75 50 40. Milwaukee-Waukesha, WI PMSA 77 50 32 9 41. Columbus, OH MSA 61 48 22 0 42. Charlotte-Gastonia-Rock Hill, NC-SC MSA 86 73 45 36 D-1
Rate Exchange Areas in the Top 100 MSAs Where CLECs Have Obtained NXX Codes Percentage of Rate Exchange Areas Served by: 1 or more 2 or more 3 or more 4 or more CLEC switch 43. Bergen-Passaic, NJ PMSA 100 100 100 72 44. New Orleans, LA MSA 62 31 24 21 45. Salt Lake City-Ogden, UT MSA 100 41 38 31 46. Greensboro-Winston Salem-High Point, NC MSA 67 67 58 42 47. Nashville, TN MSA 78 53 38 34 48. Austin-San Marcos, TX MSA 100 50 25 25 49. Buffalo-Niagara Falls, NY MSA 100 44 44 28 50. Middlesex-Somerset-Hunterdon, NJ PMSA 100 95 95 86 51. Hartford, CT MSA NA NA NA NA 52. Monmouth-Ocean, NJ PMSA 100 68 68 41 53. Raleigh-Durham-Chapel Hill, NC MSA 100 89 89 78 54. Memphis, TN-AR-MS MSA 62 46 31 23 55. Providence-Fall River-Warwick, RI-MA MSA 100 96 96 92 56. Jacksonville, FL MSA 92 62 54 38 57. Rochester, NY MSA 93 57 57 0 58. Grand Rapids-Muskegon-Holland, MI MSA 86 29 10 5 59. West Palm Beach-Boca Raton, FL MSA 100 100 100 100 60. Oklahoma City, OK MSA 86 33 14 5 61. Louisville, KY-IN MSA 75 50 25 25 62. Richmond-Petersburg, VA MSA 100 89 89 53 63. Dayton-Springfield, OH MSA 6 0 0 0 64. Greenville-Spartanburg-Anderson, SC MSA 96 54 29 21 65. Fresno, CA MSA 94 19 13 0 66. Birmingham, AL MSA 100 93 21 21 67. Albany-Schenectady-Troy, NY MSA 100 70 70 45 68. Honolulu, HI MSA 100 0 0 0 69. Tucson, AZ MSA 38 38 38 13 70. Tulsa, OK MSA 65 15 5 0 71. Ventura, CA PMSA 100 89 56 22 72. Syracuse, NY MSA 94 65 65 47 73. Tacoma, WA PMSA 100 57 43 43 74. El Paso, TX MSA 25 0 0 0 75. Omaha, NE-IA MSA 85 46 15 15 76. Akron, OH PMSA 30 10 0 0 77. Albuquerque, NM MSA 29 14 14 14 78. Knoxville, TN MSA 59 29 29 29 79. Bakersfield, CA MSA 93 29 14 0 80. Gary, IN PMSA 18 0 0 0 81. Allentown-Bethlehem-Easton, PA MSA 100 93 93 67 82. Harrisburg-Lebanon-Carlisle, PA MSA 100 77 77 46 83. Scranton-Wilkes-Barre-Hazleton, PA MSA 100 89 89 11 84. Toledo, OH MSA 71 43 29 14 85. Youngstown-Warren, OH MSA 0 0 0 0 86. Baton Rouge, LA MSA 50 50 50 20 87. Sarasota-Bradenton, FL MSA 100 71 71 43 88. Wilmington-Newark, DE-MD PMSA 100 91 91 55 D-2
Rate Exchange Areas in the Top 100 MSAs Where CLECs Have Obtained NXX Codes Percentage of Rate Exchange Areas Served by: 1 or more 2 or more 3 or more 4 or more CLEC switch 89. Springfield, MA MSA 100 100 100 57 90. Ann Arbor, MI PMSA Included in Detroit, MI PMSA 91. Little Rock-North Little Rock, AR MSA 7 7 0 0 92. Stockton-Lodi, CA MSA 86 29 29 0 93. Charleston-North Charleston, SC MSA 100 50 38 38 94. Jersey City, NJ PMSA 100 100 100 100 95. McAllen-Edinburg-Mission, TX MSA 25 0 0 0 96. Mobile, AL MSA 83 50 17 17 97. Vallejo-Fairfield-Napa, CA PMSA 100 80 30 20 98. New Haven-Meriden, CT PMSA NA NA NA NA 99. Columbia, SC MSA 100 40 20 20 100. Wichita, KS MSA 67 13 4 4 Total for Top 100 MSAs 85 65 56 41
D-3
APPENDIX E. CLEC PACKET SWITCHES
This appendix tabulates the packet switches that CLECs operate. It is based on information from New Paradigm Resource Group’s CLEC Report 2002.
This appendix includes the switches owned by CLECs that have declared bankruptcy. Most such CLECs are still operational (and some are now emerging from bankruptcy). Moreover, switches are a sunk investment, so if one company ceases to use its switch it is highly likely that another company will quickly seize the opportunity to do so (and will probably be able to obtain the switch at a fire-sale price). In addition, even though some CLECs may now be experiencing financial troubles, the fact that they were able to deploy so many switches at one time is still highly probative of the ability of CLECs to deploy switches generally. In any event, switches operated by CLECs that have declared bankruptcy (as of March 31, 2002) represent no more than 19 percent of the total counted here.
CLEC Packet Switches State CLEC Number of Switch Type City Switches AL ITC^DELTACOM 2 2 ASCEND FRAME RELAY ANNISTON AL ITC^DELTACOM 1 FRAME RELAY CASCADE 9000 ARAB AL AT&T 1 ERICCSON STP BIRMINGHAM AL E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE BIRMINGHAM AL INTERMEDIA COMMUNICATIONS 1 ASCEND 9000 BIRMINGHAM AL ITC^DELTACOM 3 2 CASCADE; 1 ATM BIRMINGHAM AL NEWSOUTH COMMUNICATIONS 1 CISCO BPX 8600 & MGX 8850 BIRMINGHAM AL US LEC 1 LUCENT CBX500 BIRMINGHAM AL WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM BIRMINGHAM AL INTERMEDIA COMMUNICATIONS 1 ASCEND 9000 HUNTSVILLE AL KNOLOGY BROADBAND 1 FORE ATM HUNTSVILLE AL E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE MOBILE AL ITC^DELTACOM 1 ASCEND FRAME RELAY MOBILE AL NEWSOUTH COMMUNICATIONS 1 CISCO BPX 8600 & MGX 8850 MOBILE AL US LEC 1 LUCENT CBX500 MOBILE AL E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE MONTGOMERY AL INTERMEDIA COMMUNICATIONS 1 ASCEND 9000 MONTGOMERY AL ITC^DELTACOM 1 ASCEND FRAME RELAY MONTGOMERY AL KNOLOGY BROADBAND 1 FORE ATM MONTGOMERY AL KNOLOGY BROADBAND PLANNED FORE ATM HUNTSVILLE AL KNOLOGY BROADBAND PLANNED FORE ATM MONTGOMERY AR E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE LITTLE ROCK AR INTERMEDIA COMMUNICATIONS 1 ASCEND 9000 LITTLE ROCK AR LOGIX COMMUNICATIONS ENTERPRISES 1 CISCO ATM LITTLE ROCK AR NUVOX COMMUNICATIONS 1 LUCENT AC 120 LITTLE ROCK AZ WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM FLAGSTAFF AZ ALLEGIANCE TELECOM 1 CISCO BPX 8650 PHOENIX AZ AT&T 2 ERICCSON; N/A PHOENIX AZ E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE PHOENIX AZ ESCHELON TELECOM 1 NORTEL PASSPORT ATM PHOENIX AZ GLOBAL CROSSING 1 LUCENT ASCEND PHOENIX AZ INTERMEDIA COMMUNICATIONS 2 ASCEND 9000; ASCEND CBX 500 PHOENIX AZ LIGHTYEAR COMMUNICATIONS 1 ACCEL AN3220 PHOENIX
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CLEC Packet Switches State CLEC Number of Switch Type City Switches AZ PAC-WEST TELECOMM 1 ALCATEL MEGAHUB 600E PHOENIX AZ WINSTAR COMMUNICATIONS 3 NEWBRIDGE ATM PHOENIX AZ WORLDCOM 1 N/A PHOENIX AZ XO COMMUNICATIONS 1* N/A PHOENIX AZ E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE TUCSON AZ WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM TUCSON AZ NTS COMMUNICATIONS PLANNED N/A PHOENIX AZ WESTERN INTEGRATED NETWORKS PLANNED N/A PHOENIX CA AT&T 2 ERICCSON STP; N/A ANAHEIM CA LIGHTYEAR COMMUNICATIONS 1 ACCEL AN3220 ANAHEIM CA ADVANCED TELCOM GROUP 1 N/A COTATI CA ICG COMMUNICATIONS 1 AIN NODES IRVINE CA WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM LONG BEACH CA ALLEGIANCE TELECOM 1 CISCO BPX 8650 LOS ANGELES CA AT&T 2 ERICCSON STP; N/A LOS ANGELES CA EAGLE COMMUNICATIONS 1 ASCEND MAX TNT LOS ANGELES CA GLOBAL CROSSING 1 LUCENT ASCEND LOS ANGELES CA GLOBALCOM 1 N/A LOS ANGELES CA ICG COMMUNICATIONS 2 AIN NODES LOS ANGELES CA INTERMEDIA COMMUNICATIONS 3* ASCEND 9000; ASCEND CBX 500 LOS ANGELES CA NET2000 COMMUNICATIONS 1* N/A LOS ANGELES CA PAC-WEST TELECOMM 1 ALCATEL MEGAHUB 600E LOS ANGELES CA US TELEPACIFIC D/B/A TELEPACIFIC 1 CISCO BPX 8620 LOS ANGELES CA WINSTAR COMMUNICATIONS 2 NEWBRIDGE ATM LOS ANGELES CA AT&T 3 1 IP; 2 N/A OAKLAND CA PAC-WEST TELECOMM 1 ALCATEL MEGAHUB 600E OAKLAND CA ALLEGIANCE TELECOM 1 CISCO BPX 8650 ORAGNE CA ADVANCED TELCOM GROUP 1 N/A PETALUMA CA ADVANCED TELCOM GROUP 1 N/A ROHNERT PARK CA ALLEGIANCE TELECOM 1 CISCO BPX 8650 SACRAMENTO CA AT&T 1 ERICCSON STP SACRAMENTO CA GLOBAL CROSSING 1 LUCENT ASCEND SACRAMENTO CA ICG COMMUNICATIONS 1 AIN NODES SACRAMENTO CA WESTERN INTEGRATED NETWORKS 1 N/A SACRAMENTO CA WINSTAR COMMUNICATIONS 1 ASCEND 9000 FRAME RELAY SACRAMENTO CA ALLEGIANCE TELECOM. 1 CISCO BPX 8650 SAN DIEGO CA AT&T 1 ATM SAN DIEGO CA GLOBAL CROSSING 1 LUCENT ASCEND SAN DIEGO CA ICG COMMUNICATIONS 1 AIN NODES SAN DIEGO CA LIGHTYEAR COMMUNICATIONS 1 ACCEL AN3220 SAN DIEGO CA TIME WARNER TELECOM 4* FORE/LUCENT/ASCEND SAN DIEGO CA US TELEPACIFIC D/B/A TELEPACIFIC 1 CISCO BPX 8620 SAN DIEGO CA WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM SAN DIEGO CA ALLEGIANCE TELECOM 1 CISCO BPX SAN FRANCISCO CA AT&T 1 N/A SAN FRANCISCO CA GLOBAL CROSSING 1 LUCENT ASCEND SAN FRANCISCO CA ICG COMMUNICATIONS 1 AIN NODES SAN FRANCISCO CA INTERMEDIA COMMUNICATIONS 3* ASCEND 9000 SAN FRANCISCO CA LIGHTYEAR COMMUNICATIONS 1 ACCEL AN3220 SAN FRANCISCO CA NET2000 COMMUNICATIONS 1* N/A SAN FRANCISCO CA WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM SAN FRANCISCO
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CLEC Packet Switches State CLEC Number of Switch Type City Switches CA ALLEGIANCE TELECOM 1 CISCO BPX 8650 SAN JOSE CA E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE SAN JOSE CA ICG COMMUNICATIONS 1 AIN NODES SAN JOSE CA NET2000 COMMUNICATIONS 1* N/A SAN JOSE CA US TELEPACIFIC D/B/A TELEPACIFIC 1 CISCO BPX 8650 SAN JOSE CA WORLDCOM 1 N/A SAN JOSE CA E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE SANTA CLARA CA WINSTAR COMMUNICATIONS 1* N/A SANTA CLARA CA WINSTAR COMMUNICATIONS 1* N/A SANTA MONICA CA ADVANCED TELCOM GROUP 3 N/A SANTA ROSA CA ICG COMMUNICATIONS 2 AIN NODES SOUTHERN CALIFORNIA EDISON REGION CA PAC-WEST TELECOMM 1 ALCATEL MEGAHUB 600E STOCKTON CA FOCAL COMMUNICATIONS PLANNED N/A LOS ANGELES CA WESTERN INTEGRATED NETWORKS PLANNED N/A LOS ANGELES CA WESTERN INTEGRATED NETWORKS PLANNED N/A SAN DIEGO CA WESTERN INTEGRATED NETWORKS PLANNED N/A SAN FRANCISCO CO E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE COLORADO SPRINGS CO ICG COMMUNICATIONS 1 AIN NODES COLORADO SPRINGS CO SUNWEST COMMUNICATIONS 1 N/A COLORADO SPRINGS CO VANION 1 SPRING TIDE IP SERVICE SWITCH COLORADO SPRINGS 5000 CO ALLEGIANCE TELECOM 1 CISCO BPX 8650 DENVER CO AT&T 2 ERICCSON STP; N/A DENVER CO ESCHELON TELECOM 1 NORTEL PASSPORT ATM DENVER CO GLOBAL CROSSING 1 LUCENT ASCEND DENVER CO ICG COMMUNICATIONS 1 AIN NODES DENVER CO INTERMEDIA COMMUNICATIONS 2 ASCEND 9000; ASCEND CBX 500 DENVER CO LIGHTYEAR COMMUNICATIONS 1 ACCEL AN3220 DENVER CO NET2000 COMMUNICATIONS 1* N/A DENVER CO VANION 1 SPRING TIDE IP SERVICE SWITCH DENVER 5000 CO WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM DENVER CT CTC COMMUNICATIONS 1 CISCO 8600/8800 FAIRFIELD CT AT&T 1 ATM HARTFORD CT INTERMEDIA COMMUNICATIONS 1 ASCEND 9000 HARTFORD CT CTC COMMUNICATIONS 1 CISCO 8600/8800 MERIDEN CT CHOICE ONE COMMUNICATIONS 1 N/A NEW HAVEN CT CABLEVISION LIGHTPATH 1* N/A NORWALK CT WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM STAMFORD DC ALLEGIANCE TELECOM 1 CISCO BPX 8650 WASHINGTON, DC DC AT&T 1 ATM WASHINGTON, DC DC BTI TELECOM 1 LUCENT ASCEND WASHINGTON, DC DC E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE WASHINGTON, DC DC GLOBAL CROSSING 1 LUCENT ASCEND WASHINGTON, DC DC INTERMEDIA COMMUNICATIONS 5* ASCEND 9000/ASCEND CBX 500 WASHINGTON, DC DC NET2000 COMMUNICATIONS 1 NORTEL 7480 WASHINGTON, DC DC US LEC 1 LUCENT CBX500 WASHINGTON, DC DC WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM WASHINGTON, DC DC WORLDCOM 1 N/A WASHINGTON, DC DC ARBROS COMMUNICATIONS 1 LUCENT ACCESS CONCENTRATOR WASHINGTON, DC FL FLORIDA DIGITAL NETWORK 1* N/A COCOA
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CLEC Packet Switches State CLEC Number of Switch Type City Switches FL INTERMEDIA COMMUNICATIONS 2* ASCEND 9000 DAYTONA BEACH FL NEWSOUTH COMMUNICATIONS 1 CISCO BPX 8600 & MGX 8850 DESTIN FL AT&T 1 ATM FORT LAUDERDALE FL E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE FORT LAUDERDALE FL EAGLE COMMUNICATIONS 1 ASCEND MAX TNT FORT LAUDERDALE FL FLORIDA DIGITAL NETWORK 1 CISCO FORT LAUDERDALE FL INTERMEDIA COMMUNICATIONS 5* ASCEND 9000; ASCEND CBX 500 FORT LAUDERDALE FL E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE FORT MYERS FL INTERMEDIA COMMUNICATIONS 2* ASCEND 9000 FORT MYERS FL US LEC 1 LUCENT CBX500 FORT MYERS FL INTERMEDIA COMMUNICATIONS 2* N/A GAINESVILLE FL AT&T 1 ERICCSON STP JACKSONVILLE FL BTI TELECOM 1 LUCENT ASCEND JACKSONVILLE FL E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE JACKSONVILLE FL FLORIDA DIGITAL NETWORK 1 CISCO JACKSONVILLE FL INTERMEDIA COMMUNICATIONS 4* ASCEND 9000; ASCEND CBX 500 JACKSONVILLE FL ITC^DELTACOM 1 ASCEND FRAME RELAY JACKSONVILLE FL LIGHTYEAR COMMUNICATIONS 1 ACCEL AN3220 JACKSONVILLE FL NEWSOUTH COMMUNICATIONS 1 CISCO BPX 8600 & MGX 8850 JACKSONVILLE FL US LEC 1 LUCENT CBX500 JACKSONVILLE FL WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM JACKSONVILLE FL INTERMEDIA COMMUNICATIONS 1* N/A KEY WEST FL ALLEGIANCE TELECOM 1 CISCO BPX 8650 MIAMI FL AT&T 1 ATM MIAMI FL BTI TELECOM 1 LUCENT ASCEND FRAME RELAY MIAMI FL E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE MIAMI FL EAGLE COMMUNICATIONS 1 ASCEND MAX TNT MIAMI FL INTERMEDIA COMMUNICATIONS 7* ASCEND 9000; ASCEND CBX 500 MIAMI FL LIGHTYEAR COMMUNICATIONS 1 ACCEL AN3220 MIAMI FL NET2000 COMMUNICATIONS 1* N/A MIAMI FL NETWORK PLUS 1* N/A MIAMI FL US LEC 1 LUCENT CBX500 MIAMI FL WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM MIAMI FL INTERMEDIA COMMUNICATIONS 1* N/A OCALA FL ITC^DELTACOM 2 1 ATM; 1 ASCEND FRAME RELAY OCALA FL AT&T 1 ATM ORLANDO FL BTI TELECOM 1 LUCENT ASCEND ORLANDO FL E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE ORLANDO FL FLORIDA DIGITAL NETWORK 1 CISCO ORLANDO FL INTERMEDIA COMMUNICATIONS 5* ASCEND 9000; ASCEND CBX 500 ORLANDO FL NET2000 COMMUNICATIONS 1* N/A ORLANDO FL ORLANDO TELEPHONE COMPANY 1 CISCO MGX 8850 ORLANDO FL TIME WARNER TELECOM 4* FORE;ALCATEL;LUCENT;ASCEND ORLANDO FL US LEC 1 LUCENT CBX500 ORLANDO FL WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM ORLANDO FL INTERMEDIA COMMUNICATIONS 2* ASCEND 9000 PANAMA CITY FL KNOLOGY BROADBAND 1 FORE ATM PANAMA CITY FL INTERMEDIA COMMUNICATIONS 2* ASCEND 9000 PENSACOLA FL INTERMEDIA COMMUNICATIONS 1 ASCEND 9000 SAINT PETERSBURG FL E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE TALLAHASSEE FL INTERMEDIA COMMUNICATIONS 5* ASCEND 9000; ASCEND CBX 500 TALLAHASSEE
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CLEC Packet Switches State CLEC Number of Switch Type City Switches FL ALLEGIANCE TELECOM 1 CISCO BPX 8650 TAMPA FL AT&T 1 ATM TAMPA FL BTI TELECOM 1 LUCENT ASCEND TAMPA FL E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE TAMPA FL EAGLE COMMUNICATIONS 1 ASCEND MAX TNT TAMPA FL FLORIDA DIGITAL NETWORK 1 CISCO TAMPA FL GLOBAL CROSSING 1 LUCENT ASCEND TAMPA FL INTERMEDIA COMMUNICATIONS 9* ASCEND 9000; ASCEND CBX 500 TAMPA FL NET2000 COMMUNICATIONS 1* N/A TAMPA FL TIME WARNER TELECOM 4* FORE/ALCATEL/LUCENT/ASCEND TAMPA FL US LEC 1 LUCENT CBX500 TAMPA FL WINSTAR COMMUNICATIONS 2 NEWBRIDGE ATM TAMPA FL WORLDCOM 1 N/A TAMPA FL FLORIDA DIGITAL NETWORK 1 CISCO WEST PALM BEACH FL INTERMEDIA COMMUNICATIONS 3* ASCEND 9000 WEST PALM BEACH FL US LEC 1 LUCENT CBX500 WEST PALM BEACH FL FLORIDA DIGITAL NETWORK 1 CISCO WINTER PARK FL BTI TELECOM PLANNED LUCENT ATM MIAMI FL KNOLOGY BROADBAND PLANNED FORE ATM MIAMI GA ALLEGIANCE TELECOM 1 CISCO BPX 8650 ATLANTA GA AT&T 2 ERICCSON STP; N/A ATLANTA GA BTI TELECOM 1 LUCENT ASCEND FRAME RELAY ATLANTA GA COX COMMUNICATIONS 1* N/A ATLANTA GA EAGLE COMMUNICATIONS 1 ASCEND MAX TNT ATLANTA GA GLOBAL CROSSING 1 LUCENT ASCEND ATLANTA GA GLOBALCOM 1 N/A ATLANTA GA ICG COMMUNICATIONS 1 AIN NODES ATLANTA GA INTERMEDIA COMMUNICATIONS 8* ASCEND 9000; ASCEND CBX 500 ATLANTA GA ITC^DELTACOM 3 2 FRAME RELAY CASCADE 900; ATLANTA 1 ATM GA LIGHTYEAR COMMUNICATIONS 1 ACCEL AN3220 ATLANTA GA NETWORK TELEPHONE 1* N/A ATLANTA GA NEWSOUTH COMMUNICATIONS 1 CISCO BPX 8600 & MBX 8850 ATLANTA GA US LEC 1 LUCENT CBX500 ATLANTA GA WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM ATLANTA GA INTERMEDIA COMMUNICATIONS 1 ASCEND 9000 AUGUSTA GA KNOLOGY BROADBAND 1 NORTEL DPN 10 AUGUSTA GA E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE COLUMBUS GA KNOLOGY BROADBAND 1 FORE ATM COLUMBUS GA E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE SAVANNAH GA INTERMEDIA COMMUNICATIONS 1 ASCEND 9000 SAVANNAH GA ITC^DELTACOM 1 CASCADE 9000 WEST POINT GA BTI TELECOM PLANNED LUCENT ATM ATLANTA GA KNOLOGY BROADBAND PLANNED FORE ATM COLUMBUS HI TIME WARNER TELECOM 31* FORE ALCATEL HONOLULU HI WINSTAR COMMUNICATIONS 1 FRAME RELAY HONOLULU IA FOREST CITY TELECOM PLANNED N/A FOREST CITY ID WINSTAR COMMUNICATIONS 1 FRAME RELAY BOISE IL DIGITAL PIPELINE COMMUNICATIONS 1* N/A ALGONQUIN IL ADELPHIA BUSINESS SOLUTIONS 1 N/A CHICAGO IL ALLEGIANCE TELECOM 1 CISCO BPX 8650 CHICAGO
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CLEC Packet Switches State CLEC Number of Switch Type City Switches IL AT&T 4 ERICCSON STP; N/A CHICAGO IL CORECOMM 1* N/A CHICAGO IL E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE CHICAGO IL EAGLE COMMUNICATIONS 1 ASCEND MAX TNT CHICAGO IL GLOBAL CROSSING 1 LUCENT ASCEND CHICAGO IL GLOBALCOM 1 N/A CHICAGO IL INTERMEDIA COMMUNICATIONS 5* ASCEND 9000; ASCEND CBX 500 CHICAGO IL LIGHTYEAR COMMUNICATIONS 1 ACCEL AN3220 CHICAGO IL NET2000 COMMUNICATIONS 1* N/A CHICAGO IL RCN 1 N/A CHICAGO IL WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM CHICAGO IL DIGITAL PIPELINE COMMUNICATIONS 1* N/A CRYSTAL LAKE IL AT&T 1 N/A LISLE IL MCLEODUSA 1 MAGELLAN ILO PEORIA IL CHOICE ONE COMMUNICATIONS 1 LUCENT/CISCO ROCKFORD IL AT&T 1 N/A ROLLING MEADOWS IN MCLEODUSA 1 N/A BLOOMINGTON IN MCLEODUSA 1 N/A EVANSVILLE IN AT&T 2 ATM; FRAME RELAY INDIANAPOLIS IN CHOICE ONE COMMUNICATIONS 1 CISCO INDIANAPOLIS IN GLOBAL CROSSING 1 LUCENT ASCEND INDIANAPOLIS IN INTERMEDIA COMMUNICATIONS 1 ASCEND 9000 INDIANAPOLIS IN LIGHTYEAR COMMUNICATIONS 1 ACCEL AN3220 INDIANAPOLIS IN NUVOX COMMUNICATIONS 1 LUCENT AC 120 INDIANAPOLIS IN TIME WARNER TELECOM 10 FORE/ALCATEL/LUCENT/ASCEND INDIANAPOLIS IN MCLEODUSA 1 N/A MERRILLVILLE IN CHOICE ONE COMMUNICATIONS 1 LUCENT/CISCO ATM SOUTH BEND IN MCLEODUSA 1 N/A SOUTH BEND IN MCLEODUSA 1 N/A TERRE HAUTE KS LOGIX COMMUNICATIONS ENTERPRISES 1 CISCO ATM KANSAS CITY KS NUVOX COMMUNICATIONS 1 LUCENT AC 120 KANSAS CITY KS GLOBAL CROSSING 1 LUCENT ASCEND TOPEKA KS LOGIX COMMUNICATIONS ENTERPRISES 1 CISCO ATM WICHITA KS NUVOX COMMUNICATIONS 1 LUCENT AC 120 WICHITA KY E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE LEXINGTON KY LIGHTYEAR COMMUNICATIONS 1 ACCEL AN3220 LEXINGTON KY AT&T 1 ERICCSON STP LOUISVILLE KY E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE LOUISVILLE KY INTERMEDIA COMMUNICATIONS 1 ASCEND 9000 LOUISVILLE KY LIGHTYEAR COMMUNICATIONS 1 ACCEL AN3220 LOUISVILLE KY NEWSOUTH COMMUNICATIONS 1 CISCO BPX 8600 & MGX 8850 LOUISVILLE KY US LEC 1 LUCENT CBX500 LOUISVILLE KY BTI TELECOM PLANNED LUCENT ASCEND LOUSIVILLE LA E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE BATON ROUGE LA INTERMEDIA COMMUNICATIONS 1 ASCEND 9000 BATON ROUGE LA XSPEDIUS CORPORATION 1* N/A BATON ROUGE LA XSPEDIUS CORPORATION 1* N/A LAFAYETTE LA XSPEDIUS CORPORATION 1* N/A LAKE CHARLES LA E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE NEW ORLEANS LA INTERMEDIA COMMUNICATIONS 3* ASCEND 9000; ASCEND CBX 500 NEW ORLEANS LA ITC^DELTACOM 1 ATM NEW ORLEANS
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CLEC Packet Switches State CLEC Number of Switch Type City Switches LA NEWSOUTH COMMUNICATIONS 1 CISCO BPX 8600 & MGX 8850 NEW ORLEANS LA US LEC 1 LUCENT CBX500 NEW ORLEANS LA INTERMEDIA COMMUNICATIONS 2* N/A SHREVEPORT LA XSPEDIUS CORPORATION 1* N/A SHREVEPORT MA ADELPHIA BUSINESS SOLUTIONS 1 N/A BOSTON MA ALLEGIANCE TELECOM 1 CISCO BPX 8650 BOSTON MA ARBROS COMMUNICATIONS 1 LUCENT ACCESS CONCENTRATOR BOSTON 120 MA AT&T 2 ATM/FRAME RELAY BOSTON MA CTC COMMUNICATIONS 1 CISCO 8600/8800 BOSTON MA EAGLE COMMUNICATIONS 1 ASCEND MAX TNT BOSTON MA GLOBAL CROSSING 1 LUCENT ASCEND BOSTON MA INTERMEDIA COMMUNICATIONS 4* ASCEND 9000/ASCEND CBX500 BOSTON MA LIGHTYEAR COMMUNICATIONS 1 ACCEL AN3220 BOSTON MA NET2000 COMMUNICATIONS 1 NORTEL 7480 BOSTON MA WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM BOSTON MA CTC COMMUNICATIONS 1 CISCO 8600/8800 BRAINTREE MA AT&T 1 N/A CAMBRIDGE MA CTC COMMUNICATIONS 1 CISCO 8600/8800 DANVERS MA CTC COMMUNICATIONS 1 CISCO 8600/8800 LEXINGTON MA CTC COMMUNICATIONS 1 CISCO 8600/8800 MANCHESTER MA AT&T 1 IP MARLBOROUGH MA CTC COMMUNICATIONS 1 CISCO 8600/8800 MARLBORO MA CTC COMMUNICATIONS 1 CISCO 8600/8800 NORTH ATTLEBORO MA EAGLE COMMUNICATIONS 1 ASCEND MAX TNT SALEM MA CHOICE ONE COMMUNICATIONS 1 LUCENT/CISCO SPRINGFIELD MA CTC COMMUNICATIONS 1 CISCO 8600/8800 SPRINGFIELD MA EAGLE COMMUNICATIONS 1 ASCEND MAX TNT SPRINGFIELD MA CTC COMMUNICATIONS 1 CISCO 8600/8800 WALTHAM MA CTC COMMUNICATIONS 1 CISCO 8600/8800 WEST SPRINGFIELD MA AT&T 1 N/A WORCESTER MA CHOICE ONE COMMUNICATIONS 1 LUCENT 5ESS WORCESTER MA LIGHTSHIP TELECOM 1 LUCENT CBX500 WORCESTER MA BROADVIEW NETWORKS PLANNED CISCO ATM BOSTON MD ALLEGIANCE TELECOM 1 CISCO BPX 8650 BALTIMORE MD AT&T 2 ATM/FRAME RELAY BALTIMORE MD GLOBAL CROSSING 1 LUCENT ASCEND BALTIMORE MD INTERMEDIA COMMUNICATIONS 2* ASCEND 9000 BALTIMORE MD LIGHTYEAR COMMUNICATIONS 1 ACCEL AN3220 BALTIMORE MD NET2000 COMMUNICATIONS 1 NORTEL 7480 BALTIMORE MD US LEC 1 LUCENT CBX500 BALTIMORE MD WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM BALTIMORE ME CTC COMMUNICATIONS 1 CISCO 8600/8800 BANGOR ME CTC COMMUNICATIONS 1 CISCO 8600/8800 PORTLAND ME LIGHTSHIP TELECOM 1 LUCENT CBX500 PORTLAND ME MID-MAINE COMMUNICATIONS 1 N/A PORTLAND MI ALLEGIANCE TELECOM 1 CISCO BPX 8650 DETROIT MI AT&T 1 N/A DETROIT MI INTERMEDIA COMMUNICATIONS 3* ASCEND 9000; ASCEND CBX 500 DETROIT MI LIGHTYEAR COMMUNICATIONS 1 ACCEL AN3220 DETROIT MI CHOICE ONE COMMUNICATIONS 1 CISCO LANSING
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CLEC Packet Switches State CLEC Number of Switch Type City Switches MI TDS METROCOM PLANNED CISCO/PARADYNE ANN ARBOR MI CTS TELECOM D/B/A CLIMAX TELEPHONE PLANNED N/A BATTLE CREEK CO. MI FOCAL COMMUNICATIONS PLANNED N/A DETROIT MN INTEGRA TELECOM 1 LUCENT BAXTER MN ALLEGIANCE TELECOM 1 CISCO BPX 8650 MINNEAPOLIS MN AT&T 1 ATM MINNEAPOLIS MN ESCHELON TELECOM 1 NORTEL PASSPORT ATM MINNEAPOLIS MN GLOBAL CROSSING 1 LUCENT ASCEND MINNEAPOLIS MN INTEGRA TELECOM 1 LUCENT MINNEAPOLIS MN INTERMEDIA COMMUNICATIONS 2 ASCEND 9000; ASCEND CBX 500 MINNEAPOLIS MN WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM MINNEAPOLIS MN WORLDCOM 1 N/A MINNEAPOLIS MN XO COMMUNICATIONS 2* N/A MINNEAPOLIS MN INTEGRA TELECOM 1 LUCENT PRIOR LAKE MN ESCHELON TELECOM 1 N/A SAINT PAUL MN HICKORYTECH PLANNED N/A NICOLLET MO AT&T 1 ERICCSON STP KANSAS CITY MO EVEREST CONNECTIONS 1 N/A KANSAS CITY MO GLOBAL CROSSING 1 LUCENT ASCEND KANSAS CITY MO INTERMEDIA COMMUNICATIONS 3* ASCEND 9000; ASCEND CBX 500 KANSAS CITY MO LIGHTYEAR COMMUNICATIONS 1 ACCEL AN3220 KANSAS CITY MO WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM KANSAS CITY MO ALLEGIANCE TELECOM 1 CISCO BPX 8650 SAINT LOUIS MO AT&T 1 ERICCSON STP SAINT LOUIS MO INTERMEDIA COMMUNICATIONS 3* ASCEND 9000; ASCEND CBX 500 SAINT LOUIS MO LIGHTYEAR COMMUNICATIONS 1 ACCEL AN3220 SAINT LOUIS MO LOGIX COMMUNICATIONS ENTERPRISES 1 CISCO ATM SAINT LOUIS MO NUVOX COMMUNICATIONS 1 LUCENT AC 120 SAINT LOUIS MO WORLDCOM 1 N/A SAINT LOUIS MO GLOBAL CROSSING 1 LUCENT ASCEND SPRINGFIELD MO LOGIX COMMUNICATIONS ENTERPRISES 1 CISCO ATM SPRINGFIELD MO NUVOX COMMUNICATIONS 1 LUCENT AC 120 SPRINGFIELD MS ITC^DELTACOM 2 ATM; FRAME RELAY GULFPORT MS AT&T 1 ERICCSON STP JACKSON MS E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE JACKSON MS INTERMEDIA COMMUNICATIONS 2* ASCEND 9000 JACKSON MS ITC^DELTACOM 1 ASCEND FRAME RELAY JACKSON MT WINSTAR COMMUNICATIONS 1 FRAME RELAY MISSOULA NC AT&T 2 ATM; FRAME RELAY CHARLOTTE NC BTI TELECOM 1 LUCENT ASCEND FRAME RELAY CHARLOTTE NC EAGLE COMMUNICATIONS 1 ASCEND MAX TNT CHARLOTTE NC INTERMEDIA COMMUNICATIONS 4* ASCEND 9000; ASCEND CBX 500 CHARLOTTE NC ITC^DELTACOM 1 ATM CHARLOTTE NC NEWSOUTH COMMUNICATIONS 1 CISCO BPX 8600 & MGX 8850 CHARLOTTE NC TIME WARNER TELECOM 18* FORE/ALCATEL/LUCENT/ASCEND CHARLOTTE NC US LEC 1 LUCENT CBX500 CHARLOTTE NC WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM CHARLOTTE NC EAGLE COMMUNICATIONS 1 ASCEND MAX TNT DURHAM NC INTERMEDIA COMMUNICATIONS 1 ASCEND 9000 FAYETTEVILLE NC AT&T 1 ERICCSON STP GREENSBORO
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CLEC Packet Switches State CLEC Number of Switch Type City Switches NC BTI TELECOM 1 LUCENT ASCEND GREENSBORO NC EAGLE COMMUNICATIONS 1 ASCEND MAX TNT GREENSBORO NC ITC^DELTACOM 2 ASCEND FRAME RELAY; ASCEND GREENSBORO ATM NC NEWSOUTH COMMUNICATIONS 1 CISCO BPX 8600 & MGX 8850 GREENSBORO NC TIME WARNER TELECOM 2* FORE/ /LUCENT/ALCATEL GREENSBORO NC US LEC 1 LUCENT CBX500 GREENSBORO NC INTERMEDIA COMMUNICATIONS 1 ASCEND 9000 GREENVILLE NC BTI TELECOM 3 2 LUCENT ASCEND FRAME RELAY; RALEIGH LUCENT ATM NC E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE RALEIGH NC EAGLE COMMUNICATIONS 1 ASCEND MAX TNT RALEIGH NC INTERMEDIA COMMUNICATIONS 3* ASCEND 9000; ASCEND CBX 500 RALEIGH NC TIME WARNER TELECOM 25* FORE/ALCATEL/LUCENT/ASCEND RALEIGH NC US LEC 1 LUCENT CBX500 RALEIGH NC BTI TELECOM 1 LUCENT ASCEND ROCKY MOUNT NC BTI TELECOM 1 LUCENT ASCEND WILMINGTON NC INTERMEDIA COMMUNICATIONS 1 ASCEND 9000 WILMINGTON NC INTERMEDIA COMMUNICATIONS 1* N/A WINSTON-SALEM NC NEWSOUTH COMMUNICATIONS 1 CISCO BPX 8600 & MGX 8850 WINSTON-SALEM NC BTI TELECOM PLANNED LUCENT ATM CHARLOTTE NE AT&T 2 ATM; FRAME RELAY OMAHA NH CTC COMMUNICATIONS 1 CISCO 8600/8800 BEDFORD NH CHOICE ONE COMMUNICATIONS 1 LUCENT/CISCO MANCHESTER NH FAIRPOINT COMMUNICATIONS 1 N/A MANCHESTER NH LIGHTSHIP TELECOM 1 LUCENT CBX500 MANCHESTER NH BAY RING 1 CONVERGENT ICS2000 PORTSMOUTH NJ AT&T 1 ERICCSON STP FREEHOLD NJ INTERMEDIA COMMUNICATIONS 1 ASCEND 9000 JERSEY CITY NJ AT&T 1 ATM NEW BRUNSWICK NJ WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM NEW BRUNSWICK NJ ALLEGIANCE TELECOM 1 CISCO BPX 8650 NEWARK NJ ARBROS COMMUNICATIONS 1 LUCENT ACCESS CONCENTRATOR NEWARK 120 NJ AT&T 2 ATM/FRAME RELAY NEWARK NJ INTERMEDIA COMMUNICATIONS 1 ASCEND 9000 NEWARK NJ LIGHTYEAR COMMUNICATIONS 1 ACCEL AN3220 NEWARK NJ NET2000 COMMUNICATIONS 1 N/A NEWARK NJ WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM NEWARK NJ ADELPHIA BUSINESS SOLUTIONS 1 ASCEND ATM PARSIPPANY NJ AT&T 1 IP PISCATAWAY NM E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE ALBUQUERQUE NM PAC-WEST TELECOMM 1* N/A ALBUQUERQUE NM NTS COMMUNICATIONS PLANNED N/A ALBUQUERQUE NV E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE LAS VEGAS NV EAGLE COMMUNICATIONS 1 ASCEND MAX TNT LAS VEGAS NV INTERMEDIA COMMUNICATIONS 2 ASCEND 9000; ASCEND CBX 500 LAS VEGAS NV PAC-WEST TELECOMM 1 ALCATEL MEGAHUB 600E LAS VEGAS NV US TELEPACIFIC D/B/A TELEPACIFIC 1 CISCO BPX 8620 LAS VEGAS NV WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM LAS VEGAS NV WESTERN INTEGRATED NETWORKS PLANNED N/A LAS VEGAS NV ESCHELON TELECOM PLANNED N/A RENO
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CLEC Packet Switches State CLEC Number of Switch Type City Switches NY CHOICE ONE COMMUNICATIONS 1 LUCENT/CISCO ALBANY NY CTC COMMUNICATIONS 1 CISCO 8600/8800 ALBANY NY INTERMEDIA COMMUNICATIONS 2 ASCEND CBX500/ ASCEND 9000 ALBANY NY TIME WARNER TELECOM 4* FORE/ALCATEL/LUCENT/ASCEND ALBANY NY CABLEVISION LIGHTPATH 1* N/A BAYVILLE NY INTERMEDIA COMMUNICATIONS 1* N/A BINGHAMTON NY TIME WARNER TELECOM 2* FORE/LUCENT/ASCEND BINGHAMTON NY CHOICE ONE COMMUNICATIONS 1 LUCENT/CISCO BUFFALO NY EAGLE COMMUNICATIONS 1 ASCEND MAX TNT BUFFALO NY INTERMEDIA COMMUNICATIONS 4* ASCEND 9000/ASCEND CBX 500 BUFFALO NY INTERMEDIA COMMUNICATIONS 3* N/A COLONIE NY CTC COMMUNICATIONS 1 CISCO 8600/8800 ELMSFORD NY INTERMEDIA COMMUNICATIONS 2* N/A GLENMONT NY CABLEVISION LIGHTPATH 1* N/A HICKSVILLE NY NET2000 COMMUNICATIONS 1* N/A LONG ISLAND NY CTC COMMUNICATIONS 1 CISCO 8600/8800 MELVILLE NY CTC COMMUNICATIONS 1 CISCO 8600/8800 NANUET NY ALLEGIANCE TELECOM 2 CISCO BPX 8650 NEW YORK NY ARBROS COMMUNICATIONS 1 LUCENT ACCESS CONCENTRATOR NEW YORK NY AT&T 2 ERICCSON STP/NA NEW YORK NY AT&T 1 ATM/FRAME RELAY NEW YORK NY BTI TELECOM 1 LUCENT ASCEND FRAME RELAY NEW YORK NY CTC COMMUNICATIONS 1 CISCO 8600/8800 NEW YORK NY E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE NEW YORK NY EAGLE COMMUNICATIONS 1 ASCEND MAX TNT NEW YORK NY GLOBAL CROSSING 1 LUCENT ASCEND NEW YORK NY GLOBALCOM 1 N/A NEW YORK NY INTERMEDIA COMMUNICATIONS 7* ASCEND 9000/ASCEND CBX 500 NEW YORK NY LIGHTYEAR COMMUNICATIONS 1 ACCEL AN3220 NEW YORK NY NET2000 COMMUNICATIONS 1 NORTEL 7480 NEW YORK NY NETWORK PLUS 1* N/A NEW YORK NY REACH COMMUNICATIONS 1 N/A NEW YORK NY SPHERA OPTICAL 1* N/A NEW YORK NY WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM NEW YORK NY WORLDCOM 1 N/A NEW YORK NY INTERMEDIA COMMUNICATIONS 2* ASCEND 9000 POUGHKEEPSIE NY CHOICE ONE COMMUNICATIONS 1 LUCENT CISCO ROCHESTER NY EAGLE COMMUNICATIONS 1 ASCEND MAX TNT ROCHESTER NY GLOBAL CROSSING 1 LUCENT ASCEND ROCHESTER NY INTERMEDIA COMMUNICATIONS 3* ASCEND 9000; ASCEND CBX 500 ROCHESTER NY TIME WARNER TELECOM 9* FORE/ALCATEL/LUCENT/ASCEND ROCHESTER NY CTC COMMUNICATIONS 1 CISCO 8600/8800 SYOSSET NY CHOICE ONE COMMUNICATIONS 1 LUCENT/CISCO SYRACUSE NY EAGLE COMMUNICATIONS 1 ASCEND MAX TNT SYRACUSE NY INTERMEDIA COMMUNICATIONS 4* ASCEND 9000/ASCEND CBX500 SYRACUSE NY AT&T 1 ERICCSON STP WHITE PLAINS NY CTC COMMUNICATIONS 1 CISCO 8600/8800 YORKTOWN HEIGHTS NY BTI TELECOM PLANNED LUCENT ATM NEW YORK NY BROADVIEW NETWORKS PLANNED CISCO ATM NEW YORK NY BROADVIEW NETWORKS PLANNED CISCO ATM SYRACUSE OH GLOBAL CROSSING 1 LUCENT ASCEND AKRON
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CLEC Packet Switches State CLEC Number of Switch Type City Switches OH NUVOX COMMUNICATIONS 1 LUCENT AC 120 AKRON OH AT&T 1 ATM CINCINNATI OH GLOBAL CROSSING 1 LUCENT ASCEND CINCINNATI OH INTERMEDIA COMMUNICATIONS 3* ASCEND 9000; ASCEND CBX 500 CINCINNATI OH LIGHTYEAR COMMUNICATIONS 1 ACCEL AN 120 CINCINNATI OH NUVOX COMMUNICATIONS 1 LUCENT AC 120 CINCINNATI OH TIME WARNER TELECOM 10 FORE/ALCATEL/LUCENT/ASCEND CINCINNATI OH WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM CINCINNATI OH ALLEGIANCE TELECOM 1 CISCO BPX 8650 CLEVELAND OH AT&T 1 ERICCSON STP CLEVELAND OH GLOBAL CROSSING 1 LUCENT ASCEND CLEVELAND OH ICG COMMUNICATIONS 1 AIN NODES CLEVELAND OH INTERMEDIA COMMUNICATIONS 2 ASCEND 9000; ASCEND CBX 500 CLEVELAND OH LIGHTYEAR COMMUNICATIONS 1 ACCEL AN3220 CLEVELAND OH WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM CLEVELAND OH WORLDCOM 1 N/A CLEVELAND OH AT&T 1 ATM COLUMBUS OH GLOBAL CROSSING 1 LUCENT ASCEND COLUMBUS OH ICG COMMUNICATIONS 1 AIN NODES COLUMBUS OH INTERMEDIA COMMUNICATIONS 1 ASCEND 9000 COLUMBUS OH TIME WARNER TELECOM 1 FORE COLUMBUS OH WINSTAR COMMUNICATIONS 1 ASCEND 9000 FRAME RELAY COLUMBUS OH ICG COMMUNICATIONS 1 AIN NODES DAYTON OH INTERMEDIA COMMUNICATIONS 1 ASCEND 9000 DAYTON OH BUCKEYE TELESYSTEM 1 NEWBRIDGE ATM/NEWBRIDGE TOLEDO FRAME RELAY OH INTERMEDIA COMMUNICATIONS 1 ASCEND 9000 TOLEDO OK AT&T 1 ERICCSON STP OKLAHOMA CITY OK LOGIX COMMUNICATIONS ENTERPRISES 1 CISCO ATM OKLAHOMA CITY OK WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM OKLAHOMA CITY OK INTERMEDIA COMMUNICATIONS 1 ASCEND 9000 TULSA OK LOGIX COMMUNICATIONS ENTERPRISES 1 CISCO ATM TULSA OK NUVOX COMMUNICATIONS 1 LUCENT AC 120 TULSA OK WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM TULSA OK NTS COMMUNICATIONS PLANNED N/A OKLAHOMA CITY OR INTEGRA TELECOM 1 LUCENT BEAVERTON OR ADVANCED TELCOM GROUP 1 N/A EUGENE OR ALLEGIANCE TELECOM 1 CISCO BPX 8650 PORTLAND OR AT&T 1 N/A PORTLAND OR ESCHELON TELECOM 1 NORTEL PASSPORT ATM PORTLAND OR GLOBAL CROSSING 1 LUCENT ASCEND PORTLAND OR INTEGRA TELECOM 1 LUCENT PORTLAND OR INTERMEDIA COMMUNICATIONS 2 ASCEND 9000 PORTLAND OR WORLDCOM 1 N/A PORTLAND OR WANTEL 1 CONVERGENT NETWORKS ICS 2000 ROSEBURG OR ADVANCED TELCOM GROUP 1 N/A SALEM OR ADVANCED TELCOM GROUP 1 N/A SPRINGFIELD OR WESTERN INTEGRATED NETWORKS PLANNED N/A PORTLAND PA CHOICE ONE COMMUNICATIONS 1 LUCENT/CISCO ATM ALLENTOWN PA PENN TELECOM D/B/A PENNTELE.COM 1 N/A GIBSONIA
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CLEC Packet Switches State CLEC Number of Switch Type City Switches PA ARBROS COMMUNICATIONS 1 LUCENT ACCESS CONCENTRATOR HARRISBURG 120 PA CHOICE ONE COMMUNICATIONS 1 LUCENT/CISCO ATM HARRISBURG PA INTERMEDIA COMMUNICATIONS 1 ASCEND 9000 HARRISBURG PA ALLEGIANCE TELECOM 1 CISCO BPX 8650 PHILADELPHIA PA ARBROS COMMUNICATIONS 1 LUCENT ACCESS CONCENTRATOR PHILADELPHIA 120 PA AT&T 1 ATM PHILADELPHIA PA BTI TELECOM 1 LUCENT ASCEND PHILADELPHIA PA E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE PHILADELPHIA PA EAGLE COMMUNICATIONS 1 ASCEND MAX TNT PHILADELPHIA PA GLOBAL CROSSING 1 LUCENT ASCEND PHILADELPHIA PA INTERMEDIA COMMUNICATIONS 4* ASCEND 9000/ ASCEND CBX500 PHILADELPHIA PA NET2000 COMMUNICATIONS 1 NORTEL PASSPORT PHILADELPHIA PA US LEC 1 LUCENT 7 R/E PACKET DRIVER, PHILADELPHIA LUCENT CBX500 PA WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM PHILADELPHIA PA WORLDCOM 1 N/A PHILADELPHIA PA ARBROS COMMUNICATIONS 1 LUCENT ACCESS CONCENTRATOR PITTSBURGH 120 PA AT&T 1 ATM PITTSBURGH PA CHOICE ONE COMMUNICATIONS 1 LUCENT/CISCO PITTSBURGH PA GLOBAL CROSSING 1 LUCENT ASCEND PITTSBURGH PA INTERMEDIA COMMUNICATIONS 3* ASCEND 9000/ASCEND CBX500 PITTSBURGH PA US LEC 1 LUCENT CBX500 PITTSBURGH PA CHOICE ONE COMMUNICATIONS 1 LUCENT/CISCO SCRANTON/WILKES- BARRE PA CEI NETWORKS 1 N/A STATE COLLEGE PA BROADVIEW NETWORKS PLANNED CISCO ATM HORSHAM RI AT&T 1 ATM PROVIDENCE RI CHOICE ONE COMMUNICATIONS 1 LUCENT/CISCO PROVIDENCE RI INTERMEDIA COMMUNICATIONS 1 ASCEND 9000 PROVIDENCE RI NET2000 COMMUNICATIONS 1 NORTEL PASSPORT PROVIDENCE SC E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE CHARLESTON SC INTERMEDIA COMMUNICATIONS 1 ASCEND 9000 CHARLESTON SC KNOLOGY BROADBAND 1 FORE ATM CHARLESTON SC NEWSOUTH COMMUNICATIONS 1 CISCO BPX 8600 & MGX 8850 CHARLESTON SC US LEC 1 LUCENT CBX500 CHARLESTON SC BTI TELECOM 1 LUCENT ASCEND COLUMBIA SC E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE COLUMBIA SC INTERMEDIA COMMUNICATIONS 2* ASCEND 9000 COLUMBIA SC ITC^DELTACOM 2 CASCADE 9000; ATM COLUMBIA SC INTERMEDIA COMMUNICATIONS 1 ASCEND 9000 FLORENCE SC BTI TELECOM 1 LUCENT ASCEND GREENVILLE SC E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE GREENVILLE SC INTERMEDIA COMMUNICATIONS 2* ASCEND 9000 GREENVILLE SC NEWSOUTH COMMUNICATIONS 1 CISCO BPX 8600 & MGX 8850 GREENVILLE SC BTI TELECOM PLANNED* N/A CHARLESTON SC KNOLOGY BROADBAND PLANNED* N/A CHARLESTON TN AT&T 1 ATM CHATTANOOGA TN INTERMEDIA COMMUNICATIONS 1 ASCEND 9000 CHATTANOOGA TN US LEC 1 LUCENT CBX500 CHATTANOOGA
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CLEC Packet Switches State CLEC Number of Switch Type City Switches TN WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM CHATTANOOGA TN AT&T 1 ATM KNOXVILLE TN EAGLE COMMUNICATIONS 1 ASCEND MAX TNT KNOXVILLE TN INTERMEDIA COMMUNICATIONS 2* ASCEND 9000 KNOXVILLE TN US LEC 1 LUCENT CBX500 KNOXVILLE TN E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE MEMPHIS TN EAGLE COMMUNICATIONS 1 ASCEND MAX TNT MEMPHIS TN INTERMEDIA COMMUNICATIONS 2 ASCEND 9000; ASCEND CBX 500 MEMPHIS TN NUVOX COMMUNICATIONS 1 N/A MEMPHIS TN TIME WARNER TELECOM 6 FORE/ALCATEL/LUCENT/ASCEND MEMPHIS TN US LEC 1 LUCENT CBX500 MEMPHIS TN E.SPIRE COMMUNICATIONS 1* N/A NASHVILLE TN EAGLE COMMUNICATIONS 1 ASCEND MAX TNT NASHVILLE TN INTERMEDIA COMMUNICATIONS 2 ASCEND 9000; ASCEND CBX 500 NASHVILLE TN ITC^DELTACOM 1 ASCEND FRAME RELAY NASHVILLE TN NEWSOUTH COMMUNICATIONS 1 CISCO BPX 8600 & MGX 8850 NASHVILLE TN NUVOX COMMUNICATIONS 1 LUCENT AC 120 NASHVILLE TN US LEC 1 LUCENT CBX500 NASHVILLE TN WINSTAR COMMUNICATIONS 1* N/A NASHVILLE TN BTI TELECOM PLANNED* N/A CHATTANOOGA TN BTI TELECOM PLANNED* N/A KNOXVILLE TN BTI TELECOM PLANNED* N/A NASHVILLE TX NTS COMMUNICATIONS 1 LUCENT AC 120 ABILENE TX E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE AMARILLO TX LOGIX COMMUNICATIONS ENTERPRISES 1 CISCO ATM AMARILLO TX NTS COMMUNICATIONS 1 LUCENT AC 120 AMARILLO TX ALLEGIANCE TELECOM 1 CISCO BPX 8650 AUSTIN TX ICG COMMUNICATIONS 1 AIN NODES AUSTIN TX INTERMEDIA COMMUNICATIONS 1 ASCEND 9000 AUSTIN TX LOGIX COMMUNICATIONS ENTERPRISES 1 CISCO ATM AUSTIN TX TIME WARNER TELECOM 7 FORE/ALCATEL/LUCENT/ASCEND AUSTIN TX WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM AUSTIN TX WORLDCOM 1 CASCADE 9000 FRAME RELAY AUSTIN TX ALLEGIANCE TELECOM 2 CISCO BPX 8650 DALLAS TX AT&T 3 ERICCSON STP; 2 IP DALLAS TX BTI TELECOM 1 LUCENT ASCEND DALLAS TX E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE DALLAS TX EAGLE COMMUNICATIONS 1 ASCEND MAX TNT DALLAS TX GLOBAL CROSSING 1 LUCENT ASCEND DALLAS TX GRANDE COMMUNICATIONS NETWORK 2 ASCEND CBX 500 ATM; DALLAS B STDX 8/9000 FRAME RELAY TX INTERMEDIA COMMUNICATIONS 5* ASCEND 9000; ASCEND CBX 500 DALLAS TX IONEX TELECOMMUNICATIONS 1 SPRING TIDE IP SERVICE SWITCH DALLAS 5000 TX ITC^DELTACOM 2 FRAME RELAY; ATM DALLAS TX LIGHTYEAR COMMUNICATIONS 1 ACCEL AN3220 DALLAS TX LOGIX COMMUNICATIONS ENTERPRISES 1 CISCO ATM DALLAS TX NET2000 COMMUNICATIONS 1* N/A DALLAS TX NTS COMMUNICATIONS 1 LUCENT CBX500 DALLAS TX TIME WARNER TELECOM 1 FORE DALLAS TX WESTERN INTEGRATED NETWORKS 1 N/A DALLAS
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CLEC Packet Switches State CLEC Number of Switch Type City Switches TX WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM DALLAS TX WORLDCOM 2 XYLAN AMT DALLAS TX E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE EL PASO TX E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE FORT WORTH TX ALLEGIANCE TELECOM 1 CISCO BPX 8650 HOUSTON TX AT&T 2 ATM; FRAME RELAY HOUSTON TX E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE HOUSTON TX EAGLE COMMUNICATIONS 1 ASCEND MAX TNT HOUSTON TX GLOBAL CROSSING 1 LUCENT ASCEND HOUSTON TX GRANDE COMMUNICATIONS NETWORK 2 ASCEND CBX500 ATM; B STDX HOUSTON 8/9000 FRAME RELAY TX INTERMEDIA COMMUNICATIONS 4* ASCEND 900; ASCEND CBX 500 HOUSTON TX LIGHTYEAR COMMUNICATIONS 1 ACCEL AN3220 HOUSTON TX LOGIX COMMUNICATIONS ENTERPRISES 1 CISCO ATM HOUSTON TX TIME WARNER TELECOM 22 FORE/ALCATEL/GDC/LUCENT/ HOUSTON ASCEND TX WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM HOUSTON TX WORLDCOM 2 CASCADE 9000 FRAME RELAY HOUSTON TX WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM IRVING TX LOGIX COMMUNICATIONS ENTERPRISES 1 CISCO ATM LUBBOCK TX NTS COMMUNICATIONS 1 LUCENT CBX500 LUBBOCK TX NTS COMMUNICATIONS 1 LUCENT AC 120 MIDLAND/ODESA TX ALLEGIANCE TELECOM 1 CISCO BPX 8650 SAN ANTONIO TX E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE SAN ANTONIO TX ICG COMMUNICATIONS 1 AIN NODES SAN ANTONIO TX LOGIX COMMUNICATIONS ENTERPRISES 1 CISCO ATM SAN ANTONIO TX TIME WARNER TELECOM 8 FORE/ALCATEL/GDC/LUCENT/ SAN ANTONIO ASCEND TX WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM SAN ANTONIO TX WORLDCOM 1 CASCADE 9000 FRAME RELAY SAN ANTONIO TX GRANDE COMMUNICATIONS NETWORK 1 B STDX 8/9000 FRAME RELAY SAN MARCOS TX WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM SUNNYVALE TX NTS COMMUNICATIONS 1 LUCENT AC 120 WICHITA FALLS TX WESTERN INTEGRATED NETWORKS PLANNED N/A AUSTIN TX FOCAL COMMUNICATIONS PLANNED N/A DALLAS TX NTS COMMUNICATIONS PLANNED N/A EL PASO TX WESTERN INTEGRATED NETWORKS PLANNED N/A HOUSTON TX WESTERN INTEGRATED NETWORKS PLANNED N/A SAN ANTONIO UT AT&T 1 ATM SALT LAKE CITY UT ESCHELON TELECOM 1 NORTEL PASSPORT ATM SALT LAKE CITY UT INTEGRA TELECOM 1 LUCENT SALT LAKE CITY UT INTERMEDIA COMMUNICATIONS 2 ASCEND 9000; ASCEND CBX 500 SALT LAKE CITY UT PAC-WEST TELECOMM 1* N/A SALT LAKE CITY VA AT&T 1 ERICCSON STP ARLINGTON VA INTERMEDIA COMMUNICATIONS 1* N/A FAIRFAX VA NET2000 COMMUNICATIONS 1 NORTEL 7480 HERNDON VA ARBROS COMMUNICATIONS 1 LUCENT ACCESS CONCENTRATOR NORFOLK 120 VA NET2000 COMMUNICATIONS 1 NORTEL 7480 NORFOLK VA US LEC 1 LUCENT CBX500 NORFOLK VA ARBROS COMMUNICATIONS 1 LUCENT ACCESS CONCENTRATOR RICHMOND 120
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CLEC Packet Switches State CLEC Number of Switch Type City Switches VA E.SPIRE COMMUNICATIONS 1 ALCATEL MULTISERVICE RICHMOND VA INTERMEDIA COMMUNICATIONS 2* ASCEND 9000 RICHMOND VA NET2000 COMMUNICATIONS 1 NORTEL 7480 RICHMOND VA US LEC 1 LUCENT CBX500 RICHMOND VA NTELOS 1 N/A ROANOKE VA INTERMEDIA COMMUNICATIONS 1* N/A VIENNA VA NTELOS 1 N/A WAYNESBORO VA NET2000 COMMUNICATIONS 1 N/A WILLIAMSBURG VA ARBROS COMMUNICATIONS PLANNED* N/A ALEXANDRIA VA NET2000 COMMUNICATIONS PLANNED N/A ALEXANDRIA VA BTI TELECOM PLANNED LUCENT ASCEND NORFOLK VA BTI TELECOM PLANNED LUCENT ASCEND RICHMOND VT CTC COMMUNICATIONS 1 CISCO 8600/8800 BURLINGTON VT LIGHTSHIP TELECOM 1 LUCENT CBX500 BURLINGTON WA INTEGRA TELECOM 1 LUCENT KENT WA ADVANCED TELCOM GROUP 1 N/A OLYMPIA WA ADVANCED TELCOM GROUP 1 N/A PUYALLUP WA AT&T 1 IP REDMOND WA ALLEGIANCE TELECOM 1 CISCO BPX 8650 SEATTLE WA AT&T 2 ATM; FRAME RELAY SEATTLE WA ESCHELON TELECOM 1 NORTEL PASSPORT ATM SEATTLE WA GLOBAL CROSSING 1 LUCENT ASCEND SEATTLE WA INTERMEDIA COMMUNICATIONS 2* N/A SEATTLE WA LIGHTYEAR COMMUNICATIONS 1 ACCEL AN3220 SEATTLE WA PAC-WEST TELECOMM 1 ALCATEL MEGAHUB 600E SEATTLE WA WINSTAR COMMUNICATIONS 3 NEWBRIDGE ATM SEATTLE WA WORLDCOM 1 N/A SEATTLE WA AT&T 1 N/A SPOKANE WA WINSTAR COMMUNICATIONS 1 FRAME RELAY SPOKANE WA ADVANCED TELCOM GROUP 3 N/A TACOMA WA WESTERN INTEGRATED NETWORKS PLANNED N/A SEATTLE WA XO COMMUNICATIONS PLANNED* N/A SEATTLE WI TDS METROCOM 1 CISCO/PARADYNE APPLETON WI MCLEODUSA 1 N/A EAU CLAIRE WI MCLEODUSA 1 N/A GREEN BAY WI CHOICE ONE COMMUNICATIONS 1 LUCENT CISCO MADISON WI MCLEODUSA 1 N/A MADISON WI TDS METROCOM 1 CISCO/PARADYNE MADISON WI AT&T 1 LUCENT 5ESS MILWAUKEE WI CHOICE ONE COMMUNICATIONS 1 LUCENT CISCO MILWAUKEE WI GLOBAL CROSSING 1 LUCENT ASCEND MILWAUKEE WI MCLEODUSA 1 N/A MILWAUKEE WI TIME WARNER TELECOM 10* FORE/ALCATEL/LUCENT/ASCEND MILWAUKEE WI WINSTAR COMMUNICATIONS 1 NEWBRIDGE ATM MILWAUKEE WI AT&T 1 N/A WAUKESHA WV NTELOS 1 LUCENT 5ESS DIGITAL CHARLESTON WV STRATUSWAVE COMMUNICATIONS 1 ALCATEL MAINSTREETXPRESS WHEELING *New Paradigm Resources Group provides switch type and location for some but not all of these switches. Sources: NPRG CLEC Report 2002, 15th ed., Chs. 5 & 6; NPRG CLEC Report 2001, 14th ed., Ch. 13; NPRG CIOC Report 2001, Ch. 7.
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APPENDIX F. WIRELESS SWITCHES
Wireless Switches Serving BOC Rate Centers State BOC Region Type CLEC City Street AL BELLSOUTH DS ALABAMA CELLULAR SERVICE BIRMINGHAM 609 35TH ST S AL BELLSOUTH DS ALABAMA CELLULAR SERVICE HUNTSVILLE 5520 HOLMES AVE NW AL BELLSOUTH DS ALABAMA CELLULAR SERVICE MOBILE 3740 INDUSTRIAL PARK DRIVE AL BELLSOUTH CMC ALABAMA CELLULAR SERVICE MONTGOMERY 1024 MONTICELLO PARK AL VERIZON DMH ALABAMA CELLULAR SERVICE PELL CITY 1701 1ST AVE S AL VERIZON GT5 ALABAMA CELLULAR SERVICE SCOTTSBORO 307 W PEACHTREE ST AL BELLSOUTH 5E ALABAMA WIRELESS BIRMINGHAM 1715 6TH AVE N AL BELLSOUTH CMC ALABAMA WIRELESS DECATUR 303 BELTLINE PL SW AL BELLSOUTH DMH ALLTEL BIRMINGHAM 1920 OXMOOR RD AL VERIZON CMC ALLTEL DOTHAN 1530 MONTGOMERY HWY AL BELLSOUTH 5EH ALLTEL MONTGOMERY 6925 HALCYON DR AL VERIZON CMC CELLULAR PARTNERS OF LAMAR ENTERPRISE 621 BOLL WEEVIL RD AL BELLSOUTH CMC CELLULAR PARTNERS OF LAMAR SELMA JCT OF S.R. 219 & S.R.14 AL BELLSOUTH CMC CORR WIRELESS COMMUNICATIONS HUNTSVILLE 8600 S MEMORIAL PKY AL BELLSOUTH CMC DIG1PH PCS MOBILE 103 DAUPHIN ST AL BELLSOUTH CMC DIG1PH PCS MOBILE 68 ST FRANCIS ST AL VERIZON CMC FARMERS CELLULAR TELEPHONE SECTION 5305 TAMMY LITTLE DR AL BELLSOUTH CMC NEXTEL ANNISTON 660 AARONS WAY AL BELLSOUTH CMC NEXTEL ATHENS 105 STEWART DR AL BELLSOUTH CMC NEXTEL AUBURN 490 N DEAN RD AL BELLSOUTH DMH NEXTEL BIRMINGHAM 600 NORTH 18TH ST AL BELLSOUTH CMC NEXTEL CLANTON 2159 GILLESPIE ST AL BELLSOUTH CMC NEXTEL DECATUR 3817 MARSHA AVE AL BELLSOUTH CMC NEXTEL GADSDEN 276 HILLVIEW RD AL BELLSOUTH CMC NEXTEL NORTHPORT 9708 HIGHWAY 43 N AL BELLSOUTH CMC NEXTEL OPELIKA 1051 DOUGLAS ST AL BELLSOUTH VCD PINE BELT CELLULAR SELMA 1207 SELMA AVE AL VERIZON DS PORTA-PHONE DIV OF JOHN H. PHIPPS DOTHAN 2312 MONTGOMERY HWY AL BELLSOUTH CMC SOUTHERN COMMUNICATIONS SERVICES ANNISTON 410 W 10TH ST AL BELLSOUTH CMC SOUTHERN COMMUNICATIONS SERVICES BIRMINGHAM 600 18TH ST N AL VERIZON CMC SOUTHERN COMMUNICATIONS SERVICES DOTHAN 2304 INDUSTRIAL RD AL BELLSOUTH CMC SOUTHERN COMMUNICATIONS SERVICES GADSDEN 749 FORREST AVE AL BELLSOUTH D10 SOUTHERN COMMUNICATIONS SERVICES HUNTSVILLE 8600 S MEMORIAL PKY AL BELLSOUTH CMC SOUTHERN COMMUNICATIONS SERVICES MOBILE 103 DAUPHIN ST AL BELLSOUTH CMC SOUTHERN COMMUNICATIONS SERVICES MOBILE 25 BATTLESHIP PKY AL BELLSOUTH ZZZ SOUTHERN COMMUNICATIONS SERVICES MONTGOMERY 204 E JEFFERSON ST AL BELLSOUTH CMC SOUTHERN COMMUNICATIONS SERVICES TUSCALOOSA 2200 4TH ST AL VERIZON DMS SPRINT PCS BIRMINGHAM 156 OXMOOR CT AL BELLSOUTH MTX SPRINT PCS BIRMINGHAM 156 OXMOOR CT AL BELLSOUTH DMS TELEPAK MOBILE 105 N BELTLINE HWY AL BELLSOUTH CMS TRITEL COMMUNICATIONS BIRMINGHAM 432 INDUSTRIAL LN AL BELLSOUTH CMC TRITEL COMMUNICATIONS HUNTSVILLE 310 FOUNTAIN CIR SW AL BELLSOUTH CMC TRITEL COMMUNICATIONS MOBILE 101 N FRANKLIN ST AL BELLSOUTH CMC TRITEL COMMUNICATIONS MONTGOMERY 38 WASHINGTON AVE AL BELLSOUTH CMC TRITEL COMMUNICATIONS MONTGOMERY 25 ADAMS AVE AL BELLSOUTH AXT VOICESTREAM ANNISTON 410 W 10TH ST AL BELLSOUTH AXT VOICESTREAM BIRMINGHAM 950 22ND ST N AL BELLSOUTH AXT VOICESTREAM GADSDEN 749 FORREST AVE AL BELLSOUTH AXT VOICESTREAM HUNTSVILLE 8600 S MEMORIAL PKY
F-1
Wireless Switches Serving BOC Rate Centers State BOC Region Type CLEC City Street AL BELLSOUTH AXT VOICESTREAM MONTGOMERY 204 E JEFFERSON ST AL BELLSOUTH 5E VOICESTREAM OPELIKA 1015 WEST POINT PKY AR VERIZON CMC ALLTEL CLARKSVILLE BIG DANGER ROAD & CLARKSVILLE AR SBC D12 TELETOUCH COMMUNICATIONS FAYETTEVILLE 138 N EAST AV AR SBC DMH TELETOUCH COMMUNICATIONS FORT SMITH 101 N 13TH AR SBC 5EH TELETOUCH COMMUNICATIONS HOT SPRINGS 220 PROSPECT AR SBC 5EH TELETOUCH COMMUNICATIONS ROGERS 700 W WALNUT AZ QWEST CMC AT&T WIRELESS PHOENIX 211 W MONROE ST AZ QWEST CMC AT&T WIRELESS PHOENIX 211 W MONROE ST AZ QWEST 5EC LEAP WIRELESS INTL PHOENIX 4050 E COTTON CENTER BLVD AZ QWEST 5EC LEAP WIRELESS INTL TUCSON 4175 S FREMONT AVE AZ QWEST CMC NETWORK SERVICES TUCSON 4555 S PALO VERDE RD AZ QWEST 5ES SPRINT PCS PHOENIX 736 E WATKINS ST AZ QWEST 5ES SPRINT PCS PHOENIX 736 E WATKINS ST AZ QWEST CMC SPRINT PCS PHOENIX 1710 E GRANT ST AZ QWEST CMC SPRINT PCS PHOENIX 736 E WATKINS ST AZ QWEST CMC TRIAD CELLULAR PAGE 812 AQUA AVE AZ QWEST CMC WESTERN WIRELESS YUMA 1289 S 2ND AVE CA VERIZON 5E ALPINE PCS SAN LUIS OBISPO 3220 S HIGUERA ST CA VERIZON AXT AT&T WIRELESS ANAHEIM 301 N CRESCENT WAY CA VERIZON AXT AT&T WIRELESS ANAHEIM 301 N CRESCENT WAY CA VERIZON AXT AT&T WIRELESS CITY OF COMMERCE 6045 E SLAUSON ST CA VERIZON AXT AT&T WIRELESS CITY OF COMMERCE 6045 E SLAUSON ST CA VERIZON CMC AT&T WIRELESS CITY OF COMMERCE 6045 E SLAUSON ST CA VERIZON CMC AT&T WIRELESS CITY OF COMMERCE 6045 E SLAUSON ST CA VERIZON CMC AT&T WIRELESS FRESNO 1445 VAN NESS AVE CA VERIZON AXT AT&T WIRELESS GARDENA 15215 S BROADWAY * CA VERIZON AXT AT&T WIRELESS GARDENA 15215 S BROADWAY * CA VERIZON CMC AT&T WIRELESS GOLETA 6485 CALLE REAL CA VERIZON CMC AT&T WIRELESS LAGUNA HILLS 31 COLUMBIA CA VERIZON AXT AT&T WIRELESS RIVERSIDE 4135 GARNER RD CA VERIZON AXT AT&T WIRELESS RIVERSIDE 4135 GARNER RD CA VERIZON CMC AT&T WIRELESS SAN BERNARDINO 455 2ND ST CA VERIZON CMC AT&T WIRELESS SANTA BARBARA 819 CHAPALA ST CA VERIZON CMC AT&T WIRELESS STOCKTON 6855 W EIGHT MILE RD FLOOR 1 CA VERIZON DM2 BAY AREA CELLULAR TELEPHONE SANTA CLARA 1700 SPACE PARK DR CA SBC DM2 DIGITCOM SERVICES ALHAMBRA 21 S 1ST ST CA SBC DMH DIGITCOM SERVICES COMPTON 608 E COMPTON BLVD CA SBC DMH DIGITCOM SERVICES CULVER CITY 3847 CARDIFF AV CA SBC DMH DIGITCOM SERVICES LOS ANGELES 720 S RAMPART BLVD CA VERIZON DMH DIGITCOM SERVICES PALMDALE 901 E PALMDALE BL CA SBC 5E DIGITCOM SERVICES PARAMOUNT 15706 S PARAMNT BL CA VERIZON 4E NETWORK SERVICES ANAHEIM 217 N LEMON ST CA VERIZON D12 NETWORK SERVICES BAKERSFIELD 148 WEEDPATCH HWY CA SBC 5E NETWORK SERVICES BAKERSFIELD 1918 M ST CA VERIZON DM2 NETWORK SERVICES FRESNO 1455 VAN NESS AV CA SBC 5EH NETWORK SERVICES MODESTO 1025-13TH ST CA SBC 5EH NETWORK SERVICES ONTARIO 211 W D ST CA VERIZON DM2 NETWORK SERVICES SACRAMENTO 1407-11-23 J ST CA VERIZON 4E NETWORK SERVICES SAN FRANCISCO 611 FOLSOM ST CA VERIZON 4E NETWORK SERVICES SANTA CLARA 1700 SPACE PARK DR
F-2
Wireless Switches Serving BOC Rate Centers State BOC Region Type CLEC City Street CA SBC DMH NETWORK SERVICES STOCKTON 345 N SAN JOAQUIN CA SBC 5E NETWORK SERVICES TURLOCK 325 N CENTER ST CA SBC DM2 NEXTEL ANAHEIM 217 N LEMON ST CA SBC DM2 NEXTEL CHICO 518 W 4TH ST CA SBC D12 NEXTEL LOS ANGELES 624 S GRAND * CA SBC DM2 NEXTEL LOS ANGELES 420 S GRAND AV CA SBC 4E NEXTEL OAKLAND 1587 FRANKLIN ST CA SBC DM2 NEXTEL OAKLAND 1587 FRANKLIN ST CA SBC DM2 NEXTEL SALINAS 340 PAJARO ST CA SBC 4E NEXTEL SAN DIEGO 650 ROBINSON AV CA SBC DM2 NEXTEL SAN DIEGO 650 ROBINSON AV CA SBC DM2 NEXTEL SAN LUIS OBISPO 872 MORRO ST CA VERIZON DM2 NEXTEL STOCKTON 345 N SAN JOAQUIN CA SBC GT5 NEXTEL THOUSAND OAKS 1204 E THOUSAND OAKS BLVD CA VERIZON 5E SPRINT PCS BURBANK 3099 N CALIFORNIA ST CA VERIZON 5E SPRINT PCS BURBANK 3099 N CALIFORNIA ST CA VERIZON 5E SPRINT PCS IRVINE 2592 DUPONT DR CA VERIZON 5E SPRINT PCS IRVINE 2592 DUPONT DR CA VERIZON 5E SPRINT PCS ONTARIO 1643 S GROVE AVE CA VERIZON 5E SPRINT PCS ONTARIO 1643 S GROVE AVE CA VERIZON 5EC SPRINT PCS SANTA FE SPRINGS 12103 BURKE ST CA VERIZON 4E THE TELEPHONE CONNECTION OF LOS GARDENA 17200 S VERMONT AV ANGELES CA VERIZON 4E THE TELEPHONE CONNECTION OF LOS LOS ANGELES 420 S GRAND AV ANGELES CA VERIZON DM2 THE TELEPHONE CONNECTION OF LOS RIVERSIDE 3580 ORANGE ST 2ND. FLOOR ANGELES CA VERIZON 4E THE TELEPHONE CONNECTION OF LOS SHERMAN OAKS 14800 VENTURA BLVD ANGELES CA VERIZON DM2 US CELLULAR SANTA ROSA 516 THIRD ST CA VERIZON D12 WESTERN WIRELESS VICTORVILLE 16461 MOJAVE DR CO QWEST CMC AT&T WIRELESS FORT COLLINS 315 W OAK ST CO QWEST CMC AT&T WIRELESS FORT LUPTON 16499 WELD COUNTY RD #18 CO QWEST CMC AT&T WIRELESS GREELEY 3115 35TH AVE CO QWEST 5EC GLENN ISHIHARA JUNCTION 1600 UTE AVE GRAND CO QWEST CMC WESTERN WIRELESS PUEBLO 1111 BONFORTE BLVD CT SBC 5E GEOTEK COMMUNICATIONS NORWALK 2 WASHINGTON ST CT SBC 5EH NEXTEL BRIDGEPORT 365 JOHN ST CT SBC 5E NEXTEL DANBURY 39 WEST ST CT SBC D12 NEXTEL HARTFORD 111 TRUMBULL ST CT SBC DE5 NEXTEL MERIDEN 27 BUTLER ST CT SBC 5EH NEXTEL NEW HAVEN 310 ORANGE ST CT SBC 5EH NEXTEL NEW LONDON 26 WASHINGTON ST CT SBC 5E NEXTEL NORWALK 2 WASHINGTON ST CT SBC 5E NEXTEL SOUTHINGTON 142 MAIN ST CT SBC 5E NEXTEL STAMFORD 555 MAIN ST CT SBC 5E NEXTEL WATERBURY 348 GRAND ST CT SBC DMH VOICESTREAM BLOOMFIELD 100 FILLEY ST DC VERIZON CMC AT&T WIRELESS WASHINGTON 725 13TH ST NW DC VERIZON CMC AT&T WIRELESS WASHINGTON 725 13TH ST NW DE VERIZON CMC NEXTEL WILMINGTON 919 N. MARKET ST., WILMINGTON FL BELLSOUTH CMC ALLTEL CHIPLEY GILBERT MILL RD
F-3
Wireless Switches Serving BOC Rate Centers State BOC Region Type CLEC City Street FL BELLSOUTH CMC ALLTEL GAINESVILLE 400 SW 2ND AVE FL BELLSOUTH 5EH ALLTEL JACKSONVILLE 661 RIVERSIDE AVE FL BELLSOUTH 5EH ALLTEL JACKSONVILLE 661 RIVERSIDE AVE FL BELLSOUTH CMC ALLTEL LAKE CITY 5 OSTEEN RD FL BELLSOUTH DS ALLTEL NORTH GAINESVILLE 7525 NW 4TH BLVD FL BELLSOUTH DS ALLTEL PENSACOLA 2620 W GADSDEN ST FL BELLSOUTH DS ALLTEL YOUNGSTOWN (BAY 12502 HWY 20 COUNTY) FL BELLSOUTH CMC ARCH WIRELESS HOLDINGS HOLLY HILL 158 RIDGEWOOD AVE FL BELLSOUTH CMC ARCH WIRELESS HOLDINGS ORLANDO 3915 E COLONIAL DR FL BELLSOUTH CMC AT&T WIRELESS BROOKSVILLE 17709 US 41 FL BELLSOUTH CMC AT&T WIRELESS COCOA 712 FLORIDA AVE FL BELLSOUTH AXT AT&T WIRELESS DAYTONA BEACH 268 N RIDGEWOOD AVE FL BELLSOUTH DS AT&T WIRELESS DAYTONA BEACH 1133 THIRD ST FL BELLSOUTH AXT AT&T WIRELESS JACKSONVILLE 424 N PEARL ST FL BELLSOUTH AXT AT&T WIRELESS OJUS 460 NE 215TH ST FL BELLSOUTH AXT AT&T WIRELESS OJUS 460 NE 215TH ST FL BELLSOUTH DS AT&T WIRELESS ORLANDO 45 N MAGNOLIA AVE FL BELLSOUTH CMC AT&T WIRELESS PENSACOLA 30 W BELMONT ST FL VERIZON CMC AT&T WIRELESS POLK CITY 16182 COMMONWEALTH AVE N FL VERIZON CMC AT&T WIRELESS POLK CITY 17924 STHWY 33 FL VERIZON CMC AT&T WIRELESS POLK CITY 16182 COMMONWEALTH AVE N FL VERIZON CMC AT&T WIRELESS TAMPA 501 E KENNEDY BLVD FL BELLSOUTH CMC AT&T WIRELESS WEST PALM BEACH 325 GARDENIA ST FL BELLSOUTH CMC AT&T WIRELESS WEST PALM BEACH 325 GARDENIA ST 9TH FLOOR FL BELLSOUTH CMC DIG1PH PCS PENSACOLA 490 W WINTROP FL BELLSOUTH DS FLORIDA CELLULAR SERVICE FORT LAUDERDALE 1841 NW 22ND ST FL BELLSOUTH DS FLORIDA CELLULAR SERVICE FT LAUDERDALE 1841 NW 22ND ST FL BELLSOUTH 5E FLORIDA CELLULAR SERVICE LAKE WORTH 7600 S MILITARY TRL FL BELLSOUTH 5E FLORIDA CELLULAR SERVICE LAKE WORTH 7600 S MILITARY TRL FL BELLSOUTH DS FLORIDA CELLULAR SERVICE MIAMI 799 NW 81ST ST FL BELLSOUTH DS FLORIDA CELLULAR SERVICE PERRINE 12224 SW 114TH PL FL BELLSOUTH G3 GABRIEL WIRELESS BOCA RATON 6971 N FEDERAL HIGHWAY #206 FL BELLSOUTH DS GEOTEK COMMUNICATIONS DAYTONA BEACH 900 N INDIAN LAKE RD & US 92 LODE STAR TOWER FL BELLSOUTH DS GEOTEK COMMUNICATIONS FT LAUDERDALE 110 SE 6TH ST FL BELLSOUTH DS GEOTEK COMMUNICATIONS JACKSONVILLE 532 RIVERSIDE AVE FL BELLSOUTH DS GEOTEK COMMUNICATIONS LAKE PARK 1115 OLD DIXIE HWY FL BELLSOUTH DS GEOTEK COMMUNICATIONS MIAMI ONE BISCAYNE TOWER, 2 SOUTH BISCAYNE, 29TH FLR. FL BELLSOUTH DS GEOTEK COMMUNICATIONS ORLANDO 200 S ORANGE AVE FL BELLSOUTH DS JACKSONVILLE MSA LIMITED JACKSONVILLE 5120 STEPP AVE PARTNERSHIP FL BELLSOUTH DS JACKSONVILLE MSA LIMITED JACKSONVILLE 5120 STEPP AVE PARTNERSHIP FL BELLSOUTH 5E METRO PCS SUNRISE 1401 HARRISON PKY FL BELLSOUTH CMC METROCALL GAINESVILLE 414 SW 3RD AVE FL BELLSOUTH CMC NETWORK SERVICES ALTAMONTE SPRINGS 283 N NORTH LAKE BLVD, SUITE 201 FL BELLSOUTH CMC NETWORK SERVICES FORT LAUDERDALE 4901 NW 17TH WAY FL BELLSOUTH CMC NETWORK SERVICES GAINESVILLE 400 SW 2ND AVE FL BELLSOUTH CMC NETWORK SERVICES JACKSONVILLE 3728 PHILLIPS HWY FL BELLSOUTH DMS NEXTEL BROOKSVILLE 509 E SUMMIT RD
F-4
Wireless Switches Serving BOC Rate Centers State BOC Region Type CLEC City Street FL BELLSOUTH CMC NEXTEL GAINESVILLE 1001 NE WALDO RD FL BELLSOUTH 5E NEXTEL JACKSONVILLE 10800 W BEAVER ST FL BELLSOUTH CMC NEXTEL JACKSONVILLE 424 N PEARL ST FL BELLSOUTH CMC NEXTEL JACKSONVILLE 421 W CHURCH ST FL BELLSOUTH CMC NEXTEL LAKE CITY 130 W NASSAU ST FL BELLSOUTH CMC NEXTEL LAKE MARY (JANE) 1150 EMMA OAKS TRL FL BELLSOUTH CMC NEXTEL NORTH DADE 18400 NE 5TH AVE FL BELLSOUTH DMH NEXTEL PALM COAST 29 UTILITY DR FL VERIZON CMC NEXTEL SARASOTA .5 MI S/O FRUITVILLE RD ON SHANNON RD FL VERIZON CMC NEXTEL TAMPA 110 N MORGAN ST FL BELLSOUTH CMC NEXTEL WEST PALM BEACH 3700 RCA BLVD FL VERIZON DMS NEXTEL WINTER HAVEN 200 AVE B FL BELLSOUTH CMC ORLANDO SMSA GAINESVILLE 400 SW 2ND AVE FL BELLSOUTH CMC ORLANDO SMSA LAKE MARY 500 TECHNOLOGY PARK FL BELLSOUTH DS ORLANDO SMSA LAKE MARY 500 TECHNOLOGY PARK FL BELLSOUTH DS ORLANDO SMSA LAKE MARY 500 TECHNOLOGY PARK FL BELLSOUTH CMC ORLANDO SMSA PANAMA CITY 111 E 5TH ST FL BELLSOUTH CMC ORLANDO SMSA PORT ORANGE 4750 CITY CENTER PKWY FL BELLSOUTH CMC PAGING SOURCE USA DELRAY BEACH 1585 S CONGRESS AVE FL BELLSOUTH CMC SOUTHERN COMMUNICATIONS SERVICES PANAMA CITY 1795 INDUSTRIAL DR FL BELLSOUTH CMC SOUTHERN COMMUNICATIONS SERVICES PENSACOLA 1490 E NINE MILE RD FL BELLSOUTH CMC SPRINT PCS DEERFIELD BEACH 734 S MILITARY TRL FL BELLSOUTH DMS SPRINT PCS DEERFIELD BEACH 734 S MILITARY TRL FL BELLSOUTH DMS SPRINT PCS JACKSONVILLE 12735 W GRAN BAY PKY FL BELLSOUTH DMS SPRINT PCS MIAMI 1050 NW 167TH ST FL BELLSOUTH DMS SPRINT PCS MIAMI 1050 NW 167TH ST FL BELLSOUTH 5E SPRINT PCS ORLANDO 360 S LAKE DESTINY DR FL BELLSOUTH CMC SPRINT PCS ORLANDO 360 S LAKE DESTINY DR FL VERIZON DMS SPRINT PCS TAMPA 7920 WOODLAND CENTER BLVD FL BELLSOUTH CMC SPRINT PCS WEST PALM BEACH 224 DATURA ST FL BELLSOUTH CMC US CELLULAR CHIPLEY 952 ALICIA LN FL BELLSOUTH CMC US CELLULAR LAKE CITY 1418 BRANFORD RD FL BELLSOUTH DS US CELLULAR NORTH GAINESVILLE 2430 NW 73RD PL FL BELLSOUTH CMC US CELLULAR PALATKA 162 CHERRY TRL FL BELLSOUTH CMC US CELLULAR STUART 4100 SW 48TH AVE FL BELLSOUTH AXT VOICESTREAM GAINESVILLE 902 S MAIN ST FL BELLSOUTH CMC VOICESTREAM HALLANDALE 600 ANSIN BLVD FL BELLSOUTH AXT VOICESTREAM JACKSONVILLE 550 WATER ST FL BELLSOUTH AXT VOICESTREAM LYNN HAVEN 810 OHIO AVE FL BELLSOUTH CMC VOICESTREAM NORTH DADE 18400 NE 5TH AVE FL BELLSOUTH CMC VOICESTREAM OCALA 319 E BROADWAY ST FL BELLSOUTH DX2 VOICESTREAM ORLANDO 200 TELECOM DR FL VERIZON DX2 VOICESTREAM TAMPA 6902 CYPRESS PARK DR FL BELLSOUTH CMC VOICESTREAM HALLANDALE 600 ANSIN BLVD GA BELLSOUTH DMS ALLTEL AUGUSTA 1490 ELLIS ST GA BELLSOUTH CMC ALLTEL SAVANNAH 7001 CHATHAM CENTER GA BELLSOUTH CMC ALLTEL WAYCROSS 675 S ANITA ST GA BELLSOUTH CMC ARCH WIRELESS HOLDINGS BRUNSWICK 1322 BAY ST GA BELLSOUTH CMC ARCH WIRELESS HOLDINGS TUCKER 2200 NORTHLAKE PKY GA BELLSOUTH CMC AT&T WIRELESS ATLANTA 51 PEACHTREE CENTER AVE NE GA BELLSOUTH CMC AT&T WIRELESS ATLANTA 51 PEACHTREE CENTER AVE NE
F-5
Wireless Switches Serving BOC Rate Centers State BOC Region Type CLEC City Street GA BELLSOUTH DS AT&T WIRELESS ATLANTA 51 PEACHTREE CENTER AVE GA BELLSOUTH DS AT&T WIRELESS NORCROSS 5856 BUFORD HWY GA BELLSOUTH DS ATLANTA - ATHENS MSA LIMITED ALBANY 304 PINE AVE PARTNERSHIP GA BELLSOUTH DS ATLANTA - ATHENS MSA LIMITED ATLANTA 2366 OLD MARIETTA RD PARTNERSHIP GA BELLSOUTH DS ATLANTA - ATHENS MSA LIMITED ATLANTA 2366 MARIETTA RD PARTNERSHIP GA BELLSOUTH DS ATLANTA - ATHENS MSA LIMITED DECATUR 1085 KATIE KERR DR PARTNERSHIP GA BELLSOUTH DS ATLANTA - ATHENS MSA LIMITED DECATUR 1085 KATIE KERR DR PARTNERSHIP GA BELLSOUTH CMC ATLANTA - ATHENS MSA LIMITED LA GRANGE 2271 GREENVILLE ROAD PARTNERSHIP GA BELLSOUTH 5E ATLANTA - ATHENS MSA LIMITED MACON 4306 SHERATON DR PARTNERSHIP GA BELLSOUTH DS ATLANTA - ATHENS MSA LIMITED NORCROSS 2850 HUMPHRIES WAY PARTNERSHIP GA BELLSOUTH DS ATLANTA - ATHENS MSA LIMITED NORCROSS 2850 HUMPHRIES WAY PARTNERSHIP GA BELLSOUTH DS ATLANTA - ATHENS MSA LIMITED NORCROSS 2850 HUMPHRIES WAY PARTNERSHIP GA BELLSOUTH DS ATLANTA - ATHENS MSA LIMITED NORCROSS 2850 HUMPHRIES WAY NW PARTNERSHIP GA BELLSOUTH CMC ATLANTA - ATHENS MSA LIMITED ROYSTON 143 OAK ST PARTNERSHIP GA BELLSOUTH DSC ATLANTA - ATHENS MSA LIMITED TIFTON 116 S VICTORY DR PARTNERSHIP GA BELLSOUTH CMC ATLANTA - ATHENS MSA LIMITED WAYCROSS 315 PLANT AVE PARTNERSHIP GA BELLSOUTH 5EC DOBSON CELLULAR SYSTEMS DALTON 92 ABUTMENT RD GA BELLSOUTH CMC ENTERPRISE COMMUNICATIONS ALBANY 2151 GILLIONVILLE RD PARTNERSHIP GA BELLSOUTH CMC GEORGIA INDEPENDENT PCS MACON 4890 RALEY RD CORPORATION GA BELLSOUTH VCD GEORGIA INDEPENDENT PCS MACON 4890 RALEY RD CORPORATION GA BELLSOUTH CMC HARGRAY WIRELESS SAVANNAH 1315 BULL ST GA BELLSOUTH 5EC LEAP WIRELESS INTL COLUMBUS 1124 13TH ST GA BELLSOUTH 5EC METRO PCS NORCROSS 2990 GATEWAY DR., STE.950 GA BELLSOUTH CMC METROCALL ATLANTA 55 MARIETTA ST NW GA BELLSOUTH CMC METROCALL AUGUSTA 3351 WRIGHTSBORO RD @ (BLDG-200) GA BELLSOUTH DS METROCALL REMERTON 1707 AL BROOKS DR GA BELLSOUTH CMC NEXTEL ATHENS 1777 W BROAD ST GA BELLSOUTH D10 NEXTEL ATLANTA 400 EMBASSY ROW GA BELLSOUTH DMH NEXTEL ATLANTA 400 EMBASSY ROW GA BELLSOUTH CMC NEXTEL COLUMBUS 1412 10TH AVE GA BELLSOUTH CMC NEXTEL CORDELE 260 FLOYD RD GA BELLSOUTH CMC NEXTEL DUBLIN 1114 N FRANKLIN ST GA BELLSOUTH CMC NEXTEL HOGANSVILLE 177 E HOPSON RD GA BELLSOUTH CMC NEXTEL MACON 4792 RALEY RD GA BELLSOUTH CMC NEXTEL NORCROSS 5952 PEACHTREE INDUSTRIAL BLVD GA BELLSOUTH CMC NEXTEL NORCROSS 4150 SHACKLEFORD RD NW GA BELLSOUTH CMC NEXTEL SAVANNAH 1300 BULL ST
F-6
Wireless Switches Serving BOC Rate Centers State BOC Region Type CLEC City Street GA BELLSOUTH CMC NEXTEL SYLVESTER 302 HARDY ST GA BELLSOUTH CMC NEXTEL THOMASVILLE 1325 W JACKSON ST GA BELLSOUTH CMC NEXTEL VALDOSTA 1000 CYPRESS ST GA BELLSOUTH CM1 PUBLIC SERVICE CELLULAR AMERICUS 220 ED CARSON RD GA BELLSOUTH DS PUBLIC SERVICE CELLULAR COLUMBUS 418 14TH ST GA BELLSOUTH 5E PUBLIC SERVICE CELLULAR UNIONVILLE 392 PANSY AVE GA BELLSOUTH CMC SOUTHERN COMMUNICATIONS SERVICES ATLANTA 55 PARK PL NE GA BELLSOUTH DS SOUTHERN COMMUNICATIONS SERVICES ATLANTA 55 PARK PL NE GA BELLSOUTH CMC SOUTHERN COMMUNICATIONS SERVICES AUGUSTA 301 15TH ST GA BELLSOUTH CMC SOUTHERN COMMUNICATIONS SERVICES COLUMBUS 424 14TH ST GA BELLSOUTH DMH SOUTHERN COMMUNICATIONS SERVICES GAINESVILLE 340 JESSE JEWELL PARKWAY GA BELLSOUTH DMH SOUTHERN COMMUNICATIONS SERVICES MACON 185 STATE ST GA BELLSOUTH CMC SOUTHERN COMMUNICATIONS SERVICES SAVANNAH 1400 MITCHELL ST GA BELLSOUTH DMS SPRINT PCS NORCROSS 5775 REPS MILLER RD NW GA BELLSOUTH DMS SPRINT PCS ROSWELL 250 HEMBREE PKY GA BELLSOUTH DMS SPRINT PCS ROSWELL 250 HEMBREE PKY GA BELLSOUTH CMC TRITEL COMMUNICATIONS COLUMBUS 1324 4TH AVE GA BELLSOUTH CMC TRITON PCS ATHENS 750 W BROAD ST GA BELLSOUTH CMC TRITON PCS AUGUSTA 1229 ELLIS ST GA BELLSOUTH CMC TRITON PCS SAVANNAH 1315 BULL ST GA BELLSOUTH CMC US CELLULAR VALDOSTA RIVER ST GA BELLSOUTH CMC US CELLULAR WAYCROSS 3645 NEEDHAM RD GA BELLSOUTH CMC VOICESTREAM ATHENS 125 REESE ST GA BELLSOUTH AXT VOICESTREAM ATLANTA 250 WILLIAMS ST NW GA BELLSOUTH AXT VOICESTREAM ATLANTA 4 CONCOURSE PARKWAY, N.E. SUITE 100 GA BELLSOUTH CMC VOICESTREAM ATLANTA 4 CONCOURSE PARKWAY, N.E. SUITE 100 GA BELLSOUTH CMC VOICESTREAM AUGUSTA 301 15TH ST GA BELLSOUTH CMC VOICESTREAM COLUMBUS 422 14TH ST GA BELLSOUTH CMC VOICESTREAM COLUMBUS 424 14TH ST GA BELLSOUTH CMC VOICESTREAM LA GRANGE 300 BROOME ST GA BELLSOUTH CMC VOICESTREAM MACON 3920 ARKWRIGHT RD GA BELLSOUTH 5E VOICESTREAM NEWNAN 203 JEFFERSON ST GA BELLSOUTH CMC VOICESTREAM NORCROSS 5855 PEACHTREE CORNERS EAST GA BELLSOUTH CMC VOICESTREAM NORCROSS 5855 PEACHTREE CORNERS EAST GA BELLSOUTH CMC VOICESTREAM VALDOSTA 111 MILLER ST HI VERIZON CMC AT&T WIRELESS KEAAU 16-212 WILIAMA PL HI VERIZON CMC AT&T WIRELESS MILILANI 500 KAHELU AVE IA QWEST 5EC AT&T WIRELESS URBANDALE 4157 109TH ST IA QWEST CMC ELECTRONIC ENGINEERING COMPANY DES MOINES 1100 KEOKUK IA QWEST CMC IOWA WIRELESS SERVICES WATERLOO 501 SYCAMORE ST IA QWEST DMS100 SPRINT PCS URBANDALE 10740 AURORA AVE IA QWEST DMS100 US CELLULAR DAVENPORT 115 W 7TH ST IA QWEST CMC US CELLULAR DES MOINES 232 SW 11TH ST IA QWEST CMC US CELLULAR DES MOINES 2066 N 54TH AVE IA QWEST CMC US CELLULAR DUBUQUE 9003 USHWY 52 IA QWEST CMC US CELLULAR IOWA CITY 2010 KEOKUK ST IA QWEST CMC US CELLULAR WATERLOO 3420 RIDGE WAY AVE W IA QWEST CMC WESTERN WIRELESS SIOUX CITY 4711 SOUTHERN HILLS DR ID QWEST 5ES AT&T WIRELESS BOISE 619 W BANNOCK ST
F-7
Wireless Switches Serving BOC Rate Centers State BOC Region Type CLEC City Street ID VERIZON CMC AT&T WIRELESS COEUR D ALENE 2115 GOVERNMENT WY ID VERIZON CMC AT&T WIRELESS SANDPOINT 120 E LAKE ST ID QWEST DMS100 EDGE WIRELESS, LLC POCATELLO 948 N HARRISON AVE ID QWEST CMC GLENN ISHIBARA POCATELLO 233 N MAIN ST ID QWEST AXE10 LEAP WIRELESS INTL BOISE 10215 EMERALD ST ID QWEST CMC SPRINT PCS BOISE 1256 EXCHANGE ST ID QWEST CMC US CELLULAR POCATELLO 1750 N 1ST AVE IL VERIZON GT5 DOUGLAS TELECOMMUNICATIONS HARRISBURG 24 W CHURCH ST IL VERIZON CMC HEARTLAND COMMUNICATIONS BLOOMINGTON 120 N WESTERN AVE IL VERIZON CMC HEARTLAND COMMUNICATIONS DE KALB 225 E LOCUST ST IL VERIZON CMC MERCURY COMMUNICATIONS COMPANY OLNEY 1013 W MAIN ST IL VERIZON CMC MICHIANA METRONET MARSHALL W/ .25MI W/ CR 1450E ON CR 1800N IL VERIZON CMC NEXTEL SYCAMORE 1 MI W ON RICH RD & STHWY 23 IL VERIZON CMC NOVACOM HERRIN 100 S 13TH ST IL VERIZON CMC RURAL CELLULAR CORP CARBONDALE .2 MI S/O DOUGLAS DR. & POULTRY CENTER RD IL VERIZON DMS SPRINT PCS GRIDLEY 207 3RD ST IL VERIZON CMC US CELLULAR CARTERVILLE C/O GREENBRIER & SYCAMORE IL VERIZON CMC US CELLULAR KEWANEE HWY 78 1/2 MI N/O 20 IL VERIZON GT5 US CELLULAR OLNEY 2 MI S/O USHWY 50 & STHWY 130 IL VERIZON CMC US CELLULAR ROCKFORD 1130 E STATE ST IN VERIZON CMC ALLTEL ELKHART 26092 CORD 26 IN VERIZON 5EC AT&T WIRELESS EVANSVILLE 4631 OHARA DR IN VERIZON CMC AT&T WIRELESS INDIANAPOLIS 710 KENTUCKY AVE IN VERIZON CMC AT&T WIRELESS INDIANAPOLIS 710 KENTUCKY AV IN VERIZON CMC MICHIANA METRONET FORT WAYNE 3741 HILLEGAS RD IN VERIZON CMC MICHIANA METRONET LOGANSPORT 416 NORTHERN AVE IN VERIZON CMC MICHIANA METRONET RICHMOND 2460 RESERVOIR RD IN VERIZON CMC ROGERS RADIO CALL MERRILLVILLE 3757 E 82ND CT IN VERIZON CMC SPRINT PCS EVANSVILLE 1513 N CULLEN AVE IN VERIZON DMS SPRINT PCS INDIANAPOLIS 5621 WEST 85 ST IN VERIZON DMT US CELLULAR DELPHI 123 E MAIN ST IN VERIZON DCO US CELLULAR GREENCASTLE 201 E WASHINGTON ST IN VERIZON CMC US CELLULAR LOGANSPORT 316 E PEARL IN VERIZON GT5 US CELLULAR WABASH 122 W MARKET ST IN VERIZON CMC VOICESTREAM INDIANAPOLIS 6215 MORENCI TRL IN VERIZON CMC WESTEL GREENCASTLE 225 W SOUTH 350 N IN VERIZON CMC WESTEL LAFAYETTE 2575 S 30TH ST IN VERIZON DMT WESTEL LOOGOOTEE 305 JOHN F KENNEDY AVE IN VERIZON CMC WESTEL TERRE HAUTE 2003 S 12TH ST KS SBC DMH METROCALL WICHITA 8442 E 37TH ST N KS SBC D12 VOICESTREAM EMPORIA 28 W 8 KS SBC 5E VOICESTREAM LAWRENCE 732 VERMONT ST KS SBC DMH VOICESTREAM LEAVENWORTH 615 SHAWNEE ST KS SBC DMH VOICESTREAM MANHATTAN 1640 FAIRCHILD ST KS SBC AXT VOICESTREAM OTTAWA 625 MAIN KY BELLSOUTH CMC AT&T WIRELESS MADISONVILLE 54 W LAKE ST @ BLDG 2 KY VERIZON CMC AT&T WIRELESS MEADS DANNA DR @ TARPON RIDGE KY VERIZON DS AT&T WIRELESS RICHMOND 124 S KEENELAND KY BELLSOUTH DMS BLUEGRASS NETWORKS LIMITED BEAVER DAM 539 ROCHESTER RD LIABILITY CO.
F-8
Wireless Switches Serving BOC Rate Centers State BOC Region Type CLEC City Street KY BELLSOUTH CMC BLUEGRASS NETWORKS LIMITED BOWLING GREEN 710 KITCHENS RD S LIABILITY CO. KY BELLSOUTH CMC BLUEGRASS NETWORKS LIMITED HARRODSBURG 1963 CORNISHVILLE RD LIABILITY CO. KY BELLSOUTH DS GEARHEART COMM. CO HAROLD HWY 23S OF 979 KY VERIZON CMC HORIZON CELLULAR TELEPHONE CO. OF ELIZABETHTOWN 2471 SPRINGFIELD RD DAWSON KY VERIZON CMC INDEPENDENT CELLULAR NETWORK MEADS TARRAPIN RIDGE RD & BUCKHAVEN CT KY VERIZON CMC INDEPENDENT CELLULAR NETWORK RUSSELL 1/4 E OF S.R.750,1/4 S OF HWY23 KY BELLSOUTH CMC KENTUCKY CGSA LOUISVILLE 3503 COLLEGE DR KY BELLSOUTH DS KENTUCKY CGSA OWENSBORO 320 RUDY RD KY BELLSOUTH DS KENTUCKY CGSA WINCHESTER OLIVER RD KY BELLSOUTH CMC NEXTEL CORBIN 3317 CUMBERLAND FALLS HWY KY VERIZON DM2 NEXTEL LOUISVILLE 526 ARMORY PL KY BELLSOUTH CMC NEXTEL LOUISVILLE 11003 BLUEGRASS PKWY KY BELLSOUTH CMC NEXTEL WINCHESTER 222 W LEXINGTON AVE KY BELLSOUTH DX2 NORTHSTAR TECHNOLOGY SOMERSET 1895 HWY 461 KY VERIZON CMC RAM TECHNOLOGIES ASHLAND 2025 13TH ST KY VERIZON CMC RAMCELL OF KENTUCKY PITTSBURG STHWY 80 KY VERIZON ESS SPRINT PCS LOUISVILLE 2800 DIODE LN KY BELLSOUTH DM5 SPRINT PCS LOUISVILLE 2800 DIODE LN KY VERIZON CMC THIRD KENTUCKY CELLULAR CORP. CORBIN 3333 E CUMBERLAND GAP PKY KY BELLSOUTH CMC TRITEL COMMUNICATIONS BOWLING GREEN 1150 STATE ST KY BELLSOUTH CMC TRITEL COMMUNICATIONS BOWLING GREEN 1150 STATE ST KY BELLSOUTH CMC TRITEL COMMUNICATIONS LOUISVILLE 2351 NELSON MILLER PKY KY BELLSOUTH CMC VOICESTREAM BOWLING GREEN 1150 STATE ST KY BELLSOUTH CMC VOICESTREAM LEXINGTON 565 W MAIN ST KY VERIZON CMC VOICESTREAM LOUISVILLE 11509 COMMONWEALTH DR KY VERIZON 5E WEBLINK WIRELESS LEXINGTON 151 S MARTIN LUTHER KING BLVD LA BELLSOUTH CMC AT&T WIRELESS ALEXANDRIA 825 MURRAY ST LA BELLSOUTH CMC AT&T WIRELESS BATON ROUGE 333 N 6TH ST LA BELLSOUTH CMC AT&T WIRELESS LAKE CHARLES 902 RAILROAD AVE LA BELLSOUTH CMC AT&T WIRELESS NEW ORLEANS 160 JAMES (ST ROSE) DR E LA BELLSOUTH CMC AT&T WIRELESS NEW ORLEANS 160 JAMES (ST ROSE) DR E SUITE 300 LA BELLSOUTH CMC AT&T WIRELESS SCOTT 220 RUE BON SECOURS LA BELLSOUTH DS AT&T WIRELESS SHREVEPORT 725 MCNEIL ST LA BELLSOUTH CMC BATON ROUGE CELLULAR TELEPHONE BATON ROUGE 566 LOBDELL AVE CO. LA BELLSOUTH CMC BATON ROUGE CELLULAR TELEPHONE KENNER 1000 WILLIAMS BLVD CO. LA BELLSOUTH CMC BATON ROUGE CELLULAR TELEPHONE NEW ORLEANS ONE SHELL SQ CO. LA BELLSOUTH CMC BATON ROUGE MSA LIMITED BATON ROUGE 2751 W. PERDUE DRIVE PARTNERSHIP LA BELLSOUTH D12 BATON ROUGE MSA LIMITED SHREVEPORT 602 CROCKETT ST PARTNERSHIP LA BELLSOUTH CMC BAY STAR SATELLITE PAGING BATON ROUGE 445 NORTH BLVD LA BELLSOUTH CMC BAY STAR SATELLITE PAGING NEW ORLEANS 639 LOYOLA AVE LA BELLSOUTH CMC CENTENNIAL SOUTHEAST LICENSE ALEXANDRIA 2006 MACARTHUR DR COMPANY LA BELLSOUTH DMS CENTENNIAL SOUTHEAST LICENSE LAFAYETTE 327 DOMINGUE AVE COMPANY
F-9
Wireless Switches Serving BOC Rate Centers State BOC Region Type CLEC City Street LA BELLSOUTH CMC CENTENNIAL SOUTHEAST LICENSE LAKE CHARLES CALCASIEU MARINE NATIONAL COMPANY LA BELLSOUTH CMC CENTENNIAL SOUTHEAST LICENSE LIVONIA 8853 USHWY 190 COMPANY LA BELLSOUTH CMC CENTURY TEL WIRELESS ALEXANDRIA 3442 HORSESHOE DR LA BELLSOUTH CMC CENTURY TEL WIRELESS MONROE 3005 DESOTO ST LA BELLSOUTH CMC CENTURYTEL SOLUTIONS ALEXANDRIA 728 MURRAY ST. LA BELLSOUTH CMC CENTURYTEL SOLUTIONS MONROE 3005 DESOTO LA BELLSOUTH SNSE CENTURYTEL SOLUTIONS SHREVEPORT 406 COTTON ST LA BELLSOUTH 5E GULF COAST WIRELESS LIMITED BATON ROUGE 620 FLORIDA ST PARTNERSHIP LA BELLSOUTH 5E GULF COAST WIRELESS LIMITED LAFAYETTE 110 E BUTCHER RD PARTNERSHIP LA BELLSOUTH CMC LAFAYETTE MSA LIMITED PARTNERSHIP ALEXANDRIA 825 MURRAY ST LA BELLSOUTH CMC LAFAYETTE MSA LIMITED PARTNERSHIP LAFAYETTE 228 LANDMARK STREET LA BELLSOUTH CMC LOUISIANA CGSA METAIRIE 1100 RIDGEWOOD AVENUE LA BELLSOUTH DS LOUISIANA CGSA METAIRIE 1100 RIDGEWOOD AVE. LA BELLSOUTH 5E LOUISIANA UNWIRED LAKE CHARLES 410 DIVISION ST LA BELLSOUTH CMC LOUISIANA UNWIRED MONROE 117 HART ST LA BELLSOUTH 5EC LOUISIANA UNWIRED NEW ORLEANS 639 LOYOLA AVE LA BELLSOUTH 5E LOUISIANA UNWIRED SHREVEPORT 330 MARSHALL ST LA BELLSOUTH DS METROCALL HARVEY 1545 LAPALCO BLVD LA BELLSOUTH CMC METROCALL METAIRIE 6820 VETERANS MEMORIAL BLVD LA BELLSOUTH DMH NEXTEL ALEXANDRIA 251 BROWNS BEND RD LA BELLSOUTH CMC NEXTEL BATON ROUGE 301 MAIN ST LA BELLSOUTH DMH NEXTEL BATON ROUGE 445 NORTH BLVD LA BELLSOUTH DMH NEXTEL LAKE CHARLES 902 RAILROAD AVE LA BELLSOUTH CMC NEXTEL METAIRIE 3540 S I-10 SERVICE RD W LA BELLSOUTH DMH NEXTEL MINDEN 1554 JACK MARTIN RD LA BELLSOUTH DMH NEXTEL NATCHITOCHES 296 HWY 6 LA BELLSOUTH DMH NEXTEL SCOTT 220 RUE BON SECOURS LA BELLSOUTH DMS SPRINT PCS KENNER 1327 DANVILLE ST LA BELLSOUTH CMC US UNWIRED LAKE CHARLES 1 LAKESHORE DR LA BELLSOUTH CMC VOICESTREAM METAIRIE 1 GALLERIA BLVD , 70001 MA VERIZON AXT AT&T WIRELESS BOSTON 230 CONGRESS ST MA VERIZON AXT AT&T WIRELESS CAMBRIDGE 250 BENT ST MA VERIZON AXT AT&T WIRELESS FRAMINGHAM 825 WAVERLY STREET MA VERIZON CMC AT&T WIRELESS FRAMINGHAM 825 WAVERLY STREET MA VERIZON 5E AT&T WIRELESS SOUTHBORO 155 NORTHBORO RD MA VERIZON 5E METROCALL BURLINGTON 1 BEDFORD ST MA VERIZON DMH METROCALL SPRINGFIELD 295 WORTHINGTON ST MA VERIZON CMC NEXTEL BOSTON 1255 BOYLSTON ST MA VERIZON CMC NEXTEL MANSFIELD 135 FORBES BLVD MA VERIZON 5E NEXTWAVE MARLBORO 19 BRIGHAM ST MA VERIZON CMC RURAL CELLULAR CORP SHELBURNE OLD ALBANY RD MA VERIZON 5E SPRINGWICH CELLULAR LIMITED SPRINGFIELD 295 WORTHINGTON ST PARTNERSHIP MA VERIZON 4E SPRINT PCS CAMBRIDGE 250 BENT ST MA VERIZON 5E SPRINT PCS WALPOLE 10 WALPOLE PARK S MA VERIZON CMC SPRINT PCS WALPOLE 10 WALPOLE PARK S MA VERIZON 5E SPRINT PCS WOBURN 74 COMMERCE WAY MA VERIZON CMC SPRINT PCS WOBURN 74 COMMERCE WAY
F-10
Wireless Switches Serving BOC Rate Centers State BOC Region Type CLEC City Street MD VERIZON DS AT&T WIRELESS BALTIMORE 323 N CHARLES ST MD VERIZON ESS DOBSON CELLULAR SYSTEMS FREDERICK 5330 SPECTRUM DR MD VERIZON CMC DOBSON CELLULAR SYSTEMS OAKLAND EAGLE ROCK RD MD VERIZON CMC DOBSON CELLULAR SYSTEMS SALISBURY BRICK KILN RD MD VERIZON DS HORIZON CELLULAR TELEPHONE CO. OF EASTON 402 BROOKLETTE AVE DAWSON MD VERIZON DS HORIZON CELLULAR TELEPHONE CO. OF HOLLYWOOD 24779 MCINTOSH RD DAWSON MD VERIZON 5E METROCALL DAMASCUS LEWIS DR MD VERIZON CMC NEXTEL BALTIMORE 109 MARKET PLC MD VERIZON DMH NEXTEL BALTIMORE 201 N CHARLES ST MD VERIZON DS NEXTEL FREDERICK 9450F GAMBRILL PARK RD MD VERIZON CMC NEXTEL HANOVER (ANNE 7249 NATIONAL DR ARUNDEL) MD VERIZON 5E NEXTEL SALISBURY 2530 N SALISBURY BLVD MD VERIZON DMH NEXTEL SILVER SPRING 11900 BOURNEFIELD WAY MD VERIZON DMH PREFERRED NETWORKS MUIRKIRK 12212 BALTIMORE AVE MD VERIZON CMC SPRINT PCS BELTSVILLE 12001 INDIAN CREEK CT MD VERIZON CMC SPRINT PCS BELTSVILLE 12001 INDIAN CREEK CT MD VERIZON DS SPRINT PCS BELTSVILLE 12001 INDIAN CREEK CT MD VERIZON DS SPRINT PCS BELTSVILLE 12001 INDIAN CREEK CT MD VERIZON 5E SPRINT PCS HANOVER (ANNE 7267 PARK CIRCLE DR ARUNDEL) MD VERIZON 5E SPRINT PCS SALISBURY 613 CALLOWAY ST MD VERIZON DS US CELLULAR HAGERSTOWN S MULBERRY ST MD VERIZON CMC US CELLULAR THAYERVILLE RTE 2 MD VERIZON 5E VOICESTREAM HAGERSTOWN 960 WILLOW CIR MD VERIZON DS VOICESTREAM HANOVER 7267 PARK CIRCLE DR ME VERIZON DS AT&T WIRELESS WESTBROOK 12 SAUNDERS WAY (HUT) ME VERIZON D12 MRCC BANGOR BOMARC RD @ (MULTI OFFICE BLDG) ME VERIZON D12 MRCC PORTLAND 45 FOREST AVE ME VERIZON CMC SACO RIVER CELL TEL CO BIDDEFORD 124 OAK RIDGE RD ME VERIZON D12 US CELLULAR AUGUSTA SHAW HILL ME VERIZON DM5 US CELLULAR MANCHESTER TOWER ROAD MI VERIZON CMC CENTURY TEL WIRELESS ADRIAN 6787 PENTECOST HWY MI VERIZON CMC CENTURY TEL WIRELESS ADRIAN 103 1/2 SAND CREEK HWY MI VERIZON CMC CENTURY TEL WIRELESS ALPENA W/O FRENCH RD ON NAYLOR RD MI VERIZON 5EH CENTURY TEL WIRELESS MUSKEGON 860 TERRACE ST MI VERIZON EX2 CENTURY TEL WIRELESS MUSKEGON 1781 N SHERIDAN RD MI VERIZON CMC MICHIANA METRONET BATTLE CREEK 14650 BEADLE LAKE RD MI VERIZON CMC MICHIANA METRONET JACKSON 120 W MICHIGAN AVE MI VERIZON CMC MICHIANA METRONET MOUNT PLEASANT 1166 E REMUS RD MI VERIZON CMC NEXTEL GRAND RAPIDS 114 N DIVISION AVE MI VERIZON CMC NEXTEL SOUTHFIELD 100 GALLERIA OFFICENTRE MI VERIZON CMC SPRINT PCS DETROIT 1320 THIRD ST MI VERIZON CMC VOICESTREAM LIVONIA 12170 MERRIMAN RD MN QWEST CMC AT&T WIRELESS HIBBING 3553 MAPLE HILL RD MN QWEST 5ES AT&T WIRELESS MINNEAPOLIS 2515 24TH AVE S MN QWEST CMC AT&T WIRELESS MINNEAPOLIS 2515 24TH AVE S MN QWEST CMC CELLULAR MOBILE SYSTEMS OF ST. MINNEAPOLIS 618 2ND AVE S CLOUD GEN PARTNERSH
F-11
Wireless Switches Serving BOC Rate Centers State BOC Region Type CLEC City Street MN QWEST CMC CELLULAR MOBILE SYSTEMS OF ST. ST CLOUD 3563 CORD 136 CLOUD GEN PARTNERSH MN QWEST CMC CYBERTEL MINNEAPOLIS PAGING GOLDEN VALLEY 610 OTTAWA AVE N MN QWEST CMC HEARTLAND COMMUNICATIONS GOLDEN VALLEY 747 BOONE AVE N MN QWEST CMC MIDWEST WIRELESS COMMUNICATION MINNEAPOLIS 618 2ND AVE S MN QWEST CMC MIDWEST WIRELESS COMMUNICATION ROCHESTER 220 S BROADWAY MN QWEST CMC NEXTEL MINNEAPOLIS 511 11TH AVE S MN QWEST CMC RURAL CELLULAR CORP CAMBRIDGE 540 N EMERSON AVE MN QWEST CMC SOURCE ONE WIRELESS MINNEAPOLIS 618 2ND AVE S MN QWEST DMS100 SPRINT PCS MINNEAPOLIS 511 11TH AVE S MN QWEST DMS100 SPRINT PCS MINNEAPOLIS 511 11TH AVE S MN QWEST CMC SPRINT PCS ST CLOUD 3563 CORD 136 MN QWEST CMC VOICESTREAM EAGAN 3070 LUNAR LN MN QWEST CMC WESTERN WIRELESS CROOKSTON SECTION 3 T149N R47W MO VERIZON D12 ALLTEL BRANSON 211 S 3RD ST MO SBC 5E METROCALL KANSAS CITY 107 E 39TH ST MO SBC DMH METROCALL KANSAS CITY 1101 MCGEE MO SBC DMH METROTEL ST LOUIS 1010 PINE MO VERIZON 5E SPRINT PCS JEFFERSON CITY 1309 EDGEWOOD MO SBC DMH TELETOUCH COMMUNICATIONS SPRINGFIELD 3028 S. FREMONT MO SBC AXT VOICESTREAM MARSHALL 210 E ARROW MS BELLSOUTH D12 CELLULAR XL ASSOCIATES HATTIESBURG #17 IVEY LN MS BELLSOUTH DMS CELLULAR XL ASSOCIATES HATTIESBURG #17 IVY LN MS BELLSOUTH CMC CENTENNIAL SOUTHEAST LICENSE NATCHEZ 231 JOHN R JUNKIN DR COMPANY MS BELLSOUTH SNSE CENTURY TEL WIRELESS GULFPORT 11270 CREEL CIR MS BELLSOUTH SNSE CENTURY TEL WIRELESS JACKSON 210 E CAPITOL ST, SUITE 2174 MS BELLSOUTH CMC DIG1PH PCS GULFPORT 333 COWAN RD MS BELLSOUTH CMC DIG1PH PCS HATTIESBURG 4225 MAMIE ST MS BELLSOUTH CMC MCTA JACKSON 293 MARKETRIDGE DR MS BELLSOUTH CMC METROCALL JACKSON 5570 I 55 N MS BELLSOUTH DMH NEXTEL BILOXI 850 BAYVIEW AVE MS BELLSOUTH CMC NEXTEL JACKSON 210 E PEARL ST MS BELLSOUTH DMH NEXTEL LONG BEACH 112 N OCAN WAVE AVE MS BELLSOUTH DMH NEXTEL PASCAGOULA 1783 OLD MOBILE AVE MS BELLSOUTH CMC SOUTHERN COMMUNICATIONS SERVICES GULFPORT 2221 17TH ST MS BELLSOUTH CMC SOUTHERN COMMUNICATIONS SERVICES HATTIESBURG 100 BRUNIE ST MS BELLSOUTH CMC SOUTHERN COMMUNICATIONS SERVICES MERIDIAN 2401 11TH ST MS BELLSOUTH DS TELEPAK GULFPORT 1723 22ND AVE & 18TH MS BELLSOUTH CMC TELEPAK JACKSON 125 S CONGRESS ST MS BELLSOUTH DMS TELEPAK JACKSON 125 S CONGRESS ST MS BELLSOUTH CMC TELETOUCH COMMUNICATIONS JACKSON 1220 E NORTHSIDE DR MS BELLSOUTH CMC TRITEL COMMUNICATIONS GULFPORT 1723 22ND AVE MS BELLSOUTH CMC TRITEL COMMUNICATIONS RIDGELAND 371 HIGHLAND COLONY PKY MS BELLSOUTH 5E US UNWIRED GREENWOOD 69601 HWY 82 W MS BELLSOUTH AXT VOICESTREAM JACKSON 308 E PEARL ST MS BELLSOUTH AXT VOICESTREAM MERIDIAN 2401 11TH ST MS BELLSOUTH DS VOICESTREAM TUPELO 1910 N GLOSTER DR (HWY 45) MT QWEST DMS100 MONTANA WIRELESS MISSOULA 1810 DEFOE ST MT QWEST 5EC WESTERN WIRELESS BILLINGS 2000 COBURN RD MT QWEST CMC WESTERN WIRELESS BILLINGS 2000 COBURN RD MT QWEST CMC WESTERN WIRELESS GREAT FALLS 3720 BOOTLEGGER TRL
F-12
Wireless Switches Serving BOC Rate Centers State BOC Region Type CLEC City Street MT QWEST CMC WESTERN WIRELESS MISSOULA 3100 PAXSON ST @ S32T13NR19W NC BELLSOUTH DS ALLTEL GARNER 3651 JUNCTION BLVD NC BELLSOUTH CMC ALLTEL LEXINGTON 18 E 2ND AVE NC VERIZON E25 ALLTEL MATTHEWS 1101 MATTHEWS - MINT HILL RD NC BELLSOUTH DS ARCH WIRELESS HOLDINGS CHARLOTTE, 1932 W MOREHEAD ST NC BELLSOUTH CMC AT&T WIRELESS CHARLOTTE 3390 SERVICE ST NC VERIZON CMC AT&T WIRELESS DURHAM 5616 CHIN PAGE RD NC BELLSOUTH CMC AT&T WIRELESS GREENSBORO 301 S ELM ST NC BELLSOUTH CMC AT&T WIRELESS WINSTON-SALEM 1480 S BROAD ST NC BELLSOUTH 5EC CRICKET COMMUNICATIONS CHARLOTTE 2915 WHITEHALL PARK DR NC BELLSOUTH 5EC CRICKET COMMUNICATIONS GREENSBORO 4351 FEDERAL DR NC BELLSOUTH DS METROCALL ASHEVILLE 640 MERRIMON AVE NC VERIZON DMH METROCALL DURHAM 2314 NELSON CHAPEL HILL HWY NC BELLSOUTH CMC METROCALL RALEIGH 3100 HIGHWOODS BLVD NC BELLSOUTH DS METROCALL WILMINGTON 108 HARLEY RD NC BELLSOUTH DMH NEXTEL CHARLOTTE 3109 WESTINGHOUSE BL NC BELLSOUTH CMC NEXTEL GREENSBORO 610 INDUSTRIAL AVE NC BELLSOUTH CMC NEXTEL LEXINGTON 18 E 2ND AVE NC VERIZON CMC NEXTEL RALEIGH 3100 SMOKETREE CT NC BELLSOUTH CMC TRITON PCS ASHEVILLE 340 VICTORIA RD NC BELLSOUTH AXT TRITON PCS GOLDSBORO 118 S BERKLY BLVD NC BELLSOUTH AXT TRITON PCS LAURINBURG 13900 DIXIE GUANO RD NC BELLSOUTH AXT TRITON PCS LUMBERTON 491 POWER PLANT RD NC BELLSOUTH CMC TRITON PCS WILMINGTON 4428 S COLLEGE RD NC BELLSOUTH CMC US CELLULAR ASHEVILLE 36 RESERVOIR RD NC BELLSOUTH CMC US CELLULAR FOREST CITY 925 S MOUNTAIN RD NC BELLSOUTH CMC US CELLULAR GOLDSBORO .45M N OF SR 1235 & SR 1236 NC VERIZON DMH US CELLULAR MARION 17 N GARDEN ST NC BELLSOUTH DM2 US CELLULAR REIDSVILLE .8MI E OF HWY 29 & HWY 158 NC BELLSOUTH DMH US CELLULAR WILMINGTON 322 VAN DYKE NC VERIZON DMH WEBLINK WIRELESS DURHAM 104 HOLLOWAY ST ND QWEST CMC WESTERN WIRELESS BISMARCK 1925 N 11TH ST NE QWEST CMC ARCH WIRELESS HOLDINGS OMAHA 122 S 77TH ST NE QWEST 5ES AT&T WIRELESS OMAHA 118 S 19TH ST NE QWEST CMC LINCOLN TELECOM. CORP. OMAHA 10630 BURT NE QWEST CMC LINCOLN TELECOM. CORP. OMAHA 10630 BURT NE QWEST DMS100 SPRINT PCS OMAHA 4829 S 114TH ST NH VERIZON DMS AT&T WIRELESS DOVER 20 ABBEY SAWYER MEMORIAL HWY NH VERIZON 5E METROCALL MANCHESTER 25 CONCORD ST NH VERIZON 5E RURAL CELLULAR CORP CLAREMONT GREEN MOUNTAIN RD NH VERIZON DMS RURAL CELLULAR CORP WEST LEBANON STATE HWY 12A S/O I89 HWY NH VERIZON CMC SACO RIVER CELL TEL CO DOVER LONG HILL RD @ (MULTI OFFICE BLDG) NH VERIZON CMC SPRINT PCS LONDONDERRY 34 LONDONDERRY RD NH VERIZON CMC US CELLULAR MERRIMACK CARON ST NJ VERIZON CMC AQUIS COMMUNICATIONS HAMILTON SQUARE 1300 WHITE HORSE RD & HAMILTON SQ NJ VERIZON CMC AT&T WIRELESS NEWARK 95 WILLIAM ST NJ VERIZON CMC AT&T WIRELESS NEWARK 95 WILLIAM ST
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Wireless Switches Serving BOC Rate Centers State BOC Region Type CLEC City Street NJ VERIZON CMC AT&T WIRELESS NEWARK 95 WILLIAM ST NJ VERIZON CMC AT&T WIRELESS PORT MURRAY- HOFFMAN RD WARREN NJ VERIZON CMC AT&T WIRELESS TETERBORO 100 HOLLISTER RD NJ VERIZON DS MAP MOBILE COMMUNICATIONS HADDON HEIGHTS 505 BLACKHORSE PIKE NJ VERIZON CMC NEXTEL ATLANTIC CITY 2715 BOARDWALK AVE NJ VERIZON CMC NEXTEL CHERRY HILL BURNT MILL & BERLIN NJ VERIZON CMC NEXTEL FAIRFIELD (ESSEX) 2 INDUSTRIAL RD NJ VERIZON CMC NEXTEL HACKENSACK 25 MAIN ST COURT PL NJ VERIZON CMC NEXTEL PLEASANTVILLE - 40 E GRANT ST ATLAN NJ VERIZON CMC SPRINT PCS BRANCHBURG 24 COUNTY LINE RD TOWNSHIP NJ VERIZON CMC SPRINT PCS PENNSAUKEN 8440 REMINGTON AVE NJ VERIZON 5E SPRINT PCS TETERBORO 100 HOLLISTER RD NJ VERIZON 5E SPRINT PCS TETERBORO 100 HOLLISTER RD NJ VERIZON DS TSR WIRELESS FORT LEE 400 KELBY ST NJ VERIZON CMC VOICESTREAM CAMDEN 12 N SEVENTH ST NJ VERIZON CMC VOICESTREAM PLEASANTVILLE - 420 W WASHINGTON AV ATLAN NJ VERIZON CMC VOICESTREAM WAYNE 360 NEWARK POMPTON TPKE NJ VERIZON CMC VOICESTREAM WAYNE 360 NEWARK POMPTON TPKE NJ VERIZON CMC VOICESTREAM WAYNE 360 NEWARK POMPTON TPKE NJ VERIZON DM1 VOICESTREAM WAYNE 360 NEWARK POMPTON TPKE NM QWEST CMC ALLTEL LAS CRUCES 670 N MOTEL BLVD NM QWEST CMC ALLTEL SANTA FE 4200 RODEO RD NM QWEST CMC AT&T WIRELESS ALBUQUERQUE 111 3RD ST NW NM QWEST CMC CONTACT NEW MEXICO ALBUQUERQUE 10820 CENTRAL AVE SE NM QWEST 5EC LEAP WIRELESS INTL ALBUQUERQUE 2420 COMANCHE RD NE NM QWEST CMC MAGNACOM WIRELESS ALBUQUERQUE 3830 SINGER BLVD NE NM VERIZON D12 PVT WIRELESS LIMITED PARTNERSHIP COTTONWOOD R 553 NORTH 13TH NM QWEST DMS100 SPRINT PCS ALBUQUERQUE 2445 ALAMO AVE S E NM QWEST CMC VOICESTREAM ALBUQUERQUE 4830 PAN AMERICAN FREEWAY NE NM QWEST CMC VOICESTREAM SANTA FE 210 E MARCY ST NV VERIZON CMC AT&T WIRELESS RENO 195 E 1ST ST NV SBC D12 NEXTEL RENO 3425 GULLING RD NV VERIZON CMC SPRINT PCS RENO 5355 CAPITAL CT NY VERIZON 5EC AT&T WIRELESS BUFFALO 65 FRANKLIN ST NY VERIZON 5E AT&T WIRELESS CHEEKTOWAGA 1690 WALDEN AVE NY VERIZON 5E AT&T WIRELESS HUNTINGTON 1444 E JERICHO TPKE NY VERIZON 5E AT&T WIRELESS HUNTINGTON 1444 E JERICHO TPKE #1ST FLOOR NY VERIZON 5E AT&T WIRELESS HUNTINGTON 1444 E JERICHO TPKE NY VERIZON CMC AT&T WIRELESS MANHATTAN 33 THOMAS ST NY VERIZON CMC AT&T WIRELESS MANHATTAN 33 THOMAS ST NY VERIZON 5E AT&T WIRELESS QUEENS 9415 100TH ST NY VERIZON DMH AT&T WIRELESS SOUTHPORT 1 COMFORT HILL RD NY VERIZON CMC AT&T WIRELESS WHITE PLAINS 400 HAMILTON AVE NY VERIZON AXT BUFFALO TELEPHONE COMPANY DBA BUFFALO RAND BLDG CELLULAR ONE BUFFALO NY VERIZON AXT GENESEE TELEPHONE CO ARCADIA 1550 FT SW/O MAXISON RD & LEMBKE RD
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Wireless Switches Serving BOC Rate Centers State BOC Region Type CLEC City Street NY VERIZON 5EH LINCOLN COMMUNICATIONS ALBANY 158 STATE ST NY VERIZON 5E MAP MOBILE COMMUNICATIONS GARDEN CITY 741 ZECKENDORF BLVD NY VERIZON CMC MAP MOBILE COMMUNICATIONS HICKSVILLE 240 N BROADWAY NY VERIZON DMH METROCALL NYACK 15 CEDAR ST NY VERIZON DMH METROCALL PLEASANTVILLE 465 MARBLE AV NY VERIZON G3L METROCALL SYRACUSE 2949 ERIE BLVD E NY VERIZON 5E METROCALL YAPHANK YAPHANK MIDDLE ISLAN NY VERIZON DMH NEXTEL ELMSFORD 175 CLEARBROOK RD NY VERIZON CMC NEXTEL GARDEN CITY 1 SOUTH ST NY VERIZON DMH NEXTEL GARDEN CITY 1 SOUTH ST NY VERIZON CMC NEXTEL SYRACUSE 1005 W FAYETTE ST NY VERIZON CMC PREFERRED NETWORKS PLAINVIEW 101 FAIRCHILD AVE NY VERIZON G3X PREFERRED NETWORKS SYOSSET 575 UNDERHILL BLVD NY VERIZON 5E SPRINT PCS ALBANY 3 ENTERPRISE DR NY VERIZON CMC SPRINT PCS CHEEKTOWAGA 50 DEWBERRY LN NY VERIZON CMC SPRINT PCS MANHATTAN 111 8TH AVE NY VERIZON CMC SPRINT PCS MANHATTAN 111 8TH AVE NY VERIZON 5E SPRINT PCS WESTBURY (NASSAU) 75 FROST ST NY VERIZON 5E SPRINT PCS WESTBURY (NASSAU) 75 FROST ST NY VERIZON CMC SPRINT PCS WESTBURY (NASSAU) 75 FROST ST NY VERIZON CMC SPRINT PCS WESTBURY (NASSAU) 75 FROST ST NY VERIZON DMH SYGNET COMMUNICATIONS BUFFALO 1800 RAND BUILDING 14 LAFAYETTE SQUARE NY VERIZON DMH SYGNET COMMUNICATIONS OLEAN PAGE RD NY VERIZON CMC VOICESTREAM BOHEMIA 21 KEYLAND CT NY VERIZON DM1 VOICESTREAM BOHEMIA 21 KEYLAND CT NY VERIZON DM5 VOICESTREAM SALINA 103 MONARCH DR NY VERIZON 5E WEBLINK WIRELESS BUFFALO 65 FRANKLIN ST NY VERIZON 5E WEBLINK WIRELESS SYRACUSE 201 S STATE ST OH VERIZON CMC ALLTEL NORTH FAIRFIELD JCT SR 150 & TOWN LN RD 131 OH VERIZON CMC AT&T WIRELESS ATHENS 7654 BITTERSWEET LN OH VERIZON DM5 AT&T WIRELESS ATHENS 7800 ROCK RIFFLE RD OH VERIZON CMC AT&T WIRELESS CAMBRIDGE 63970 LARRICK RIDGE RD OH VERIZON CMC AT&T WIRELESS DOVER W SIDE OF TOWN ON TWP 384 OH VERIZON CMC AT&T WIRELESS PORTSMOUTH 2736 SCIOTO TRL OH SBC 5EC BROADWING BLUE ASH 11480 NORTHLAKE DR OH SBC NT5 BROADWING BLUE ASH 11480 NORTHLAKE DR OH SBC 5EC BROADWING DAYTON 40 W 4TH ST & (PRIMARY BLDG) OH VERIZON DMH DOBSON CELLULAR SYSTEMS BELLEVUE 2481 COUNTRY RD 302 RD OH VERIZON CMC INDEPENDENT CELLULAR NETWORK ATHENS N/O USHWY 33 ON PEACH RIDGE RD OH VERIZON CMC INDEPENDENT CELLULAR NETWORK STONE CREEK 6959 BUEHLER HILL RD OH VERIZON CMC NEXTEL TOLEDO 319 MADISON AVE OH VERIZON CMC RAM TECHNOLOGIES SCIOTOVILLE 6416 GALLIA ST OH VERIZON CMC SOUTHERN OHIO COMMUNICATION WAVERLY 100 E THIRD ST SERVICES OH VERIZON CMC SPRINT PCS CHILLICOTHE 68 E MAIN ST OH VERIZON CMC US CELLULAR PORTSMOUTH 2574 SUNRISE AVE OH VERIZON CMC VOICESTREAM TOLEDO 130 N ERIE ST OR QWEST CMC ARCH WIRELESS HOLDINGS PORTLAND 5901 SW MACADAM AVE OR QWEST CMC AT&T WIRELESS EUGENE 1398 WILLAMETTE ST OR QWEST CMC AT&T WIRELESS MEDFORD 435 N BARTLETT ST
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Wireless Switches Serving BOC Rate Centers State BOC Region Type CLEC City Street OR QWEST CMC AT&T WIRELESS PORTLAND 819 SW OAK ST OR QWEST CMC AT&T WIRELESS PORTLAND 819 SW OAK ST OR QWEST AXE10 LEAP WIRELESS INTL SALEM 3995 FAIRVIEW INDUSTRIAL DR SE OR QWEST CMC NEXTEL EUGENE 76 CENTENNIAL LOOP OR QWEST CMC NEXTEL PORTLAND 511 SW 10TH AVE OR VERIZON CMC RCC HOLDINGS PENDLETON 1660 NW 49TH OR QWEST CMC SPRINT PCS BEAVER CREEK BEAVER CREEK OR QWEST CMC SPRINT PCS PORTLAND 215 SE MORRISON ST OR QWEST 5ES SPRINT PCS TIGARD 10799 SW CASCADE BLVD OR QWEST CMC SPRINT PCS TIGARD 10799 SW CASCADE BLVD OR VERIZON CMC SPRINT PCS TIGARD 10799 SW CASCADE BLVD OR QWEST DMS100 US CELLULAR MEDFORD 515 PARSONS DR OR QWEST CMC VOICESTREAM PORTLAND 1500 NE IRVING ST PA VERIZON CMC ALLTEL AVOCA 1400 SPRUCE ST PA VERIZON DS ALLTEL HARRISBURG COCKLEY RD PA VERIZON CMC ALLTEL OIL CITY .23 MI W/O HORNE LN & GRANDVIEW RD PA VERIZON DS ALLTEL WARREN 109 CHAPMAN RD PA VERIZON CMC ALLTEL YORK WQXA TOWER LOCN PA VERIZON DS AMERICELL LOCK HAVEN GLEN RD PA VERIZON CMC AQUIS COMMUNICATIONS HARRISBURG 210 PINE ST PA VERIZON CMC AQUIS COMMUNICATIONS PHILADELPHIA 900 RACE ST PA VERIZON DM5 AT&T WIRELESS ALLEGHENY 2463 N. OLD RT220 PA VERIZON DM5 AT&T WIRELESS CATAWISSA RD2 PA VERIZON DS AT&T WIRELESS CRAFTON 270 BILMAR DRIVE PA VERIZON DS AT&T WIRELESS CRAFTON 270 BILMAR DRIVE PA VERIZON DS AT&T WIRELESS HARRISBURG 4375 LEWIS RD PA VERIZON NT5 AT&T WIRELESS HUGHESVILLE BUCK HILL RD WLPT CELLULA PA VERIZON CMC AT&T WIRELESS PHILADELPHIA 500 S 27TH ST PA VERIZON CMC AT&T WIRELESS SOMERSET WILLS CHURCH RD PA VERIZON DS AT&T WIRELESS WILKES-BARRE 485 LASLEY AVE PA VERIZON DM5 AT&T WIRELESS YORK 1803 MT ROSE AVE PA VERIZON CMC CONESTOGA WIRELESS COMPANY BOYERTOWN E 2ND ST & WARWICK ST PA VERIZON ESS MAP MOBILE COMMUNICATIONS PHILADELPHIA 21 S 63 ST PA VERIZON CMC METROCALL ERIE 1324 CHESTNUT ST PA VERIZON CMC METROCALL JOHNSTOWN RESEVOIR PARK RD WESTMONT (CAMBRIA) PA VERIZON D12 NEXTEL AUDUBON 901 JEFFERSON AVE PA VERIZON CMC NEXTEL BRIDGEVILLE 400 BURSCA DR PA VERIZON CMC NEXTEL HARRISBURG 210 PINE ST PA VERIZON CMC NEXTEL PHILA 1818 MARKET ST., FLR 38 PA VERIZON DS PREFERRED NETWORKS PITTSBURGH 1485 CRANE AVE PA VERIZON 5EC SOUTH CANAAN CELLULAR SOUTH CANAAN RT 296 @ BOX 160 COMMUNICATIONS COMPANY PA VERIZON 5E SPRINT PCS PHILADELPHIA 401 N BROAD ST PA VERIZON 5E SPRINT PCS PHILADELPHIA 401 N BROAD ST PA VERIZON 5E SPRINT PCS PITTSBURGH 22 39TH ST PA VERIZON CMC SPRINT PCS PITTSBURGH 22 39TH ST PA VERIZON RSM SYGNET COMMUNICATIONS WEST VIEW 122 BLUEBELLE ST PA VERIZON CMC TERN WIRELESS STROUDSBURG 9 S 7TH ST PA VERIZON DMH VOICESTREAM EPHRATA 130 E MAIN ST PA VERIZON DX2 VOICESTREAM PITTSBURGH 6437 DAHLEM PL.
F-16
Wireless Switches Serving BOC Rate Centers State BOC Region Type CLEC City Street PA VERIZON CMC VOICESTREAM WEST NORRITON 30 S MONTGOMERY AVE RI VERIZON AXT AT&T WIRELESS PROVIDENCE 1 GREENE ST RI VERIZON DMH METROCALL PROVIDENCE 234 WASHINGTON ST RI VERIZON DM2 NEXTEL PROVIDENCE 234 WASHINGTON ST RI VERIZON CMC VOICESTREAM EAST PROVIDENCE 50 CATAMORE BLVD RI VERIZON CMC VOICESTREAM PROVIDENCE 1 GREENE ST SC BELLSOUTH 5E AIRGATE WIRELESS COLUMBIA 411 HUGER ST SC VERIZON GT5 ALLTEL GEORGETOWN 1113 FRONT ST SC VERIZON DCO ALLTEL LAURENS LAURENS CELL SITE RURAL ROUTE 3 OFF SC HWY 14N SC BELLSOUTH CMC ALLTEL NORTH CHARLESTON 4920 APPIAN WAY SC BELLSOUTH CMC ALLTEL PIEDMONT 6931 STHWY 81 SC VERIZON CMC AT&T WIRELESS MYRTLE BEACH 48TH AVE N & HWY 17 SC VERIZON CMC CAROLINA PCS 1 LIMITED PARTNERSHIP COLUMBIA 1426 MAIN ST SC BELLSOUTH CMC CAROLINA PCS 1 LIMITED PARTNERSHIP FLORENCE 224 W CHEVES ST SC VERIZON DS CAROLINA PCS 1 LIMITED PARTNERSHIP GREENVILLE 400 BROOKFIELD PARWAY SC BELLSOUTH CMC METROCALL GREENVILLE 1901 LAURENS RD SC BELLSOUTH DS NEXTEL CHARLESTON 478 E BAY ST SC BELLSOUTH DS NEXTEL COLUMBIA 124 S ASSEMBLY ST SC BELLSOUTH DS NEXTEL GREENVILLE 7N LAURENS ST SC BELLSOUTH CMC SPRINT PCS GREENVILLE 12 LOGUE CT SC BELLSOUTH Z22 TEEPAGE INC. COMMUNICATIONS GREENVILLE 2919 WHITE HORSE RD SC BELLSOUTH CMC TELE-ONE COMMUNICATIONS NORTH AUGUSTA 114 SIDEREAL AVE SC BELLSOUTH CMC TRITON PCS CHARLESTON 185 FAIRCHILD DR SC BELLSOUTH CMC TRITON PCS FLORENCE 224 W CHEVES ST SC BELLSOUTH CMC TRITON PCS IRMO 800 LAKE MURRAY BLVD SC BELLSOUTH CMC TRITON PCS IRMO 800 LAKE MURRAY BLVD SC VERIZON CMC TRITON PCS MYRTLE BEACH 1455 CANNON RD SC VERIZON CMC TRITON PCS MYRTLE BEACH 1455 CANNON ROAD SC BELLSOUTH RSM VOICESTREAM NORTH AUGUSTA 114 SIDEREAL AVE SC VERIZON DMH WEBLINK WIRELESS MYRTLE BEACH 914 E CHESTER ST @ 9TH AVE SD QWEST CMC WESTERN WIRELESS RAPID CITY 2449 W CHICAGO ST SD QWEST CMC WESTERN WIRELESS SIOUX FALLS 2800 W 10TH ST SD QWEST CMC WIRELESS ALLIANCE LLC SIOUX FALLS 2900 W 10TH ST TN BELLSOUTH DC0 ADVANTAGE CELLULAR SYSTEMS SMITHVILLE 104 W BROAD ST TN BELLSOUTH CMC ARCH WIRELESS HOLDINGS KNOXVILLE 425 W DEPOT AVE TN BELLSOUTH CMC AT&T WIRELESS MEMPHIS 4400 S MENDENHALL RD TN BELLSOUTH CMC AT&T WIRELESS MORRISTOWN 1199 SHANNON LITTLE MOUNTAIN RD TN BELLSOUTH CMC CHATTANOOGA MSA LIMITED CHATTANOOGA 5718 LEE HWY PARTNERSHIP TN BELLSOUTH 5E CRICKET COMMUNICATIONS CHATTANOOGA 515 AIRPORT RD TN BELLSOUTH 5EC CRICKET COMMUNICATIONS KNOXVILLE 1828 MIDPARK RD TN BELLSOUTH 5EC CRICKET COMMUNICATIONS MEMPHIS 5425 E RAINES RD TN BELLSOUTH 5E CRICKET COMMUNICATIONS NASHVILLE 770 MELROSE AVE TN BELLSOUTH DS MEMPHIS SMSA LIMITED PARTNERSHIP MEMPHIS 201 COURT AVE TN BELLSOUTH DS METROCALL NASHVILLE 830 FESSLERS PKY TN BELLSOUTH CMC NASHVILLE / CLARKSVILLE MSA NASHVILLE 2627 BRICK CHURCH PIKE LIMITED PARTNERSHIP TN BELLSOUTH DMH NEXTEL NASHVILLE 741 MELROSE AVE TN BELLSOUTH DMS SPRINT PCS MEMPHIS 3087 MILLBRANCH RD TN BELLSOUTH CMC SPRINT PCS NASHVILLE 735 MELROSE AVE TN BELLSOUTH CMC SPRINT PCS NASHVILLE 735 MELROSE AVE
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Wireless Switches Serving BOC Rate Centers State BOC Region Type CLEC City Street TN BELLSOUTH CMC TELEPAK MEMPHIS 2565 HORIZON LAKE DR TN BELLSOUTH DMS TRITEL COMMUNICATIONS CHATTANOOGA 300 E M L KING BLVD TN BELLSOUTH CMC TRITEL COMMUNICATIONS JACKSON 315 E COLLEGE ST TN BELLSOUTH CMC TRITEL COMMUNICATIONS KNOXVILLE 3585 YORKMAN RD TN BELLSOUTH CMC TRITEL COMMUNICATIONS KNOXVILLE 3585 WORKMAN RD TN BELLSOUTH CMC TRITEL COMMUNICATIONS NASHVILLE 698 MELROSE AVE TN BELLSOUTH CMC US CELLULAR CONCORD 707 CONCORD RD TN BELLSOUTH CMC US CELLULAR KNOXVILLE 6525 ASHEVILLE WAY TN BELLSOUTH AXT VOICESTREAM JACKSON 122 RADIO RD TN BELLSOUTH DS VOICESTREAM MEMPHIS 3895 VANTECH DRIVE BLDG. D SUITE 7 TN BELLSOUTH CMC VOICESTREAM NASHVILLE 3800 EZELL RD TN BELLSOUTH CMC WOOD COMMUNICAITONS DBA UNION CITY 417 W REELFOOT AVE CELLPAGE TN BELLSOUTH CMC YORKVILLE TELEPHONE COOPERATIVE YORKVILLE HWY 77 TX VERIZON CMC ALLTEL COPER COVE 5668 CIRCUIT TX VERIZON 5E AT&T WIRELESS AUSTIN 4400 STAGGERBRUSH RD TX VERIZON CMC AT&T WIRELESS BRYAN 500 S WASHINGTON AVE TX VERIZON 5E AT&T WIRELESS DALLAS 4100 BRYAN ST TX VERIZON CMC AT&T WIRELESS DALLAS 13733 NEUTRON RD TX VERIZON CMC AT&T WIRELESS HOUSTON 1407 JEFFERSON ST TX VERIZON CMC AT&T WIRELESS SHERMAN STHWY 11 TX VERIZON CMC AT&T WIRELESS TEXARKANA 1700 ROSEWOOD- KENNEDY TWR #2 TX VERIZON CMC AT&T WIRELESS VICTORIA 202 W GOODWIN AVE TX VERIZON CMC COLEMAN COUNTY SANTA ANNA 215 N 2ND ST TELECOMMUNICATIONS TX VERIZON CMC CT CUBE SAN ANGELO OLD CHRISTOVAL HWY & CO RD TX VERIZON GT5 LINSHAW COMMUNICATIONS SHERMAN 201 N WALNUT ST TX SBC D12 METROCALL FORT WORTH 4801 MATLOCK RD TX SBC AXT METROCALL WICHITA FALLS TANK FARM RD TX SBC 5E METROTEL DALLAS 2605 SHERMAN AV TX VERIZON CMC MID-TEX CELLULAR BROWNWOOD 102 N GREENLEAF ST TX SBC 1AE POKA LAMBRO PCS ODESSA 301 W. 7TH TX SBC DMH S.M.R. SYSTEMS HOUSTON 1310 RICHMOND TX VERIZON CMC SPRINT PCS AUSTIN 10701 METRIC BLVD TX VERIZON DMS SPRINT PCS AUSTIN 10701 METRIC BLVD TX VERIZON DMS SPRINT PCS DALLAS 4939 READING ST TX VERIZON DS SPRINT PCS DALLAS 4939 READING ST TX VERIZON CMC SPRINT PCS DENTON .3 MI E/O HARTLEE FIELD RD & FM 428 TX VERIZON CMC SPRINT PCS FORT WORTH 300 INDUSTRIAL AVE TX VERIZON DMX SPRINT PCS HOUSTON 15413 W VANTAGE PKY TX VERIZON DMS SPRINT PCS LAREDO 201 W DEL MAR BLVD TX VERIZON CMC SPRINT PCS MCALLEN 1400 E UPAS AVE TX VERIZON DMS SPRINT PCS SAN ANTONIO 217 WARREN ST TX VERIZON CMC SPRINT PCS SHERMAN 118 NORTHEAST ST TX SBC DMH STPCS JOINT VENTURE EAGLE PASS 416 N MONROE ST TX SBC 5E STPCS JOINT VENTURE LAREDO 902 SAN EDUARDO TX SBC DMH TELETOUCH COMMUNICATIONS ARLINGTON 312 W ABRAMS TX SBC 1AE TELETOUCH COMMUNICATIONS LONGVIEW 214 E WHALEY TX SBC DMH TELETOUCH COMMUNICATIONS NACOGDOCHES 227 MIMS ST
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Wireless Switches Serving BOC Rate Centers State BOC Region Type CLEC City Street TX VERIZON GT5 TELETOUCH COMMUNICATIONS TEXARKANA 500 OLIVE ST TX VERIZON GT5 US CELLULAR DEL RIO 305 PECAN ST TX VERIZON D12 VOICESTREAM DALLAS 11830 WEBB CHAPEL RD TX VERIZON CMC WCS COMMUNICATIONS SAN ANGELO 320 W 26TH ST TX VERIZON CMC WESTERN WIRELESS SAN ANGELO 2800 ARMSTRONG ST TX VERIZON GT5 WESTERN WIRELESS WESLACO 521 S MISSOURI AVE UT QWEST CMC AT&T WIRELESS LAYTON 1370 N MAIN UT QWEST CMC AT&T WIRELESS OGDEN 2510 WASHINGTON BLVD UT QWEST CMC AT&T WIRELESS PROVO 1150 N 1750 E UT QWEST CMC AT&T WIRELESS SALT LAKE CITY 3100 KENNEDY DR UT QWEST 5EC LEAP WIRELESS INTL WEST VALLEY CITY 2322 PRESIDENTS DR UT QWEST 5ES SPRINT PCS SALT LAKE CITY S ORANGE @ BLDG C UT QWEST DMS100 VOICESTREAM SALT LAKE CITY 1497 S 700 WEST ST VA VERIZON DS ALLTEL CULPEPER 700 US AVE VA VERIZON CMC ALLTEL DANVILLE OLD MT CROSS RD VA VERIZON CMC ALLTEL EMPORIA I 95 VA VERIZON CMC ALLTEL GLOUCESTER 100 FT N/O STHWY 606 & STHWY 615 VA VERIZON CMC ALLTEL LYNCHBURG 3506 MAYFLOWER DR VA VERIZON CMC ALLTEL NORTON EAGLE KNOB VA VERIZON D6E ALLTEL RICHMOND 2501 GOODES BRIDGE VA VERIZON CMC APPALACHIAN CELLULAR GENERAL ROANOKE 1ST & CHURCH ST PARTNERSHIP VA VERIZON AXT AT&T WIRELESS ARLINGTON 900 S WALTER REED DR VA VERIZON 5E AT&T WIRELESS CULPEPER 614 BRANDY RD VA VERIZON DS CFW CELLULAR STAUNTON 123 W FREDERICK AVE VA VERIZON DS NEXTEL FREDERICKSBURG 418 HUDGINS RD VA VERIZON DS NEXTEL RICHMOND 2800 LAUREL BROOK DR VA VERIZON 5E SPRINT PCS FAIRFAX 2720-D PROSPERITY AVE VA VERIZON DS SPRINT PCS STAUNTON 123 W FREDERICK AVE VA VERIZON 5E TRITON PCS FREDERICKSBURG @ JEFFERSON DAVIS HWY & INDUSTRIAL DR VA VERIZON 5E TRITON PCS GLENALLEN 5500 COX RD VA VERIZON AXT TRITON PCS LYNCHBURG 700-06 CHURCH ST VA VERIZON AXT TRITON PCS NORFOLK 1194 AZALEA GARDEN RD VA VERIZON AXT TRITON PCS NORFOLK 1194 AZALEA GARDEN RD VA VERIZON 5E TRITON PCS ROANOKE 2830 NICHOLAS AVE NE VA VERIZON AXT TRITON PCS WINCHESTER 831 GREENWOOD RD VA VERIZON DS US CELLULAR ROANOKE 9 KIRK ST SW VA VERIZON CMC VIRGINIA CELLULAR STAUNTON 1762 ENGLEWOOD DR VA VERIZON 5E VIRGINIA PCS ALLIANCE BLACKSBURG 1309 S MAIN VA VERIZON DS VIRGINIA PCS ALLIANCE BLAIRS 460 CARTER LODGE RD VA VERIZON D12 VIRGINIA PCS ALLIANCE LEXINGTON 102 E WASHINGTON ST VA VERIZON CMC VIRGINIA PCS ALLIANCE NORFOLK 945 NORFOLK SQ VA VERIZON CMC VIRGINIA PCS ALLIANCE RICHMOND 2413 OWNBY LN VA VERIZON DS VIRGINIA PCS ALLIANCE TROUTVILLE 75 SUNSET AVE VA VERIZON DS VIRGINIA PCS ALLIANCE WINCHESTER 3074 MIDDLE RD VA VERIZON DS VOICESTREAM FAIRFAX 2720-D PROSPERITY AVE VA VERIZON DMT WEBLINK WIRELESS FAIRFAX 10431 LEE HWY VA VERIZON 5E WEBLINK WIRELESS NORFOLK 120 BUTE ST VT VERIZON 5E LINCOLN COMMUNICATIONS SOUTH BURLINGTON 2026 WILLISTON RD VT VERIZON CMC PERSONAL COMMUNICATION NETWORK SOUTH BURLINGTON 3 BALDWIN AVE
F-19
Wireless Switches Serving BOC Rate Centers State BOC Region Type CLEC City Street VT VERIZON DX6 RURAL CELLULAR CORP COLCHESTER 1100 MOUNTAIN VIEW DR WA VERIZON CMC AMERICELL EAST WENATCHEE 2.5 MI NW/O CLARK RD SW ON LOWER BADGER MOUNTAIN RD WA QWEST CMC ARCH WIRELESS HOLDINGS SEATTLE 2001 6TH AVE WA QWEST CMC ARCH WIRELESS HOLDINGS SEATTLE 2001 6TH AVE WA QWEST CMC AT&T WIRELESS MILLWOOD 10906 E MARIETTA AVE WA QWEST CMC AT&T WIRELESS SEATTLE 15008 8TH AVE SW WA QWEST CMC AT&T WIRELESS SEATTLE 15008 8TH AVE SW WA QWEST CMC AT&T WIRELESS TACOMA 757 S FAWCETT AVE WA QWEST CMC AT&T WIRELESS YAKIMA 208 W YAKIMA AVE WA VERIZON CMC AT&T WIRELESS EVERETT (PRIMARY CENTER) WA QWEST CMC LEAP WIRELESS INTL SPOKANE 157 S HOWARD ST WA QWEST CMC NEXTEL SEATTLE 2001 6TH AVE WA QWEST CMC NEXTEL TACOMA 616 61ST AVE NE WA QWEST CMC NEXTEL TUMWATER 419 1/2 L47-00-45 L122-54-45 @ 5TH AVE S WA VERIZON CMC NEXTEL EVERETT (PRIMARY CENTER) WA QWEST 5ES SPRINT PCS REDMOND 12208 134 COURT NE WA QWEST CMC SPRINT PCS SEATTLE 2001 6TH AVE WA QWEST 5ES SPRINT PCS SPOKANE E 360 THIRD AVE WA QWEST CMC SPRINT PCS VANCOUVER 1111 MAIN ST WA QWEST 5ES SPRINT PCS E REDMOND 12208 134 COURT N WA QWEST CMC US CELLULAR YAKIMA 215 N 3RD AVE WA QWEST DM5 VOICESTREAM BOTHELL 19807 N CREEK PARKWAY WA VERIZON DM5 VOICESTREAM BOTHELL 19807 N CREEK PARKWAY WI VERIZON CMC AT&T WIRELESS RHINELANDER CTY TRK HWY G WI VERIZON CMC AT&T WIRELESS WAUSAU 2700 STEWART AVE WI VERIZON GT5 BUSINESS SERVICE CENTER WAUSAU 607 WASHINGTON ST WI VERIZON CMC CENTURY TEL WIRELESS DODGEVILLE FIRE #3728 COHWY Z & CELL SITE WI VERIZON CMC EINSTEIN PCS WAUSAU 221 SCOTT ST WI VERIZON CMC SPRINT PCS APPLETON 890 S WESTLAND DR WI VERIZON CMC SPRINT PCS NEW BERLIN 2937 S 166TH ST WI VERIZON CMC US CELLULAR BROOKFIELD 3545 N 124TH ST WI VERIZON CMC US CELLULAR MADISON 4417 HELGESEN DR WI VERIZON CMC US CELLULAR MAUSTON SE1/4 & SE1/4,SEC 13, TWSP 15N, R WI VERIZON CMC US CELLULAR NEW BERLIN 2885 S 166TH ST WI VERIZON CMC US CELLULAR PLOVER 6292 5TH ST WI VERIZON CMC US CELLULAR WAUSAU 2220 GRAND AVE WI VERIZON CMC VOICESTREAM WAUKESHA N19 W24075 RIVERWOOD DR WV VERIZON DS ALLTEL HUNTINGTON 2924 OVERLOOK DR WV VERIZON DS ALLTEL LOGAN WARD ROCK WV VERIZON DS ALLTEL PARKERSBURG WV STATE ROUTE 2 WV VERIZON DS AT&T WIRELESS CULLODEN 2975 BENEDICT RD WV VERIZON 5E AT&T WIRELESS LOGAN AHN 763 WARD ROCK MOUNTAIN WV VERIZON DS AT&T WIRELESS MORGANTOWN 250 SCOTT AVE WV VERIZON DS AT&T WIRELESS PARKERSBURG RT10,BX 169,RIDGE RD WV VERIZON DM5 AT&T WIRELESS WEST UNION 313 LOUISE AVE WV VERIZON DS HIGHLAND CELLULAR BECKLEY 550 N EISENHOWER DR WV VERIZON CMC NEXTEL CLARKSBURG 7 ARMORY RD
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Wireless Switches Serving BOC Rate Centers State BOC Region Type CLEC City Street WV VERIZON 5E RONDALL LAWRENCE DBA MORGANTOWN 145 FAYETTE ST COMMUNICATION CENTER/PAGE 1 WV VERIZON CMC VIRGINIA PCS ALLIANCE CHARLESTON 500 SUMMERS ST WV VERIZON CMC VIRGINIA PCS ALLIANCE CHARLESTON 301 VIRGINIA ST E WV VERIZON CMC VIRGINIA PCS ALLIANCE HUNTINGTON 1122 7TH AVE WY QWEST CMC WESTERN WIRELESS CASPER 334 S WOLCOTT ST WY QWEST CMC WESTERN WIRELESS CHEYENNE 6621 SPEER RD @ S33R67WT13 Source: Telcordia, January 2002 LERG.
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APPENDIX G. COMPETITIVE COLLOCATION PROVIDERS IN THE TOP 50 MSAS
MSA (rank) Competitive Collocation Provider Los Angeles-Long Beach, CA PMSA (1) E-COLO.com [3], Switch & Data, Telehouse America, TelX, Gateway Colo, , Equinix, IX2 Networks [3], Universal Access, ClearBlue New York, NY PMSA (2) AccessColo [2], E-COLO.com [2], Switch & Data [2], Telehouse America [3], ColoSolutions, Equinix, TelX, The Raco Group, Universal Access [3], Fiber Connect, ClearBlue Chicago, IL PMSA (3) E-COLO.com, Switch & Data, Layerone, Core Location, Gateway Colo*, Equinix, Universal Access [2], ClearBlue Philadelphia, PA-NJ PMSA (4) E-COLO.com, Switch & Data Washington, DC-MD-VA-WV PMSA AccessColo*, E-COLO.com [4], Switch & Data [2], ColoSafe[one (5) operational, and one planned], Gateway Colo*, Equinix, Universal Access Detroit, MI PMSA (6) E-COLO.com, Switch & Data, ColoVault Houston, TX PMSA (7) E-COLO.com, MetroNexus Atlanta, GA MSA (8) E-COLO.com, MetroNexus, Switch & Data, Core Location, Gateway Colo*, Collocation Solutions*, 56 Marietta, Universal Access Dallas, TX PMSA (9) E-COLO.com [2], Switch & Data, Layerone, Colo4-Dallas, Gateway Colo*, Collocation Solutions, Equinix, TeleTeam [2], Universal Access, ClearBlue Boston, MA-NH PMSA (10) AccessColo*, COLO.com, E-COLO.com, Switch & Data, Gateway Colo*, Universal Access Riverside-San Bernardino, CA PMSA Digital Internet Services Corp., Linkline Communications, Swiftcomm*, (11) Time Warner Telecom Phoenix-Mesa, AZ MSA (12) E-COLO.com, Switch & Data, ColoVault, Universal Access San Diego, CA MSA (13) E-COLO.com, MetroNexus, Switch & Data Minneapolis-St. Paul, MN-WI MSA (14) E-COLO.com, Switch & Data, Axon Telecom, ColoVault* Orange County, CA PMSA (15) COLO.com, E-COLO.com, The Next Millennium Nassau-Suffolk, NY PMSA (16) St. Louis, MO-IL MSA (17) E-COLO.com, Switch & Data, Axon Telecom, ColoVault* Baltimore, MD PMSA (18) E-COLO.com, ColoCo, Oakland, CA PMSA (19) E-COLO.com [2], ClearBlue Seattle-Bellevue-Everett, WA PMSA E-COLO.com [at least one site], MetroNexus, Switch & Data, Gateway (20) Colo, Apollo Communications, Tres, Universal Access Tampa-St. Petersburg-Clearwater, FL E-COLO.com, Switch & Data, ColoSolutions MSA (21) Pittsburgh, PA MSA (22) E-COLO.com, Switch & Data, ColoSolutions Cleveland-Lorain-Elyria, OH PMSA (23) E-COLO.com, Switch & Data, ColoSolutions Miami, FL PMSA (24) COLO.com, E-COLO.com, Switch & Data, Layerone, Gateway Colo, Universal Access Denver, CO PMSA (25) E-COLO.com, Switch & Data, Gateway Colo*, @lightspeed, Universal Access
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MSA (rank) Competitive Collocation Provider Newark, NJ PMSA (26) E-COLO.com, Gateway Colo Portland-Vancouver, OR-WA PMSA E-COLO.com, Switch & Data, Universal Access, ClearBlue (27) San Francisco, CA PMSA (28) E-COLO.com, Wave Exchange, UPNetworks, Universal Access, ClearBlue Kansas City, MO-KS MSA (29) E-COLO.com, Switch & Data, Axon Telecom [2] San Jose, CA PMSA (30) Wave Exchange, Universal Access, E-COLO.com [at least one site], Switch & Data, Telehouse America, Core Location, Gateway Colo*, Equinix Cincinnati, OH-KY-IN PMSA (31) E-COLO.com FortWorth-Arlington, TX PMSA (32) E-COLO.com ClearBlue Orlando, FL MSA (33) E-COLO.com [2], ColoSolutions [2], ClearBlue Sacramento, CA PMSA (34) E-COLO.com, Switch & Data, Wave Exchange* San Antonio, TX MSA (35) E-COLO.com, ColoSolutions Las Vegas, NV-AZ MSA (36) E-COLO.com, Collocation Solutions Fort Lauderdale, FL PMSA (37) E-COLO.com, Dialtone Internet, Valueweb Indianapolis, IN MSA (38) E-COLO.com, Switch & Data Norfolk-Virginia Beach-Newport News, E-COLO.com VA-NC MSA (39) Milwaukee-Waukesha, WI PMSA (40) E-COLO.com Columbus, OH MSA (41) E-COLO.com, Switch & Data, ColoSolutions, ColoVault* Charlotte-Gastonia-Rock Hill, NC-SC E-COLO.com, Switch & Data, ColoSolutions, ColoVault* MSA (42) Bergen-Passaic, NJ PMSA (43) New Orleans, LA MSA (44) E-COLO.com Salt Lake City-Ogden, UT MSA (45) E-COLO.com [2], Switch & Data Greensboro-Winston Salem-High Point, E-COLO.com NC MSA (46) Nashville, TN MSA (47) E-COLO.com, Switch & Data Austin-San Marcos, TX MSA (48) E-COLO.com, Collocation Solutions Buffalo-Niagara Falls, NY MSA (49) E-COLO.com, The Raco Group Middlesex-Somerset-Hunterdon, NJ Advanticom PMSA (50) Sources: See Appendix M.
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APPENDIX H. HOT-CUT PERFORMANCE
Verizon Hot-Cut Performance: Percent Completed On Time*
Connecticut Delaware
100% 100%
80% 80%
60% 60%
40% 40%
20% 20%
0% 0% Jan-01 Mar-01 May-01 Jul-01 Sep-01 Nov-01 Jan-01 Mar-01 May-01 Jul-01 Sep-01 Nov-01
Maine Maryland
100% 100%
80% 80%
60% 60%
40% 40%
20% 20%
0% 0% Jan-01 Mar-01 May-01 Jul-01 Sep-01 Nov-01 Jan-01 Mar-01 May-01 Jul-01 Sep-01 Nov-01
Massachusetts New Hampshire
100% 100%
80% 80%
60% 60%
40% 40%
20% 20%
0% 0% Jan-01 Mar-01 May-01 Jul-01 Sep-01 Nov-01 Jan-01 Mar-01 May-01 Jul-01 Sep-01 Nov-01
New Jersey New York
100% 100%
80% 80%
60% 60%
40% 40%
20% 20%
0% 0% Jan-01 Mar-01 May-01 Jul-01 Sep-01 Nov-01 Jan-01 Mar-01 May-01 Jul-01 Sep-01 Nov-01
* Data for all Verizon States represent the results for performance measurement PR 9-01 and do not include results for the former GTE service area.
H-1
Verizon Hot-Cut Performance: Percent Completed On Time*
Pennsylvania Rhode Island
100% 100%
80% 80%
60% 60%
40% 40%
20% 20%
0% 0% Jan-01 Mar-01 May-01 Jul-01 Sep-01 Nov-01 Jan-01 Mar-01 May-01 Jul-01 Sep-01 Nov-01
Vermont Virginia
100% 100%
80% 80%
60% 60%
40% 40%
20% 20%
0% 0% Jan-01 Mar-01 May-01 Jul-01 Sep-01 Nov-01 Jan-01 Mar-01 May-01 Jul-01 Sep-01 Nov-01
West Virginia Washington, D.C.
100% 100%
80% 80%
60% 60%
40% 40%
20% 20%
0% 0% Jan-01 Mar-01 May-01 Jul-01 Sep-01 Nov-01 Jan-01 Mar-01 May-01 Jul-01 Sep-01 Nov-01
* Data for all Verizon States represent the results for performance measurement PR 9-01 and do not include results for the former GTE service area.
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Southwestern Bell Telephone Hot-Cut Performance: Percent Completed On Time
Arkansas Kansas
100% 100% 80% 80% 60% 60% 40% 40% 20% 20% 0% 0% Aug-00 Nov-00 Feb-01 May-01 Aug-01 Nov-01 Aug-00 Nov-00 Feb-01 May-01 Aug-01 Nov-01
Missouri Oklahoma
100% 100% 80% 80% 60% 60% 40% 40% 20% 20% 0% 0% Aug-00 Nov-00 Feb-01 May-01 Aug-01 Nov-01 Aug-00 Nov-00 Feb-01 May-01 Aug-01 Nov-01
Texas
100% 80% 60% 40% 20% 0% Aug-00 Nov-00 Feb-01 May-01 Aug-01 Nov-01 Pacific Bell & Nevada Bell Hot-Cut Performance: Percent Completed On Time**
California Nevada
100% 100%
80% 75% 60% 50% 40% 25% 20%
0% 0% Jul-99 Nov-99 Mar-00 Jul-00 Nov-00 Mar-01 Jul-01 Nov-01 Jul-99 Nov-99 Mar-00 Jul-00 Nov-00 Mar-01 Jul-01 Nov-01 * Data for SWBT States represent results for performance measurement 114.1. ** Data for Pacific Bell and Nevada Bell represent results for performance measurement 9.
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Ameritech Hot-Cut Performance: Percent Completed On Time*
Indiana Illinois
100% 100% 80% 80% 60% 60% 40% 40% 20% 20% 0% 0% Aug-00 Nov-00 Feb-01 May-01 Aug-01 Nov-01 Aug-00 Nov-00 Feb-01 May-01 Aug-01 Nov-01
Michigan Ohio 100% 100% 80% 80% 60% 60% 40% 40% 20% 20% 0% 0% Aug-00 Nov-00 Feb-01 May-01 Aug-01 Nov-01 Aug-00 Nov-00 Feb-01 May-01 Aug-01 Nov-01
Wisconsin
100% 80% 60% 40% 20% 0% Aug-00 Nov-00 Feb-01 May-01 Aug-01 Nov-01
* Data for Ameritech States represent results for performance measurement 114.1.
H-4
BellSouth Hot-Cut Performance: Percent Completed On Time*
Alabama Florida
100% 100% 80% 80% 60% 60% 40% 40% 20% 20% 0% 0% Feb-01 Apr-01 Jun-01 Aug-01 Oct-01 Dec-01 Feb-01 Apr-01 Jun-01 Aug-01 Oct-01 Dec-01
Georgia Kentucky**
100% 100% 80% 80% 60% 60% 40% 40% 20% 20% 0% 0% Feb-01 Apr-01 Jun-01 Aug-01 Oct-01 Dec-01 Feb-01 Apr-01 Jun-01 Aug-01 Oct-01 Dec-01
Louisiana Mississippi
100% 100% 80% 80% 60% 60% 40% 40% 20% 20% 0% 0% Feb-01 Apr-01 Jun-01 Aug-01 Oct-01 Dec-01 Feb-01 Apr-01 Jun-01 Aug-01 Oct-01 Dec-01
* Data for BellSouth States represent results for performance measurement P-7. ** There was no hot-cut activity for BellSouth in Kentucky in August 2001.
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BellSouth Hot-Cut Performance: Percent Completed On Time*
North Carolina South Carolina
100% 100% 80% 80% 60% 60% 40% 40% 20% 20% 0% 0% Feb-01 Apr-01 Jun-01 Aug-01 Oct-01 Dec-01 Feb-01 Apr-01 Jun-01 Aug-01 Oct-01 Dec-01
Tennessee
100% 80% 60% 40% 20% 0% Feb-01 Apr-01 Jun-01 Aug-01 Oct-01 Dec-01
* Data for BellSouth States represent the results for performance measurement P-7.
H-6
Qwest Hot-Cut Performance: Percent Completed On Time*
Arizona Colorado
100% 100% 80% 80% 60% 60% 40% 40%
20% 20%
0% 0% May-00 Aug-00 Nov-00 Feb-01 May-01 Aug-01 Nov-01 May-00 Aug-00 Nov-00 Feb-01 May-01 Aug-01 Nov-01
Idaho Iowa
100% 100% 80% 80% 60% 60% 40% 40% 20% 20% 0% 0% May-00 Aug-00 Nov-00 Feb-01 May-01 Aug-01 Nov-01 May-00 Aug-00 Nov-00 Feb-01 May-01 Aug-01 Nov-01
Minnesota Montana
100% 100% 80% 80% 60% 60% 40% 40% 20% 20% 0% 0% May-00 Aug-00 Nov-00 Feb-01 May-01 Aug-01 Nov-01 May-00 Aug-00 Nov-00 Feb-01 May-01 Aug-01 Nov-01
Nebraska New Mexico
100% 100% 80% 80% 60% 60% 40% 40% 20% 20% 0% 0% May-00 Aug-00 Nov-00 Feb-01 May-01 Aug-01 Nov-01 May-00 Aug-00 Nov-00 Feb-01 May-01 Aug-01 Nov-01
* Data for Qwest States represent the combined results for performance measurements OP-13A – Analog and OP-13A – Other.
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Qwest Hot-Cut Performance: Percent Completed On Time*
North Dakota Oregon
100% 100% 80% 80% 60% 60% 40% 40% 20% 20% 0% 0% May-00 Aug-00 Nov-00 Feb-01 May-01 Aug-01 Nov-01 May-00 Aug-00 Nov-00 Feb-01 May-01 Aug-01 Nov-01
South Dakota Utah
100% 100% 80% 80% 60% 60% 40% 40% 20% 20% 0% 0% May-00 Aug-00 Nov-00 Feb-01 May-01 Aug-01 Nov-01 May-00 Aug-00 Nov-00 Feb-01 May-01 Aug-01 Nov-01
Washington Wyoming
100% 100% 80% 80% 60% 60% 40% 40% 20% 20% 0% 0% May-00 Aug-00 Nov-00 Feb-01 May-01 Aug-01 Nov-01 May-00 Aug-00 Nov-00 Feb-01 May-01 Aug-01 Nov-01
* Data for Qwest States represent the combined results for performance measurements OP-13A – Analog and OP-13A – Other.
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APPENDIX I. CLECS PROVIDING ATM AND FRAME RELAY
CLEC Service: Market Adelphia ATM/Frame Relay: Albany, Buffalo, New York, Rome, and Syracuse, NY; Allentown, Altoona, Bethlehem, Easton, Erie, Harrisburg, Lancaster, Philadelphia, Pittsburgh, Reading, Scranton, State College, Wilkes-Barre, and York, PA; Boston, MA Chicago, IL; Cincinnati, Cleveland, and Columbus, OH; Fresno, Los Angeles, and San Francisco, CA; Hartford, CT; Kansas City, MO; Little Rock, AR; Wichita, KS; Albany, Atlanta and Savannah, GA; Austin, Dallas, Houston, and San Antonio, TX; Baltimore and Hagerstown, MD; Baton Rouge, Lafayette, New Orleans, and Shreveport, LA; Birmingham and Mobile AL; Boise, ID; Camden, Parsippany, and Piscataway, NJ; Charleston, Columbia, and Greenville, SC; Charlotte and Raleigh, NC; Charlottesville, Danville, Fairfax, Harrisonburg, Richmond, Roanoke, and Winchester, VA; Denver, CO; Des Moines, IA; Detroit, MI; Fort Lauderdale, Jacksonville, Miami, Orlando, and Tampa, FL; Fort Wayne and Indianapolis, IN; Jackson, MS; Knoxville and Nashville, TN; Montpellier, VT; Phoenix, AZ; Portland, OR; Seattle and Vancouver, WA; Washington, DC; Wilmington, DE Allegiance ATM/Frame Relay: Detroit, MI; Chicago, Naperville, Northbrook, Oak Brook, Schaumburg, and Winnetka, IL; Brookfield, Madison, and Oshkosh, WI; White Plains, NY. ATM: Baltimore, MD; Boston, MA; New York, NY; Newark and Rutherford, NJ; Philadelphia and Pittsburgh, PA; Washington, DC; Austin, Dallas, Fort Worth, Houston, and San Antonio, TX; Bridgeton, Kirkwood, and St. Charles, MO; Oakland, Sacramento, San Diego, and San Francisco, CA; Atlanta, GA; Cincinnati, OH; Denver, CO; Fort Lauderdale, Miami, Saint Petersburg, and Tampa, FL; Minneapolis and Saint Paul, MN; Seattle, WA ALLTEL ATM: Augusta and Savannah, GA; Bentonville, Cabot, Conway, Fayetteville, Fort Smith, Jacksonville, Little Rock, North Little Rock, Rogers, Russellville, Sherwood, and Springdale, AR; Cary, Chapel Hill, Durham, Greensboro, Raleigh, and Winston-Salem, NC; Charleston, Columbia, Greenville, and Spartanburg, SC; Clarion, PA; Fremont, Grand Island, Kearney, and Omaha, NE; Gainesville, Jacksonville, Mandarin, and Tallahassee, FL; Hampton, Newport News, Norfolk, Portsmouth, Richmond, and Virginia Beach, VA; Montgomery, AL; Springfield, MO; Toledo, OH Arbros ATM/Frame Relay: Washington, DC; Boston, MA; Baltimore and Landover, MD; Newark, NJ; New York, NY; Harrisburg, Philadelphia and Pittsburgh, PA; Alexandria, Arlington, Norfolk, and Richmond, VA AT&T ATM/Frame Relay: Baltimore, MD; Newark, NJ; Manhattan, NY; Providence, RI; Alexandria, VA; Austin, Dallas, and Houston, TX; Chicago, IL; Cincinnati, and Columbus, OH; Detroit, MI; Hartford, CT; Indianapolis, IN; Anaheim, San Diego, and San Francisco, CA; Atlanta, GA; Birmingham, AL; Charlotte, NC; Knoxville and Nashville, TN; Denver, CO; Fort Lauderdale, Miami, and Tampa, FL; Waukesha, WI; Minneapolis and Saint Paul, MN; Omaha, NE; Seattle, WA
I-1
CLEC Service: Market ATG ATM/Frame Relay: Reno, NV; Bend, Klamath Falls, and Portland, OR; Bellingham and Yakima, WA. ATM: Carson City and Sparks, NV; Corte Madera, Ignacio, Larkspur, Mill Valley, Napa, Novato, Petaluma, Rohnert Park, San Rafael, and Santa Rosa, CA; Greenwich, Norwalk, and Stamford, CT; Albany, Ashland, Astoria, Baker City, Corvallis, Cottage Grove, Dallas, Eugene, Grant’s Pass, Independence, Kaiser, Lake Oswego, Madras, Medford, Milwaukie, Monmouth, Newport, Oregon City, Pendleton, Prineville, Redmond, Roseburg, Salem, Springfield, Sunriver, and Woodburn, OR; Atwater, Bellevue, Bothell, Cherry, Duwamish, East Seattle, Elliot, Everett, Fife, Lacy, Lakewood, Marysville, Mount Vernon, Olympia, Puyallup, Tacoma, and Walla Walla, WA; Bethesda, Chevy Chase, Cockeysville, Frederick, Gaithersburg, Germantown, Hagerstown, Owings Mill, Rockville, and Towson, MD; Broomfield, Fort Collins, Lafayette, Longmont, Louisville, Loveland, and North Glenn, CO; Ewing, Hamilton Township, Lawrence, Plainsboro, Princeton, Trenton, and West Windsor, NJ; Centerville, Chantilly, Fairfax, Herndon, Manassas, and Reston, VA; Farmingdale, Floral Park, Freeport, Garden City, Hempstead, Hicksville, Levittown, Lynbrook, Mamaroneck, Massapequa, Mineola, Mount Vernon, New Rochelle, Port Chester, Uniondale, Wantagh, Westbury, White Plains, and Yonkers, NY Bay Ring ATM/Frame Relay: Dover, ME; Hampton and Portsmouth, NH Communications Birch Telecom ATM: Abilene, Amarillo, Austin, Beaumont, Corpus Christi, Dallas, El Paso, Fort Worth, Houston, Longview/Marshall, Lubbock, Midland/Odessa, San Antonio, Tyler, Waco, and Wichita Falls, TX; Kansas City, St. Joseph, and St. Louis, MO; Topeka and Wichita, KS; Oklahoma City and Tulsa, OK; Atlanta and Augusta, GA; Mobile and Montgomery, AL; Knoxville and Nashville, TN Broadslate ATM: Allentown and Harrisburg, PA; Richmond and Tidewater, VA; Cincinnati and Dayton, OH Broadview ATM: Boston, MA; Albany, Buffalo, Long Island City, New York, and Syracuse NY; Horsham and Philadelphia, PA BTI ATM/Frame Relay: Atlanta, GA; Charlotte and New Bern, NC; Miami, FL. Frame Relay: Philadelphia, PA; Norfolk and Richmond, VA; Dallas, TX; Chattanooga, Greensboro, Greenville, and Rocky Mount, NC; Charleston, Columbia, and Greenville, SC; Fort Lauderdale, Jacksonville, Orlando, Tallahassee, and Tampa, FL; Knoxville and Nashville, TN; Louisville, KY; Philadelphia, PA; Washington, DC Buckeye Tel. ATM/Frame Relay: Bowling Green, Fremont, Sandusky, and Toledo, OH Choice One ATM/ Frame Relay: Springfield and Worcester, MA; Portsmouth and Manchester, NH; Albany, Buffalo, Rochester and Syracuse, NY; Allentown, Harrisburg, Pittsburgh, and Scranton/Wilkes-Barre, PA; Providence, RI; Akron, Columbus, and Dayton, OH; Appleton, Green Bay, Madison, Milwaukee, Oshkosh, WI; Bloomington, Elkhart, Evansville, Fort Wayne, Indianapolis, and South Bend, IN; Ann Arbor, Grand Rapids, Kalamazoo, Lansing, MI; Hartford and New Haven, CT; Rockford, IL Coast to Coast ATM: Ann Arbor, Detroit, Flint, Grand Rapids, Lansing, Livonia, Pontiac, Port Huron, and Troy, MI Comcast Frame Relay: Anne Arundel County and Prince George’s County, MD; Alexandria and Prince Business William County, VA Communications CoreComm ATM/Frame Relay: Camden, NJ; Philadelphia, PA; Chicago, IL; Cleveland and Columbus, (ATX) OH Cox ATM/Frame Relay: Providence and West Warwick, RI; Hampton Roads and Roanoke, VA; Hartford and Meriden, CT; Las Vegas, NV; Oklahoma City, OK; Orange County, San Diego, and Santa Barbara, CA; Atlanta, GA; New Orleans, LA; Gainesville and Pensacola, FL; Omaha, NE; Phoenix and Tucson, AZ
I-2
CLEC Service: Market CTC ATM/Frame Relay: Boston, Braintree, Danvers, Lexington, Manchester, Marlboro, North Attleboro, Springfield, Waltham and West Springfield, MA; Bangor and Portland, ME; Bedford, NH; Albany, Elmsford, Melville, Nanuet, New York, Syosset and Yorktown Heights, NY; Burlington, VT; Fairfield and Meriden, CT CTC Telcom ATM/Frame Relay: Barron, Chetek, and Rice Lake, WI CTSI ATM: Harrisburg and Wilkes-Barre, PA Digital Teleport ATM/Frame Relay: Little Rock, AR; Oklahoma City, OK; St. Louis, MO; Memphis, TN; . Frame Relay: Jefferson City and Kansas City, MO e.spire ATM/Frame Relay: Albuquerque, NM; Amarillo, Dallas, El Paso, and Fort Worth, TX; Communications Columbus, GA; Baltimore, MD; Baton Rouge and New Orleans, LA; Birmingham, Mobile, and Montgomery, AL; Charleston, Columbia, and Greenville, SC; Fort Lauderdale, Fort Myers, Jacksonville, Miami, Orlando, Tallahassee, and Tampa, FL; Jackson, MS; Las Vegas, NV; Lexington and Louisville, KY; Little Rock, AR; Philadelphia, PA; Phoenix and Tucson, AZ; Richmond, VA. ATM: San Antonio, TX Electric ATM/Frame Relay: Washington, DC; Austin, Dallas and Houston, TX; Chicago, IL; Lightwave Cleveland, OH; Elk Grove, Fair Oaks, Los Angeles, Roseville, Sacramento, San Diego, San Francisco, and Wabash, CA; Las Vegas, NV; Aloha, Beaverton, Eugene, Gresham, Hillsboro, Milwaukee, Portland, Salem, Tigard, and Wilsonville, OR; Atlanta, GA; Bellevue, Bothell, Kirkland, Olympia, Orchards, Redmond, Renton, Seattle, Spokane, Tacoma, and Vancouver, WA; Boise, ID; Chandler, Deer Valley, Holbrook, Kingman, Phoenix, Scottsdale, and Tempe, AZ; Denver, CO; Murray, Ogden, Orem, Provo, Salt Lake City, and Tremonton, UT; New York, NY, Philadelphia, PA Eschelon ATM: Denver, CO; Saint Paul, MN Telecom Fairpoint ATM: Augusta, ME; Bellingham, Olympia, and Yakima, WA; Bloomsburg, Erie, Hazelton, Lock Haven, and Williamsport, PA; Dallas, TX; East Greenbush, New York, and Yakim, NY; Lebanon and Manchester, NH; Morgantown, WV; Springfield, MA Fibernet ATM/Frame Relay: New York, NY; Chicago, IL; Los Angeles, CA Telecom Fidelity ATM: Rolla, MO Communication Services Florida Digital ATM: Clearwater, Cocoa Beach, Daytona Beach, De Land, Fort Lauderdale, Gainesville, Network Jacksonville, Jacksonville Beach, Jupiter, Lake Mary, Melbourne, Miami, Orlando, Oviedo, Port Orange, Saint Augustine, Saint Petersburg, Sanford, Seminole, Stuart, Tampa, Titusville, West Palm Beach, and Winter Park, FL Focal ATM: Washington, DC; Boston, MA; Baltimore, MD; Camden, Jersey City, New Brunswick, Newark and Rochelle Park, NJ; New York and White Plains, NY; Philadelphia, PA; Arlington and Northern Virginia, VA; Chicago, IL; Cleveland, OH; Dallas, Fort Worth, and Houston, TX; Detroit, MI; Los Angeles, Oakland, Orange County, San Diego, San Francisco, and San Jose, CA; St. Louis, MO; Atlanta, GA; Minneapolis, MN; Seattle, WA General ATM/Frame Relay: Anchorage, Fairbanks and Juneau, AK Communications Global Crossing ATM/Frame Relay: Washington, DC; Boston, MA; Baltimore, MD; New York and Rochester, NY; Philadelphia and Pittsburgh, PA; Akron, Cincinnati, and Cleveland, OH; Chicago, IL; Dallas, TX; Kansas City, MO; Los Angeles, San Diego, and San Francisco, CA; Milwaukee, WI; Atlanta, GA; Denver, CO; Milwaukee, WI; Minneapolis, MN; Tampa, FL; Portland, OR; Seattle, WA. Frame Relay: Columbus, OH; El Paso, TX; Springfield, MO. ATM: Indianapolis, IN; Topeka, KS; Sacramento, CA; Phoenix, AZ
I-3
CLEC Service: Market Global NAPs ATM: Atlanta, GA; Baltimore, MD; Brattleboro, VT; Manchester, NH; Manhattan and Poughkeepsie, NY; Miami and Orlando, FL; New Haven, CT; Newark, DE; Newark, NJ; Philadelphia, PA; Providence, RI; Quincy and Springfield, MA; Reston, VA Globalcom ATM/Frame Relay: New York, NY; Chicago, IL; Dallas, TX; Los Angeles, CA; Atlanta, GA Grande Comm. ATM/Frame Relay: San Marcos, TX. HickoryTech Frame Relay: New Richland, Saint Peter, and Waseca, MN ICG ATM: Anaheim, Burbank, Inglewood, Los Angeles, Ontario, and Oxnard, CA Communications Integra Telecom ATM: Baxter, Minneapolis, and Prior Lake, MN; Beaverton, Hillsboro, Portland, and Salem, OR; Kent, WA; Salt Lake City, UT IP ATM: Abilene, Amarillo, Austin, Beaumont, Corpus Christi, Dallas, El Paso, Fort Worth, Communications Galveston, Houston, Laredo, Longview, Lubbock, McAllen/Harlingen/Brownsville, Midland/Odessa, Orange, Port Arthur, San Antonio, Temple, Texas City, Tyler, Victoria, Waco, and Wichita Falls, TX; Dodge City, Kansas City, Topeka, and Wichita, KS; Kansas City, Springfield, and St. Louis, MO; Lawton, Norman, Oklahoma City, and Tulsa, OK ITC^DeltaCom ATM/Frame Relay: Austin, Beaumont, Bryan, Dallas, Houston, Longview, and San Antonio, TX; Little Rock and Pine Bluff, AR; Albany, Athens, Atlanta, Augusta, Columbus, Gainesville, Hartwell, La Grange, Macon, Newnan, Rome, Savannah, Valdosta, and West Point, GA; Alexander City, Anniston, Arab, Birmingham, Dothan, Gadsden, Huntsville, Mobile, Montgomery, Opelika, and Tuscaloosa, AL; Asheville, Charlotte, Concord, Fayetteville, Greensboro, High Point, Jacksonville, Jefferson, Laurinburg, Lexington, Raleigh, Rocky Mount, Wilmington, and Winston-Salem, NC; Baton Rouge, Lafayette, Lake Charles, Monroe, New Orleans, Shreveport, and West Monroe, LA; Beaufort, Charleston, Columbia, Florence, Greenville, Hilton Head Island, Myrtle Beach, Orangeburg, Spartanburg, and Sumter, SC; Bradenton, Cocoa, Daytona Beach, Fort Lauderdale, Fort Myers, Gainesville, Hollywood, Jacksonville, Melbourne, Ocala, Orlando, Panama City, Pensacola, Port Charlotte, Saint Augustine, Sarasota, Tallahassee, Tampa, Vero Beach, and West Palm Beach, FL; Chattanooga, Memphis, and Nashville, TN; Gulfport, Jackson, Hattiesburg, Meridian, and Vicksburg, MS KMC Telecom ATM/Frame Relay: Akron, Dayton, and Toledo, OH; Ann Arbor and Lansing, MI; Corpus Christi and Longview, TX; Augusta and Savannah, GA; Baton Rouge, Monroe, and Shreveport, LA; Charleston, Columbia, and Spartanburg, SC; Chattanooga, TN; Daytona Beach, Fort Meyers, Greater Pinellas, Pensacola, Sarasota, and Tallahassee, FL; Eden Prairie, MN; Fayetteville, Greensboro, and Winston-Salem, NC; Fort Wayne, IN; Hampton Roads and Roanoke, VA; Huntsville and Montgomery, AL; Madison, WI; Topeka, KS Knology ATM: Augusta, Columbus, Evans, Forest Hills, Grovetown, Martinez, Midland, and West Broadband Point, GA; Charleston, Ladson, Mount Pleasant, and Summerville, SC; Harvest, Huntsville, Lanett, Madison, Maxwell Air Force Base, Montgomery, Pike Road, Prattville, Redstone Arsenal, and Valley, AL; Lynn Haven, Panama City, and Panama City Beach, FL LecStar ATM: Atlanta, GA Communications Lightship Frame Relay: Waltham and Worcester, MA; Portland, ME; Atlantic County and Mercer Telecom County, NJ; Buck County, Chester County and Montgomery, PA; Burlington, VT; Manchester, NH Lightyear ATM/Frame Relay: Boston, MA; Baltimore, MD; Newark, NJ; New York, NY; Anaheim, San Diego, and San Francisco, CA; Chicago, IL; Cincinnati and Cleveland, OH; Dallas and Houston, TX; Detroit, MI; Indianapolis, IN; Kansas City and St. Louis, MO; Atlanta, GA; Denver, CO; Jacksonville and Miami, FL; Lexington and Louisville, KY; Phoenix, AZ; Seattle, WA
I-4
CLEC Service: Market Log On America Frame Relay: Portland, ME; Providence, RI Logix ATM/Frame Relay: Amarillo, TX; Tulsa, OK. ATM: Austin, Corpus Christi, Dallas, Houston, Lubbock, San Antonio and Wichita Falls, TX; Kansas City and Wichita, KS; Little Rock, AR; Oklahoma City, OK; St. Louis and Springfield, MO Madison River ATM: Atlanta, GA; Biloxi, MS; Chapel Hill, Durham, Greensboro, and Winston-Salem, NC; Dallas and Houston, TX; New Orleans, LA; Pensacola, FL; Peoria, IL McLeodUSA ATM/Frame Relay: Aberdeen, Canton, Centerville, Harrisburg, Madison, Pierre, Rapid City, Sioux Falls, Tea, Viborg, and Watertown, SD; Albuquerque, NM; Ames, Boone, Burlington, Cedar Rapids, Charles City, Clinton, Council Bluffs, Davenport, Decorah, Des Moines, Dubuque, Iowa City, Marshall Town, Mason City, Ottumwa, Sioux City, Spencer, Storm Lake, and Waterloo, IA; Appleton, Burke, Eau Claire, Green Bay, Janesville, Madison, Milwaukee, Oshkosh, Racine, and Sheboygan, WI; Bartonville, Belleville, Bloomington, Champaign, Chicago, Chicago (North), Chicago (South) Collinsville, Danville, Decatur, East Peoria, Effingham, Kankakee, Mattoon, Naperville, Pekin, Peoria, Peoria Heights, Quincy, Springfield, and Sterling, IL; Bellevue, Richland, Seattle, Spokane, and Tukwila, WA; Bismarck, Fargo, and Grand Forks, ND; Bloomington Township, Center Township, Evansville, Fishers, Indianapolis, Marion, Merrillville, South Bend, and Terre Haute, IN; Boise, ID; Boulder, Canon City, Colorado Springs, Denver, Ft. Collins, Greeley, Pueblo, and Sterling, CO; Cape Girardeau, Joplin, Kansas City, Springfield, and St. Louis, MO; Cleveland, Columbus, Dayton, Steubenville, Youngstown, and Zanesville, OH; Eugene, Portland, and Salem, OR; Marshall, Minneapolis, St. Cloud, St. Paul, and Winona, MN; Omaha, NE; Phoenix, and Tucson, AZ; Provo, Salt Lake City, and Taylorsville, UT Mid-Maine Frame Relay: Auburn, Augusta, Bangor, Brewer, Cumberland, Ellsworth, Lewiston, Lincoln Counties, Portland, Sagadahoc, Waterville and York, ME Mid-Rivers Frame Relay: Fairview, Glendive, Miles City, Sidney, Sidney, Terry, and Wibaux, MT; East Fairview, ND MFN ATM/Frame Relay: Washington, DC; Wilmington, DE; Bedford, Boston, Cambridge, Lexington, Medford, Netwon, Waltham, Wellesley and Woburn, MA; Bethesda, Chevy Chase, College Park, Rockville and Silver Spring, MD; Garden City, Morristown, New Brunswick, Newark, Paramus, Parsippany, Piscataway, Princeton and Whippany, NJ; Brookhaven, Hauppage, Long Island, New York, Nyack, Shirley and White Plains, NY; Bala Cynwyd, King of Prussia, Malvern, Paoli, Philadelphia and Radnor, PA; Alexandria, Arlington, Fairfax, McLean, Reston, Tyson’s Corner and Vienna, VA; Alameda, Anaheim, Berkley, Brisbane, Burbank, Century City, Costa Mesa, Culver City, El Segundo, Glendale, Irvine, Long Beach, Los Angeles, Newport Beach, Oakland, Orange, San Francisco, San Jose, San Mateo, Santa Clara, Santa Monica, and Tustin, CA; Arlington, Dallas/Ft Worth, Galleria, Greenspoint, Houston, Irving, Las Colinas, and Richardson, TX; Arlington Heights, Chicago, Des Plaines, Downers Grove, Elk Grove Village, Franklin Park, Hinsdale, Hoffman Estates, Naperville, Oak Brook, Rosemont, and Schaumburg, IL; Atlanta, Burlington, Chamblee-Doraville, Fair Oaks, Marietta, Norcross, Northeast Cobb, Roswell-Alpharetta, Smyrna, and Vinings, GA; Bellevue, Kirkland, Redmond, Renton, and Seattle, WA; Bridgeport, New Haven, and Stamford, CT; Cleveland, OH; Denver, CO; Detroit, MI; Miami, FL; St. Louis, MO; Chandler, Glendale, Guadalupe, Paradise Valley, Phoenix, and Tempe, AZ MP Telecom ATM: Superior, WI; Babbitt, Brainerd, Duluth, Ely, Eveleth, Grand Rapids, Hibbing, Hinckley, Minneapolis, Saint Cloud, Saint Paul, and Winona, MN Mpower ATM: Ann Arbor and Detroit, MI; Austin, Dallas, Fort Worth, Houston, and San Antonio, TX; Chicago and Wheeling, IL; Cleveland and Columbus, OH; Las Vegas, NV; La Mesa, Long Beach, Los Angeles, Oakland, Ontario, Orange County, Palm Springs, Pomona, Sacramento, San Diego, San Fernando Valley, San Francisco, and San Jose, CA; Milwaukee, WI; Atlanta, GA; Boca Raton, Fort Lauderdale, Miami, and Tampa, FL; Memphis, TN
I-5
CLEC Service: Market NEON Optica ATM/Frame Relay: Washington, DC; Boston, Cambridge, Framingham, Lawrence, Northfield, Springfield and Worcester, MA; Baltimore, MD; Portland, ME; Dover, Keene, Manchester, Nashua and Portsmouth, NH; Newark, NJ; New York and White Plains, NY; Philadelphia, PA; Green Hill and Providence, RI; Bridgeport, Hartford, New Haven, New London, and Stamford, CT Net2000 ATM/Frame Relay: Baltimore, MD; Boston, MA; Long Island and New York, NY; Newark, NJ; Norfolk and Richmond, VA; Providence, RI; Washington, DC New Edge ATM/Frame Relay: Abilene, Amarillo, Beaumont, Brownsville, Bryan, Copperas Cove, Networks Corpus Christi, El Paso, Edinburg, Harlingen, Killeen, Laredo, Longview, Lubbock, Marshall, Mcallen, Midland, Mission, Nederland, Odessa, Pharr, Port Arthur, Sherman, Temple, Tyler, Victoria, Waco, and Wichita Falls, TX; Apple Valley, Arroyo Grande, Atascadero, Atwater, Auburn, Bakersfield, Banning, Baywood Park, Beaumont, Calimesa, Carlsbad, Carmel, Carpinteria, Chico, Davis, Eureka, Fairfield, Fallbrook, Fresno, Goleta, Grass Valley, Hanford, Hesperia, Lodi, Lompoc, Madera, Manteca, Marina, Marysville, Merced, Modesto, Monterey, Morro Bay, Murrieta, Oakdale, Oroville, Palm Desert, Palm Springs, Paradise, Paso Robles, Perris, Placerville, Porterville, Rancho Mirage, Red Bluff, Redding, Salinas, San Luis Obispo, San Marcos, Santa Barbara, Santa Maria, Seaside, Shingle Springs, Sonora, South Tahoe, Stockton, Sun City, Tracy, Tulare, Turlock, Vacaville, Valley Center, Victorville, Visalia, Vista, Watsonville, Woodland, Yuba City, and Yucaipa, CA; Bay City, Benton Harbor, Charlotte, East Lansing, Grand Haven, Holland, Hollister, Holt, Hudsonville, Jackson, Kalamazoo, Lansing, Midland, Niles, Okemos, Oshtemo, Port Huron, Portage, Saginaw, St. Joseph, and Traverse City, MI; Broken Arrow, Claremore, Lawton, Muskogee, Sapulpa, Tulsa, OK; Cabot, Fayetteville, Fort Smith, Jacksonville, Little Rock, Rogers, Russellville, and Springdale, AR; St. Joseph, MO; Carson City, Reno, Sparks, and Sun Valley, NV; De Pere, Green Bay, Madison, Neenah, Sheboygan, and Stoughton, WI; El Dorado, Hutchinson, Manhattan, Salina, and Wichita, KS; Findlay, Holland, Maumee, Middletown, Perrysburg, and Toledo, OH; Kokomo, Lafayette, Michigan City, Mishawaka, and South Bend, IN; Albany, Ashland, Bend, Corvallis, Eugene, Grants Pass, Keizer, Klamath Falls, Mcminnville, Medford, Milwaukie, Newberg, Redmond, Roseburg, Salem, and Springfield, OR; Albuquerque, Farmington, Las Cruces, and Santa Fe, NM; American Fork, Brigham City, Cedar City, Clearfield, Kaysville, Logan, Ogden, Orem, Pleasant Grove, Provo, Springville, and St. George, UT; Battle Ground, Bremerton, Camas, Federal Way, Graham, Kennewick, Lacey, Longview, Olympia, Pasco, Port Angeles, Port Townsend, Poulsbo, Pullman, Sequim, Shelton, Silverdale, Spokane, Tacoma, Vancouver, Walla Walla, and Yakima, WA; Ankeny, Cedar Rapids, Davenport, Des Moines, Iowa City, Sioux City, and Waterloo, IA; Anoka, Austin, Bemidji, Blaine, Brainerd, Duluth, Owatonna, Rochester, Shoreview, St. Cloud, and Winona, MN; Aspen, Breckinridge, Carbondale, Durango, Ft Collins, Grand Junction, Glenwood Springs, Greeley, Loveland, Pueblo, Steamboat Springs, and Table Mesa, CO; Augusta, GA; Billings, Bozeman, Butte, Great Falls, Helena, and Missoula, MT; Boise, Caldwell, Coeur D’Alene, Eagle, Idaho Falls, Hayden Lake, Lewiston, Meridian, Moscow, Nampa, Pocatello, Post Falls, Rexburg, and Twin Falls, ID; Bonita Springs, Cape Coral, Cocoa, Cocoa Beach, Daytona Beach, Deland, Destin, Fort Myers, Fort Pierce, Fort Walton Beach, Gainesville, Gulf Breeze, Hobe Sound, Hudson, Jensen Beach, Jupiter, Lakeland, Lehigh Acres, Lynn Haven, Marco Island, Melbourne, Milton, Naples, New Port Richey, New Smyrna Beach, Ocala, Ormond Beach, Pace, Panama City, Pensacola, Plant City, Port Charlotte, Port St. Lucie, Punta Gorda, Sebastian, St. Augustine, Stuart, Tallahassee, Tarpon Springs, Titusville, Vero Beach, and Winter Haven, FL; Bossier City and Shreveport, LA; Casper, Cheyenne, Gillette, Jackson, and Laramie, WY; Fargo, Grand Forks and West Fargo, ND; Flagstaff, Green Valley, Prescott, Sierra Vista, Tucson, and Yuma, AZ; Columbus, Fremont, Kearney, and Omaha, NE; Rapid City, Sioux Falls, SD NAS ATM/Frame Relay: Washington, DC; Boston, MA; Baltimore, MD; New York, NY; Philadelphia and Pittsburgh, PA; Norfolk and Richmond, VA; Wilmington, DE
I-6
CLEC Service: Market Northland Frame Relay: Auburn, Binghamton, Elmira, Ithaca, Rochester, Rome, Syracuse and Utica, NY NewSouth ATM/Frame Relay: Alpharetta, Atlanta, Augusta, Jonesboro, Macon, Peachtree City, and Communications Savannah, GA; Charlotte, Greensboro, Hickory, Raleigh, and Winston-Salem, NC; Baton Rouge, Lafayette, and New Orleans, LA; Biloxi and Jackson, MS; Birmingham, Huntsville, Mobile, and Montgomery, AL; Charleston, Columbia, Greenville, and Myrtle Beach, SC; Chattanooga, Knoxville, Memphis, and Nashville, TN; Daytona Beach, Destin, Fort Myers, Jacksonville, Melbourne, Miami, Orlando, Panama City, Pensacola, Sarasota, Tallahassee, Tampa, and Winter Haven, FL; Lexington, and Louisville, KY NTELOS ATM/Frame Relay: Harrisonburg, Lynchburg, Martinsville, New River Valley, Roanoke, Staunton and Waynesboro, VA; Charleston, Clarksburg, Fairmont, and Morgantown, WV. Frame Relay: Huntington, WV NTS Comm. ATM/Frame Relay: Abilene, Amarillo, Dallas, Louisville, Lubbock, Midland/Odessa, Pampa, Plainview, San Angelo, San Antonio, and Wichita Falls, TX; Albuquerque, NM; Phoenix and Tucson, AZ NuVox ATM: Akron, Cincinnati, Columbus, and Dayton, OH; Indianapolis, IN; Kansas City and Wichita, KS; Little Rock, AR; Oklahoma City and Tulsa, OK; St. Louis and Springfield, MO; Atlanta, GA; Burlington, Charlotte, Greensboro, Raleigh, Wilmington, and Winston-Salem, NC; Columbia, Greenville, and Spartanburg, SC; Knoxville, Memphis, and Nashville, TN; Fort Lauderdale, Jacksonville, and Miami, FL; Lexington and Louisville, KY Pac-West ATM/Frame Relay: Bakersfield, Chico, Fresno, Los Angeles, Oakland, Palm Springs, Sacramento, Salinas, San Diego, San Jose, San Luis Obispo, Santa Barbara, and Stockton, CA; Las Vegas and Reno, NV; Denver, CO; Phoenix, AZ; Portland, OR; Seattle and Tukwila, WA; West Valley City, UT Penn Telecom ATM/Frame Relay: Butler, Cranberry, Gibsonia, Perrysville, Pittsburgh and Sewickley, PA Pine Tree ATM/Frame Relay: Auburn, Lewiston, Portland, Scarborough, South Portland, Westbrook, Networks and Windham, ME Prospeed.Net ATM/Frame Relay: Lowell, MA Reliant Energy ATM/Frame Relay: Austin, Dallas, and Houston, TX Rio ATM/Frame Relay: Bend, Eugene, and Medford, OR Communications TDS Metrocom ATM/Frame Relay: Appleton, Beloit, De pere, Fon Du Lac, Fox Valley, Green Bay, Janesville, Kenosha, Madison, Menasha, Milwaukee, Neenah, Oak Creek, Oshkosh, Racine, Stoughton, and Waukesha, WI; Northbrook, Rockford, and Waukegan, IL; Ann Arbor, Battle Creek, Farmington, Grand Haven, Grand Rapids, Holland, Jackson, Kalamazoo, Lansing, and Wayne, MI Telergy ATM/Frame Relay: Boston, MA; Albany, Batavia, Binghamton, Buffalo, Glens Falls, Ithaca, New York, Oswego, Poughkeepsie, Rochester, Syracuse, Utica and Watertown, NY; Erie, PA Teligent ATM: Cleveland, OH; Dallas and Houston, TX; Chicago, IL; Los Angeles, CA; Hartford, CT; Boston, MA; New York, NY; Philadelphia, PA; Phoenix, AZ; Washington, DC Time Warner ATM: Jersey City, NJ; Albany, Binghamton, New York and Rochester, NY; Austin, Dallas, Telecom Houston, and San Antonio, TX; Cincinnati and Columbus, OH; Indianapolis, IN; Los Angeles and San Diego, CA; Milwaukee, WI; Los Angeles and San Diego, CA; Charlotte, Fayetteville, Greensboro, Raleigh-Durham, and Winston-Salem, NC; Chicago, IL; Columbia, SC; Honolulu, HI; Indianapolis, IN; Memphis, TN; Milwaukee, WI; Minneapolis, MN; Orlando and Tampa, FL TXU Comm. ATM/Frame Relay: Austin, Corpus Christi, Dallas, Fort Worth, Huntsville, Nacogdoches, San Antonio, Temple, Tyler, and Waco, TX
I-7
CLEC Service: Market US LEC ATM/Frame Relay: Philadelphia and Pittsburgh, PA; Norfolk and Richmond, VA; Atlanta, GA; Baltimore, MD; Birmingham and Mobile, AL; Charleston, SC; Charlotte, Greensboro, and Raleigh, NC; Chattanooga, Knoxville, Memphis, and Nashville, TN; Ft. Myers/Naples, Jacksonville, Miami, Orlando, and St. Petersburg, FL; Louisville, KY; New Orleans, LA;, ATM: Washington, DC; Virginia Beach, VA; Huntsville, Montgomery, and Tuscaloosa, AL; Hickory and Wilmington, NC; Johnson City, TN; Daytona Beach, Fredericksburg, Ft. Lauderdale, Gainesville, Tampa, and West Palm Beach, FL Vanion ATM/Frame Relay: Colorado Springs, CO WanTel ATM/Frame Relay: Roseburg, OR Western ATM/Frame Relay: Sacramento, CA Integrated Networks WinStar/IDT ATM/Frame Relay: Austin, Dallas, Fort Worth, Houston, Irving, San Antonio, and Sunnyvale, TX; Chicago, and Oak Brook, IL; Cincinnati, Cleveland, and Columbus, OH; Detroit, MI; Long Beach, Oakland, Sacramento, San Diego, and San Francisco, CA; Indianapolis, IN; Kansas City and St. Louis, MO; Las Vegas, NV; Milwaukee, WI; Oklahoma City and Tulsa, OK; Stamford, CT; Atlanta, GA; Baltimore, MD; Birmingham, AL; Boise, ID; Boston, MA; Charlotte, NC; Chattanooga, TN; Denver, CO; Flagstaff, Phoenix, and Tucson, AZ; Honolulu, HI; Jacksonville, Miami, Orlando, and Tampa, FL; Long Island and New York, NY; Newark, NJ; Norfolk, VA; Philadelphia, PA; Portland, OR; Minneapolis and Saint Paul, MN; Salt Lake City, UT; Seattle and Spokane, WA; Washington, DC. ATM: Los Angeles, CA WorldCom ATM/Frame Relay: Washington, DC; Acton, Boston, Cambridge and Springfield, MA; Manchester and Nashua, NH; Laurel Springs, New Brunswick, and Newark, NJ; Buffalo, Garden City, Manhattan, New York, Westbury and White Plains, NY; King of Prussia, Philadelphia, and Pittsburgh, PA; Providence, RI; Reston, VA; Austin, Dallas, Houston, Irving, Richardson, and San Antonio, TX; Anaheim, Bakersfield, Fresno, Hayward, Irvine, Los Angeles, Rancho Cordova, Redwood City, Sacramento, San Diego, San Francisco, San Jose, Santa Clara, Stockton, Sunnyvale, and West Sacramento, CA; Bensenville, Chicago, and Elk Grove Village, IL; Cincinnati, Cleveland, and Toledo, OH; Detroit, Grand Rapids, Holland, Lansing, Southfield, Traverse City, and Zeeland, MI; Hartford and Stamford, CT; Indianapolis, IN; Kansas City, St. Louis and Springfield, MO; Oklahoma City, Stillwater, and Tulsa, OK; Little Rock, AR; Milwaukee, WI; Reno, NV; Albuquerque, NM; Baltimore, MD; Atlanta, Georgia, Jonesboro, and Marietta, GA; Aurora and Denver, CO; Jackson, MS; Kirkland and Seattle, WA; Knoxville and Memphis, TN; Maplewood, Minneapolis, and Saint Paul, MN; Miami, Orlando, Pompano Beach, and Tampa, FL; Morrisville, NC; Phoenix and Tucson, AZ; Portland, ME; Portland, OR; Salt Lake City, UT XO ATM: Washington, DC; Boston, MA; Baltimore, MD; New York, NY; Philadelphia, PA; Akron, Cleveland and Columbus, OH; Austin, Dallas, Houston, San Antonio, TX; Chicago and Wood Dale, IL; Detroit, MI; Las Vegas, NV; Long Beach, Los Angeles, Roseville, Sacramento, San Diego, San Francisco, and Santa Ana, CA; St. Louis, MO; Atlanta, GA; Newark, NJ; Couer D-Alene, ID; Denver, CO; Miami and Tampa, FL; Minneapolis and Saint Paul, MN; Phoenix, AZ; Portland, OR; Salt Lake City, UT Sources: See Appendix M.
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APPENDIX J. ADDITIONAL INFORMATION ON SOFTSWITCHES
Table 1. Features of Packet Switches/Softswitches vs. Traditional Circuit Switches Less fixed • “Currently a Softswitch costs 40% to 45% less than an equivalent circuit switch.” investment • “Originally envisioned to replace the monstrous Class 5 switches, softswitch platforms, by recent estimates, can be as much as 20 times smaller physically and 10 times cheaper.” • CLEC DixieNet “found that for ’10 percent’ of the cost of traditional class 5 equipment, it could accomplish everything the firm intended to do with a switch through softswitch technology.” • TelePacific Communications: “With the new convergent systems, we will be able to move into new service areas in weeks rather than months and add new services instantly rather than wait for months for vendors to enhance their switches.” Less expensive • “Carrying voice traffic on a packet platform saves up to 70% in operating costs, by [Banc of America] estimates.” to operate and • “In addition to providing its customers with 10-25 percent cost reductions on local voice service, the new architecture maintain provides CTC with higher margins – about 50 percent, versus the 10-30 percent margin afforded by CTC’s former resale business.” • “New business models based on the use of IP-oriented switches have an infinitely better value proposition for carriers. . . . They’ll enable gross margins in the 60 percent-plus range and the ability to provide differentiated offerings.” • DixieNet: “Other switch-related expenses – operation, maintenance, power, air conditioning, vendor support, training expenses, the cost of upgrades – all the costs were significantly lower with the softswitch system.” • BroadRiver: “you get all the functionality of a basic class 5 type of switch in about a tenth the floor space for about a third the power. ” • “A majority of the cost savings is derived from Sonus’ dramatically smaller footprint. A circuit-switched network requires roughly 40 bays of equipment to simultaneously switch 50,000 calls. Sonus’ packet-based platform is capable of switching the same number of calls with just two 19-inch racks of equipment.” Reduced • WorldCom: these new switches “provides input for IP, frame relay, ATM and voice all in a single box. We no longer have peripheral the need of putting out an IP router, an ATM switch, a frame relay switch and a voice switch. We do it all with the Multi- equipment Services Switch. We can get a capital reduction because of a single box versus many boxes. And secondly, we get a needs trunking efficiency because now we only have to trunk back one box versus multiple boxes. That capital efficiency improvement is anywhere from 50-75%.” Increased • Allegiance: “The traditional switch with its time-space-time architecture is constrained. By deploying networks of media scalability gateways which use standardized packets, new more-scalable networks are possible.” • XO: Softswitch technology will allow XO to realize cost savings both in reduced equipment cost and reduced physical co- location space needs. Additionally, softswitches are expected to be quickly scaleable and have capabilities to launch new and enhanced services. Increased • “Network intelligence in data networks offers carriers opportunities to offer differentiated, value-added enhanced services flexibility for regardless of transport method.” new services • Electric Lightwave: “Another key concept in the softswitch model is the ability to quickly provide new services and applications.” • “Softswitches have greater flexibility. Legacy switches . . . contain a lot of proprietary code, whereas softswitches are easier to customize, enabling service providers to develop a wider variety of services and create new revenue streams.” High quality • “With technologies currently available, it is possible to obtain quality voice calls over dedicated IP data networks.” and reliability • “Because it is truly a Central Office in a single system, the FUSION 5000 passed all platform tests with flying colors in the first attempt and is approved for general deployment in service provider central offices throughout the country.”) • “Now soft switches like that of Lucent can do between 144,000 and 5.25 million busy-hour call attempts, which is in the neighborhood of what a PSTN Class 5 can do.” • BroadRiver: “‘I would even say that the flexibility associated with this type of approach and technique gives you better survivability and reliability . . . The flexibility in terms of being able to dynamically switch and route traffic . . . is very open and very flexible,’ Buttermore said. ‘From a problem-resolution perspective, that’s great.’” Sources: See Appendix M.
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Table 2. The Emergence of Softswitches
• “At first used only for limited functions, in the past 12 months, softswitches have emerged as a possible alternative to the traditional class 5 devices at a number of small carriers.” • “[I]t is fair to say that CLECs are about to graduate from Class 5 to a new generation of multiservice platforms-capable of carrying Internet protocol (IP) and circuit-switched traffic and consolidating functions that previously were supported in separate, standalone devices.” • “Nobody doubts that the new switches will eventually overtake the current products. . . . ‘The benefits that the new switches offer are so enticing that all carriers eventually will incorporate them in their networks.’” • “a CLEC today is unlikely to buy a Class 5 switch for a new buildout in a city . . . and will likely go with a softswitch solution.” • “Only a few short years ago, any company that wanted to get into the facilities-based telecom market had only one choice: The heavy, expensive, inflexible and complex class 5 switch, the technology that has driven telecommunications for decades. . . . In the past few years, a new option has emerged. It’s less expensive, more capable of adding new features, much smaller and easier to run: The humble softswitch.” Sources: See Appendix M.
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Table 3. CLECs Deploying Softswitches CLEC Softswitch Deployment Allegiance “announced today the official deployment of softswitch technology as a complement to its existing network infrastructure. . . . will now be able to utilize packet switching - in addition to the traditional circuit-switched technology already deployed in its 21 U.S. markets.” Broadriver “using Cisco BTS 10200 softswitches and 2400 series integrated access devices (IADs) . . . launched VOIP-based converged voice, data and Internet service in Atlanta, Nashville and Orlando, and announced plans to expand service into Charlotte, Ft. Lauderdale, Miami and St. Petersburg by year’s end.” Tom Buttermore, CEO of Alpharetta, Ga-based competitive-communications firm BroadRiver Communications, said the advent of softswitches was the main reason his company was formed. CTC Communications “By introducing softswitch technology into its network, CTC will only lease T1 (1.5-megabit-per- second) loops from the incumbents, providing the intelligence for basic and enhanced voice services on its own.” CTC “built its own facilities-based network, without installing any circuit switches, in 1999,” but instead has used a combination of softswitches and ATM switches. Global NAPs Global NAPS has reportedly “gone so far as to deactivate four class 5 switches and deploy 35 softswitches, with 40 more in the pipeline as substitutes.” KMC Telecom “Lucent’s Softswitch IPO allows us to protect our switching infrastructure, save on real estate and reduce expenses without deploying costly circuit switches. . . . Now, we can deploy more telecom ports per square foot in a cost-effective manner.” Level 3 “By deploying Sonus’ IP technologies into our network, we can deliver new services more rapidly and cost-effectively than we could before.” NewSouth “Tekelec’s softswitch will provide long-distance service to NewSouth’s customers in a nine-state Communications coverage area.” Time Warner Telecom “has deployed Sonus’ packet telephony product family, including softswitches and media gateways, in eight markets throughout the United States . . . [and] is now delivering revenue- generating traffic over those networks.” USA Datanet “selected the Sonus Packet Telephony suite, including the . . . PSX6000 SoftSwitch . . . as the platform for its next-generation VoIP network.” WorldCom “WorldCom is taking the softswitch route and will deploy six of the devices by year-end [2001] . . . The new switches handle dial-up Internet traffic more cost-effectively than traditional Class 5 switches and have the capability to do voice over IP.” XO Communications “plans to use the Sonus Networks platform, which includes . . . the PSX6000 SoftSwitch . . . The system is expected to act as an integral piece of XO’s future network foundation, and will support a full range of local, long distance and Internet services to enterprise customers.” Kancharla “VocalData Inc., a leader in the service delivery softswitch market, today announced that Kancharla Corp., a leading competitive local exchange carrier based in Huntsville, Ala., has purchased and deployed VocalData's award-winning VOISS (Voice Over IP Softswitch) solution.” Go-Comm “VocalData Inc., the technology leader in the service delivery softswitch market, today announced that its award-winning Voice Over IP Softswitch (VOISS) solution has been deployed by Go- Comm, Inc. to provide voice over IP services in the Dallas area.” Sources: See Appendix M.
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Table 4. Major Softswitch Manufacturers Manufacturer Softswitch Description Product Tachion Fusion 5000 “will be used by our service provider customers as an alternative to traditional legacy central office composed of a class 5 voice switch surrounded by a number of data devices”; “collapses all the functions of the telephone company’s central office into a box the size of a dorm room refrigerator”; It starts at around $270,000 compared to up to $2 million for a traditional Class 5 circuit switch. Axtar Limited OneSwitch “supports both circuit switched interfaces such as TDM (E1 or T1) as well as IP (Ethernet) network interfaces,” and is “a complete replacement for a CLASS 5 or CLASS 4 central office switch and can be implemented on its own as the primary (core) switch in a small network or as an edge switch for larger networks.” Santera Systems SanteraOne “an all-in-one C.O. solution that integrates the entire next-generation switching solution within a single chassis. This all-inclusive solution offers CLASS 4 and CLASS 5 functionality, ATM, IP, TDM, and frame relay switching, signaling, media gateways and controllers, and IP routing.”; “costs about as much as what you’d spend on the switch room for a Class 5 switch”; “can be a replacement for either a legacy Class 4 or Class 5 circuit switch” Uniphere Networks BroadSoft In March 2001, “completed Class 5 customer trials of its BroadSoft platform.” Cisco BTS 10200 “has been in a GA [generally available] state for about eight months.” It is “being upgraded to its second release of software. It supports a substantial number of business voice calling features, making it one of the front runner contenders for Class 5 replacement opportunities. It also implements all mandatory Class 5 and core network switch features, such as 911, LNP, DAOS, SS7, AIN application access, etc.” Sonus GSX9000 “a carrier-class switch that is currently capable of supporting roughly 100,000 simultaneous calls while maintaining 99.999% reliability. One of the benefits of the GSX9000 is the small footprint needed for deployment; Sonus’ GSX9000 reduces the required C.O. space by roughly 90% compared to traditional circuit-based switches. This greatly reduces the cost of deployment, which management estimates to be roughly 50% of per-port costs and 45% of operating costs.”; “Our switch is ready for prime time because it’s already widely in deployment, mostly in Class 4.” Convergent Integrated Convergent Networks is “expected to have a softswitch with Class 5 Networks Convergence functionality available this quarter. Switch (ICS) Tacqua Open Compact “Class 5 alternative switching system with integrated Softswitch functionality Exchange (OCX) providing a clear migration path to next-generation packet-based networks.” Nortel Communication “New venture capital startups with little or no telephony experience can use Server 3000 this solution as an entry-level vehicle to the Voice-over-IP market – supporting next generation line-side services.” Syndeo Corporation The Syion 426 “The Syion 426 is a powerful second-generation, carrier-grade CLASS 5/Local Exchange softswitch”; “The Syion architecture was purpose-built for the delivery of regulatory (primary local exchange) services such as emergency/lifeline services, operator services, directory assistance, and lawful intercept.” In February 2002, The Armstrong Group, which operates telephone and cable networks in the eastern U.S., announced that it would deploy the Syndeo Syion 426 softswitch platform in Western Pennsylvania. Convedia Convedia CMS- “The Convedia CMS-6000 Media Server has been designed and developed Corporation 6000 Media specifically to meet the challenges of delivering enhanced voice and video Server services over packet networks. . . . Convedia’s modular hardware and software architecture lets you enter the enhanced services market quickly and affordably.”
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Table 4. Major Softswitch Manufacturers Manufacturer Softswitch Description Product Gallery IP Telephony CAssiopeia “CAssiopeia Softswitch is the first ever standard-based Class-5 softswitch to Softswitch Class 5 demonstrate high-reliability, high capacity and performance, great flexibility Alternative and scalability, primary line architecture, revenue-generating services and features platform, and open standards interfaces. It enables service providers to reap the benefits of IP Telephony better, faster and cheaper.” MetaSwitch Meta MetaSwitch “The Meta MetaSwitch VP3000 Broadband Voice Platform Switch Platform VP3000 . . . provides a full range of Class 5 services without a legacy Class 5 switch. . . This feature set makes the VP3000 ideal for service providers seeking to: generate additional revenue from data lines (such as DSL) by adding high- revenue voice; services; expand into new geographical regions, where backhauling long distances to their existing; facilities may be overly complex and expensive; add next-generation Class 5 services to their network, either replacing existing Class 5; switches or as existing capacity is exhausted; build an entirely green-field network providing broadband voice and data and/or POTS voice using a single switching platform.” Lucent Softswitch – T3 Will “offer Voice over Packet Connectivity for toll/tandem (Class 4) functions . . . will include core revenue generating voice services . . . running in a converged-voice/data-network.” VocalData VOISS “The VOISS solution is a feature-rich service delivery softswitch that enables service providers to offer carrier-grade voice services and enhanced applications on an open architecture.” Sources: See Appendix M.
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APPENDIX K. CLEC NETWORKS BY MSA
This appendix tabulates the number of CLEC networks in the 150 largest Metropolitan Statistical Areas (MSAs). It is based on the CLEC reports prepared by New Paradigm Resources Group (NPRG).
The data for 2001 are from NPRG’s latest report – the CLEC Report 2002 – which describes CLEC networks as either “Operational,” “On-Net,” “Resale,” or “Planned.” We have tabulated only Operational and On-Net networks, both of which appear to involve the use of a CLEC’s own facilities. CLECs operating On-Net networks are indicated in italics.
The data for 1998 are based on NPRG’s CLEC Report 1999, which describe CLEC networks as either “Operational,” “Off-Net,” or “Planned.” We have counted both “Operational” and “Off-Net” networks in the 1998 totals. CLECs operating “Off-Net” networks are indicated in italics.
In some MSAs, the total number of Operational and On-Net networks exceeds the number of CLECs operating within those MSAs. This is due to the fact that, in some instances, individual CLECs operate multiple networks within the same MSA.
The 2001 totals include the networks of CLECs that have declared bankruptcy. Most such CLECs are still operational (and some are now emerging from bankruptcy). Moreover, network facilities such as fiber are a sunk investment, so if one company ceases to use its network it is highly likely that another company will quickly seize the opportunity to do so (and will probably be able to obtain the facilities at a fire-sale price). In any event, networks operated by CLECs that have declared bankruptcy (as of March 31, 2002) represent no more than 18 percent of the totals counted here.
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MSA CLEC Networks – 1998 CLEC Networks – 2001 1. Los Angeles-Long Allegiance Telecom; AT&T; Electric Lightwave; Adelphia Business Solutions; Allegiance Telecom; Beach, CA FirstWorld Communications; Focal; Global NAPs; AT&T; Cogent Communications; Cox GST Telecommunications; ICG Communications; Communications; Eagle Communications; Focal; Intermedia; Level 3 Communications; MediaOne Global Crossing; Globalcom; ICG Communications; Telecommunications*; MGC Communications; Net- IntelliSpace; Intermedia; Mpower; Net2000; Tel Corporation; NEXTLINK Communications Network Plus; Pac-West Telecomm; PaeTec; RCN; (XO); Pac West Telecom; US Telepacific; WinStar; Sphera Optical Networks; Telseon; Time Warner WorldCom Telecom, Inc., US Telepacific; Verado Holdings; WinStar; WorldCom; XO CLECs: 18 CLECs: 26 Operational Networks: 29 Operational Networks: 33 Off-Net Networks: 2 On-Net Networks: 12 2. New York, NY Allegiance Telecom; AT&T; BTI; Cablevision Adelphia Business Solutions; Allegiance Telecom; Lightpath; Community Networks; CTC Arbros Communications; AT&T; Broadview Communications; DualStar Communications; Networks; BTI; Cablevision Lightpath; Cogent e.spire; Eagle Communications; Electric Lightwave; Communications; CTC Communications; e.spire; Focal; Frontier Communications; Global NAPs; Eagle Communications; Fairpoint Communications; Hyperion Telecommunications; Intermedia; Level 3 Focal; GiantLoop Network; GlobalCrossing; Communications; d/b/a Met Tel; Marathon Globalcom; IntelliSpace; Intermedia; Lightyear Communications; Metromedia Fiber Network; Communications; NECLEC; Net2000; Network Net2000; Net-Tel Corporation; NEXTLINK Plus; PaeTec; RCN; Reach Communications; Communications (XO); North American Sphera Optical Networks; Telseon; Time Warner Telecommunications; NorthEast Optic Network Telecom; WinStar; WorldCom; XO Services; RCN; Reach Communications; RNK; Time Warner Telecom; WinStar; WorldCom CLECs: 30 CLECs: 31 Operational Networks: 41 Operational Networks: 56 Off-Net Networks: 2 On-Net Networks: 8 3. Chicago, IL 21st Century; Allegiance Telecom; AT&T; Dakota Adelphia Business Solutions; Allegiance Telecom; Services; Eagle Communications; Electric AT&T; Cogent Communications; CoreComm; Lightwave; Focal; Frontier Communications; Digital Pipeline Communications; Eagle Global NAPs; Globalcom; InterAccess; Intermedia; Communications; Focal; GiantLoop Network; Level 3 Communications; MGC Communications; Global Crossing; Globalcom; IntelliSpace; Net-Tel Corporation; NEXTLINK Communications Intermedia; Lightyear Communications; (XO); Ovation Communications; Sharon Telephone McLeodUSA; Mpower; Net2000; Network Plus; Company; WinStar; WorldCom PaeTec; RCN; Sharon Telephone Company; TDS Metrocom; Telseon; Time Warner Telecom; WinStar; WorldCom; XO; Yipes CLECs: 20 CLECs: 28 Operational Networks: 23 Operational Networks: 47 Off-Net Networks: 1 On-Net Networks: 8 4. Philadelphia, PA-NJ Allegiance Telecom; AT&T; Conectiv Adelphia Business Solutions; Allegiance Telecom; Communications; e.spire; Eagle Communications; Arbros Communications; AT&T; Broadview Focal; Hyperion Telecommunications; Intermedia; Networks; BTI Telecom; CEI Networks; Cogent Level 3 Communications; Metromedia Fiber Communications; Comcast Business Network; Net-Tel Corporation; NEXTLINK Communications; CoreComm; e.spire; Eagle Communications (XO); WinStar; WorldCom Communications; Focal; GiantLoop Network; Global Crossing; IntelliSpace; Intermedia; Net2000; RCN; Telseon; US LEC; WinStar; WorldCom; XO; Yipes CLECs: 14 CLECs: 25 Operational Networks: 19 Operational Networks: 40 Off-Net Networks: 2 On-Net Networks: 15
* The names of CLECs operating Off-Net networks in 1998, or On-Net networks in 2001, appear in italics.
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MSA CLEC Networks – 1998 CLEC Networks – 2001 5. Washington, DC-MD- AT&T; e.spire; Electric Lightwave; FairPoint Adelphia Business Solutions; Advanced TelCom VA-WV Communications; Fiber Services, Inc.; Focal; Group; Allegiance Telecom; Arbros Frontier Communications; Global NAPs; Hyperion Communications; AT&T; BTI Telecom; Cavalier Telecommunications; Intermedia; Jones Telephone; Cogent Communications; Comcast Communications; Level 3 Communications; Business Communications; e.spire; Fairpoint Metromedia Fiber Network; Net2 Communications; Communications; Focal; Global Crossing; Global Net-Tel Corporation; RCN; WinStar; WorldCom NAPs; Globalcom; IntelliSpace; Intermedia; Net2000; PaeTec; RCN; Sigma Networks; US LEC; WinStar; WorldCom; XO. CLECs: 18 CLECs: 25 Operational Networks: 31 Operational Networks: 59 Off-Net Networks: 2 On-Net Networks: 13 6. Detroit, MI AT&T; Coast to Coast Telecommunications; Adelphia Business Solutions; Allegiance Telecom; Frontier Communications; Intermedia; Level 3 AT&T; Comcast Business Communications; Focal; Communications; Net-Tel Corporation; US MidTel; Intermedia; Lightyear Communications; MichTel; WinStar; WorldCom. Mpower; TDS Metrocom; TelNet Worldwide; Telseon; WorldCom; XO. CLECs: 9 Operational Networks: 18 CLECs: 14 Off-Net Networks: 1 Operational Networks: 35 7. Houston, TX AT&T; CapRock Communications; Digital Adelphia Business Solutions; Allegiance Telecom; Teleport; e.spire; Eagle Communications; GST AT&T; Birch Telecom; Cogent Communications; Telecommunications; ICG Communications; e.spire; Eagle Communications; Focal; Global Intermedia; ITC DeltaCom; Level 3 Crossing; ICG Communications; Intermedia; Ionex Communications; Logix Communications; Net-Tel Telecommunications; ITC^DeltaCom; Lightyear Corporation; OpTel Telecom; Pointe Communications; Logix Communications Communications; Time Warner Telecom; WinStar; Enterprises; Madison River Communications; WorldCom Mpower; Telseon; Time Warner Telecom; WorldCom; XO; Yipes CLECs: 17 CLECs: 22 Operational Networks: 16 Operational Networks: 25 Off-Net Networks: 1 On-Net Networks: 3 8. Atlanta, GA Allegiance Telecom; BTI; Convergent Adelphia Business Solutions; Allegiance Telecom; Communications; e.spire; Eagle Communications; AT&T; Birch Telecom; BTI Telecom; Cbeyond Electric Lightwave; Frontier Communications; Communications; Cogent Communications; Cox Global NAPs; ICG Communications; Intermedia; Communications; e.spire; Eagle Communications; ITC DeltaCom; Level 3 Communications; Marietta Focal; Global Crossing; Globalcom; ICG Fibernet; MediaOne Telecommunications; MGC Communications; IntelliSpace; Intermedia; Communications; Net-Tel Corporation; ITC^DeltaCom; LecStar; Lightyear NEXTLINK Communications (XO); Pointe Communications; Madison River Communications; Communications; US LEC; WinStar; WorldCom Mpower; Network Plus; Network Telephone; NewSouth Communications; NuVox Communications; Telseon; Time Warner Telecom; US LEC; WorldCom; XO; Yipes CLECs: 21 CLECs: 31 Operational Networks: 35 Operational Networks: 45 Off-Net Networks: 1 On-Net Networks: 6
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MSA CLEC Networks – 1998 CLEC Networks – 2001 9. Dallas, TX Allegiance Telecom; AT&T; BTI; CapRock Adelphia Business Solutions; Allegiance Telecom; Communications; Convergent Communications; AT&T; Birch Telecom; BTI Telecom; Cbeyond e.spire; Eagle Communications; Electric Lightwave; Communications; Cogent Communications; e.spire; Frontier Communications; GST Eagle Communications; Fairpoint Communications; Telecommunications; ICG Communications; Focal; GiantLoop Network; Global Crossing; ICG Intermedia; ITC DeltaCom; Level 3 Communications; IntelliSpace; Intermedia; Ionex Communications; Logix Communications; Net-Tel Telecommunications; ITC^DeltaCom; Lightyear Corporation; NEXTLINK Communications (XO); Communications; Logix Communications OpTel Telecom; Pointe Communications; Enterprises; Madison River Communications; Telephone Plus; WinStar; WorldCom Mpower; Net2000; NTS Communications; Sphera Optical Networks; Tellaire Corporation; Telseon; Time Warner Telecom; WorldCom; XO; Yipes CLECs: 22 CLECs: 31 Operational Networks: 23 Operational Networks: 36 Off-Net Networks: 2 On-Net Networks: 2 10. Boston, MA-NH Allegiance Telecom; AT&T; CTC Adelphia Business Solutions; Allegiance Telecom; Communications; Eagle Communications; Focal; Arbros Communications; AT&T; Broadview Frontier Communications; Global NAPs; Networks; Cogent Communications; Conversent HarardNet; Intermedia; Level 3 Communications; Communications; CTC Communications; Eagle MediaOne Telecommunications; Net-Tel Communications; Focal; GiantLoop Network; Corporation; NorthEast Optic Network Services; Global Crossing; IntelliSpace; Intermedia; Lightship RCN; RNK; WinStar; WorldCom Telecom; Lightyear Communications; NECLEC; Net2000; Network Plus; PaeTec; RCN; RNK Telecom; Sphera Optical Networks; WinStar; WorldCom; XO; Yipes CLECs: 17 CLECs: 27 Operational Networks: 46 Operational Networks: 54 Off-Net Networks: 1 On-Net Networks: 35 11. Riverside-San GST Telecommunications; ICG Communications; AT&T; ICG Communications; Mpower; Pac-West Bernardino, CA MGC Communications; Pac West Telecom Telecomm; Verado Holdings
CLECs: 4 CLECs: 5 Operational Networks: 11 Operational Networks: 6 On-Net Networks: 4 12. Phoenix-Mesa, AZ Advanced Radio Telecom; AT&T; CapRock Adelphia Business Solutions; Allegiance Telecom; Communications; Cox Communications; Digital AT&T; Cox Communications; e.spire; Eschelon Teleport; Electric Lightwave; Frontier Telecom; Global Crossing; Intermedia; Lightyear Communications; GST Telecommunications; ICG Communications; McLeodUSA; Pac-West Communications; Intermedia; Net-Tel Corporation; Telecomm; Telseon; WorldCom; XO NEXTLINK Communications (XO); Telephone Plus; WinStar; WorldCom CLECs: 15 Operational Networks: 14 CLECs: 14 Off-Net Networks: 1 Operational Networks: 16 13. San Diego, CA AT&T; Electric Lightwave; Frontier Allegiance Telecom; AT&T; Cox Communications; Communications; GST Telecommunications; ICG Global Crossing; ICG Communications; Communications; Level 3 Communications; MGC IntelliSpace; Lightyear Communications; Mpower; Communications; Net-Tel Corporation; PacWest Pac-West Telecomm; PaeTec; RCN; Telseon; Time Telecom; Time Warner Telecom; WinStar; Warner Telecom; US Telepacific; WorldCom; WorldCom Verado Holdings; XO; Yipes CLECs: 12 CLECs: 18 Operational Networks: 17 Operational Networks: 17 On-Net Networks: 6
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MSA CLEC Networks – 1998 CLEC Networks – 2001 14. Minneapolis-St. Paul AT&T; Bresnan Communications; Frontier Allegiance Telecom; AT&T; Eschelon Telecom; Communications; InfoTel Communications; Integra Focal; Global Crossing; HickoryTech; Integra Telecom; KMC Telecom; MediaOne Telecom; Intermedia; KMC Telecom; McLeod Telecommunications; Net-Tel Corporation; Ovation USA; Time Warner Telecom; WorldCom; XO Communications; WinStar; WorldCom CLECs: 11 CLECs: 13 Operational Networks: 12 Operational Networks: 16 Off-Net Networks: 1 On-Net Networks: 6 15. Orange County, CA AT&T; Cox Communications; FirstWorld Allegiance Telecom; AT&T; Cox Communications; Communications; Focal; Frontier Communications; Focal; Global Crossing; ICG Communications; GST Telecommunications; ICG Communications; Lightyear Communications; Mpower; Pac-West MGC Communications; Net-Tel Corporation; Telecomm; PaeTec; Time Warner Telecom; Verado NEXTLINK Communications (XO); Pac West Holdings; US Telepacific; WorldCom; XO Telecomm; WinStar; WorldCom CLECs: 13 CLECs: 15 Operational Networks: 21 Operational Networks: 27 Off-Net Networks: 1 On-Net Networks: 4 16. Nassau-Suffolk, NY Cablevision Lightpath; CTC Communications; AT&T; Cablevision Lightpath; Conversent Intermedia Communications; CTC Communications; IntelliSpace; Intermedia; WorldCom CLECs: 3 CLECs: 7 Operational Networks: 9 Operational Networks: 15 On-Net Networks: 5 17. St. Louis, MO-IL AT&T; Birch Telecom; BroadSpan Allegiance Telecom; AT&T; Birch Telecom; Communications; Digital Teleport; Frontier Global Crossing; Intermedia; Lightyear Communications; Intermedia; Net-Tel Corporation; Communications; Logix Communications WinStar; WorldCom Enterprises; McLeodUSA; NuVox Communications; Telseon; WorldCom; XO CLECs: 9 CLECs: 12 Operational Networks: 8 Operational Networks: 23 Off-Net Networks: 1 On-Net Networks: 1 18. Baltimore, MD AT&T; Conectiv; e.spire; Intermedia; Level 3 Adelphia Business Solutions; Advanced TelCom Communications; Net2 Communications; Net-Tel Group; Allegiance Telecom; Arbros Corporation; WinStar; WorldCom Communications; AT&T; Cavalier Telephone; Comcast Business Communications; e.spire; Focal; Global Crossing; IntelliSpace; Intermedia; Lightyear Communications; Net2000; PaeTec; RCN; US LEC; WorldCom; XO CLECs: 9 CLECs: 19 Operational Networks: 9 Operational Networks: 16 Off-Net Networks: 1 On-Net Networks: 4 19. Oakland, CA Allegiance Telecom; AT&T; Focal; Frontier Allegiance Telecom; AT&T; Focal; Global Communications; GST Telecommunications; ICG Crossing; ICG Communications; Mpower; Pac- Communications; Net-Tel Corporation; West Telecomm; US Telepacific; WorldCom; XO NEXTLINK Communications (XO); Pac West Telecomm; WinStar; WorldCom CLECs: 11 CLECs: 10 Operational Networks: 20 Operational Networks: 10 Off-Net Networks: 1 On-Net Networks: 3
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MSA CLEC Networks – 1998 CLEC Networks – 2001 20. Seattle-Bellevue- Advanced Radio Telecom; AT&T; Convergent Adelphia Business Solutions; Allegiance Telecom; Everett, WA Communications; Electric Lightwave; Frontier AT&T; Cogent Communications; Eschelon Communications; GST Telecommunications; Level Telecom; Focal; Global Crossing; Integra Telecom; 3 Communications; Marathon Communications; Intermedia; Lightyear Communications; Net-Tel Corporation; Telephone Plus; WinStar; McLeodUSA; Pac-West Telecomm; Telseon; WorldCom Terabeam; WinStar; WorldCom; XO CLECs: 12 CLECs: 17 Operational Networks: 13 Operational Networks: 20 On-Net Networks: 2 21. Tampa-St. Petersburg- AT&T; e.spire; Eagle Communications; Florida Adelphia Business Solutions; Allegiance Telecom; Clearwater, FL Digital Network; Frontier Communications; AT&T; BTI; e.spire; Eagle Communications; Hyperion Telecommunications; Intermedia; Net-Tel Florida Digital Network; Global Crossing; Corporation; Time Warner Telecom; US LEC; Intermedia; ITC DeltaCom; Mpower; Net2000; WinStar; WorldCom NewSouth Communications; Telseon; Time Warner Telecom; US LEC; WinStar; WorldCom; XO CLECs: 12 CLECs: 19 Operational Networks: 12 Operational Networks: 23 On-Net Networks: 5 22. Pittsburgh, PA AT&T; Hyperion Telecommunications; Intermedia; Adelphia Business Solutions; Arbros Net-Tel Corporation; WorldCom Communications; AT&T; Choice One Communications; Global Crossing; Intermedia; PennTelecom; RCN; US LEC; WorldCom; Yipes CLECs: 5 CLECs: 11 Operational Networks: 4 Operational Networks: 21 Off-Net Networks: 1 On-Net Networks: 2 23. Cleveland-Lorain- AT&T; Cox Communications; e.spire; Frontier Adelphia Business Solutions; Allegiance Telecom; Elyria, OH Communications; ICG Communications; AT&T; Cablevision Lightpath; CoreComm; Focal; Intermedia; Net-Tel Corporation; NEXTLINK Global Crossing; ICG Communications; Intermedia; Communications (XO); WinStar; WorldCom Lightyear Communications; McLeodUSA; Mpower; WorldCom; XO CLECs: 10 CLECs: 14 Operational Networks: 9 Operational Networks: 15 Off-Net Networks: 1 24. Miami, FL BTI; Eagle Communications; Florida Digital Adelphia Business Solutions; Allegiance Telecom; Network; Global NAPs; Hyperion AT&T; BTI Telecom; Cogent Communications; Telecommunications; Intermedia; MediaOne e.spire; Eagle Communications; Florida Digital Telecommunications; Net-Tel Corporation; Network; Intermedia; Lightyear Communications; NEXTLINK Communications (XO); Pointe Mpower; Net2000; Network Plus; NewSouth Communications; US LEC; WinStar; WorldCom Communications; NuVox Communications; PaeTec; Sphera Optical Networks; Telseon; US LEC; WorldCom; XO; Yipes CLECs: 13 CLECs: 22 Operational Networks: 13 Operational Networks: 23 Off-Net Networks: 1 On-Net Networks: 3 25. Denver, CO AT&T; Convergent Communications; Electric Adelphia Business Solutions; Allegiance Telecom; Lightwave; Frontier Communications; GST AT&T; Eschelon Telecom; Global Crossing; ICG Telecommunications; ICG Communications; Communications; Intermedia; Lightyear Intermedia; Level 3 Communications; Net-Tel Communications; McLeodUSA; Net2000; Pac- Corporation; NEXTLINK Communications (XO); West Telecomm; Telseon; Terabeam; Time Warner Telephone Plus; WinStar; WorldCom Telecom; Vanion; WinStar; WorldCom; XO; Yipes CLECs: 13 CLECs: 19 Operational Networks: 12 Operational Networks: 24 Off-Net Networks: 1 On-Net Networks: 1
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MSA CLEC Networks – 1998 CLEC Networks – 2001 26. Newark, NJ Focal; Hyperion Telecommunications; MH Adelphia Business Solutions; Allegiance Telecom; Lightnet; Net-Tel Corporation; WinStar; WorldCom Arbros Communications; AT&T; Cablevision Lightpath; Comcast Business Communications; Focal; IntelliSpace; Lightyear Communications; Net2000; RCN; WorldCom; XO CLECs: 6 CLECs: 13 Operational Networks: 6 Operational Networks: 16 Off-Net Networks: 1 On-Net Networks: 5 27. Portland-Vancouver, Advanced Radio Telecom; AT&T; Beaver Creek Adelphia Business Solutions; Advanced TelCom OR-WA Cooperative Telephone; Convergent Group; Allegiance Telecom; AT&T; Eschelon Communications; Electric Lightwave; FirstWorld Telecom; Global Crossing; Integra Telecom; Communications; Frontier Communications; GST Intermedia; McLeodUSA; RIO Communications; Telecommunications; Integra Telecom; Net-Tel WorldCom; XO. Corporation; NEXTLINK Communications (XO); Telephone Plus; WinStar; WorldCom CLECs: 14 CLECs: 12 Operational Networks: 17 Operational Networks: 15 Off-Net Networks: 1 28. San Francisco, CA Allegiance Telecom; AT&T; Convergent Adelphia Business Solutions; Allegiance Telecom; Communications; Electric Lightwave; Focal; GST AT&T; Cogent Communications; Focal; GiantLoop Telecommunications; ICG Communications; Network; Global Crossing; Globalcom; ICG Intermedia; Level 3 Communications; Net-Tel Communications; IntelliSpace; Intermedia; Corporation; NEXTLINK Communications (XO); Lightyear Communications; Mpower; Net2000; Pac West Telecomm; Telephone Plus; WinStar; Pac-West Telecomm; RCN; Telseon; US WorldCom Telepacific; WorldCom; XO CLECs: 15 CLECs: 20 Operational Networks: 17 Operational Networks: 21 On-Net Networks: 9 29. Kansas City, MO-KS Advanced Communications Group; AT&T; Birch AT&T; Birch Telecom; e.spire; Global Crossing; Telecom; Digital Teleport; e.spire; ExOp of Ionex Telecommunications; Intermedia; Lightyear Missouri; Frontier Communications; Intermedia; Communications; Logix Communications; Logix Communications; Net-Tel Corporation; McLeodUSA; NuVox Communications; WorldCom WinStar; WorldCom CLECs: 12 CLECs: 11 Operational Networks: 17 Operational Networks: 11 Off-Net Networks: 2 On-Net Networks: 2 30. San Jose, CA AT&T; Focal; Frontier Communications; ICG Allegiance Telecom; AT&T; Cogent Communications; Level 3 Communications; Net-Tel Communications; e.spire; Focal; Global Crossing; Corporation; NEXTLINK Communications (XO); ICG Communications; Net2000; Pac-West Pac West Telecomm; WorldCom Telecomm; US Telepacific; WorldCom; XO; Yipes CLECs: 9 CLECs: 13 Operational Networks: 21 Operational Networks: 19 Off-Net Networks: 2 On-Net Networks: 4 31. Cincinnati, OH-KY-IN AT&T; ICG Communications; Intermedia; Net-Tel Adelphia Business Solutions; AT&T; Broadslate Corporation; Time Warner Telecom; WorldCom Networks; Global Crossing; ICG Communications; Intermedia; Lightyear Communications; NuVox Communications; Telseon; Time Warner Telecom; WorldCom CLECs: 6 CLECs: 11 Operational Networks: 5 Operational Networks: 13 Off-Net Networks: 1
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MSA CLEC Networks – 1998 CLEC Networks – 2001 32. Fort Worth-Arlington, Allegiance Telecom; AT&T; CapRock Allegiance Telecom; AT&T; Birch Telecom; TX Communications; e.spire; Frontier e.spire; Focal; Global Crossing; Intermedia; Logix Communications; Logix Communications; Net-Tel Communications; Mpower Corporation; WorldCom CLECs: 8 CLECs: 9 Operational Networks: 8 Operational Networks: 10 Off-Net Networks: 1 On-Net Networks: 2 33. Orlando, FL AT&T; BTI; Florida Digital Network; Hyperion Adelphia Business Solutions; AT&T; BTI; e.spire; Telecommunications; Intermedia; ITC DeltaCom; Florida Digital Network; Global Crossing; Net-Tel Corporation; Orlando Telephone Company; Intermedia; ITC^DeltaCom; Net2000; Network Time Warner Telecom; US LEC; WorldCom Plus; Network Telephone; NewSouth Communications; Orlando Telephone Company; Telseon; Time Warner Telecom; US LEC; WorldCom CLECs: 11 CLECs: 17 Operational Networks: 11 Operational Networks: 23 Off-Net Networks: 2 On-Net Networks: 4 34. Sacramento, CA AT&T; Electric Lightwave; Frontier Allegiance Telecom; AT&T; Global Crossing; ICG Communications; GST Telecommunications; ICG Communications; Mpower; Pac-West Telecomm; Communications; Net-Tel Corporation; Pac West Western Integrated Networks; WorldCom; XO Telecomm; Telephone Plus; WinStar; WorldCom CLECs: 10 CLECs: 9 Operational Networks: 10 Operational Networks: 11 35. San Antonio, TX e.spire; ICG Communications; Intermedia; ITC Adelphia Business Solutions; Allegiance Telecom; DeltaCom; Logix Communications; Net-Tel; AT&T; Birch Telecom; e.spire; Global Crossing; Telephone Plus; Time Warner Telecom; Waller Grande Communications; ICG Communications; Creek Communications; WorldCom ITC^DeltaCom; Logix Communications; Mpower; Time Warner Telecom; WorldCom; XO CLECs: 10 CLECs: 14 Operational Networks: 10 Operational Networks: 15 On-Net Networks: 1 36. Las Vegas, NV-AZ Digital Teleport; e.spire; Electric Lightwave; GST Cox Communications; e.spire; Eagle Telecommunications; MGC Communications; Net- Communications; Intermedia; Mpower; Pac-West Tel Corporation; NEXTLINK Communications Telecomm; US Telepacific; XO (XO); Telephone Plus; WinStar CLECs: 9 CLECs: 8 Operational Networks: 9 Operational Networks: 8 Off-Net Networks: 1 On-Net Networks: 1 37. Fort Lauderdale, FL AT&T; e.spire; Eagle Communications; Florida Adelphia Business Solutions; Allegiance Telecom; Digital Network; Intermedia; MediaOne AT&T; BTI; e.spire; Eagle Communications; Telecommunications; MGC Communications; Net- Florida Digital Network; Intermedia; Tel Corporation; Supra Telecommunications & ITC^DeltaCom; Mpower; Network Plus; NuVox Information Systems; WorldCom Communications; PaeTec; US LEC; WorldCom; Yipes CLECs: 10 CLECs: 16 Operational Networks: 10 Operational Networks: 19 Off-Net Networks: 1 On-Net Networks: 3 38. Indianapolis, IN AT&T; Frontier Communications; Intermedia; Net- Adelphia Business Solutions; AT&T; Choice One Tel Corporation; Time Warner Telecom; Communications; Global Crossing; Intermedia; WorldCom Lightyear Communications; McLeodUSA; NuVox Communications; Time Warner Telecom; WinStar; WorldCom CLECs: 6 CLECs: 11 Operational Networks: 5 Operational Networks: 15 Off-Net Networks: 1
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MSA CLEC Networks – 1998 CLEC Networks – 2001 39. Norfolk-Virginia Cox Communications; Hyperion Adelphia Business Solutions; ALLTEL; Arbros Beach-Newport News, Telecommunications; KMC Telecom; Net2 Communications; AT&T; Cavalier Telephone; Cox VA-NC MSA Communications; US LEC Communications; KMC Telecom; Net2000; US LEC CLECs: 5 CLECs: 9 Operational Networks: 5 Operational Networks: 17 On-Net Networks: 2 40. Milwaukee-Waukesha, AT&T; Dakota Services; Globalcom; Net-Tel AT&T; Choice One Communications; Global WI Corporation; Ovation Communications; Time Crossing; Globalcom; McLeodUSA; TDS Warner Telecom; US Xchange; WinStar; Metrocom; Time Warner Telecom; WinStar; WorldCom WorldCom CLECs: 9 CLECs: 9 Operational Networks: 10 Operational Networks: 12 Off-Net Networks: 1 On-Net Networks: 1 41. Columbus, OH ICG Communications; Intermedia; Net-Tel Adelphia Business Solutions; AT&T; Choice One Corporation; NEXTLINK Communications (XO); Communications; CoreComm; Global Crossing; Time Warner Telecom; WinStar ICG Communications; Intermedia; McLeodUSA; Mpower; NuVox Communications; Time Warner Telecom; XO CLECs: 6 CLECs: 12 Operational Networks: 5 Operational Networks: 12 Off-Net Networks: 1 42. Charlotte-Gastonia- AT&T; BTI; Eagle Communications; FairPoint Adelphia Business Solutions; AT&T; Birch Rock Hill, NC-SC Communications; ICG Communications; Telecom; BTI; CTC Communications; Eagle Intermedia; Time Warner Telecom; US LEC Communications; Global Crossing; ICG Communications; Intermedia; ITC^DeltaCom; Network Telephone; NewSouth Communications; NuVox Communications; Time Warner Telecom; US LEC CLECs: 8 CLECs: 15 Operational Networks: 8 Operational Networks: 16 On-Net Networks: 2 43. Bergen-Passaic, NJ AT&T; Intermedia Allegiance Telecom; Conversent Communications; Focal; IntelliSpace CLECs: 2 CLECs: 4 Operational Networks: 2 Operational Networks: 5 44. New Orleans, LA American MetroComm; Columbia Adelphia Business Solutions; Cox Communications; Telecommunications; Cox Communications; e.spire; Global Crossing; Intermedia; e.spire; Hyperion Telecommunications; Intermedia; ITC^DeltaCom; Madison River Communications; ITC DeltaCom; NewSouth Communications; Network Telephone; NewSouth Communications; WinStar US LEC; Xspedius CLECs: 9 CLECs: 11 Operational Networks: 9 Operational Networks: 12 45. Salt Lake City-Ogden, AT&T; Convergent Communications; Electric AT&T; Eschelon Telecom; Global Crossing; UT Lightwave; GST Telecommunications; Net-Tel Integra Telecom; Intermedia; McLeodUSA; Pac- Corporation; NEXTLINK Communications (XO); West Telecomm; WorldCom; XO Telephone Plus; WinStar; WorldCom CLECs: 9 CLECs: 9 Operational Networks: 11 Operational Networks: 9 Off-Net Networks: 1
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MSA CLEC Networks – 1998 CLEC Networks – 2001 46. Greensboro-Winston BTI; Eagle Communications; Intermedia; ITC ALLTEL; AT&T; BTI; Birch Telecom; CTC Salem-High Point, NC DeltaCom; KMC Telecom; Time Warner Telecom; Communications; Eagle Communications; US LEC Intermedia; ITC^DeltaCom; KMC Telecom; Madison River Communications; Network Telephone; NewSouth Communications; NuVox Communications; Time Warner Telecom; US LEC; Xspedius CLECs: 7 CLECs: 16 Operational Networks: 11 Operational Networks: 28 Off-Net Networks: 1 On-Net Networks: 3 47. Nashville, TN AT&T; Eagle Communications; Hyperion Adelphia Business Solutions; AT&T; Birch Telecommunications; ICG Communications; Telecom; BTI; Eagle Communications; ICG Intermedia; NewSouth Communications; Communications; Intermedia; ITC^DeltaCom; NEXTLINK Communications (XO); US LEC Network Telephone; NewSouth Communications; NuVox Communications; US LEC; XO; Xspedius CLECs: 8 CLECs: 14 Operational Networks: 8 Operational Networks: 18 On-Net Networks: 2 48. Austin-San Marcos, e.spire; ICG Communications; Intermedia; ITC Adelphia Business Solutions; Allegiance Telecom; TX DeltaCom; Level 3 Communications; Logix AT&T; Birch Telecom; e.spire; Global Crossing; Communications; Net-Tel Corporation; Grande Communications; ICG Communications; NEXTLINK Communications (XO); Telephone Intermedia; ITC^DeltaCom; Logix Plus; Time Warner Telecom; Waller Creek Communications; Mpower; Time Warner Telecom; Communications; WorldCom WorldCom; XO CLECs: 12 CLECs: 15 Operational Networks: 11 Operational Networks: 15 Off-Net Networks: 1 On-Net Networks: 2 49. Buffalo-Niagara Falls, AT&T; Choice One Communications; Hyperion Adelphia Business Solutions; AT&T; Broadview NY Telecommunications; Intermedia; Net-Tel Networks; Choice One Communications; Eagle Corporation; WorldCom Communications; Intermedia; WorldCom CLECs: 6 CLECs: 7 Operational Networks: 5 Operational Networks: 7 Off-Net Networks: 1 On-Net Networks: 1 50. Middlesex-Somerset- AT&T; Hyperion Telecommunications; Intermedia; Adelphia Business Solutions; AT&T; Focal; Hunterdon, NJ Net-Tel Corporation; WorldCom IntelliSpace; WorldCom CLECs: 5 CLECs: 5 Operational Networks: 4 Operational Networks: 8 Off-Net Networks: 1 On-Net Networks: 1 51. Hartford, CT AT&T; Cox Communications; ICG AT&T; Choice One Communications; Conversent Communications; Intermedia; Net-Tel Corporation; Communications; Cox Communications; Global NorthEast Optic Network Services; WorldCom Crossing; Intermedia; Network Plus; PaeTec; WorldCom CLECs: 7 CLECs: 9 Operational Networks: 6 Operational Networks: 9 Off-Net Networks: 1 52. Monmouth-Ocean, NJ AT&T CLECs: 1 Operational Networks: 1
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MSA CLEC Networks – 1998 CLEC Networks – 2001 53. Raleigh, Durham, BTI; Eagle Communications; Intermedia; Net-Tel Adelphia Business Solutions; ALLTEL; AT&T; Chapel Hill, NC Corporation; Time Warner Telecom; US LEC; BTI; CTC Communications; Eagle WorldCom Communications; Intermedia; ITC^DeltaCom; Madison River Communications; Network Telephone; NewSouth Communications; NuVox Communications; Time Warner; US LEC; WorldCom CLECs: 7 CLECs: 15 Operational Networks: 10 Operational Networks: 29 Off-Net Networks: 1 On-Net Networks: 2 54. Memphis, TN-AR-MS Eagle Communications; Hyperion Adelphia Business Solutions; AT&T; Birch Telecommunications; Intermedia; NEXTLINK Telecom; Eagle Communications; ICG Communications (XO); Time Warner Telecom; US Communications; Intermedia; ITC^DeltaCom; LEC; WorldCom Mpower; Network Telephone; NewSouth Communications; NuVox Communications; Time Warner Telecom; US LEC; WorldCom; XO; Xspedius CLECs: 7 CLECs: 16 Operational Networks: 7 Operational Networks: 16 Off-Net Networks: 1 On-Net Networks: 2 55. Providence-Fall River- AT&T; CTC Communications; Intermedia; Net-Tel AT&T; Choice One Communications; Conversent Warwick, RI-MA Corporation; NorthEast Optic Network Services; Communications; Cox Communications; CTC RNK Communications; Intermedia; Log On America; Net2000; PaeTec; WorldCom CLECs: 6 CLECs: 10 Operational Networks: 4 Operational Networks: 10 Off-Net Networks: 2 On-Net Networks: 1 56. Jacksonville, FL e.spire; Florida Digital Network; Frontier Adelphia Business Solutions; ALLTEL; AT&T; Communications; Hyperion Telecommunications; BTI; e.spire; Florida Digital Network; Intermedia; Intermedia; ITC DeltaCom; MediaOne ITC^DeltaCom; Lightyear Communications; Telecommunications; Net-Tel Corporation; US NewSouth Communications; NuVox LEC Communications; US LEC CLECs: 9 CLECs: 12 Operational Networks: 8 Operational Networks: 15 Off-Net Networks: 1 On-Net Networks: 3 57. Rochester, NY AT&T; Eagle Communications; Frontier AT&T; Choice One Communications; Eagle Communications; Intermedia; Net-Tel ; Time Communications; Global Crossing; Intermedia; Warner Telecom; WorldCom Northland Communications; PaeTec; Time Warner Telecom CLECs: 7 CLECs: 8 Operational Networks: 7 Operational Networks: 8 On-Net Networks: 1 58. Grand Rapids- Net-Tel Corporation; WorldCom Choice One Communications; MichTel; TDS Muskegon-Holland, Metrocom; WorldCom MI CLECs: 2 CLECs: 4 Operational Networks: 1 Operational Networks: 8 Off-Net Networks: 1 59. West Palm Beach, FL AT&T; Intermedia; Net-Tel; Supra Florida Digital Network; Intermedia; Telecommunications & Information Systems ITC^DeltaCom; Mpower; Network Telephone; PaeTec; US LEC CLECs: 4 CLECs: 7 Operational Networks: 4 Operational Networks: 11 On-Net Networks: 3
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MSA CLEC Networks – 1998 CLEC Networks – 2001 60. Oklahoma City, OK Cox Communications; Intermedia; Logix AT&T; Birch Telecom; Cox Communications; Communications; Net-Tel Corporation; WinStar; Logix Communications; NuVox Communications; WorldCom WorldCom CLECs: 6 CLECs: 6 Operational Networks: 4 Operational Networks: 6 Off-Net Networks: 2 On-Net Networks: 1 61. Louisville, KY e.spire; Hyperion Telecommunications; ICG Adelphia Business Solutions; AT&T; e.spire; ICG Communications; Intermedia Communications; Intermedia; Lightyear Communications; NewSouth Communications; NuVox Communications; US LEC CLECs: 4 CLECs: 9 Operational Networks: 4 Operational Networks: 9 On-Net Networks: 1 62. Richmond-Petersburg, Hyperion Telecommunications; Intermedia; Adelphia Business Solutions; ALLTEL; Arbros VA MediaOne Telecommunications; Net2 Communications; AT&T; Broadslate Networks; Communications; Net-Tel; WorldCom BTI; Cavalier Telephone; Intermedia; Net2000; NTELOS; US LEC CLECs: 6 CLECs: 11 Operational Networks: 6 Operational Networks: 11 On-Net Networks: 2 63. Dayton-Springfield, ICG Communications; Intermedia. AT&T; Broadslate Networks; Choice One OH Communications; ICG Communications; Intermedia; KMC Telecom; McLeodUSA; NuVox Communications; Time Warner Telecom CLECs: 2 CLECs: 9 Operational Networks: 2 Operational Networks: 8 On-Net Networks: 2 64. Greenville- e.spire; Intermedia; ITC DeltaCom; NewSouth ALLTEL; Birch Telecom; BTI; e.spire; Intermedia; Spartanburg-Anderson, Communications ITC^DeltaCom; KMC Telecom; Network SC Telephone; NewSouth Communications; NuVox Communications CLECs: 4 CLECs: 10 Operational Networks: 5 Operational Networks: 13 On-Net Networks: 1 65. Fresno, CA GST Telecommunications; Net-Tel Corporation; Adelphia Business Solutions; ICG Pac West Telecom; WorldCom Communications; Pac-West Telecomm; WorldCom CLECs: 4 CLECs: 4 Operational Networks: 4 Operational Networks: 4 Off-Net Networks: 1 66. Birmingham, AL AT&T; e.spire; ICG Communications; Intermedia; Adelphia Business Solutions; AT&T; Birch ITC DeltaCom; WinStar Telecom; e.spire; ICG Communications; Intermedia; ITC^DeltaCom; Network Telephone; NewSouth Communications; US LEC; Xspedius CLECs: 6 CLECs: 11 Operational Networks: 5 Operational Networks: 13 Off-Net Networks: 1 On-Net Networks: 1 67. Albany-Schenectady- AT&T; Choice One Communications; CTC Adelphia Business Solutions; AT&T; Broadview Troy, NY Communications; Hyperion Telecommunications; Networks; Cablevision Lightpath; Choice One Intermedia; Net-Tel Corporation; Time Warner Communications; CTC Communications; Fairpoint Telecom; WorldCom Communications; Intermedia; PaeTec; Time Warner Telecom CLECs: 8 CLECs: 10 Operational Networks: 8 Operational Networks: 10 Off-Net Networks: 1 On-Net Networks: 1
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MSA CLEC Networks – 1998 CLEC Networks – 2001 68. Honolulu, HI GST Telecommunications; Time Warner Telecom; Time Warner Telecom WinStar CLECs: 3 CLECs: 1 Operational Networks: 3 Operational Networks: 1 69. Tucson, AZ Cox Communications; e.spire; GST Cox Communications; e.spire; McLeodUSA; Telecommunications; Net-Tel Corporation; WorldCom Telephone Plus; WinStar; WorldCom CLECs: 7 CLECs: 4 Operational Networks: 6 Operational Networks: 3 Off-Net Networks: 1 On-Net Networks: 1 70. Tulsa, OK e.spire; ICG Communications; Intermedia; Logix Birch Telecom; e.spire; Intermedia; Logix Communications; Net-Tel; WinStar; WorldCom Communications; NuVox Communications; WorldCom CLECs: 7 CLECs: 6 Operational Networks: 6 Operational Networks: 6 Off-Net Networks: 1 On-Net Networks: 1 71. Ventura, CA ICG Communications On-Net Networks: 1 72. Syracuse, NY AT&T; Eagle Communications; Hyperion Adelphia Business Solutions; AT&T; Broadview Telecommunications; Intermedia; Net-Tel Networks; Choice One Communications; CTSI; Corporation Eagle Communications; Global Crossing; Intermedia; Northland Communications CLECs: 5 CLECs: 9 Operational Networks: 5 Operational Networks: 10 73. Tacoma, WA AT&T; Electric Lightwave Advanced TelCom Group; Eschelon Telecom CLECs: 2 CLECs: 2 Operational Networks: 2 Operational Networks: 2 On-Net Networks: 1 74. El Paso, TX Digital Teleport; e.spire; Frontier Communications; Birch Telecom; e.spire; Ionex Telecommunications; Intermedia; Net-Tel Corporation Logix Communications CLECs: 5 CLECs: 4 Operational Networks: 4 Operational Networks: 3 Off-Net Networks: 1 On-Net Networks: 2 75. Omaha, NE AT&T; Convergent Communications; Cox ALLTEL; AT&T; Cox Communications; Communications; McLeodUSA McLeodUSA CLECs: 4 CLECs: 4 Operational Networks: 4 Operational Networks: 5 On-Net Networks: 1 76. Akron, OH ICG Communications Choice One Communications; Global Crossing; ICG Communications; KMC Telecom; NuVox Communications; XO CLECs: 1 CLECs: 6 Operational Networks: 1 Operational Networks: 6 77. Albuquerque, NM e.spire; GST Telecommunications; Net-Tel e.spire; McLeodUSA; NTS Communications; Pac- Corporation; WorldCom West Telecomm; WorldCom CLECs: 4 CLECs: 5 Operational Networks: 3 Operational Networks: 4 Off-Net Networks: 1 On-Net Networks: 1
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MSA CLEC Networks – 1998 CLEC Networks – 2001 78. Knoxville, TN AT&T; Eagle Communications; Hyperion Adelphia Business Solutions; AT&T; Birch Telecommunications; Intermedia; Net-Tel Telecom; BTI Telecom; Eagle Communications; Corporation; US LEC; WorldCom Intermedia; NewSouth Communications; NuVox Communications; US LEC; WorldCom CLECs: 7 CLECs: 10 Operational Networks: 6 Operational Networks: 9 Off-Net Networks: 1 On-Net Networks: 3 79. Bakersfield, CA GST Telecommunications; Net-Tel Corporation; AT&T; Pac-West Telecomm; Verado Holdings; Pac West Telecomm; WorldCom WorldCom CLECs: 4 CLECs: 4 Operational Networks: 3 Operational Networks: 3 Off-Net Networks: 1 On-Net Networks: 1 80. Gary, IN AT&T CLECs:1 Networks: 1 81. Allentown-Bethlehem- Hyperion Telecommunications; NEXTLINK Adelphia Business Solutions; Broadslate Networks; Easton, PA Communications (XO); RCN Choice One Communications; RCN; XO CLECs: 3 CLECs: 5 Operational Networks: 6 Operational Networks: 8 82. Harrisburg-Lebanon- Conectiv Communications; CTSI; Hyperion Adelphia Business Solutions; Arbros Carlisle, PA Telecommunications; Intermedia; NEXTLINK Communications; Broadslate Networks; Choice One Communications (XO) Communications; CTSI; Intermedia; XO CLECs: 5 CLECs: 7 Operational Networks: 5 Operational Networks: 7 On-Net Networks: 1 83. Scranton-Wilkes- CTSI; Hyperion Telecommunications; NEXTLINK Adelphia Business Solutions; Choice One Barre-Hazleton, PA Communications (XO) Communications; CTSI; Fairpoint Communications; XO CLECs: 3 CLECs: 5 Operational Networks: 7 Operational Networks: 11 84. Toledo, OH Buckeye TeleSystem; Intermedia; Net-Tel; ALLTEL; Buckeye TeleSystem; ICG WorldCom Communications; Intermedia; KMC Telecom; WorldCom CLECs: 4 CLECs: 6 Operational Networks: 4 Operational Networks: 7 85. Youngstown-Warren, Net-Tel McLeodUSA OH CLECs: 1 CLECs: 1 Operational Networks: 1 On-Net Networks: 1 86. Baton Rouge, LA American MetroCom; e.spire; Hyperion Adelphia Business Solutions; e.spire; Telecommunications; Intermedia; ITC DeltaCom; ITC^DeltaCom; Intermedia; KMC Telecom; KMC Telecom; Net-Tel Corporation; State Network Telephone; NewSouth Communications; Communications; US Unwired Xspedius CLECs: 9 CLECs: 8 Operational Networks: 8 Operational Networks: 6 Off-Net Networks: 1 On-Net Networks: 2 87. Sarasota-Bradenton, KMC Telecom Intermedia; ITC^DeltaCom; KMC Telecom; FL NewSouth Communications CLECs: 1 CLECs: 4 Operational Networks: 1 Operational Networks: 5 On-Net Networks: 1
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MSA CLEC Networks – 1998 CLEC Networks – 2001 88. Wilmington-Newark, AT&T; Conectiv Communications; Focal; Hyperion Adelphia Business Solutions; PaeTec DE-MD Telecommunications; Net-Tel; WorldCom CLECs: 6 CLECs: 2 Operational Networks: 7 Operational Networks: 2 89. Springfield, MA AT&T; CTC Communications; Eagle Adelphia Business Solutions; AT&T; Choice One Communications; Net-Tel; NorthEast Optic Communications; CTC Communications; Eagle Network Services; WorldCom Communications; Fairpoint Communications; NECLEC; WorldCom CLECs: 6 CLECs: 8 Operational Networks: 7 Operational Networks: 9 On-Net Networks: 1 90. Ann Arbor, MI KMC Telecom; US MidTel Choice One Communications; KMC Telecom; MichTel; Mpower; TDS Metrocom CLECs: 2 CLECs: 5 Operational Networks: 2 Operational Networks: 9 91. Little Rock-North e.spire; Hyperion Telecommunications; Intermedia; Adelphia Business Solutions; ALLTEL; e.spire; Little Rock, AR Net-Tel Corporation; WorldCom Intermedia; ITC^DeltaCom; Logix Communications; NuVox Communications; WorldCom CLECs: 5 CLECs: 8 Operational Networks: 4 Operational Networks: 13 Off-Net Networks: 1 92. Stockton-Lodi, CA Net-Tel; Pac West Telecom; WorldCom Pac-West Telecomm; WorldCom
CLECs: 3 CLECs: 2 Operational Networks: 3 Operational Networks: 2 93. Charleston-North e.spire; Intermedia; Knology Holdings ALLTEL; Birch Telecom; BTI; e.spire; Intermedia; Charleston, SC ITC^DeltaCom; KMC Telecom; Knology Broadband; Network Telephone; NewSouth Communications; US LEC CLECs: 3 CLECs: 11 Operational Networks: 3 Operational Networks: 14 On-Net Networks: 6 94. Jersey City, NJ AT&T; Intermedia; Net-Tel Corporation; AT&T; Focal; IntelliSpace; Intermedia; RCN; Time WorldCom Warner Telecom
CLECs: 4 CLECs: 6 Operational Networks: 3 Operational Networks: 5 Off-Net Networks: 1 On-Net Networks: 3 95. McAllen-Edinburg- CapRock Communications Ionex Telecommunications Mission, TX CLECs: 1 CLECs: 1 Operational Networks: 1 On-Net Networks: 1 96. Mobile, AL e.spire; Hyperion Telecommunications; ITC Adelphia Business Solutions; Birch Telecom; DeltaCom; Net-Tel Corporation e.spire; ITC^DeltaCom; Network Telephone; NewSouth Communications; US LEC; Xspedius CLECs: 4 CLECs: 8 Operational Networks: 3 Operational Networks: 7 Off-Net Networks: 1 On-Net Networks: 1
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MSA CLEC Networks – 1998 CLEC Networks – 2001 97. Vallejo-Fairfield-Napa, Not Available Not Available CA 98. New Haven-Meriden, AT&T; Cox Communications; CTC AT&T; Choice One Communications; Conversent CT Communications; Intermedia; NorthEast Optic Communications; Cox Communications; CTC Network Services; RNK Communications; PaeTec CLECs: 6 CLECs: 6 Operational Networks: 6 Operational Networks: 6 Off-Net Networks: 1 99. Columbia, SC BTI; e.spire; Intermedia; ITC DeltaCom Adelphia Business Solutions; ALLTEL; Birch Telecom; BTI; e.spire; Intermedia; ITC^DeltaCom; KMC Telecom; Network Telephone; NewSouth Communications; NuVox Communications; Time Warner Telecom CLECs: 4 CLECs: 12 Operational Networks: 4 Operational Networks: 10 On-Net Networks: 2 100. Wichita, KS Advanced Communications Group; Birch Telecom; Adelphia Business Solutions; Birch Telecom; Ionex Hyperion Telecommunications Telecommunications; Logix Communications; NuVox Communications CLECs: 3 CLECs: 5 Operational Networks: 3 Operational Networks: 5 101. Colorado Springs, CO Hyperion Telecommunications; e.spire; Net-Tel AT&T; e.spire; ICG Communications; Corporation McLeodUSA; SunWest Communications; Vanion CLECs: 3 CLECs: 6 Operational Networks: 2 Operational Networks: 6 Off-Net Networks: 1 On-Net Networks: 1 102. Worcester, MA-CT AT&T; NorthEast Optic Network Services AT&T; Choice One Communications; Conversent Communications; Lightship Telecom; PaeTec CLECs: 2 CLECs: 5 Operational Networks: 2 Operational Networks: 5 On-Net Networks: 1 103. Fort Wayne, IN KMC Telecom; US Xchange Adelphia Business Solutions; Choice One Communications; KMC Telecom CLECs: 2 CLECs: 3 Operational Networks: 2 Operational Networks: 3 Off-Net Networks: 1 104. Melbourne, Titusville, Florida Digital Network; ITC^DeltaCom; Palm Bay, FL NewSouth Communications CLECs: 3 Operational Networks: 4 On-Net Networks: 2 105. Lakeland-Winter NewSouth Communications Haven, FL CLECs: 1 Operational Networks: 1 106. Daytona Beach, FL Intermedia; KMC Telecom Florida Digital Network; Intermedia; ITC^DeltaCom; KMC Telecom; NewSouth Communications; PaeTec; US LEC CLECs: 2 CLECs: 7 Operational Networks: 2 Operational Networks: 6 On-Net Networks: 2
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MSA CLEC Networks – 1998 CLEC Networks – 2001 107. Johnson City- NA Communications; Net-Tel Corporation; P.V. US LEC Kingsport-Bristol, TN- Telecommunications VA CLECs: 3 CLECs: 1 Operational Networks: 2 Operational Networks: 1 Off-Net Networks: 1 On-Net Networks: 1 108. Lexington, KY e.spire; Hyperion Telecommunications Adelphia Business Solutions; Duro Communications; e.spire; ICG Communications; Lightyear Communications; NewSouth Communications; NuVox Communications CLECs: 2 CLECs: 7 Operational Networks: 2 Operational Networks: 7 On-Net Networks: 1 109. Lancaster, PA Conectiv Communications; CTSI; Hyperion Adelphia Business Solutions; CTSI; XO Telecommunications; NEXTLINK Communications (XO) CLECs: 4 CLECs: 3 Operational Networks: 4 Operational Networks: 3 110. Augusta-Aiken, GA Intermedia; ITC DeltaCom; KMC Telecom; ALLTEL; Birch Telecom; Intermedia; Knology Holdings; Net-Tel Corporation ITC^DeltaCom; KMC Telecom; Knology Broadband; NewSouth Communications CLECs: 5 CLECs: 7 Operational Networks: 4 Operational Networks: 6 Off-Net Networks: 1 On-Net Networks: 6 111. Chattanooga TN-GA AT&T; e.spire; Intermedia; WinStar AT&T; Birch Telecom; BTI; e.spire; Intermedia; ITC^DeltaCom; KMC Telecom; Network Telephone; NewSouth Communications; US LEC CLECs: 4 CLECs: 10 Operational Networks: 3 Operational Networks: 9 Off-Net Networks: 1 On-Net Networks: 3 112. Lansing-East Lansing, Net-Tel Corporation; WorldCom Choice One Communications; KMC Telecom; TDS MI Metrocom; WorldCom CLECs: 2 CLECs: 4 Operational Networks: 1 Operational Networks: 4 Off-Net Networks: 1 113. Kalamazoo-Battle CTS Telecom; US Xchange Choice One Communications; CTS Telecom; TDS Creek, MI Metrocom CLECs: 2 CLECs: 3 Operational Networks: 6 Operational Networks: 3 114. Santa Rosa, CA ICG Communications Advanced TelCom Group; ICG Communications CLECs: 1 CLECs: 2 Operational Networks: 1 Operational Networks: 4 On-Net Networks: 1 115. Des Moines, IA Convergent Communications; McLeodUSA AT&T; Hickory Tech; McLeodUSA CLECs: 2 CLECs: 3 Operational Networks: 2 Operational Networks: 6 116. Bridgeport, CT AT&T; Cablevision Lightpath; CTC Cablevision Lightpath; CTC Communications; Communications; NorthEast Optic Network IntelliSpace Services; RNK CLECs: 5 CLECs: 3 Operational Networks: 4 Operational Networks: 2 Off-Net Networks: 1 On-Net Networks: 1
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MSA CLEC Networks – 1998 CLEC Networks – 2001 117. Modesto, CA Not Available Not Available 118. Flint, MI Ovation Communications MichTel CLECs: 1 CLECs: 1 Operational Networks: 1 Operational Networks: 2 119. Jackson, MS e.spire; Hyperion Telecommunications; Intermedia; Adelphia Business Solutions; AT&T; e.spire; ITC DeltaCom; Net-Tel Corporation; WorldCom Intermedia; ITC^DeltaCom; Network Telephone; NewSouth Communications; WorldCom; Xspedius CLECs: 6 CLECs: 9 Operational Networks: 5 Operational Networks: 9 Off-Net Networks: 1 120. Fort Myers-Cape Intermedia; KMC Telecom Intermedia; ITC^DeltaCom; KMC Telecom; Coral, FL NewSouth Communications; US LEC CLECs: 2 CLECs: 5 Operational Networks: 2 Operational Networks: 5 121. Spokane, WA Convergent Communications; Electric Lightwave; AT&T; McLeodUSA; XO GST Telecommunications; NEXTLINK Communications (XO); WinStar CLECs: 5 CLECs: 3 Operational Networks: 4 Operational Networks: 3 Off-Net Networks: 1 On-Net Networks: 2 122. Madison, WI Bresnan Communications; Dakota Services; KMC AT&T; Choice One Communications; KMC Telecom; TDS MetroCom; US Xchange Telecom; McLeodUSA; TDS Metrocom CLECs: 5 CLECs: 5 Operational Networks: 5 Operational Networks: 6 123. Pensacola, FL Intermedia; KMC Telecom Cox Communications; Intermedia; ITC^DeltaCom; KMC Telecom; Madison River Communications; Network Telephone; NewSouth Communications CLECs: 2 CLECs: 7 Operational Networks: 2 Operational Networks: 7 124. Boise City, ID Electric Lightwave; GST Telecommunications; Net- McLeodUSA; Pac-West Telecomm Tel Corporation; WinStar CLECs: 4 CLECs: 2 Operational Networks: 2 Operational Networks: 2 Off-Net Networks: 2 125. Santa Barbara-Santa Cox Communications; GST Telecommunications Cox Communications; ICG Communications Maria-Lompoc CLECs: 2 CLECs: 2 Operational Networks: 2 Operational Networks: 2 126. Canton-Massillon, OH Not Available Not Available 127. Saginaw-Bay City- Bresnan Communications; Ovation Midland, MI Communications CLECs: 2 Operational Networks: 4 128. Salinas, CA Pac West Telecomm Pac-West Telecomm CLECs: 1 CLECs: 1 Operational Networks: 1 Operational Networks: 1 129. Corpus Christi, TX CapRock Communications; e.spire; ICG Birch Telecom; e.spire; ICG Communications; Communications; KMC Telecom; Net-Tel KMC Telecom; Logix Communications Corporation; NEXTLINK Communications (XO); WorldCom CLECs: 7 CLECs: 5 Operational Networks: 6 Operational Networks: 5 Off-Net Networks: 1 On-Net Networks: 1
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MSA CLEC Networks – 1998 CLEC Networks – 2001 130. Beaumont-Port Arthur, CapRock Communications Birch Telecom; Ionex Telecommunications; TX ITC^DeltaCom CLECs: 1 CLECs: 3 Operational Networks: 1 Operational Networks: 1 On-Net Networks: 3 131. Newburgh, NY-PA Not Available Not Available 132. York, PA CTSI; Hyperion Telecommunications Adelphia Business Solutions; CTSI CLECs: 2 CLECs: 2 Operational Networks: 2 Operational Networks: 2 133. Shreveport-Bossier e.spire; Hyperion Telecommunications; Intermedia; Adelphia Business Solutions; CenturyTel; e.spire; City, LA KM Telecom Intermedia; ITC^DeltaCom; KMC Telecom; Network Telephone; Xspedius CLECs: 4 CLECs: 8 Operational Networks: 4 Operational Networks: 8 134. Lafayette, LA American MetroComm; Hyperion Adelphia Business Solutions; ITC^DeltaCom; Telecommunications Network Telephone; NewSouth Communications; Xspedius CLECs: 2 CLECs: 5 Operational Networks: 2 Operational Networks: 6 135. Lawrence, MA-NH AT&T; NorthEast Optic Network Services; RNK; Intermedia Vitts CLECs: 4 CLECs: 1 Operational Networks: 3 Operational Networks: 1 Off-Net Networks: 1 136. Visalia-Tulare- Not Available Not Available Porterville, CA 137. Reading, PA CTSI; Hyperion Telecommunications; NEXTLINK Adelphia Business Solutions; CEI Networks; CTSI; Communications (XO) XO CLECs: 3 CLECs: 4 Operational Networks: 3 Operational Networks: 4 138. Davenport-Moline- McLeodUSA; Net-Tel Corporation AT&T; McLeodUSA Rock Island, IA-IL CLECs: 2 CLECs: 2 Operational Networks: 1 Operational Networks: 2 Off-Net Networks: 1 139. Rockford, IL Dakota Services; US Xchange Choice One Communications; TDS Metrocom CLECs: 2 CLECs: 2 Operational Networks: 2 Operational Networks: 2 140. Provo-Orem, UT Electric Lightwave; Net-Tel Corporation; McLeodUSA; XO NEXTLINK Communications (XO); WorldCom CLECs: 4 CLECs: 2 Operational Networks: 4 Operational Networks: 1 Off-Net Networks: 1 On-Net Networks: 1 141. Appleton-Oshkosh- Dakota Services; TDS MetroCom; US Xchange Choice One Communications; TDS Metrocom; Neenah, WI McLeodUSA CLECs: 3 CLECs: 3 Operational Networks: 4 Operational Networks: 6 On-Net Networks: 2 142. Biloxi-Gulfport- American MetroCom; ITC DeltaCom ITC^DeltaCom; Madison River Communications; Pascagoula, MS Network Telephone; NewSouth Communications CLECs: 2 CLECs: 4 Operational Networks: 3 Operational Networks: 4 On-Net Networks: 1
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MSA CLEC Networks – 1998 CLEC Networks – 2001 143. Peoria-Pekin, IL McLeodUSA Madison River Communications; McLeodUSA CLECs: 1 CLECs: 2 Operational Networks: 4 Operational Networks: 5 On-Net Networks: 4 144. Huntsville, AL Intermedia; ITC DeltaCom; KMC Telecom; Intermedia; ITC^DeltaCom; KMC Telecom; Knology Holdings Knology Broadband; Network Telephone; NewSouth Communications; US LEC CLECs: 4 CLECs: 7 Operational Networks: 4 Operational Networks: 9 On-Net Networks: 3 145. Salem, OR Advanced TelCom Group; AT&T; Eschelon Telecom; Integra Telecom; McLeodUSA CLECs: 5 Operational Networks: 7 On-Net Networks: 2 146. Atlantic-Cape May, NJ Conectiv Communications AT&T CLECs: 1 CLECs: 1 Operational Networks: 1 Operational Networks: 1 147. Trenton, NJ AT&T; Conectiv Communications; Net-Tel AT&T Corporation; WorldCom CLECs: 4 Operational Networks: 5 CLECs: 1 Off-Net Networks: 1 Operational Networks: 1 148. Hamilton-Middletown, Intermedia OH CLECs: 1 Operational Networks: 1 149. Stamford-Norwalk, CT Cablevision Lightpath; Net-Tel Corporation; AT&T; Cablevision Lightpath; Intellispace; PaeTec; NorthEast Optic Network Services; RNK; WinStar; WorldCom WorldCom CLECs: 6 CLECs: 5 Operational Networks: 7 Operational Networks: 6 Off-Net Networks: 1 On-Net Networks: 2 150. Reno, NV Net-Tel; WorldCom WorldCom CLECs: 2 CLECs: 1 Operational Networks: 2 Operational Networks: 1 Sources: NPRG CLEC Report 2002, 15th ed.; NPRG CLEC Report 1999, 10th ed.
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APPENDIX L. ESTIMATING CLEC SPECIAL ACCESS MARKET SHARE
According to the FCC’s most recent Telecommunications Industry Revenues report, the Bell companies earned $13.3 billion in the provision of “local private line and special access” and “long distance private line services” in 2000.1 Special access revenues are the sum of these two revenue categories.2
The problem with using the FCC’s revenue data to estimate CLEC special access revenues is that several CLECs – including the two largest, AT&T and WorldCom – report their special revenues as both CLECs and “toll carriers.”3 For example, when AT&T and WorldCom use their local facilities to supply special access to their long distance network, they typically report that revenue as toll carriers.4 Not all of the local and long distance private line revenue that these carriers report as toll carriers is necessarily special access revenue, however, and there is no precise way to back out the portion that is.
Rather than engage in guesswork, we have relied on an alternative source for CLEC special access revenue. According to New Paradigm Resource Group’s CLEC Report 2002 (15th ed. 2002), CLECs earned $8.4 billion from the provision of special access/private line services in 2000.5 Using the New Paradigm figure for CLEC special access revenues and the FCC figure for BOC special access revenues yields a CLEC market share of approximately 39 percent in 2000.
Even using FCC data, however, yields a very high market share. According to the most recent Telecommunications Industry Revenues report, CLECs earned $4.1 billion in the provision of local private line and special access and long distance private line services in 2000.6 In addition, toll carriers reported $100 million in local private line revenues.7 AT&T also has
1 FCC Telecommunications Industry Revenues, 2002 ed. at 13 (Table 5, Lines 305 & 312), 17 (Table 6, Lines 406 & 415). 2 The FCC defines “long distance private line services” to “include revenues from dedicated circuits, private switching arrangements, and/or predefined transmission paths, extending beyond the basic service area. This category should include revenues from the resale of special access services.” FCC, Telecommunications Reporting Worksheet, FCC Form 499-A, Instructions for Completing the Worksheet for Filing Contributions to Telecommunications Relay Service, Universal Service, Number Administration, and Local Number Portability Support Mechanisms, at 18 (Feb. 2001) (emphasis added). AT&T has acknowledged that special access revenues represent the sum of these two categories. See Declaration of C. Michael Pfau on Behalf of AT&T Corp. ¶¶ 13-14, attached to Reply Comments of AT&T Corp., Implementation of Local Competition Provisions of the Telecommunications Act of 1996, CC Docket No. 96-98 (FCC filed Apr. 30, 2001) (“Pfau Decl.”). 3 See id. ¶ 16 (“Arguably, MCI/WorldCom and AT&T fall within the category of ‘Toll Carrier’ and, as a result, any self-supplied special access may not be included in the CLEC figure.”). 4 See id. ¶ 17 (“self-supplied access would not be encompassed in the figures and, hence, the need for an adjustment”). 5 NPRG CLEC Report 2002, 15th ed., Ch. 3 at Table 10. 6 FCC Telecommunications Industry Revenues, 2002 ed. at 14 (Table 5, Lines 305 & 312), 18 (Table 6, Lines 406 & 415). 7 FCC Telecommunications Industry Revenues, 2002 ed. at 16 (Table 5, Line 305), 19 (Table 6, Line 406).
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acknowledged that the access that AT&T and WorldCom supply to themselves was worth approximately $900 million as of 1999.8 Assuming that the value of these two carriers’ self- supplied special access increased in 2000 by the same amount as it did between 1998 and 1999, the value of this self-supply was approximately $1.1 billion in 2001.9 That brings total CLEC special access revenues to $5.3 billion under FCC data. This represents a market share of 28 percent.
This figure is undoubtedly too low, however. First, it fails to account for self-supply by long distance carriers other than AT&T and WorldCom, even though many such carriers have local access facilities of their own, and can reasonably be expected to use these facilities to self- provide access to some extent. Second, it excludes completely any special access revenue that AT&T and other interexchange carriers report as long distance private line revenue and that is earned by reselling the services of other CLECs and ILECs. This amount is substantial, as the interexchange carriers are the largest special access customers of both many CLECs and the ILECs, and purchase such services in order to resell them to end users.10
Finally, CLECs’ share of the special access market was likely even higher in 2001 than it was in 2000. For example, according to the FCC’s most recent Local Telephone Competition report, CLECs’ share of large business lines increased from 17.5 percent to 19.1 percent from December 2000 to June 2001.11 New Paradigm reports that CLEC special access revenue grew by more than 20 percent between 2000 and 2001.12
8 Pfau Decl. ¶ 16. 9 Pfau Decl. ¶ 16 (value of AT&T and WorldCom self-supply increased from $627 million in 1998 to $856 million in 1999). 10 AT&T has acknowledged that adding this total to CLEC local access and private line revenue would bring total special access revenues in line with the totals reported by New Paradigm. See Pfau Decl. ¶ 19 n.4. AT&T has nonetheless argued that it is appropriate to exclude such revenues, but neither of its explanations provides an adequate justification for its approach. First, AT&T has claimed that CLEC/IXC long distance private line revenues should not be counted because the ILECs do not typically compete in the provision of long distance private line service. But the extent to which ILECs provide long distance private service obviously is irrelevant; the only relevant question is the extent to which competing carriers provide private line and special access services that compete with the private line and special access service that ILECs provide. Second, AT&T has claimed that including in the market share calculation the toll carrier special access revenues reported as long distance private line would lead to double counting because ILEC wholesale revenues are included as a cost for Toll Carrier services and reflected in their end user revenues. But including the revenue that competing carriers earn from leasing a CLECs’ or ILECs’ facilities or reselling their service is not necessarily double counting, because the competing carrier invariably marks up its own retail service to end users over and above the wholesale price. In addition, CLECs often will supplement the services they resell with one or more value-added services to distinguish themselves. In any event, even assuming that there would be some double counting, this is hardly an argument for excluding this entirely as CLEC revenue. Such revenue clearly is CLEC revenue, even if it is earned from customers that are not served entirely over the CLEC’s own facilities. 11 FCC Local Competition Report, Feb. 2002 ed. at Table 2. 12 NPRG CLEC Report 2002, 15th ed., Ch. 3 at Table 11.
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APPENDIX M. ADDITIONAL SOURCES
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AT&T/TCG Application Application, Teleport Communications Group, Inc., Transferor, AT&T Corp. Transferee, Application for Authority Pursuant to Section 214 of the Communications Act of 1934, as Amended, for Transfer of Control of Authorization To Provide International Facilities-Based and Resold Communications Services, CC Docket No. 98-24 (FCC filed Feb. 3, 1998).
Broadband 2001 McKinsey & Co. and JP Morgan H&Q, Broadband 2001 (Apr. 2, 2001).
CSFB 3Q01 CLEC Vital Signs Review M. Kastan, et al., Credit Suisse First Boston, Telecom Services: CLECs – Third Quarter Vital Signs Review (Dec. 2001).
CSFB 4Q00 CLEC Vital Signs Review M. Kastan, et al., Credit Suisse First Boston, Telecom Services – CLECs (Apr. 11, 2001).
CTIA’s Semi-Annual Wireless Industry CTIA, CTIA’s Semi-Annual Wireless Industry Survey Results, June 1985 Survey Results to June 2001, http://www.wow-com.com/pdf/ wireless_survey_2000a.pdf.
D. Culver, Construction Boom for D. Culver, Construction Boom for Colocation, Interactive Week (Mar. Colocation 13, 2000), http://www.zdnet.com/intweek/stories/news/ 0,4164,2468788,00.html.
DOJ Arkansas/Missouri Evaluation Evaluation of U.S. Department of Justice, Joint Application by SBC Communications Inc., Southwestern Bell Telephone Company, and Southwestern Bell Communications Services, Inc. d/b/a Southwestern Bell Long Distance for Provision of In-Region, InterLATA Services in Arkansas and Missouri, CC Docket 01-194 (FCC filed Sept. 24, 2001).
DOJ Kansas/Oklahoma Evaluation Evaluation of U.S. Department of Justice, Joint Application by SBC Communications Inc., Southwestern Bell Telephone Company, and Southwestern Bell Communications Services, Inc. d/b/a Southwestern Bell Long Distance for Provision of In-Region, InterLATA Services in Kansas and Oklahoma, CC Docket No. 00-217 (FCC filed Dec. 4, 2000).
DOJ Massachusetts Evaluation Evaluation of U.S. Department of Justice, Application by Verizon New England Inc., Bell Atlantic Communications, Inc. (d/b/a Verizon Long Distance), NYNEX Long Distance Company (d/b/a Verizon Enterprise Solutions), and Verizon Global Networks Inc. for Authorization to Provide In-Region, InterLATA Services in Massachusetts, CC Docket No. 00-176 (FCC filed Oct. 27, 2000).
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Gartner U.S. Residential Wireline Report M. Schoener, Gartner, U.S. Residential Wireline Voice Access Lines Head South, Revenue Heads North (Aug. 31, 2001).
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IDC Wireless Displacement Report S. Ellison, IDC, Wireless Displacement of Wireline Forecast and Analysis, 2001-2005 (Dec. 2001).
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JP Morgan Cable Industry Report J. Bazinet & D. Pinsker, JP Morgan H&Q, The Cable Industry (Nov. 2, 2001).
JP Morgan Telecom Services 2001 Report T.A. Jacobs, et al., JP Morgan H&Q, Telecom Services 2001 (Nov. 2, 2001).
J. Yoshida, Modem Issues Put Cable Voice- J. Yoshida, Modem Issues Put Cable Voice-Over-IP Service On Hold, EE Over-IP Service on Hold Times (June 15, 2001), http://www.eetimes.com/story/ OEG20010615S0116.
Legg Mason Wireless Industry Scorecard S. Butson, et al., Legg Mason, 3Q 2001 Wireless Industry Scorecard (2001).
Lehman/McKinsey MAN Report Lehman Brothers and McKinsey & Co., The Future of Metropolitan Area Networks (Aug. 24, 2001).
M. Reddig, Softswitches Emerge from the M. Reddig, Softswitches Emerge from the Shadows, clec.com (May Shadows 2001), http://www.clec.com/index.asp?page=SRarticle.asp& articleID=530&SRCatName=&Ads=0
M. Reddig, Top 10 Advances in Switching M. Reddig, Top 10 Advances in Switching, clec.com (May 2001), http://www.clec.com.
Morgan Stanley Cable Modem/xDSL R.A. Bilotti, et al., Morgan Stanley, Dean Witter, Cable Modem and Report xDSL Conference Call (Jan. 18, 2002).
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NCTA Cable Telephony Report NCTA, Cable Telephony: Offering Consumers Competitive Choice (July 2001).
NCTA Industry Statistics NCTA, Industry Statistics, http://www.ncta.com/industry_overview/indStat.cfm?indOverviewID=2.
NPRG CIOC Report 2001 New Paradigm Resources Group, Inc., Competitive IOC Report 2001 (1st ed. 2001).
NPRG CLEC Report 1999, 10th ed. New Paradigm Resource Group, Inc., The 1999 CLEC Report, Ch. 2 at 3 (10th ed. 1999).
NPRG CLEC Report 2000, 12th ed. New Paradigm Resources Group, CLEC Report 2000, Ch. 1 (12th ed. 2000).
NPRG CLEC Report 2001, 13th ed. New Paradigm Resources Group, Inc., CLEC Report 2001 (13th ed. 2001).
NPRG CLEC Report 2001, 14th ed. New Paradigm Resources Group, Inc., CLEC Report 2001 (14th ed. 2001).
NPRG CLEC Report 2002, 15th ed. New Paradigm Resources Group, Inc., CLEC Report 2002 (15th ed. 2002).
Salomon Smith Barney Battle for High- N. Gupta, et al., Salomon Smith Barney, The Battle for the High-Speed Speed Data Report Data Subscriber: Cable vs. DSL (Aug. 20, 2001).
Stratecast ATM/Frame Relay Report Stratecast Partners, ATM and Frame Relay Market Assessment, Data/Internet Services Growth Strategies, Vol. II, No. 10 (Sept. 2001).
Strategis Group U.S. IP Cable Telephony K. Kennebeck, et al., Strategis Group, U.S. IP Cable Telephony: Report Operator, Are You There? (Aug. 2001).
TeleChoice DSL Deployment Summary xDSL.com, TeleChoice 4Q01 DSL Deployment Summary, http://www.xdsl.com/content/resources/deployment_info.asp.
UNE Fact Report UNE Fact Report, attached to Comments of the United States Telephone Association, Implementation of the Local Competition Provisions in the Telecommunications Act of 1996, CC Docket No. 96-98 (FCC filed May 26, 1999).
Wall Street Transcript Corp. Interview, Wall Street Transcript Corp., Investext Rpt. No. 8002421, CEO John Peters – Sigma Networks Interview: John Peters – Sigma Networks – Company Report (Oct. 16, 2001)
Yankee Group Critical Mass Report M. Goodman, Yankee Group, Residential Broadband: Cable Modems and DSL Reach Critical Mass, Media and Entertainment Strategies, Vol. 5, No. 3 (Mar. 2001).
Yankee Group Consumer Broadband I. Khan, et al., Yankee Group, Cable Modem Providers Continue to Lead Report the High-Speed Internet Charge: The Yankee Group’s Predictions on Consumer Broadband Services, Consumer Market Convergence, Vol. 18, No. 11 (Aug. 2001).
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Yankee Group Fiber and Fixed Wireless Yankee Group, Fiber-to-the-Curb, Fiber-to-the-Home, Fixed Wireless, Report and Powerline Communications: Threatening Cable Modem’s and DSL’s Hegemony?, Consumer Market Convergence, Vol. 18, No. 13 (Nov. 6, 2001)
Yankee Group State of the Wireless Union Yankee Group, The State of the Wireless Union – 2001 Edition (Nov. 26, Report 2001).
ZDNet Tech Update: Advantages of a Dialing for Fewer Dollars, Advantages of Network PBX, ZDNet Tech Network PBX Update, http://techupdate.zdnet.com/techupdate/stories/main/ 0,14179,2805999-5,00.html
FCC Sources Cited as Source
Arkansas/Missouri Order Joint Application by SBC Communications Inc., Southwestern Bell Telephone Company, and Southwestern Bell Communications Services, Inc. d/b/a Southwestern Bell Long Distance Pursuant to Section 271 of the Telecommunications Act of 1996 To Provide In-Region, InterLATA Services in Arkansas and Missouri, Memorandum Opinion and Order, 16 FCC Rcd 20719 (2001).
AT&T/MediaOne Order Applications for Consent to the Transfer of Control of Licenses and Section 214 Authorizations from MediaOne Group, Inc., Transferor, to AT&T Corp. Transferee, Memorandum Opinion and Order, 15 FCC Rcd 9816 (2000).
Bell Atlantic/NYNEX Merger Order Applications of NYNEX Corporation, Transferor, and Bell Atlantic Corporation, Transferee, for Consent to Transfer Control of NYNEX Corporation and Its Subsidiaries, Memorandum Opinion and Order, 12 FCC Rcd 19985 (1997).
Connecticut Order Application of Verizon New York Inc., Verizon Long Distance, Verizon Enterprise Solutions, Verizon Global Networks Inc., and Verizon Select Services Inc., for Authorization to Provide In-Region, InterLATA Services in Connecticut, Memorandum Opinion and Order, 16 FCC Rcd 14147 (2001).
Eighth Video Competition Report Annual Assessment of the Status of Competition in the Market for the Delivery of Video Programming, Eighth Annual Report, 17 FCC Rcd 1244 (2002)
First Advanced Services Report Inquiry Concerning the Deployment of Advanced Telecommunications Capability to All Americans in a Reasonable and Timely Fashion, and Possible Steps to Accelerate Such Deployment Pursuant to Section 706 of the Telecommunications Act of 1996, Report, 14 FCC Rcd 2398 (1999).
Fourth CMRS Report Implementation of Section 6002(b) of the Omnibus Budget Reconciliation Act of 1993; Annual Report and Analysis of Competitive Market Conditions With Respect to Commercial Mobile Services, Fourth Report, 14 FCC Rcd 10145 (1999).
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FCC Local Competition Report, Dec. 1998 Ind. Anal. Div., FCC, Local Competition (Dec. 1998). ed.
FCC Local Competition Report, Aug. 1999 Ind. Anal. Div., FCC, Local Competition: August 1999 (Aug. 1999). ed.
FCC Local Competition Report, Ind. Anal. Div., FCC, Local Telephone Competition: Status as of May 2001 ed. December 31, 2000 (May 2001).
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FCC Telecommunications Industry J. Lande & K. Lynch, Ind. Anal. Div., FCC, Telecommunications Revenues, 2002 ed. Industry Revenues 2000 (Jan. 2002).
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Kansas/Oklahoma Order Joint Application by SBC Communications Inc., Southwestern Bell Telephone Company, and Southwestern Bell Communications Services, Inc. d/b/a Southwestern Bell Long Distance for Provision of In-Region, InterLATA Services in Kansas and Oklahoma, Memorandum Opinion and Order, 16 FCC Rcd 6237 (2001).
Line Sharing Order Deployment of Wireline Services Offering Advanced Telecommunications Capability and Implementation of the Local Competition Provisions of the Telecommunications Act of 1996, Third Report and Order in CC Docket No. 98-147 and Fourth Report and Order in CC Docket No. 96-98, 14 FCC Rcd 20912 (1999).
Massachusetts Order Application of Verizon New England Inc., Bell Atlantic Communications, Inc. (d/b/a Verizon Long Distance), NYNEX Long Distance Company (d/b/a Verizon Enterprise Solutions) and Verizon Global Networks Inc., for Authorization to Provide In-Region, InterLATA Service in Massachusetts, Memorandum Opinion and Order, 16 FCC Rcd 8988 (2001).
New York Order Application by Bell Atlantic New York for Authorization Under Section 271 of the Communications Act to Provide In-Region, InterLATA Service in the State of New York, Memorandum Opinion and Order, 15 FCC Rcd 3953 (1999).
Pennsylvania Order Application of Verizon Pennsylvania Inc., Verizon Long Distance, Verizon Enterprise Solutions, Verizon Global Networks Inc., and Verizon Select Services Inc. for Authorization to Provide In-Region, InterLATA Services in Pennsylvania, Memorandum Opinion and Order, 16 FCC Rcd 17419 (2001).
M-5
Cited as Source
Pricing Flexibility Order Access Charge Reform; Price Cap Performance Review for Local Exchange Carriers; Interexchange Carrier Purchases of Switched Access Services Offered by Competitive Local Carriers; Petition of U S WEST Communications, Inc. for Forbearance from Regulation as a Dominant Carrier in the Phoenix, Arizona MSA, Fifth Report and Order and Further Notice of Proposed Rulemaking, 14 FCC Rcd 14221 (1999).
Rhode Island Order Application by Verizon New England Inc., et al., for Authorization To Provide In-Region, InterLATA Services in Rhode Island, Memorandum Opinion and Order, CC Docket No. 01-324, FCC 02-63 (rel. Feb. 22, 2002).
Second Advanced Services Report Inquiry Concerning the Deployment of Advanced Telecommunications Capability to All Americans in a Reasonable And Timely Fashion, and Possible Steps To Accelerate Such Deployment Pursuant to Section 706 of the Telecommunications Act of 1996, Second Report, 15 FCC Rcd 20913 (2000).
Texas Order Application by SBC Communications Inc., Southwestern Bell Telephone Company, and Southwestern Bell Communications Services, Inc. d/b/a Southwestern Bell Long Distance Pursuant to Section 271 of the Telecommunications Act of 1996 to Provide In-Region, InterLATA Services in Texas, Memorandum Opinion and Order, 15 FCC Rcd 18354 (2000).
Third Advanced Services Report Inquiry Concerning the Deployment of Advanced Telecommunications Capability to All Americans in a Reasonable And Timely Fashion, and Possible Steps To Accelerate Such Deployment Pursuant to Section 706 of the Telecommunications Act of 1996, Third Report, 17 FCC Rcd 2844 (2002).
Third CMRS Report Implementation of Section 6002(b) of the Omnibus Budget Reconciliation Act of 1993; Annual Report and Analysis of Competitive Market Conditions With Respect to Commercial Mobile Services, Third Report, 13 FCC Rcd 19746 (1998).
UNE Remand Order Implementation of the Local Competition Provisions of the Telecommunications Act of 1996, Third Report and Order and Fourth Further Notice of Proposed Rulemaking, 15 FCC Rcd 3696 (1999).
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I. OVERVIEW
Tables
Table 1. Competitive Networks Cities with Voice Networks. NPRG CLEC Report 1999, 10th ed., Ch. 8 (1998); NPRG CLEC Report 2002, 15th ed., Ch. 6 (2001). Circuit Switches. Bellcore, TR-EQP-000315, Local Exchange Routing Guide (Mar. 1, 1999) (1998); January 2002 LERG (2001). Packet Switches. NPRG CLEC Report 2000, 12th ed., Ch. 6 at Table 8 (restated 1998 data); NPRG CLEC Report 2002, 15th ed., Ch. 4 at Table 18 (2001) (This is a highly conservative estimate. It does not include the 840 packet switches NPRG lists for competitive Independent Operating Companies, utility CLECs, data providers, or Gig-E providers. In addition, it does not include the 7,000 packet switches that NPRG lists for AT&T as of year-end 2001. According to NPRG’s prior reports, AT&T had only 50 packet switches as of year-end 2000. Because one-year growth of this magnitude is unlikely, in an abundance of caution we have used the 2000 figure for AT&T’s packet switches). Route Miles of Fiber (local and long haul). NPRG CLEC Report 2000, 12th ed., Ch. 6 at Table 5 (restated 1998 route miles); NPRG CLEC Report 2002, 15th ed., Ch. 4 at Table 13 (2001) (This is a highly conservative estimate. It does not include 117,000 route-miles of fiber that NPRG lists for competitive Independent Operating Companies, utility CLECs, data providers, or Gig-E providers. Moreover, the total miles for 2001 have been adjusted downward to address the concerns that CLECs raised in the Special Access proceeding in April of 2001 (CC Docket No. 96-98)). Average Number of CLEC Networks in Top 100 MSAs. NPRG CLEC Report 1999, 10th ed., Ch. 8 (1998); NPRG CLEC Report 2002, 15th ed., Ch. 6 (2001). Buildings Served (on- and off-net). NPRG CLEC Report 2000, 12th ed., Ch. 6 at Table 11 (restated 1998 buildings served); NPRG CLEC Report 2002, 15th ed., Ch. 4 at Table 19 (2001) (This is a highly conservative estimate. It excludes not only the buildings served by literally dozens of CLECs, but also does not include the 27,000 additional buildings NPRG reports for competitive Independent Operating Companies, utility CLECs, data providers, Gig- E providers, fiber layers, and other providers. Moreover, the total buildings have been adjusted downward to address the concerns that CLECs raised in the Special Access proceeding in April of 2001 (CC Docket No. 96-98)). Homes with Access to Cable Telephony Service. According to NCTA there were 80,000 cable telephony subscribers as of year-end 1998. See NCTA Cable Telephony Report at 3. Conservatively assuming that the penetration rate of cable telephony service was between 4 and 5 percent, this means that there were between 1.6 million and 2 million homes passed for cable telephony service. See also JP Morgan Cable Industry Report at Table 22 (2001). % of Population in Counties with 3 or More/5 or More Wireless Operators. Sixth CMRS Report at 24-25. Wireless Carriers Offering Data Services. Fourth CMRS Report at 56- 57 (1998); Sixth CMRS Report at 47 (2001). % of Homes with Access to Cable Modem Service. UNE Fact Report at III-20 & n.54 (1998); Broadband 2001 at Table 6 (estimating 82.031 million homes passed by cable modem service as of year-end 2001.); JP Morgan Telecom Services 2001 Report at Table 15 (estimating 106.4 million US households as of year-end 2001) (82.031/106.4 = 77.10 percent of US homes passed by cable modem service); Morgan Stanley Cable Modem/xDSL Conference Call at Exh. 3 (estimating 74.92 million homes passed by cable modem service as of year-end 2001) (74.92/106.4 = 70.4 percent of US homes passed by cable modem service); NCTA Industry Statistics (70 million homes passed by cable modem service as of December 2001) (70.00/106.4 = 65.79 percent of US homes passed by cable modem service); Yankee Group Consumer Broadband Report at 4 (“At year-end 2001, approximately 66% of the households in the United States will have cable modem service available to them.”). % of Homes with Access to Two-Way Satellite. Hughes Network Systems Press Release, Hughes Network Systems Ships Two-Way DirecPC Systems (Dec. 21, 2000); Yankee Group, Residential Broadband: Competition Arrives Via Satellite at 4, Vol. 4, Issue 18 (Dec. 30, 2000). Markets with MMDS. The FCC granted MMDS and ITFS providers the right to engage in fixed two-way transmissions in September of 1998. See Amendment of Parts 21 and 74 to Enable Multipoint Distribution Service and Instructional Television Fixed Service Licensees to Engage in Fixed Two-Way Transmissions, Report and Order, 13 FCC Rcd 19112 (1998); see also Eighth Video Competition Report ¶ 69. See also Sixth CMRS Report, Appendix A at Table 1; WorldCom Press Release, WorldCom Launches New High-Speed, Fixed-Wireless Internet Service in Hartford (Jan. 8, 2001).
Table 3. Competitive Lines/Subscribers Facilities-Based Residential Lines. NCTA Cable Telephony Report at 3 (1998). Wireless Subscribers. CTIA’s Semi-Annual Wireless Survey (1998); CTIA, CTIA’s World of Wireless, http://www.wow-com.com/ (2001). Wireless Data Subscribers. Legg Mason Wireless Industry Scorecard at Exh. 11 (2001). Cable Modem Subscribers. Cable Datacom News, December 1998 Highlights, http://cabledatacomnews.com/ dec98/dec98-1.html (1998); Morgan Stanley Cable Modem/xDSL Report at Exh. 3 (2001). Fixed Wireless/Satellite Subcribers. EchoStar Hopes New Plan Will Boost Deal’s Chances, Communications Daily at 3 (Feb. 27, 2002); Yankee Group Fiber and Fixed Wireless Report at Table 6; Hughes Network Systems Press Release, Hughes Network Systems Ships Two-Way DirecPC Systems (Dec. 21, 2000). The FCC granted MMDS and ITFS providers the right to engage in fixed two-way transmissions in September 1998. See Amendment of Parts 21 and 74 to Enable Multipoint Distribution Service and Instructional Television Fixed Service Licensees to Engage in Fixed Two-Way Transmissions, Report and Order, 13 FCC Rcd 19112 (1998); see also Eighth Video Competition Report ¶ 69.
Table 5. CLEC Mergers & Acquisition Activity See generally W.T. Scott, et al., Morgan Stanley, A Brief Critique – CLEC Events of the Week at 13 (Dec. 12, 2001). NEXTLINK/ Concentric Network. NEXTLINK and Concentric Close $2.54 Billion Equity Value Merger Creating Broadband Communications Powerhouse, Bus. Wire (June 19, 2000). McLeodUSA/Splitrock Services. McLeodUSA Press Release, McLeod USA Completes Acquisition of Splitrock (Apr. 3, 2000). CoreComm/ATX. Corecomm Press Release, Corecomm Limited Completes Acquisition of Voyager.Net, Inc. and ATX Telecommunications Services, Inc. (Sept. 29, 2000). Advanced Radio Telecom/Broadstream. Advanced Radio Telecom Closes Major Spectrum Acquisitions, Bus. Wire (Aug. 28, 2000). Mpower/Primary Network. Mpower Communications News Release, Mpower Communications Completes Acquisition of Primary Network (June 26, 2000). Choice One/US XChange. ALTS, The State of Local Competition 2001 at 18 (Feb. 2001) (citing Morgan Stanley Dean Witter); Choice One Communications Press Release, Choice One Completes Merger with US Xchange; Company Also Secures $550 Million in New Financing (Aug. 1, 2000). Covad/BlueStar. ALTS, The State of Local Competition 2001 at 18 (Feb. 2001) (citing Morgan Stanley Dean Witter); Covad Communications Press Release, Covad Completes Acquisition of BlueStar.net (Sept. 25, 2000). Gabriel/TriVergent. ALTS, The State of Local Competition 2001 at 18 (Feb. 2001) (citing Morgan Stanley Dean Witter); Nuvox Communications Press Release, Gabriel Communications and TriVergent Complete Merger; Company Also Closes on $225 Million Credit Facility (Nov. 2, 2000). Time Warner Telecom/GST. Time Warner Telecom Press Release, Time Warner Telecom Finalizes Purchase of GST Assets (Jan. 10, 2001). WorldCom/Intermedia. ALTS, The State of Local Competition 2001 at 18 (Feb. 2001) (citing Morgan Stanley Dean Witter); WorldCom Press Release, WorldCom, Inc./Intermedia Merger Completed (July 1, 2001). McLeodUSA/CapRock. McLeodUSA Press Release, McLeod Completes Acquisition of CapRock and Names Hiram Hoed to Lead Southwestern Region (Dec. 7, 2000). Hughes Electronics/Telocity. DirecTV Broadband, Inc. Press Release, Hughes Successfully Completes Acquisition of Telocity; Offers First Nationwide
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Portfolio of Digital Entertainment and Internet Access Via DSL and Satellite (Apr. 3, 2001). AT&T/NorthPoint. AT&T News Release, AT&T Completes Acquisition of NorthPoint Communications (May 25, 2001). Allegiance/Coast-to-Coast Communications. Allegiance Telecom, Form 10-Q at 6 (SEC filed Nov. 14, 2001). Cavalier Telephone/Conectiv Communications. Cavalier Telephone Press Release, Cavalier Telephone Announces Close of Conectiv Communications Acquisition (Nov. 14, 2001). WorldCom/Rhythms NetConnections. WorldCom Press Release, WorldCom Closes Rhythms Transaction (Dec. 5, 2001). IDT Corp./WinStar. IDT Press Release, IDT Corp. Announces the Acquisition of Winstar Communications, Inc. (Dec. 20, 2001). Choice One/Fairpoint. Choice One Press Release, Choice One Completes Asset Purchase from Fairpoint Communications Solutions Corporation (Dec. 21, 2001). Comcast/AT&T Broadband. Comcast Press Release, AT&T Broadband to Merge with Comcast Corporation in $72 Billion Transaction (Dec. 19, 2001). Allegiance/Intermedia. Allegiance Telecom, Inc. Press Release, Allegiance Telecom Acquires Intermedia Business Internet Assets from WorldCom (Jan. 3, 2002). Cavalier Telephone/Net2000. Verizon Tries to Block Cavalier’s Net2000 Acquisition, Newsbytes (Jan. 25, 2002), http://www.newsbytes.com/news/02/173823.html; Cavalier Telephone Press Release, Cavalier Telephone Completes Purchase of Net2000 Communications (Jan. 21, 2002). Broadview Networks/Net2000. In Brief (Financial Section), Wash. Post (Jan. 29, 2002); Broadview Networks Press Release, Broadview Networks Acquires Net2000 Assets from Cavalier Telephone (Jan. 28, 2002). New Edge Networks/@Work. W. Kawamoto, New Edge Networks Buys AtHome Assets, CLEC-Planet (Feb. 18, 2002), http://www.clec-planet.com/news/02feb2002/18newedge.html. Cogent/Allied Riser. Cogent Communications Press Release, Cogent Communications Acquisition of Allied Riser Completed (Feb. 4, 2002). Broadview Networks/Network Plus. Broadview Networks Press Release, Broadview Networks Signs “Letter of Intent” to Acquire Assets of Network Plus Corp. (Feb. 28, 2002).
Figures
Figure 2. Decline of BOC Access Lines CSFB 3Q00 CLEC Vital Signs Review at Table 10; CSFB 4Q01 CLEC Vital Signs Review at Exh. 10; FCC Statistics of Common Carriers, at Table 2.10 (1995/1996, 1996/1997, 1997/1998 and 1998/1999 eds.).
Figure 3. CLEC Access Line Distribution NPRG CLEC Report 2000, 12th ed., Ch. 6 at Table 13 (1998); NPRG CLEC Report 2002, 15th ed., Ch. 4 at Table 21 (2001).
Figure 7. CLEC Revenues 1996: New Paradigm Resources Group, Inc. & Connecticut Research, 1997 Annual Report on Local Telecommunications Competition, Ch. 3 at Table 12 (8th ed. 1996). 1997: New Paradigm Resources Group, Inc., 1998 Annual Report on Local Telecommunications Competition, Ch. 1 at Table 3 (9th ed. 1998). 1998: NPRG CLEC Report 2000, 12th ed., Ch. 7 at Table 17. 1999-2001, 2005: NPRG CLEC Report 2002, 15th ed., Ch. 3 at Table 10.
Figure 8. CLEC Revenue Distribution 1998: NPRG CLEC Report 2000, 12th ed., Ch. 6 at Table 15. 2001: NPRG CLEC Report 2002, 15th ed., Ch. 4 at Table 24.
Figure 9. Wireless and Data Overtaking Voice JP Morgan Telecom Services 2001 Report at Table 1.
Figure 10. Wireless vs. Wireline Growth Access Lines. JP Morgan Telecom Services 2001 Report at Tables 19 & 23. Revenues. JP Morgan Telecom Services 2001 Report at Tables 1 & 19.
II. SWITCHING
Tables
Table 1. Competition for ILEC Circuit-Switched Local Traffic CLEC Circuit Switches. Switches: January 2002 LERG. Revenues: CSFB 3Q01 CLEC Vital Signs Review at Exh. 9. Wireless. Switches: January 2002 LERG. Subscribers/Lines: CTIA, CTIA’s World of Wireless Communications, http://www.wow-com.com/index.cfm. Minutes: C.F. Carvalho, Morgan Stanley, Dean Witter, Investext Rpt. No. 8285600, Telecom – Wireless Services: Industry Outlook: Life After 50 – Industry Report at *4 (Nov. 28, 2001); CTIA, CTIA’s World of Wireless Communications, http://www.wow-com.com; JP Morgan Telecom Services 2001 Report at Table 31. Revenues: CTIA’s Semi-Annual Wireless Industry Survey Results. Data. Switches: NPRG CLEC Report 2002, 15th ed. at Ch. 4, Table 18 (This is a highly conservative estimate. It does not include the 840 packet switches NPRG lists for competitive Independent Operating Companies, utility CLECs, data providers, or Gig-E providers. In addition, it does not include the 7,000 packet switches that NPRG lists for AT&T as of year-end 2001. According to NPRG’s prior reports, AT&T had only 50 packet switches as of year-end 2000. Because one-year growth of this magnitude is unlikely, in an abundance of caution we have used the 2000 figure for AT&T’s packet switches). Subscribers/Lines: Morgan Stanley Cable Modem/xDSL Report at Exh. 1; EchoStar Hopes New Plan Will Boost Deal’s Chances, Communications Daily at 3 (Feb. 27, 2002); Yankee Group Fiber and Fixed Wireless Report at Table 6. Minutes: T. McElligott, A Slice of Humble Pie, Telephony (July 2, 2001); Nielsen/NetRatings Press Release, Broadband Net Surfing Accounts for More than Half of All Time Spent Online, According to Nielsen/NetRatings (Mar. 5, 2002). Revenues: JP Morgan Telecom Services 2001 Report at Figure 21; IDC Packet Switching Report at Figures 8-9, 30-31. PBX. Subscribers/Lines: Multimedia Telecommunications Association, 1998 Multimedia Telecommunications Market Review and Forecast at 92 (1998); Telecommunications Industry Association, 2001 Multimedia Telecommunications Market Review and Forecast at 105, 108 (2001). Minutes: Multimedia Telecommunications Association, 1998 Multimedia Telecommunications Market Review and Forecast at 92 (1998); Telecommunications Industry Association, 2001 Multimedia Telecommunications Market Review and Forecast at 105, 108 (2001); FCC Statistics of Common Carriers 2000/2001 ed. at Table 2.4.
Table 7. Use of CLEC Switches to Serve Large Geographic Areas WorldCom. Prefiled Rebuttal Testimony of Don Price at 48-49, GA Docket No. 11901-U (GA PSC filed Aug. 3, 2000). ICG. Prefiled Direct Testimony of Michael Starkey, NC Docket No. P-582, Sub 6 at 21 (NC PUC filed May 27, 1999); Direct Testimony of Michael Starkey, LA Docket No. U-24206 at 24 (LPSC filed Sept. 3, 1999). AT&T. Direct Testimony of Gregory R. Follensbee at 42, TN Docket No. 00-00079
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(TRA filed Dec. 20, 2000). Intermedia. Direct Testimony of J. Carl Jackson, Jr. at 10,12, AL Docket No. 27385 (APSC filed Jan. 3, 1999). US LEC. Direct Testimony of Wanda Montano at 11, FL Docket No. 000084-TP (FPSC filed Oct. 13, 2000).
Table 8. CLECs Providing Facilities-Based Residential Service ALLTEL. ALLTEL, National Coverage, http://www.alltel.com/news_information/maps/national.html; NPRG CIOC Report 2001, Ch. 7 – ALLTEL at 8; ALLTEL News Release, ALLTEL Offers Local Telephone Service in Raleigh, N.C. (Nov. 17, 1999). AT&T. AT&T Broadband, Tariffs, Price Lists and Service Guides http://www.attbroadband.com/tariffs/; Applications and Public Interest Statement of AT&T Corp. and Comcast Corporation, Application for Consent to the Transfer of Control of Licenses at 36, Comcast Corporation and AT&T Corp., Transferors, to AT&T Comcast Corporation, Transferee, MB Docket No. 02-70 (FCC filed Feb. 28, 2002)AT&T News Release, AT&T Announces Fourth Quarter Earnings (Jan. 30, 2002). BayRing. BayRing Communications, Company Overview, http://www.bayring.com/subpages/ companyoverview.html; BayRing Communications, BayRing Communications Selects Convergent Networks for Next-Generation Broadband Network Deployment (Nov. 7, 2000). Broadview Networks. Broadview Networks Press Release, Broadview Networks Announces Wholesale Agreement with InfoHighway Communications (Feb. 11, 2002). Cavalier Telephone. Cavalier Telephone Pays $29M for Conectiv Carrier, Phil. Bus. J. at 5 (June 15, 2001). Cablevision Systems Corp. Cablevision Systems Corp., Form 10K at 7 (SEC filed March 30, 2001). CenturyTel. NPRG CIOC Report 2001, Ch. 7 – CenturyTel at 3. Comcast. M. Stump, Comcast’s Phone Forecast: Legacy Subs In Black by ‘02, Multichannel News at 25 (Aug, 27, 2001). CoreComm. NPRG CLEC Report 2002, 15th ed., Ch. 6 – CoreComm, LTD. at 3. Cox Communications. NCTA Cable Telephony Report at 2. CTC Exchange Services. NPRG CIOC Report 2001, Ch. 7 – CTC Exchange at 3. CTSI. Commonwealth Telephone Enterprises, Inc., Form 10-K405 (SEC filed Mar. 27, 2001). Grande Communications Network. Grande Communications Press Release, Grande Communications Receives Franchises to Offer Bundled Internet, Phone and Cable Services in Four New Central Texas Cities (Nov. 29, 2001). Insight. J. Baumgartner, Cable Telephony Builds Momentum, Multichannel News at 2 (July 30, 2001). Knology. Knology, Knology Cities, http://www.knology.com/services/cities.cfm?ReturnToPage=/services/telephone.cfm; NPRG CLEC Report 2002, 15th ed., Ch. 6 – Knology Broadband at 2. LecStar. LecStar Communications, Service Areas, http://dev.lecstar.com/About_LecStar/ Service_Area/service_area.html; LecStar Launches Service in Savanah, Bus. Wire (Nov. 13, 2001). NTELOS. NPRG CIOC Report 2001, Ch. 7 – NTELOS at 2-3. NTS Communications. NPRG CLEC Report 2002, 15th ed., Ch. 6 – NTS Communications, Inc. at 3; NTS Communications, Products, Residential, Local Dial Tone, Facilities Based Product, http://www.ntscom.com/products.html. RCN Corp. RCN Corp., Phone, http://www.rcn.com/phone/; RCN Corp., Form 10-K405 (SEC filed Apr. 2, 2001). Rio Communications. S. McDonald, Challengers Target US West’s Business Customers in Eugene, Ore., Area, Register Guard (June 14, 1999).
Table 9. Commercial Circuit-Switched Cable Telephony Deployment AT&T. Applications and Public Interest Statement of AT&T Corp. and Comcast Corporation, Application for Consent to the Transfer of Control of Licenses at 36, Comcast Corporation and AT&T Corp., Transferors, to AT&T Comcast Corporation, Transferee, MB Docket No. 02-70 (FCC filed Feb. 28, 2002); AT&T and Comcast Remain on Watch Neg, Yahoo! Bus. (Dec. 20, 2001), http://biz.yahoo.com/bw/011220/202353_1.html. Cox. K. Darce, Local Phone Arena Gets New Players, Times-Picayune at 1 (Feb. 8, 2002); R. Moore, Cabling Home, Nashville Bus. J. at 17 (Feb. 1, 2002). Comcast. M. Stump, Comcast’s Phone Forecast. Legacy Subs in Black by ‘02, Multichannel News at 25 (Aug. 27, 2001); R. Moore, Cabling Home, Nashville Bus. J. at 17. Cablevision. Eighth Video Competition Report ¶ 53. Insight. Insight Communications, Services, http://www.insight-com.com/services/; T. Kerver, Operator Of the Year, Cablevision (Oct. 22, 2001), http://www.tvinsite.com/ cablevision/index.asp?layout=story&articleId=CA178402&pubdate=10/22/2001&stt=001&display=searchResults.
Table 11. Average Number of CLEC Packet Switches in Top 100 MSAs 1998. NPRG CLEC Report 1999, 10th ed., Ch. 8. 2001. NPRG CLEC Report 2002, 15th ed., Ch. 6.
Table 12. Selected CLEC Data Service Offerings AT&T. AT&T, AT&T Local Frame Relay and ATM Services, http://www.ipservices.att.com/brochures2/atm1.pdf. Cablevision Lightpath. Cablevision Lightpath, Powerful Solutions, http://www.lightpath.net/solutions. Choice One. Choice One News Release, Choice One Selects Lucent To Provide Infrastructure for New Local Networks; Companies Sign $100 Million Equipment Deal (Apr. 20, 2000). Global Crossing. Platinum Network Systems, Global Crossing Internet and Data Services, http://www.platinumn.com/global_data.html; Asia Global Crossing, Products and Services: ATM, http://www.asiaglobalcrossing.com/products_services/ds_atm.htm. Time Warner Telecom. Telistar, Access & Connectivity, http://www.telistar.com/access.html. US LEC. US LEC, Internet and Enhanced Data Services, http://www.uslec.com/ enhanced.htm. WorldCom. WorldCom, Metro Frame Relay Service, http://www1.worldcom.com/us/products/datanetworking/framerelay/ metro/. XO Communications. NEXTLINK Communications, 1999 Annual Report at 14-15.
Table 13. Growth of E-mail and Instant Messaging Forrester Research, Ready for Richer Communication at 2, 6 (Sept. 2001); M. Dano, IBM Enters Wireless Instant Messaging Arena, RCR Wireless at 28 (June 25, 2001); InstantMessagingPlanet.com, Welcome to InstantMessagingPlant.com (Oct. 15, 2001), http://www.instantmessagingplanet.com/features/article/0,,2841_903101,00.html; Enabling Technologies Selects EAS As “Best Of Breed” Solution For US Government, Internet Wire (Nov. 27, 2001); T. Chea, Workplace Is Being Altered By E-Mail, Wash. Post at E07 (June 29, 2000); L. Guernsey, Instant Messaging Is a Hit Among Most Online Teenagers, N.Y. Times at G3 (June 21, 2001).
Table 14. CLECs Using Packet Switches To Provide Voice Services AT&T. M. Johnston, ATT Launches VoIP Portfolio, ITWorld.com (Jan. 31, 2001), http://www.itworld.com/News/2001/1/ITW0131att/. Choice One. Choice One Press Release, Choice One Selects Lucent To Provide Infrastructure For New Local Networks; Companies Sign $100 Million Equipment Deal (Apr. 20, 2000). CTC. ThruPoint Press Release, CTC Communications Teams with ThruPoint in Transition to Packet-Based Network (Apr. 3, 2001). Global Crossing. Global Crossing Press Release, Global Crossing Ltd. Lights up Carrier Class Voice over IP in Its Production Network (Sep. 27, 2000). Level 3. Level 3 Communications, (3) Voice, http://www.level3.co.uk/us/services/3voice/ (updated 2001). US LEC. US LEC Press Release, US LEC Deploys ATM Network (Nov. 1, 1999). WorldCom. WorldCom Presents Plans for Commercial IP Communications Services: Carrier-Grade IP Communications Will Enable Businesses To Integrate, Voice, Data and Video for All E-Business Applications, MCK Communications News (Jan. 30, 2001), http://www.mck.com/html/ni_ne_01_01_30.htm. XO. XO Press Release, XO Selects Sonus Networks to Provide Next-Generation Switching and Softswitch Technology; Leading Broadband Communications Provider to Deploy Sonus Gear in Its Nationwide Network (Nov. 7, 2000).
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Table 15. Cable IP Telephony Time Warner. J. Baumgartner, No Large VoIP Roll-Outs Until Late 2002, CED at 10 (Jan. 1, 2002); D. Iler, Readying the Roll, Broadband Week (Mar. 19, 2001), http://www.broadbandweek.com/news/010319/010319_cable_voip.htm; Harrington, Time Warner Takes Phone Fight to Verizon, St. Petersburg Times Online (Dec. 22, 2001), http://www.sptimes.com/News/122201/Business/Time_Warner_takes_pho.shtml. AT&T. D. Iler, Voice of Reason, Broadband Week at 30 (July 9, 2001); M. Stump, IP Telephony Approaches Are Growing On Big MSOs, MultiChannel News at Inside Broadband (Oct. 2, 2000). Cox. M. McGinity, AT&T/Comcast: Mixed Signals, Net Economy (Jan. 21, 2002), http://www.theneteconomy.com/article/0,3658,s%253D907%2526a%253D21613,00.asp; C. Kuhl, Navigating the Telephony Business Waters, CED (Apr. 2001), http://www.cedmagazine.com/ced/2001/0401/04b.htm; NCTA Press Release, Testimony of Jim Robbins, CEO, Cox Communications, Before the Senate Judiciary Subcommittee pn Antitrust, Business Rights, and Competition (May 2, 2001). Comcast. A. Wahlman, UBS Warburg, Investext Rpt No. 8115886, Cable Telephony and Digital Cable: Alive and Kicking at *2 (Aug. 2, 2001). D. Iler, Readying the Roll, Broadband Week (Mar. 19, 2001), http://www.broadbandweek.com/news/010319/010319_cable_voip.htm; Cable Calls on Hold, Net Economy (Apr. 2, 2001), http://www.theneteconomy.com/article/0,3658,s%253D923%2526a%253D8292,00.asp. Adelphia. J. Whalen, The 2000 Service in Technology Award, Communications Technology (June 2000), http://www.cabletoday.com/ct2/archives/0600/ 0600fe1.htm#5. Cablevision. Comments of Cablevision Systems Corporation, Request for Comments Deployment of Broadband Networks and Advanced Telecommunications, Docket No. 011109273-1273-01 (Dec. 19, 2001). Charter. G. Lawyer and C. Wolter, The Cable Giant Stirs, Soundingboard (Dec. 1, 2001), http://www.soundingboardmag.com/articles/1c1vox.html; K. Brown, Charter Flips the Circuit Switch, Broadband Week (Feb. 18, 2002), http://www.broadbandweek.com/news/020218/020218_cable_flip.htm; M. Stump, Charter to Expand IP Tests with Wisc. Marketing Trial, Broadband Week (Feb. 11, 2002), http://www.broadbandweek.com/news/020211/020211_cable_charter.htm.
Figures
Figure 1. Distribution of CLEC Switches 1998. Bellcore, TR-EQP-000315, Local Exchange Routing Guide (Mar. 1, 1999). 2001. Telcordia, January 2002 LERG.
Figure 6. CLEC Revenues 1996. New Paradigm Resources Group, Inc. & Connecticut Research, 1997 Annual Report on Local Telecommunications Competition, Ch. 3 at Table 12 (8th ed. 1996). 1997. New Paradigm Resources Group, Inc., 1998 Annual Report on Local Telecommunications Competition, Ch. 1 at Table 3 (9th ed. 1998). 1998. NPRG CLEC Report 2000, 12th ed., Ch. 7 at Table 17. 1999-2001, 2005. NPRG CLEC Report 2002, 15th ed., Ch. 3 at Table 10.
Figure 7. Wireless vs. Wireline Growth Access Lines. JP Morgan Telecom Services 2001 Report at Tables 19 & 23. Revenues. JP Morgan Telecom Services 2001 Report at Tables 1 & 19.
III. TRANSPORT
Tables
Table 4. Average Number of CLEC Networks by MSA 1998. NPRG CLEC Report 2000, 12th ed., Ch. 8. 2001. NPRG CLEC Report 2002, 15th ed., Ch. 5.
Table 5. Wholesale Local Fiber Suppliers Metromedia Fiber Networks. Metromedia Fiber Network, MFN Metropolitan Fiber Maps, http://www.mfn.com/network/usmaps.shtm (as of Mar. 11, 2002); Metromedia Fiber Network, Inc., Form 10-Q (SEC filed Nov. 14, 2001). Fiberworks. Fiberworks, Our Networks, http://www.fiberworks.com/ProductsandServices/MetroAccess/OurNetworks/ (as of Mar. 11, 2002); Fiberworks, About Fiberworks, http://www.fiberworks.com/AboutFiberworks/ (as of Mar. 11, 2002). American Fiber Systems. American Fiber Systems Press Release, Nashville, TN Dark-Fiber Network Now Operational (Mar. 4, 2002); American Fiber Systems Press Release, American Fiber Systems Poised to Eliminate Bandwidth Bottleneck in 131 American Cities (Aug. 9, 2000); American Fiber Systems Press Release, American Fiber Systems Solves the Bandwidth Capacity Shortage (Dec. 11, 2000). Fibertech Networks. Fibertech Networks, Our Network Plan, Current, http://www.fibertechnologies.net/network/phaseOne.cfm (as of Mar. 11, 2002); Fibertech Networks, Our Network Plan, Pending Completion, http://www.fibertechnologies.net/network/phaseTwo.cfm (as of Mar. 11, 2002); Fibertech Networks, Our Network Plan, Future Markets, http://www.fibertechnologies.net/network/phaseThree.cfm (as of Mar. 11, 2002); Fibertech Networks Press Release, Choice One Activates Fiber Ring in Pittsburgh, Pennsylvania (Feb. 18, 2002). Yipes. Yipes Press Release, Yipes Opens 20th Market in Rapid National Buildout of Optical IP Networks (Dec. 11, 2000); Yipes Press Release, Yipes Lights New York City with Gigabit Optical Networks, (June 25, 2001); Yipes Press Release, Yipes Announces Company Results at First Annual Meeting (July 2, 2001). Telseon. Telseon Press Release, Pihana Pacific and Telseon to Deliver High Speed Bandwidth to Customers Located in Los Angeles Facility (Nov. 7, 2001). Looking Glass. Looking Glass Networks, Our Network, http://www.lglass.net/network/index.jsp (as of Mar. 11, 2002). Telergy. Telergy, The Telergy Network, http://www.telergy.net/about_us/network/ (as of Mar. 11, 2002). W. Kates, Telergy to Cut 300 More Jobs, AP Online (Sept. 24, 2001). Northeast Optic Network. Northeast Optic Network, Product/Services, FAQs, http://www.neoninc.com/page.cfm?contented=125 (as of Mar. 11, 2002); Northeast Optic Network, Company Overview, http://www.neoninc.com/page.cfm?contentID=96. Progress Telecom. Progress Telecom, Our Network, Network Coverage Area, http://www.progresstelecom.com/our_network_cov_area.html; Progress Telecom Press Release, Progress Telecom Opens New Network Operations Center (Dec. 12, 2001). EPIK Communications. EPIK Communications Press Release, EPIK Communications Turns Up High-Capacity Circuits in Florida for Wireless Carrier (Dec. 19, 2001). NEESCom. NEESCom, Metro Rings, http://www.neescom.com/prod_servc/metro/index.htm (as of Mar. 11, 2002); NEESCom, Products & Services, http://www.neescom.com/prod_servc/index.htm.
Table 6. Utilities Providing Local Fiber Alameda Power & Telecom. Automation Developments, Transmission & Distribution World (Apr. 2001). Bristol Virginia Utilities Board. City Utility Extends High-Speed Internet Connections to Businesses, Associated Press State & Local Wire (May 22, 2001). Cinergy. K. Maddox, New Era, New Partner – Old-Line Manufacturer Chooses Cinergy for Network Build, Tele.com (Mar. 5, 2001). ConEdison. E. Krapf, Another Last Mile for Fiber Access: Briefing, Bus. Comm. Review (Jan. 1, 2002). Edison Communications. L. Trager, Utilities Still Aim to Compete in
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Broadband Market, Washington Internet Daily (Jan. 23, 2002). Electric Power Board. D. Flessner, Collapse Doesn’t Ruin City’s Vision, Chattanooga Times/Chattanooga Free Press (Feb. 10, 2002). El Paso Global Networks. L. LaBarba, Someone Is Still Spending, Telephony (Feb. 26, 2001). FPL Fibernet. P. Patterson, ABN AMRO Bank N.V. U.S.A, Investext Rpt No. 8340873, Company Report – FPL Group at *4 (Jan. 18, 2002); FPL FiberNet Announces Lighting of Florida Metros, PR Newswire (Mar. 7, 2001). Grant County Public Utility District. R. Pease, Rural Washington County Pioneers Optical Broadband Services, Lightwave (Feb. 2002). Lafayette Utility System. A. Simoneaux, Lafayette Utilities Adopts Fiber Optics for Communications, Advocate (Feb. 4, 2002). PPL Telecom. C. Berg, PPL Launching Telecommunications Business: Allentown Company Will Provide Telephone, Internet Services, Morning Call (Jan. 22, 2002). Progress Telecom. Progress Telecom Appears on Alexander Haig’s World Business Review TV Series, Discusses Telecommunication Solutions for Electric Utility Infrastructure, Bus. Wire (Oct. 30, 2000). Reliant Energy Communications. Reliant Energy Communications Opens Austin Internet Data Center, PR Newswire (Feb. 26, 2001). Sempra Communications. L. Trager, Utilities Still Aim to Compete in Broadband Market, Washington Internet Daily (Jan. 23, 2002) (quoting Sempra President Michael Allman). Telergy MidAtlantic. Telergy MidAtlantic Begins Marketing Services. Santaliz Named General Manager, PR Newswire (Apr. 3, 2001). Touch America. Telecom Company Touch America Completes Transformation, Emerges as Unique Broadband Network and Services Entity; Becomes Debt Free, Stand-Alone Telecommunications Company with Sale Of Utility Subsidiary to NorthWestern, PR Newswire (Feb. 15, 2002); Montana Power to Divest Energy Businesses, Company to Become Touch America, PR Newswire (Mar. 28, 2000).
Table 7. Local Fiber Networks of IXCs That Supply Dark Fiber Williams Communications. Williams Communications, Metro Access Points Map, http://www.wcg.com/brochures/network/ metro_access_map.pdf (as of Mar. 11, 2002). Level 3 Communications. Level 3 Press Release, Level 3 Completes Two Metropolitan Fiber Optic Networks in New Jersey (July 25, 2000); Level 3 Communications, (3) Link Dark Fiber, http://www.level3.com/us/products/darkfiber (as of Mar. 11, 2002). Global Crossing. Global Crossing Press Release, Global Crossing Reports 2000 Pro Forma Cash Revenue Up 36%, Recurring Adjusted EBITDA Up 54% from 1999 (Feb. 14, 2001). Qwest Communications. Qwest Communications Press Release, Qwest Communications Launches Local Broadband Services in Washington D.C. and Baltimore (Feb. 12, 2001).
IV. LOOPS Tables
Table 4. CLEC Operations of Non-Bell Company ILECs ALLTEL Communications. NPRG CIOC Report 2001, Ch. 7 – ALLTEL Communications at 4, 8. Blackfoot Telephone Cooperative Inc. NPRG CIOC Report 2001, Ch. 7 – Blackfoot Telephone Cooperative, Inc. at 3. CEI Networks. NPRG CIOC Report 2001, Ch. 7 – CEI Networks at 3. CenturyTel, Inc. NPRG CIOC Report 2001, Ch. 7 – CenturyTel, Inc. at 3. CTC Exchange Services, Inc. NPRG CIOC Report 2001, Ch. 7 – CTC Exchange Services, Inc. at 3. CTC Telcom. NPRG CIOC Report 2001, Ch. 7 – CTC Telecom at 2. CTS Telecom d/b/a Climax Tel. Co. NPRG CIOC Report 2001, Ch. 7 – CTS Telecom d/b/a Climax Telephone Co. at 2. CTSI, Inc. NPRG CIOC Report 2001, Ch. 7 – CTSI, Inc. at 7, 9. ExOp of Missouri, Inc. NPRG CIOC Report 2001, Ch. 7 – ExOp of Missouri, Inc. at 2-3. Fidelity Communication Services. NPRG CIOC Report 2001, Ch. 7 – Fidelity Communications Services at 2. Goldfield Access Network (GAN). NPRG CIOC Report 2001, Ch. 7 – Goldfield Access Network at 2. Heart of Iowa Communications, Inc. NPRG CIOC Report 2001, Ch. 7 – Heart of Iowa Communications, Inc. at 2. HickoryTech. NPRG CIOC Report 2001, Ch. 7 – HickoryTech at 3. HTC Communications, Inc. NPRG CIOC Report 2001, Ch. 7 – HTC Communications, Inc. at 2. Mid-Maine Communications. NPRG CIOC Report 2001, Ch. 7 – Mid-Maine Communications at 2. Mid Rivers Communications, Inc. NPRG CIOC Report 2001, Ch. 7 – Mid-Rivers Communications at 2. Nex-Tech. J. Dooley, There’s No Place Like Home Kansas-based Rural Telephone Takes FTTH to the Heartland, Outside Plant Magazine (June 2000). NTELOS, Inc. NPRG CIOC Report 2001, Ch. 7 – NTELOS, Inc. at 3. Otter Tail, Inc. NPRG CIOC Report 2001, Ch. 7 – Otter Tail, Inc. at 2. Panhandle Telecom. Systems, Inc. NPRG CIOC Report 2001, Ch. 7 – Panhandle Telecommunications Systems, Inc. at 3. Penn Telecom (d/b/a Penntele.com). NPRG CIOC Report 2001, Ch. 7 – Penn Telecom, Inc. at 2, 3. Sharon Telephone Company. NPRG CIOC Report 2001, Ch. 7 – Sharon Telephone Company at 2. Silver Star Communications. NPRG CIOC Report 2001, Ch. 7 – Silver Star Communications at 2. TDS Metrocom. NPRG CIOC Report 2001, Ch. 7 – TDS Metrocom at 2.
Table 5. Hybrid Fiber Coax (HFC) and Multi-Dwelling Unit (MDU) Providers RCN/Starpower. Robert Currey, Vice Chairman, RCN Corporation, Prepared Testimony before the Senate Subcommittee on Antitrust, Business Rights, and Competition, Committee on the Judiciary, Cable And Video: Competitive Choices, Federal News Service (Apr. 4, 2001). Knology. E. Gubbins, Body Snatchers, Upstart (Apr. 2001). Multiband (Vicom). Growth in Residential Broadband Fuels Vicom’s MultiBand Subsidiary; Forecasts Indicate Opportunities in Multi Dwelling Unit Market, Bus. Wire (Dec. 10, 2001). Grande Communications. Grande Communications News Release, Grande Communications and U.S. Online Sign Exclusive 10-Year Agreement (Jan. 2, 2002).
Table 6. Availability of Broadband Services McKinsey/JP Morgan estimates. Broadband 2001 at Tables 1, 6, 7, 8. Yankee Group estimates. Yankee Group Critical Mass Report at Exh. 4; M. Davis, Yankee Group, 2001 DSL Subscriber Forecast at 2, E-Networks and Broadband Access (July 2001). Satellite estimates. DirecPC, Comparisons, http://www.direcpc.com/index2.html; StarBand, Q&A; What is StarBand Service, http://www.starband.com/faq/ starbandfacts.htm#service; StarBand, Q&A, http://www.starband.com/faq/starbandfacts.htm#available; Yankee Group, Residential Broadband: Competition Arrives Via Satellite, Media and Entertainment Strategies, Vol. 4, No. 18 at 4 (Dec. 30, 2000). Fixed Wireless estimates. D. Whipple, Fixed Wireless Increases Broadband Access, Interactive Week (Mar. 20, 2001), http://www.zdnet.com/zdnn/stories/news/ 0,4586,2698833,00.html; JP Morgan Cable Industry Report at Table 2.
Figures
Figure 3. Access Line Growth (1998 – 2001) Access Lines. CSFB 3Q01 CLEC Vital Signs Review at Table 9; CSFB 3Q00 CLEC Vital Signs Review at Table 11 (ILEC/CLEC); CTIA’s Semi- Annual Wireless Survey; CTIA, CTIA’s World of Wireless Communications, http://www.wow-com.com/ (wireless); NCTA Industry Statistics; NCTA, Residential Cable Telephony Subscribers (in Thousands): 1999-2001, http://www.ncta.com/broadband/broadband.cfm?broadID=3 (cable). Revenues. JP Morgan Telecom Services 2001 at Tables 1, 11, 21.
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Figure 4. Decline of BOC Access Lines CSFB 3Q00 CLEC Vital Signs Review at Table 10; CSFB 4Q01 CLEC Vital Signs Review at Exh. 10; FCC Statistics of Common Carriers, at Table 2.10 (1995/1996, 1996/1997, 1997/1998 and 1998/1999 eds.).
Figure 5. Growth of Cable as a Voice and Data Competitor Homes Passed by Two-Way. 1998: Annual Assessment of the Status of Competition in Markets for the Delivery of Video Programming, Fifth Annual Report, 13 FCC Rcd 24284, ¶ 41 (1998); Comcast Corp., Form 10-K (SEC filed Feb.26, 1999); Cox Communications, Form 10-K/405 (SEC filed Mar. 29, 1999); Cablevision Systems Corp., Form 10-K (SEC filed Mar. 31, 1999); Adelphia Communications Corp., Form 10-K (SEC filed May 25, 1999); AT&T News Release, AT&T and TCI Complete Merger (Mar. 9, 1999); MediaOne Group, Form 10-K (SEC filed Mar. 30, 1999); U.S. Dep’t of Commerce, USA Statistics in Brief (2001), http://www.census.gov/statab/www/part1.html. 2001 & 2004: Broadband 2001 at Table 4 & 6. Homes Passed by Cable Modem Service. 1998: NCTA, 2001 Cable TV Handbook at 2-B-13 (May 2001); NCTA, Industry Statistics, Basic Cable Growth, 1980-2000, http://ncta.com/industry_overview/indStats.cfm?statID=1; U.S. Dep’t of Commerce, USA Statistics in Brief (2001), http://www.census.gov/statab/www/part1.html. 2001 & 2004: Yankee Group Critical Mass Report at Exh. 4. Homes Passed by Cable Telephony. 1998: n/a. 2001 & 2004: JP Morgan Cable Industry Report at Tables 22 & 23; JP Morgan Telecom Services 2001 Report at Table 15. Cable Modem Subscribers. 1998: Cable Datacom News, December 1998 Highlights: Cable Modem Customer Count to Top 500,000 at Year’s End (Dec. 1998), http:// cabledatacomnews.com/dec98-1.htm. 2001 & 2004: Morgan Stanley Cable Modem/xDSL Report at Exhs. 1 & 3; Broadband 2001 at Table 9; Salomon Smith Barney Battle for High-Speed Data Report at Figure 11; J. Bellace, et al., Jefferies & Co., Telecommunications Equipment: Industry Update at Exh. 1 (Feb. 4, 2002). Cable Telephony Subscribers. 1998: NCTA Cable Telephony Report. 2001: NCTA Industry Statistics. 2004: JP Morgan Cable Industry Report at Tables 22 & 23.
Figure 6. Market Share of Residential Broadband Subscribers, YE 2001 Morgan Stanley Cable Modem/xDSL Report at Exh. 3 (cable modem subscribers as of 4Q 2001); TeleChoice DSL Deployment Summary (DSL subscribers); Salomon Smith Barney Battle for High-Speed Data Report at Figures 1 & 5 (other technologies).
Figure 7. Market Share of New Residential Broadband Subscribers Salomon Smith Barney Battle for High-Speed Data Report at Figure 1 (3Q and 4Q 2001 est. for other technologies based on 2Q 2001 share); Ind. Anal. Div., FCC, High-Speed Services for Internet Access: Subscribership as of June 20, 2001 at Tables 1 & 3 (Feb. 2002) (percent of satellite & fixed wireless subscribers that serve mass market customers); Cable Datacom News, North American Cable Modem Subscriber Count Tops 8 Million (Dec. 1, 2001), http://cabledatacomnews.com/dec01/dec01-2.html (Kinetic Strategies estimates for cable modem subscribers); Morgan Stanley Cable Modem/xDSL Report at Exh. 3 (cable modem subscribers as of 4Q 2001); TeleChoice DSL Deployment Summary (TeleChoice estimates for DSL subscribers).
V. RESALE
Tables
Table 1. CLECs Opposing the Availability of UNE Platforms Allegiance Telecom. Ex Parte Letter from Kevin M. Joseph, Allegiance Telecom, to Magalie R. Salas, Secretary, FCC, CC Docket Nos. 96-98, 96-262, 97-146, Att. at 2 (Feb. 2, 2001). Allegiance Telecom, Cablevision Lightpath, Cbeyond Communications, Time Warner Telecom, XO. Letter from Kevin Joseph, Vice President – Government Affairs, Allegiance Telecom, et al., to Magalie Roman Salas, Secretary, FCC, CC Docket No. 96-98 (Oct. 25, 2000). Choice One Communications. Ex Parte Letter from Kim Robert Scovill, Vice President and General Counsel, Choice One Communications, Inc., to Magalie Roman Salas, Secretary, FCC, CC Docket No. 96-98 (Mar. 12, 2001). TCG. Comments of Teleport Communications Group at 61, Implementation of the Local Competition Provisions in the Telecommunications Act of 1996, CC Docket No. 96-98 (FCC filed May 16, 1996).
Table 2. Twenty Largest CLECs (by Revenues): 1998 vs. 2001 1998. NPRG CLEC Report 2000, 12th ed., Ch. 6 at Tables 5 & 15; Bellcore, TR-EQP-000315 LERG CD-ROM, Local Exchange Routing Guide (Mar. 1, 1999). 2001. NPRG CLEC Report 2002, 15th ed., Ch. 4 at Tables 13 & 24; Telcordia, January 2002 LERG.
Table 3. Examples of CLECs That Have Specifically Targeted Smaller Markets Advanced TelCom Group. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Advanced TelCom Group at 2, 3. AFN Communications. G. Bischoff, Establish a Beachhead, Telephony (May 21, 2001). BayRing Communications. NPRG CLEC Report 2002, 15th ed., Ch. 6 – BayRing Communications at 2. Choice One Communications. Choice One Communications, Our Company, http://www.choiceonecom.com/ ourcompany/. Cinergy Communications. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Cinergy Communications at 2. Volaris Online. MyCity Networks Press Release, MyCity.com & DUROCOM Forge Strategic Partnership (Feb. 5, 2001). e.spire Communications. Stratecast Partners Reflects on e.spire’s Need to Inspire Capital, Bus. Wire (Jan. 17, 2001). Crescent Telephone. R. Schadelbauer, Zeroing in on the Competition, Rural Telecommunications (Mar./Apr. 2001), http://www.ruraltelecom.org/marapr01/compit-b2.html. KMC Telecom. KMC Telecom, Corporate Profile, http://www.kmctelecom.com/company/index.cfm. Knology. E. Gubbins, Body Snatchers, Upstart (Apr. 2001). LecStar Communications. NPRG CLEC Report 2002, 15th ed., Ch. 6 – LecStar Communications at 2-3. Lightship Telecom. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Lightship Telecom at 2. NECLEC. NPRG CLEC Report 2002, 15th ed., Ch. 6 – NECLEC at 2.
Table 4. Operating Statistics for Public DLECs at Time of IPO Choice One. Choice One Press Release, Choice One Closes IPO, Underwriters Exercise Over-Allotment Option (Feb. 23, 2000); Choice One Communications, Inc., Form S-1/A (SEC filed Feb. 16, 2000). Covad. Covad Communications Group, Inc., Form S-1/A (SEC filed Jan. 21, 1999); Covad Communications Group, Inc., Form 10-K/405 (SEC filed Mar. 30, 2000). DSL.net. DSL Net, Inc., Form 10-K/405 (SEC filed Mar. 30, 2000); DSL Net, Inc., Form S-1/A (SEC filed Oct. 4, 1999). Log On America. Log On America Press Release, Log On America Announces Exercise of Over-Allotment Option (Apr. 28, 1999); Log On America, Inc., Form SB-2/A (SEC filed Apr. 14, 1999). Mpower. MGC Communications, Inc., Form 10-K (SEC filed Mar. 30, 2000); MGC Communications, Inc., Form S-1 (SEC filed Apr. 1, 1998). Net2000. Net2000 Communications, Inc., Form 10-Q (SEC filed May 15, 2000); Net2000 Communications, Inc., Form S-1/A (SEC filed Mar. 6, 2000). Network Access Solutions Corp. Network Access Solutions Corp., Form 10-K (SEC filed Mar. 27, 2000); Network Access Solutions Corp., Form S-1/A (SEC filed June 1, 1999). NorthPoint Communications Group Inc. NorthPoint Communications Group, Inc., Form 10-K405 (SEC
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filed Mar. 30, 2000); NorthPoint Communications Group, Inc., Form S-1/A (SEC filed May 5, 1999); NorthPoint Reports 5,700 Installed DSL Lines, ATM News Digest (July 22, 1999), http://www.atmdigest.com/archive/v6n139.txt. Rhythms NetConnections, Inc. Rhythms NetConnections, Inc., Form 10-K405 (SEC filed Mar. 30, 2000); Rhythms NetConnections, Inc., Form S-1/A (SEC filed Apr. 6, 1999).
Table 5. Emerging Broadband Applications Next-Generation Game Consoles. Microsoft, Xbox FAQ, http://www.xbox.com/support/default.htm; K. Rath, Broadband Networks, IEEE Multimedia (Oct./Dec. 2000), http://www.computer.org/multimedia/mu2000/pdf/u4010.pdf. Online Gaming. New Mexico DSL.net, Broadband and DSL Applications, http://www.newmexicodsl.net/applications.htm. Downloading Music. M. Sargent, Twisted List: Top Five Reasons to Go Broadband, TechTV (Feb. 25, 2002), http://www.techtv.com/screensavers/twistedlist/story/0,24330,3359303,00.html. Internet Radio. M. Sargent, Twisted List: Top Five Reasons to Go Broadband, TechTV (Feb. 25, 2002), http://www.techtv.com/screensavers/twistedlist/ story/0,24330,3359303,00.html. Telemedicine – Distance Diagnoses. G. Wachter, Telecommunication, Linking Providers and Patients, Telemedicine Information Exchange (June 30, 2000), http://tie2.telemed.org/telemed101/topics/telecom.asp#bandwidth2. Distance Learning. Nortel Networks White Paper, Implementing Distance Learning Networks (Feb. 1999), http://www.nortelnetworks.com/products/02/papers/ 3387.html. Video-on-Demand. See S. Zeidler, Experts: Broadband Not Ready for Hollywood, azcentral.com (Feb. 3, 2002), http://www.azcentral.com/news/reuters/stories/NET-MEDIA-BROADBAND-DC.shtml (quoting Gartner G2 analyst PJ McNealy). Streaming Video. R. La Franco, The Serious Game: Digital Video is Still Off-Track, Red Herring (Aug. 22, 2001). Full-Length Video Downloads. J. Yaukey, Movies on Demand are Coming to a PC Near You, Gannett News Service (Sept. 24, 2001). Videoconferencing. G. Wachter, Telecommunication, Linking Providers and Patients, Telemedicine Information Exchange (June 30, 2000), http://tie2.telemed.org/telemed101/ topics/telecom.asp#bandwidth2. Telesurgery. A. Kerven, FT Connects Surgeons to Patient 4,000 Miles Away, CED Daily Direct (Sept. 21, 2001), http://www.cedmagazine.com/cedailydirect/0109/cedaily010921.htm.
Figures
Figure 1. Distribution of CLEC Circuit Switches 1998. Bellcore, TR-EQP-000315, Local Exchange Routing Guide (Mar. 1, 1999). 2001. Telcordia, January 2002 LERG.
Figure 2. Distribution of CLEC Packet Switches 1998. NPRG CLEC Report 2000, 12th ed., Ch. 6, Table 9 (restated 1998 data). 2001. NPRG CLEC Report 2002, 15th ed., Ch. 4 at Table 18. This is a highly conservative estimate. It does not include the 840 packet switches NPRG lists for competitive Independent Operating Companies, utility CLECs, data providers, or Gig-E providers. In addition, it does not include the 7,000 packet switches that NPRG lists for AT&T as of year-end 2001. According to NPRG’s prior reports, AT&T had only 50 packet switches as of year-end 2000. Because one-year growth of this magnitude is unlikely, in an abundance of caution we have used the 2000 figure for AT&T’s packet switches.
Figure 3. Distribution of CLEC Fiber 1998. NPRG CLEC Report 2000, 12th ed., Ch. 6 at Table 5 (restated 1998 data). 2001. NPRG CLEC Report 2002, 15th ed., Ch. 4 at Table 13. This is a highly conservative estimate. It does not include 117,000 route-miles of fiber that NPRG lists for competitive Independent Operating Companies, utility CLECs, data providers, or Gig-E providers. Moreover, the total miles for 2001 have been adjusted downward to address the concerns that CLECs raised in the Special Access proceeding in April of 2001 (CC Docket No. 96-98).
Figure 4. CDMA Network Configuration Nortel Networks, CDMA Networks, http://nortelnetworks.com/products/01/cdma/index.html#.
Figure 5. Increase in Speed/Bandwidth of Various Technologies Processor Speed/PC Bus Speed. PC Guide, Intel 8086, http://www.pcguide.com/ref/cpu/fam/g1I8086-c.html; PC Guide, Intel 80286, http://www.pcguide.com/ref/cpu/fam/g2I80286-c.html; Dell, i386 Specifications, http://docs.us.dell.com/docs/dta/320SLI/00000003.htm; Intel’s Developer Site, Pentium Processor, http://developer.intel.com/design/intarch/pentium/pentium.htm; Dr. Dobb’s Microprocessor Resources, Pentium Pro Manuals, ftp://download.intel.com/design/pro/datashts/24276905.pdf; Dr. Dobb’s Microprocessor Resources, Pentium II Manuals, ftp://download.intel.com/design/PentiumII/manuals/24350201.pdf; Intel’s Developer Site, Intel® Pentium® III Processor and Intel® 815E Performance Brief, http://developer.intel.com/procs/perf/PentiumIII_815E/brief/docs/pentiumiii_815E.pdf; Intel’s Developer Site, Intel® Pentium® III Processor and Intel® 815E Performance Brief, http://developer.intel.com/procs/perf/Pentium4/brief/docs/pentium4.pdf. Hard Drive Capacity. Fortune City.com, Storage Devices, http://www.fortunecity.com/marina/reach/435/storage.html; A Brief History of the Hard Disk Drive, PC Guide.com (Apr. 17, 2001), http://www.pcguide.com/ref/hdd/hist.htm; J & R Music World, Computers, Hard Drives, http://www.jandr.com/JRSectionView.process?IWAction=SortBy&Merchant_Id=1&Section_Id=1128&pbegin=0&pdir=0&Sort=Current_Price. Floppy Drive Capacity. Floppy Disk Drive Primer, Accurite White Paper, http://www.accurite.com/FloppyPrimer.html; Fortune City.com, Storage Devices, http://www.fortunecity.com/marina/reach/435/storage.html; Memorex, Company History, http://www.memorex.com/ about_memorex/company_history.php; J. Healey, Format War in DVD Recording Leaves Compatibility Out, L.A. Times (Dec. 27, 2001), http://www.latimes.com/technology/la-000102332dec27.story?coll=la-headlines-technology. LAN Speed. Ethernet’s and IEEE 802.3 History, Rad.com, http://www.rad.com/networks/2001/ethernet/hist.htm; 10 Gigabit Ethernet Alliance, 10GEA White Papers, http://www.10gea.org/Tech- whitepapers.htm.
Figure 6. Internet Backbone Traffic Growth Gilder Technology Report, Wasteland at Chart 2, Vol. VI, No. 11 (Nov. 2001).
Figure 7. Cable Network Upgrades Homes Passed by Two Way and 550 MHz or Higher. NCTA, Cable Television Industry Overview 2000 at 2 (2000). Homes Passed by Cable Modem Service. NCTA, The Cable TV Handbook at 2-B-13 (2001), http://www.ncta.com/industry_overview/ aboutIND.cfm?indOverviewID=50&prevID=1; NCTA Industry Statistics.
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APPENDICES
Appendix G. Competitive Collocation Providers in the Top 50 MSAs 56 Marietta Net. 56 Marietta Net, Home, http://www.56marietta.net/. @lightspeed. R. Miller, @Lightspeed Debuts Denver ‘Power Play’, Carrier Hotels (Mar. 19, 2001). Access Colo Inc. Access Colo Inc., Locations, http://www.accesscolo.com/locations.asp?toggle=1&highl=10. Advanticom. Advanticom Press Release, Advanticom Celebrates Grand Opening of Enterprise Data Center in Somerset, New Jersey (Apr. 27, 2001). Apollo Communications. Apollo Communications, Centers and Solutions, http://www.apollo-com.net/network.html. Axon Telecom. Axon Telecom, Presence, http://www.axontelecom.com/presence.htm. ClearBlue Technologies. ClearBlue Technologies, Connectivity, www.clearblue.com. Collocation Solutions. Collocation Solutions, Data Centers – Locations, http://www.collocationsolutions.com/datacenters/ locations.htm; Collocation Solutions, Site Locations, http://www.colosolutions.com/html/data___colocation_centers.html. Colo4Dallas. Colo4Dallas, Home, http://www.colo4dallas.com/. ColoCo. ColoCo, About our Facility, http://www.coloco.com/facility.html. ColoSafe. ColoSafe, Locations, http://www.colosafe.com/locations.html. ColoVault. ColoVault, Locations, Colhttp://www.colovault.com/locations.htm. Core Location. Core Location, Projects, http://www.corelocation.net/. COLO.com. COLO.com, Facilities, http://www.colo.com/english/ facilities/index.htm. Dialtone Internet. Dialtone Internet, Company Info – Investors, www.dialtone.com. Digital Internet Services Corporation. Digital Internet Services Corporation, About Us – Network, www.dis.net/about_us/network_info.php. E-COLO.com. E- COLO.com, Collocation Sites, http://www.e-colo.com/colocation_services_and_sites.htm. Equinix. Equinix, Fact Sheet, http://www.equinix.com/fact_sheet.htm. Fiber Connect. Fiber Connect, Collocation, http://www.fiber-connect.com/available.htm. Gateway Colocation. Gateway Colocation, Project Sites, http://www.gatecolo.com/project.html. IX2 Networks. IX2 Networks, Data Centers, http://www.ix2.net/DataCenters.htm. Layerone. Layerone, Layerone Locations, http://layerone.com/locations/index.html. Millennium Systems Inc. Millennium Systems Inc., Co-Location Division, http://colocation.nextmill.net/. MetroNexus. MetroNexus, Properties, http://www.metronexus.com/properties/properties_index. The Raco Group. The Raco Group, Site Locations, http://www.racogroup.net/ sitelocations.htm. Swiftcomm. D.M. Tucker, Inland Empire Focus: Battling Against Lost Bytes: I.E. Becomes Attractive to Firms Wanting Backup for Vital Info, Press Enterprise (Jan. 28, 2002); Swiftcomm, DataCenter, www.swiftcomm.com/datacenter_right.htm. Switch & Data. Switch and Data, Our Locations, http://www.switchanddata.com/locations/footprint.html. TeleTeam. TeleTeam, Co-Location, http://www.teleteam.com/serviceCLocation.asp?SectionID=9. Tres. Tres, Milestones, http://www.telecomrealestate.com/abou_mile.asp. Universal Access. Universal Access, UTX Locations, http://www.universalaccess.com/about/locations.asp. Telehouse America. Telehouse America, Facility Space, http://www.telehouse.com/fspace.html. TelX. TelX, Locations, http://www.telx.com/. Time Warner Telecom. Time Warner Telecom, National Network, http://www.twtelecom.com/la.html. UPNetworks. UPNetworks, Facility Facts, http://www.upn.net/facilty.htm. ValueWeb. ValueWeb, Colocation, http://www.valueweb.net/colocation/. Wave Exchange. Wave Exchange, Facilities; Locations and Features, http://www.waveexchange.com.
Appendix I. CLECs Providing ATM and Frame Relay Adelphia. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Adelphia Business Solutions at 18-19. Allegiance. NPRG CLEC Report 2001, 13th ed., Ch. 13 – Allegiance Telecom, Inc. at 15-16. ALLTEL. NPRG CIOC Report 2001, Ch. 6 – ALLTEL Communications, Inc. at 9-10. Arbros. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Arbros Communications at 8. AT&T. NPRG CLEC Report 2002, 15th ed., Ch. 6 – AT&T Corp. at 22-24. ATG. NPRG CLEC Report 2002, 15th ed., Ch. 6 – ATG Advanced Telcom Group, Inc. at 12-14. Bay Ring Communications. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Bay Ring Communications at 5. Birch Telecom. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Birch Telecom, Inc. at 12-13. Broadslate. NPRG CLEC Report 2001, 13th ed., Ch. 9 – Broadslate Networks, Inc. at 5. Broadview. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Broadview Networks, Inc. at 10. BTI. NPRG CLEC Report 2002, 15th ed., Ch. 6 – BTI Telecom Corp. at 14. Buckeye Tel. NPRG CLEC Report 2001, 13th ed., Ch. 9 – Buckeye TeleSystem at 5. Cablevision Lightpath. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Cablevision Lightpath, Inc. at 8-9. Choice One. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Choice One Communications at 12. Coast to Coast. NPRG CLEC Report 2001, 13th ed., Ch. 9 – Coast to Coast Telecommunications, Inc. at 7. Comcast Business Solutions. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Comcast Business Solutions at 9. CoreComm (ATX). NPRG CLEC Report 2002, 15th ed., Ch. 6 – CoreComm, Ltd. at 8. Cox. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Cox Communications at 9-10. CTC. NPRG CLEC Report 2002, 15th ed., Ch. 6 – CTC Communications, Corp. at 12-13. CTC Telcom. NPRG CIOC Report 2001, Ch. 6 – CTC Telcom at 6. CTSI. NPRG CIOC Report 2001, Ch. 6 – CTSI, Inc. at 7-8. Digital Teleport. NPRG CLEC Report 2001, 13th ed., Ch. 9 – Digital Teleport, Inc. at 10-11. e.spire Communications. NPRG CLEC Report 2002, 15th ed., Ch. 6 – e.spire Communications, Inc. at 14-15. Electric Lightwave. NPRG CLEC Report 2001, 13th ed., Ch. 9 – Electric Lightwave, Inc. at 11-12. Eschelon Telecom. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Eschelon Telecom, Inc. at 9. Fairpoint. NPRG CIOC Report 2001, Ch. 6 – Fairpoint Communications Corp. at 8-9. FiberNet Telecom. NPRG CLEC Report 2001, 13th ed., Ch. 9 – FiberNet Telecom Group at 8. Fidelity Communications Services. NPRG CIOC Report 2001, Ch. 6 – Fidelity Communications Services at 5. Florida Digital Network. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Florida Digital Network at 8-9. Focal. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Focal Communications at Corp at 11. General Communications. NPRG CLEC Report 2002, 15th ed., Ch. 6 – General Communications, Inc. at 9. Global Crossing. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Global Crossing, Ltd. at 8-9. Global NAPs. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Global NAPs at 7. Globalcom. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Globalcom, Inc. at 6. Grande Comm. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Grande Communications Network, Inc. at 12-13. HickoryTech. NPRG CLEC Report 2001, 13th ed., Ch. 9 – HickoryTech at 8. ICG Communications. NPRG CLEC Report 2002, 15th ed., Ch. 6 – ICG Communications, Inc. at 12. Integra Telecom. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Integra Telecom at 7. IP Communications. NPRG CLEC Report 2001, 13th ed., Ch. 9 – IP Communications Corp. at 6. ITC^DeltaCom. NPRG CLEC Report 2002, 15th ed., Ch. 6 – ITC^DeltaCom, Inc. at 14-16. KMC Telecom. NPRG CLEC Report 2002, 15th ed., Ch. 6 – KMC Telecom, Inc. at 14. Knology Broadband. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Knology Broadband at 9. LecStar Communications. NPRG CLEC Report 2002, 15th ed., Ch. 6 – LecStar Communications at 7-8. Lightship Telecom. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Lightship Telecom at 8. Lightyear. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Lightyear Communications, Inc. at 8-9. Log On America. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Log On America, Inc. at 7. Logix. NPRG CIOC Report 2001, Ch. 6 – Logix Communications Enterprises, Inc. Madison River. NPRG CIOC Report 2001, Ch. 6 – Madison River Communications at 7. McLeodUSA. NPRG CLEC Report 2002, 15th ed., Ch. 6 – McLeodUSA, Inc. at 24- 26. Mid-Maine. NPRG CIOC Report 2001, Ch. 6 – Mid-Maine Communications at 5. Mid-Rivers. NPRG CIOC Report 2001, Ch. 6 – Mid- Rivers Communications, Inc. at 7. MFN. NPRG CLEC Report 2001, 13th ed., Ch. 9 – Metromedia Fiber Network at 16-18. MP Telecom. NPRG CLEC Report 2001, 13th ed., Ch. 9 – MP Telecom at 6. Mpower. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Mpower Communications at 13. NEON Optica. NPRG CLEC Report 2001, 13th ed., Ch. 9 – NEON Optica, Inc. at 9. Net2000. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Net2000 Communications, Inc. at 8. New Edge. NPRG CLEC Report 2001, 13th ed., Ch. 9 – New Edge Networks, Inc. at 8-19. NAS. NPRG CLEC Report 2001, 13th ed., Ch. 9 – Network Access Solutions, Inc. at 6-7. Northland. NPRG CIOC Report 2001, Ch. 6 – Northland
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Communications Group at 6. NewSouth Communications. NPRG CLEC Report 2002, 15th ed., Ch. 6 – NewSouth Communications Corp. at 17-18. NTELOS. NPRG CIOC Report 2001, Ch. 6 – NTELOS, Inc. at 8. NTS Comm. NPRG CLEC Report 2002, 15th ed., Ch. 6 – NTS Communications, Inc. at 8. NuVox. NPRG CLEC Report 2002, 15th ed., Ch. 6 – NuVox Communications at 7-8. Pac-West. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Pac-West Telecomm, Inc. at 9-10. Penn Telecom. NPRG CIOC Report 2001, Ch. 6 – Penn Telecom, Inc. at 5. Pine Tree Networks. NPRG CIOC Report 2001, Ch. 6 – Pine Tree Networks at 6. Prospeed.Net. NPRG CLEC Report 2001, 13th ed., Ch. 9 – Prospeed.Net at 7. Reliant Energy. NPRG CLEC Report 2001, 13th ed., Ch. 9 – Reliant Energy Communications, Inc. at 7. RIO Communications. NPRG CLEC Report 2002, 15th ed., Ch. 6 – RIO Communications at 5. TDS Metrocom. NPRG CIOC Report 2001, Ch. 6 – TDS Metrocom at 8. Telergy. NPRG CLEC Report 2001, 13th ed., Ch. 9 – Telergy, Inc. at 8-9. Teligent. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Teligent, Inc. at 10. Time Warner Telecom. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Time Warner Telecom, Inc. at 18-19. TXU Comm. NPRG CLEC Report 2001, 13th ed., Ch. 9 – TXU Communications at 8. US LEC. NPRG CLEC Report 2002, 15th ed., Ch. 6 – US LEC Corp. at 10-11. Vanion. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Vanion, Inc. at 6. WanTel. NPRG CLEC Report 2002, 15th ed., Ch. 6 – WanTel, Inc. at 5. Western Integrated Networks. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Western Integrated Networks at 5-6. WinStar/IDT. NPRG CLEC Report 2002, 15th ed., Ch. 6 – Winstar Communications at 10-12. WorldCom. NPRG CLEC Report 2002, 15th ed., Ch. 6 – WorldCom, Inc. at 16-18. XO. NPRG CLEC Report 2002, 15th ed., Ch. 6 – XO Communications at 15-17.
Appendix J. Additional Information on Softswitches Table 1. Features of Packet Switches/Softswitches vs. Traditional Circuit Switches Less Fixed Investment. A. Lindstrom, Talkin’ ‘Bout Next-Generation Telcos; Level 3 Communications, Form 8-K (SEC filed Feb. 7, 2000); C. Wolter, Softswitch Defined, Xchange (May 2000), http://www.x-changemag.com/articles/051feat2.html; M. Reddig, Softswitches Emerge from the Shadows; The Heart Of Convergence, tele.com (May 29, 2000), http://www.teledotcom.com/article/TEL20001002S0031. Less Expensive to Operate and Maintain. P. Korzeniowski, Pieces of Concern – The Communications Market Is One Big Puzzle, and CLECs Are Scrambling to Find the Right Fit, http://www.itlmetro.com/press1.htm; M. Reddig, Softswitches Emerge from the Shadows; M. Brown, Dain Rauscher Wessels, Investext Rpt. No. 2311326, Sonus Networks Inc. – Company Report at *1 (Oct. 3, 2000). Reduced Peripheral Equipment Needs. WorldCom, Inc., Form 425 (Press Call Transcript of Nov. 3, 2000) (SEC filed Nov. 6, 2000) (statement of Ron Beaumont, President and CEO, Operations and Technology, WorldCom). Increased Scalability. M. Reddig, Top 10 Advances in Switching (quoting Dana Crowne, CTO, Allegiance Telecom); XO Press Release, XO Selects Sonus Networks to Provide Next-Generation Switching and Softswitch Technology (Nov. 7, 2000). Increased Flexibility for New Services. M. Reddig, Top 10 Advances in Switching (citing Travis Ewert, manager of network-engineering planning, Electric Lightwave); M. Reddig, Softswitches Emerge from the Shadows (citing Jon Arnold, VoIP-equipment-industry manager, Frost & Sullivan); D. Mossberg, Southwest Securities, Investext Rpt. No. 2126012, INET Technologies Inc. Initiating Coverage – Company Report at *13 (Apr. 10, 2000). High Quality and Reliability. D. Mossberg, Southwest Securities, Investext Rpt. No. 2126012, INET Technologies Inc.: Initiating Coverage – Company Report at *13 (Apr. 10, 2000); Tachion Networks’ Fusion 5000 Collapsed Central Office Gains NEDS Level 3, ETSI and SBC/Verizo Certifications, Innovation Garden, http://www.innovationgarden.org/news_events/nj_tech_briefs/news_0066.asp; P. Bernier, Softswitches Head for the Last Stretch: Are Class 5 Replacements Ready to Run?, Xchange (June 1, 2001), http://www.xchangemag.com/articles/ 161solutions4.html (citing Joe Mele, V.P. of open network solutions, Lucent Technologies); M. Reddig, Softswitches Emerge from the Shadows (citing Tom Buttermore, CEO, Broadriver Communications).
Table 2. The Emergence of Softswitches M. Reddig, Softswitches Emerge from the Shadows; P. Korzeniowski, Pieces of Concern – The Communications Market Is One Big Puzzle, and CLECs Are Scrambling to Find the Right Fit, tele.com (May 29, 2000); C. Wolter, Softswitch Defined, Xchange (May 2000), http://www.x- changemag.com/articles/051feat2.html.
Table 3. CLECs Deploying Softswitches Allegiance. Allegiance Telecom News Release, Allegiance Telecom Announces Initiation Of Softswitch Technology (May 3, 2000). Broadriver. A. Lindstrom, Talkin’ ‘Bout Next-Generation Telcos. CTC Communications. C. Wilson, Softswitch Goes Real World, Interactive Week (Sept. 4, 2000), http://www.zdnet.com/intweek/stories/news/0,4164,2624929,00.html; A. Lindstrom, Talkin’ ‘Bout Next-Generation Telcos. Global NAPs. M. Reddig, Softswitches Emerge from the Shadows (citing New Paradigm Resources Group, Inc.). KMC Telecom. Lucent News Release, Lucent Technologies media gateway enhancements complement Lucent Softswitch, providing path to IP-based networks (Jan. 16, 2001). Level 3. Sonus News Release, Sonus Networks Announces Voice Infrastructure Systems Agreement With Level 3 (Aug. 9, 2001). NewSouth Communications. W. Kawamoto, NewSouth Selects Tekelec’s Softswitch Solution, CLEC-Planet (June 7, 2001), http://www.clec- planet.com/news/000106/june7newsouth.html. Time Warner Telecom. Sonus News Release, Time Warner Telecom Begins Traffic Flow on Sonus-Based Infrastructure (Apr. 9, 2001). USA Datanet. USA Datanet Press Release, USA Datanet Goes Live with Sonus Networks Packet Voice Infrastructure (June 14, 2000). WorldCom. M. Johnston and D. Pappalardo, WorldCom Sees Promise in Move to Softswitches, Network World (Jan. 29, 2001), http://www.nwfusion.com/news/2001/0129carrier.html. XO Communications. Sonus News Release, XO Communications Selects Sonus Networks to Provide Next-Generation Switching and Softswitch Technology (Nov. 7, 2000).
Table 4. Major Softswitch Manufacturers Tachion. J. Boyd, The End of the Central Office (Aug. 14, 2000), http://www.internetwk.com/infastructure/infra081400-3.htm; Tachion Networks’ Fusion 5000 Collapsed Central Office Gains NEDS Level 3, ETSI and SBC/Verizo Certifications, The Innovation Garden State, http://www.innovationgarden.org/news_events/nj_tech_briefs/news_0066.asp. Axtar Limited. Axtar Announces the Industry’s First Programmable cPCI Central Office Switch Based on LINUX, ECTA, http://www.ectaweb.org/press/member/07aug2000_axtar.htm. Santera Systems. M. Brown, Dain Rauscher Wessels, Investext Report No. 2311326, Sonus Networks Inc. – Company Report (Oct. 2000). Uniphere Networks. P. Bernier, Softswitches Head for the Last Stretch: Are Class 5 Replacements Ready to Run?, Xchange (June 1, 2001) http://www.xchangemag.com/articles/161solutions4.html. Cisco. E. Pimentel (CTO, BroadRiver Communications), Letter to the Editor, Xchange, http://www.x-changemag.com/articles/181let2.html (Aug. 1, 2001). Sonus. M. Brown, Dain Rauscher Wessels, Investext Rpt. No. 2311326, Sonus Networks Inc. – Company Report at *1 (Oct. 3, 2000); P. Bernier, Softswitches Head for the Last Stretch: Are Class 5 Replacements Ready to Run?, Xchange (June 1, 2001), http://www.xchangemag.com/articles/161solutions4.html (quoting Terri Griffin, VP of INIP, Sonus). Convergent Networks. P. Bernier, Softswitches Head for the Last Stretch: Are Class 5 Replacements Ready to Run?, Xchange (June 1, 2001), http://www.xchangemag.com/articles/161solutions4.html. Tacqua. Integral Access Press Release, Integral Access Completes Interoperability with Taqua Systems and Joins the Taqua Open Partner Program (TOPP) (Sept. 4, 2001). Nortel. Nortel Networks, Softswitch
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Portfolio. Communication Server 3000, http://www.nortelnetworks.com/products/01/succession/cs/cs3000.html. Syndeo Corporation. Syndeo Corporation Press Release, Syndeo’s Carrier-Class Softswitch Chosen for Deployment with the Armstrong Group (Feb. 19, 2002). Convedia Corporation. Convedia, Products. CMS-6000 Media Server, http://www.convedia.com/cms.htm. Gallery IP Telephony. Gallery IP Telephony News Release, Cisco Systems and Gallery IP Telephony Showcase NextGen Telephony for Service Providers Networks Cisco Expo (Jan. 22, 2002). Metaswitch. MetaSwitch Press Release, MetaSwitch VP3000 Wins Internet Telephony’s Product of the Year for Second Year Running (Jan. 7, 2002). Lucent. Lucent Technologies, Softswitch Solutions. Softswitch - T3 (Toll/Tandem/Transit), http://www.lucent.com/products/ solution/0,,CTID+2002-STID+10253-SOID+950-LOCL+1,00.html.
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Attachment C Before the Federal Communications Commission Washington, D.C. 20554
In the Matter of ) ) Review of the Section 251 Unbundling ) Obligations of Incumbent Local ) CC Docket No. 01-338 Exchange Carriers ) ) Implementation of the Local Competition ) Provisions in the Telecommunications ) CC Docket No. 96-98 Act of 1996 ) ) Deployment of Wireline Services ) Offering Advanced Telecommunications ) CC Docket No. 98-147 Capability )
Declaration of Howard A. Shelanski
Statement of Qualifications I am Acting Professor of Law at the University of California at Berkeley. I received my B.A. from Haverford College in 1986, my J.D. from the University of California at Berkeley in 1992, and my Ph.D. in economics from the University of California at Berkeley in 1993. I have been a member of the Berkeley faculty since 1997. In 1998- 2000 I was on leave from my faculty position to serve as a Senior Economist to the President’s Council of Economic Advisers (1998-99) and then as Chief Economist of the Federal Communications Commission (1999-2000). I rejoined the Berkeley faculty on a full time basis in July 2000. I formerly practiced law in Washington, D.C. with the firm of Kellogg, Huber, Hansen, Todd and Evans and served as a law clerk to Justice Antonin Scalia of the U.S. Supreme Court.
1
I teach and conduct research in the areas of telecommunications regulation, antitrust, and applied microeconomics. My recent publications include articles in the Journal of Law, Economics and Organization, the Yale Journal on Regulation, the University of Chicago Law Review, the Journal of Law and Economics, the University of Chicago Legal Forum, and the Columbia Law Review. I am co-author of the recently published legal textbook Telecommunications Law and Policy (Carolina Academic Press, 2001). I am a regular participant in academic conferences related to telecommunications policy and antitrust and lecture regularly on both topics at universities in the United States and abroad. I have served as a referee for a number of economics journals and am an editor of the International Review of Law and Economics. My C.V. is attached.
Introduction
1. The Commission’s Triennial Review proceeding affords the opportunity for the agency to assess the current state of local exchange competition and to review its network unbundling regulations. The purpose of this paper is to respond to the Commission’s Notice by examining the empirical evidence to date on entry and UNE consumption and discussing the economic implications of that data both for current market performance and for unbundling policy going forward. The principal conclusions of this paper are the following:
· Unbundling in the absence of a clear showing of impairment would be socially costly. Facilities-based competition promises far greater benefits than does competition through unbundled access and should never be displaced by unbundling rules.
· Unbundling can undermine facilities-based competition and therefore cannot be considered a costless policy that will merely provide an alternative or complement to competing facilities. A rigorous showing of general (as opposed to firm specific) impairment to competition should be required before unbundling is retained for a network element. Such a showing should be considered defeated by actual evidence that competitors are obtaining necessary facilities without recourse to UNEs.
2 · Even when unbundling has proven necessary to initiate competition, the Commission should not find that market entry continues to be impaired once competing facilities actually do, or feasibly could, become available.
· Once facilities-based competition arises or proves economically feasible, unbundling should not be mandated at any price. The question of whether to require a network element to be unbundled should be treated independently of, and prior to, the question of the pricing of such unbundled access. Of course, once a determination is made as to which elements should be unbundled, it then becomes critically important to establish prices that preserve economically rational incentives to invest in competing facilities.
· Empirical evidence demonstrates that the local exchange market has become significantly more competitive since passage of the 1996 Act and, more importantly for the instant proceeding, that some network elements that have been required to be unbundled are now being competitively supplied in substantial amounts.
· Current data provide a compelling case that new entrants would face no competitive impairment if ILECs did not unbundle local switching. Similarly, interoffice transport is now being competitively supplied by competitive local exchange carriers as well as by third-party suppliers of transport facilities. Finally, the loop market is also becoming increasingly competitive, especially in the provision of high-capacity loops. New entrants are in fact entering the market for each of these elements unimpaired and the case for their mandatory unbundling has evaporated.
· In light of the empirical evidence, the FCC should reduce the current list of unbundled elements and should adopt a strong presumption against finding impairment where actual market data shows entry through paths other than unbundling.
2. This declaration is organized as follows. Part I provides theoretical background on unbundling and on the comparative economics of alternative entry paths into the local exchange business to provide a framework for drawing policy inferences from the empirical evidence. Part II discusses the policy precedent for eliminating unbundling where there is evidence of competing facilities. Part III examines empirical data on competition in the local exchange presented in the UNE Fact Report 2002, filed in this proceeding by BellSouth, SBC, Qwest and Verizon (“Fact Report”), and discusses the changing case for the unbundling of several individual network elements. Part IV concludes.
3 I. The Economic Importance of Correct Unbundling Policy
3. The overarching question for the Commission in this proceeding is whether competitors are currently impaired in entering the local exchange market if they lack access to a given unbundled network element (UNE) from an ILEC. To have any economic content, “impairment” must at a minimum mean that there is no option that would enable a carrier to compete in the local exchange market other than obtaining the element at issue from the ILEC under regulated unbundling. If other, non-UNE, options are available to CLECs—e.g. purchasing their own facilities or obtaining access to those owned by third parties—then the case for impairment cannot be made and unbundling should be repealed for that element.
4. In assessing the case for impairment, it is important for the Commission to adopt a realistic baseline from which to judge the development of local competition. If the standard for successful progress in local telephony is geographically ubiquitous entry, then the Commission risks finding impairment in markets that CLECs never intended to enter in the first place. The relevant question is not whether CLECs are entering local markets everywhere, but whether CLECs can enter without impairment the markets that they have demonstrated a realistic intent to enter. When the question is phrased this way, the Commission can more correctly assess alleged ILEC advantages due to incumbency. An incumbent’s unrivaled presence in markets that present an unattractive business case does not necessarily mean the incumbent has advantages over rivals in other markets.
5. Unbundling of network elements is not a costless path to competition. If unbundling substitutes for facilities-based competition, consumers lose on multiple fronts. First, they will receive fewer price and output related benefits than they would receive from head-to-head competition among independent networks. Second, they will receive fewer long-term benefits from development and deployment of innovative technologies and services. In addition, they will not have the robustness and security that comes from having multiple sources of local exchange service. Unbundling
4 should not, therefore, be viewed as a harmless policy for fostering competition or as a mere back-up to more conventional means of competitive entry. The back-up can become the primary path and in so doing cause important social benefits to be lost. Unbundling thus needs to be understood for what it is: a risky policy that, if not carefully and selectively implemented, could deter innovation and displace superior improvements to market performance through conventional, facilities-based, entry.
6. Accordingly, as the Commission moves forward with its unbundling regulations the appropriate policy guideline where the case is close is to err against finding impairment. For reasons to be discussed in this section, the expected costs of any errors against unbundling will be much lower than the costs of errors that extend or maintain unbundling. The Commission therefore should not require that any element be unbundled if empirical evidence shows the market for that element to be susceptible to facilities-based entry and competition. In such cases, the presumption against impairment should be strong and be rebuttable only by a convincing and particularized demonstration to support a finding by the FCC that, without unbundling, efficient entry into a given market would not be feasible. To set the presumption otherwise would be to harm non-UNE-based competition, to lose substantial consumer benefits over time, and to undermine the objectives of the 1996 Act.
A. Comparison of Unbundled Access and Facilities-Based Entry 7. Consider the comparative dynamics of competition through unbundling and competition based on rival facilities. When two firms use the same network to provide service, they for the most part have the same minimum production costs. To be sure, they may have some costs that are independent, such as those of marketing or customer service. But the sharing of facilities necessarily reduces the scope of the carriers’ abilities and competitive incentives to reduce production costs. In comparison, when rival facilities compete in the marketplace, they have distinct production costs and each competitor has strong incentives to reduce the costs of producing its service in order to cut prices to consumers and gain market share. All
5 else being equal, facilities-based competition promises much greater price and output benefits for consumers than competition over shared network facilities does. As Justice Breyer plainly put the point somewhat in his separate opinion in Iowa Utilities Board. v. AT&T, 525 U.S. 366, 430 (1999): “A totally unbundled world—a world in which competitors share every part of an incumbent's existing system, including, say, billing, advertising, sales staff, and work force (and in which regulators set all unbundling charges)—is a world in which competitors would have little, if anything, to compete about.”
8. Similarly, when firms use common facilities, the industry at issue is less likely to create or deploy innovative technology or services. The fewer the competing networks, the smaller the possible set of alternative approaches to innovation. With fewer firms pursuing independent innovation efforts, the less likely it is that new services will be introduced in a given time frame. More fundamentally, the incentive to engage in innovation in the first place declines when rival service operators use a shared network. For, the innovator will share any benefits it creates with others using the network rather than capturing the returns itself. The incumbent’s investment in its network will in effect create a positive externality for UNE users, and the operator’s incentive to undertake such investments will diminish to the extent it cannot capture returns from that externality. Much of the incentive to innovate can come from desire to gain an edge over rivals, which is not possible if those rivals automatically get access to the innovation in question.
9. On the other hand, when a carrier faces competition from rival networks, it will have an incentive to cut its own costs and to offer new services to its customers as a means of gaining market share from its rivals. Indeed, empirical evidence suggests that, over the history of U.S. telecommunications, deployment of new technology and services has occurred more quickly in markets that contain competing networks than in markets with only one network.1 An analysis by FCC staff, for example, attributed
1 See, e.g., Howard Shelanski, “Competition and Deployment of New Technology in U.S. Telecommunications,” U. Chi. Leg. Forum 85 (2001).
6 accelerated deployment of DSL service to pressure from cable networks’ broadband offerings. 2 Fiber deployment in the long-distance telephone sector, the virtues of which were appreciated by the late 1970’s, accelerated only with the full-scale, facilities-based entry of Sprint upon the implementation of equal IXC/LEC interconnection after the AT&T divestiture in 1984. 3
10. Innovation concerns not only counsel against retaining unbundling requirements where market evidence shows competitive facilities, but also against extending unbundling obligations to new kinds of equipment or services. When new, advanced technology becomes available and new kinds of services are introduced into the marketplace, the costs, risks, and uncertainty may all be quite substantial. To require ILECs to unbundle such facilities to competitors will impede deployment of new technology and services, to the detriment of consumers. Just as the balance of risks weighs against continuing to unbundle facilities that are becoming competitively supplied, it weighs against unbundling advanced facilities that are not yet supplied at all on a wide scale or that are just beginning to be supplied. The ILEC itself is newly entering the provision of such services and facilities.
11. Even if the ILEC were the sole emerging provider of such advanced capabilities (which is not the case), the Commission should not extend unbundling to the relevant new facilities if implementation of advanced technology is to be encouraged. Simply put, just as impairment should not be found for existing UNEs that become competitively available in the marketplace, impairment should not be found for advanced services facilities that are just entering the market and which the ILECs themselves are just beginning to deploy. Examples of such new technology include fiber-based local loop technologies and packet switching.
2 Broadband today: A Staff Report to William E. Kennard, Chairman, FCC, at 27 (October 1999), available at http://www.fcc.gov/bureaus/cable/reports/broadbandtoday.pdf.
3 Shelanski, “Competition and Deployment of New Technology in U.S. Telecommunications,” supra.
7 12. Whereas both the current and long-run costs of displacing facilities-based competition with unbundled access may be quite high, the countervailing benefits of unbundling are limited. Unbundling can in theory lead to more efficient use of existing facilities and thereby dissipate any monopoly effects in the incumbent’s provision of network- based services. It can also create competitive pressure to innovate in non-facilities aspects of service provision, such as marketing, customer service, or packaging of services. It is essential to recognize, however, that none of the above benefits is unique to unbundling. Each would flow, and to a much greater degree, from facilities- based entry. Pricing, service quality, and innovation would all improve more directly and dramatically from efficient introduction of competing facilities than from allowing new entrants to use existing networks.
13. The most important benefit generally ascribed to unbundling is that it can serve as a transitional mechanism to facilities-based competition where otherwise such competition would not arise or would arise only piecemeal. As a threshold matter, that is not how UNEs are in fact used and the mere fact that new entrants cannot feasibly construct ubiquitous networks does not make the case for unbundled access. Even if new entrants cannot offer full networks from the outset, they may be able to build out incrementally and to obtain interconnection with other carriers such that viable entry does not depend on unbundling. Currently, more than half of CLEC lines are served entirely over the CLECs’ own facilities (Fact Report, Section I, Figure 3). To the extent the choice is genuinely one between monopoly and competition through unbundling, requiring unbundled access may be sound policy. 4 But the unbundling- as-transition argument cannot by its terms provide an enduring justification for such regulation. There is a serious risk with infant-industry or infant-firm policies that the infants never grow up. Once the transition to non-UNE-based competition actually occurs, or once it can be shown that competition can occur without resort to UNEs, there is no need to maintain unbundling requirements.
4 It is not necessarily the case that unbundling will be preferred to monopoly, however. There are administrative costs to unbundling as well as productive inefficiencies—for example from possible reduction of investment incentives for the network owner—that could offset the benefits of competition
8
14. Equally importantly, even if the transition to facilities-based competition does not occur and UNE consumption continues, then regulators must consider the possibility that unbundling has been implemented in a manner that causes firms to substitute entry using incumbent networks for entry over their own facilities. The paradox is that the same evidence some might use to prove impairment but for unbundling— high levels of unbundled access consumption—might in fact prove something very different and lead to exactly the opposite policy prescription. Indeed, it could demonstrate that unbundling provides an alternative to facilities-based entry that benefits some new entrants (those that choose not to invest in facilities) but not competition or consumers.
15. Substitution of UNEs for facilities-based entry is not merely conjectural. By 1999, when the FCC last reviewed its UNE regulations, competitive provision of DSL was well under way. Many data CLECs supplied their own electronic facilities (i.e. DSLAMs), which they collocated in ILEC central offices. Yet many other CLECs nonetheless contended that competition would be impaired without an unbundled “packet UNE.” The Commission mostly rejected that unbundling request, but the key point is that even where impairment clearly did not exist, a group of entrants preferred to opt for unbundling over purchase of their own facilities.
16. It is thus necessary, if sound policy is to be implemented, for regulators to examine market developments carefully and to credit fully the importance of data on the entry of independent, competitive facilities. Costly tradeoffs are likely to result if regulations require unbundling of a network element once market evidence demonstrates that new competitors can—whether they actually choose to or not— economically provide that facility for itself, obtain it from third parties, or obtain if from the ILEC under arrangements other than regulated unbundling. Such a policy runs the risk of supplanting the substantial benefits of facilities-based entry with the
through unbundled access. But it cannot be questioned that the case for unbundling is strongest where it can be demonstrated that there is no other likelihood of competitive entry.
9 comparatively anemic returns, and potentially high costs, of unbundled access. Given this tradeoff, the Commission should presume impairment does not exist where the market demonstrates the entry of alternative facilities and should in such cases place the burden on CLECs rigorously to demonstrate that impairment persists if unbundling of a given element is to be continued.
B. Once Entry Without Reliance on UNEs Proves Viable, The Case for Impairment, and hence for Unbundling, Evaporates
17. Once entrants have demonstrated that they can enter the local exchange market without resort to particular unbundled elements, the Commission should no longer mandate that those elements be unbundled. The feasibility of facilities-based entry and other alternatives to UNE-based competition accomplish all of the goals that the 1996 Act sought to reach through unbundling. Such options first and foremost demonstrate that entrants will not be impaired without unbundled access to ILEC facilities. Second, they either provide a transitional mechanism to full facilities-based entry or show that such a transitional alternative is not necessary. And third, they show that the market has become a less uncertain place for CLECs to do business in terms of the availability of competitive facilities or of the financial feasibility of constructing one’s own facilities.
18. The case of interoffice transport is a good example of the above changes. CLECs and third parties both found a business case for building transport facilities to use themselves or lease to others. Any CLEC entering the market can thus see that construction of its own transport is feasible, yet can still purchase such transport from a third party if it opts not to build over the short or even long run. The same facts apply to switching. As new entrants add their own switch capacity, they not only free themselves from relying on ILEC facilities, but they also create a non-ILEC source of leased switching capacity for new entrants who choose, for whatever reason, not to invest in their own equipment.
10 19. The same arguments that counsel against unbundling where competitive facilities can exist also apply to extending unbundling to cases where regulated or tariffed arrangements between ILECs and other carriers eliminate impairment. Interexchange carriers and CMRS providers, for example, have had no difficulty obtaining special access from the ILECs through non-UNE agreements. Indeed, IXCs and others have been successfully providing competitive access for a decade. There is thus no case for extending unbundling obligations to special access or indeed any case in which other arrangements have proven sufficient to defeat competitive impairment.
20. One might argue that unbundling will simply coexist with, and not supplant, facilities-based competition where the latter is feasible. From that standpoint unbundling is simply another alternative entry path that should be left open to entrants. This argument is flawed for several reasons. To begin with, even if unbundling were to substitute only marginally for facilities-based entry, the foregone consumer gains could be substantial. But when unbundling is available, its substitution effect is likely to be more than merely marginal.
21. First, unbundled access may offer a new entrant certain advantages over facilities- based entry, even if the latter would better serve competition and consumers. For example, an entrant may perceive entry over the incumbent’s facilities as less risky or more profitable than entry on a facilities basis, even where, absent the unbundling option, the entrant would have found it economical to build its own facilities. An entrant might also prefer to limit the competitive pressure that would result from facilities-based competition by opting instead for unbundled access. That option would free the entrant from having to engage in independent innovation efforts and, moreover, afford it an option on any advance in the network implemented by the incumbent. While an economically correct UNE price would include the value of that option, the pricing solution (which would itself be very difficult accurately to achieve) does nothing to compensate for the reduction in independent innovation activities. Consumers bear the resulting costs in the form of reduced flow of cost- reducing advances in the network and reduced flow of new service options.
11
22. An entrant might also use unbundled access as a way to defer investment in its own facilities until such time as a new generation of technology emerges. This latter strategy is not inefficient in cases where no firm would rationally invest in today’s technology because of forecasts about tomorrow’s better technology. No firm wants to strand costs and there may be times when it is rational to wait to enter the market when significant technological change is in prospect. A problem arises, however, where it would be efficient for a firm to invest in today’s technology and enter the market with its own equipment, but where it instead opts for unbundling while it waits for future technological developments. Each such use of unbundling to play socially inefficient “wait and see” games further defers true competition.
23. Second, unbundling requirements entail regulated rates for unbundled access, which in turn add to the costs and economic risks of unbundling. The administrative difficulties of setting economically correct prices for network elements are not trivial. If rates turn out not to match costs exactly and instead to understate actual costs, then those rates will fail accurately to communicate to entrants the relative prices of alternative entry options. The costs of such inaccuracies are very high. In particular, if UNE prices understate the total costs of unbundled entry, they will systematically bias entrants towards unbundling and away from facilities-based competition.
24. At the same time, prices that are too low will deter the incumbents from making investments in their own networks because they will have to share the benefits, although not the full costs, with competitors using UNEs. Moreover, to retain mandatory unbundling once there is no longer impairment is to raise the possibility that UNE prices will undermine those CLECs that have invested in their own facilities. State or federal regulators must not only get pricing right initially, but they must ensure pricing remains appropriate each time they revisit and revise pricing over time. Even if UNE prices send accurate signals for a time, they might later fall to the point that facilities-based CLECs are at a comparative disadvantage to CLECs using UNEs, even though the former may have more efficient networks. This problem of
12 shifting price signals is not conjectural. Several states have already held multiple pricing proceedings and in some cases, for example New York, have radically revised UNE rates over just a couple of years.
25. I do not here intend to delve into the complex and contentious issue of UNE pricing. The point is simply that an unrealistically strong assumption of sustained accuracy in setting regulated UNE prices is required before one can say with any confidence that an unbundling option will not affect incentives to build new, competing facilities or to improve existing ones. The results of different state pricing proceedings make clear just how unlikely it is that regulators will set prices correctly. In Indiana, for example, the UNE price for a loop is between $8.00 and $8.99 per month, with an average price of about $8.30. This is about half the national average. It is also far less than the rates in all states with similar population densities. The population per square mile in Indiana is 168. In North Carolina, with a population density of 155 per square mile, the average loop price is $15.88. In Georgia, with a population density of 142, the average loop price is $16.51, while in Tennessee, where the population density is 136 people per square mile, the loop rate in Tennessee is $14.92. It seems improbable that these price differences reflect purely cost differences. The correct explanation is more likely that setting UNE rates is an exercise fraught with opportunity for imprecision and error.
26. Of course, once a determination is made that some elements should be unbundled, it is important that the prices for unbundled network elements be set correctly where unbundling does occur. Otherwise, those prices will further exacerbate the deterrent effect that unbundling has on investment in competing facilities. I have explained elsewhere that the Commission’s current TELRIC pricing rules do not preserve economically rational investment incentives and need to be revisited. But for the present purpose the key point is that these efficient price adjustments should not substitute for careful analysis of whether competitors are truly impaired without access to a given network element. The potential economic costs of unwarranted unbundling cannot be cured through mere adjustments in the price of unbundled
13 access. Once facilities-based competition in a UNE market arises or proves economically feasible, unbundling should not be mandated at any price. The question of whether to require a network element to be unbundled should be treated independently of, and prior to, the question of the pricing of such unbundled access.
27. The arguments against trying to adjust unbundling rules at the level of pricing instead of at the level of the elements themselves include the same reasons, listed above, for why firms might privately choose unbundling even where the social benefits of facilities-based entry are higher. But there are other reasons as well. First, ongoing price regulation entails ongoing administrative costs. Once CLECs are no longer impaired in their ability to build or obtain network elements in the marketplace, there is no reason to incur the administrative cost of overseeing regulated access to that element.
28. Second, the mere opportunity to obtain unbundled access at cost-based rates may induce new entrants to resort to UNE price negotiations or arbitration in the hope of obtaining comparatively advantageous entry terms, even where they face no impairment in entering on a non-UNE basis. Again, there is no need to speculate about such strategies: several states have held proceedings to adjust UNE rates over the same time period that the Fact Report shows facilities-based entry to be proving viable in markets covered by the UNE rates at issue.
C. Neither Alleged Transaction Costs of Combining UNEs Nor Demand for a UNE “Platform” Should Affect the Commission’s Element-by-Element Impairment Analysis
29. Once the Commission determines that competitors are not impaired by lack of regulated access to an ILEC network element, the inquiry should end. The FCC’s determination should not be undermined by claims that the element should nonetheless be unbundled because it is part of a desired UNE platform or because of
14 alleged transactions costs in combining a mix of the CLEC’s own facilities, UNEs, and/or third party facilities.
30. The threshold, necessary condition for unbundling in the 1996 Act is impairment, which must be demonstrated on an element-by-element basis.5 If evidence demonstrates that CLECs have viable alternatives to an ILEC’s network elements, then there is no economic impairment as to those elements. It might be that in some cases there are costs to combining elements that a CLEC obtains on its own with those that it obtains on an unbundled basis. But those “combination costs” should not be a mechanism by which network facilities, which on their own cause no competitive impairment, are bootstrapped back onto the list of required unbundled elements. In such cases competitors should bear the burden of showing that the transaction costs of combining elements are so high that they make alternatives economically infeasible for each UNE and thus create impairment compared to the ILECs, which themselves must incur the costs of combining their own network elements. In other words, the CLECs must show that despite availability of non-ILEC facilities for lease or purchase, they will be truly, comparatively impaired by resorting to those alternatives.
31. The mere existence of some combination costs, or the mere fact that entrants would find unbundling to be cheaper than building their own facilities or other alternatives, does not carry this burden because carriers could still compete without reliance on the UNE. Indeed, the CLECs must be able to show that the up-front or continuing transaction costs of non-UNE alternatives are so high as to render them uneconomic for competitive entry. Given the facts of actual competitive entry for the services CLECs seek to offer, without reliance on UNEs, this is an argument that may exist in theory, but fails in fact.
5 In section 251(d)(2), the Act sets up impairment as a “minimum” limiting factor on unbundling. Impairment is a necessary but not always sufficient condition for unbundling under the Act. The Commission may therefore limit the list of unbundled elements even if carriers can demonstrate impairment.
15 32. Similarly, arguments that a UNE “platform” is necessary for entry should not be able to drive individualized, element-by-element analysis of competitive impairment. There is no “platform” UNE, only a platform of those individual elements the Commission has ordered to be unbundled. The “platform” proceeds from the list of individual UNEs. To allow the determination to work in reverse would pervert the statute and undermine more complete development of local exchange competition.
33. There are a number of ways that the platform might be claimed to require continued unbundling of a UNE that can be competitively provided or obtained. For example, some competitors might argue that removal of a UNE from the platform would disrupt their current infrastructure configuration and impose transaction costs, so that the element should be kept on the UNE list. Yet this turns impairment analysis on its head and creates a one-way ratchet in the direction of sustained unbundling. Second, such CLECs might propose that even if an element need not be unbundled in itself, it should be retained as a required element for CLECs buying the whole platform. This creates a new UNE, the platform itself, and creates a bias towards increased UNE consumption by effectively granting a longer list of available UNEs to CLECs that adopt an entirely UNE-based strategy than those who actually build their own facilities or obtain them from competitive sources to the ILEC. The result is a disincentive for non-UNE-based competition that directly contradicts the intention that UNEs serve as a transitional mechanism towards facilities-based entry.
34. Finally, it might be argued that even if an element no longer causes impairment and hence need not be unbundled, it should nonetheless be made available on some basis as part of the platform. This option drags regulators into a complex pricing exercise and amounts to maintaining a “platform UNE,” albeit at perhaps a higher price than would otherwise prevail. Such a hybrid of UNEs and services is not an option under the statute and would be an administrative quagmire.
D. Unbundling Imposes Substantial Costs on Regulated Carriers
16 35. In addition to the substantial social costs that result when competitors substitute UNEs for facilities-based entry, other economic harm flows from the costs that unbundling imposes on the ILECs directly. To provision a UNE, an ILEC must not only incur a new set of administrative costs unrelated to serving its end-users, but it must also make investment and design decisions with estimates of CLEC demand factored in. But because CLECs need not continue to purchase a UNE over time, an ILEC may be stuck with investment, made to accommodate projected CLEC demands, which the ILEC cannot recover. ILECs must therefore factor in much higher risk in all of their forward-looking network investments. This in turn raises the cost of such investment and impedes network development over time.
36. The costs to ILECs and ultimately to consumers are likely to be especially high where new technology is at issue. Deployment of new infrastructure proceeds well in advance of demand. Substantial risk and uncertainty accompany any such investment. If ILECs must also contemplate having to unbundle such infrastructure to competitors at cost, the return on such investment becomes less certain and hence less attractive. This is particularly so where the amount of ILEC investment necessary to implement new technology is increased by the possibility of mandated access for CLECs to that technology. Consider the case of SBC’s provision of collocation for CLEC electronics on the line-side of new, digital loop carrier plant. To comply with this requirement, SBC has reported that it has spent $20 million thus far and will be forced to spend an additional $30 million if it continues to deploy remote terminals in accordance with its original Project Pronto plans. SBC also states that it was required to reconfigure its network design so that the transmission component of its broadband service could be made available to competitors. This requirement forced SBC to deploy in its central offices optical concentration devices that would not otherwise have been necessary and that have added nearly $200 million to Project Pronto network costs. In addition, SBC reports that state requirements that it provide splitters for line sharing have added another $107 million in costs. SBC says that it has been able to recover virtually none of these additional costs because, as it turned out, not a single CLEC has collocated in an SBC remote terminal or elected to use its
17 broadband service (other than its own affiliate), and only 14% of the line splitters it deployed are being used.6 SBC’s reported experience illustrates why the costs of accommodating competitive access need not always be productive and can in fact cause substantial waste of resources. Regulatory mandates that such expenditures be made to enable unbundled access, well in advance of any demonstrable need and demand for the end-user service at issue, will raise costs without likelihood of compensating benefits.
II. A Cautious And Rigorous Approach to Unbundling is Consistent with Established Principles of Competition Policy
37. Evidence of competition in the provision of a network element should weigh heavily against continued unbundling of that element. Such a policy presumption is consistent with general principles of competition policy and with important precedents from antitrust.
38. As a threshold matter, one might object that the Telecommunications Act of 1996 is not meant to replicate the antitrust laws and is expressly intended to impose a different and more generous standard for unbundling than that which might be implied under the Sherman Act. That may well be true and I take no position here on the comparison between the 1996 Act’s “impair” standard and the “essential facilities” doctrine of antitrust law. Rather, the important point is that antitrust law contains valuable lessons for network unbundling that do not hinge on possible differences in statutory standards. First, antitrust law requires or permits use of common facilities only when competition overall will not be harmed by such outcomes. To be sure, applicable antitrust precedents require that much more be shown before a firm can get access to a competitor’s facilities. But even if the FCC’s
6 Comments of SBC Communications, Inc., In the Matter of Deployment of Broadband Networks and Advanced Telecommunications Services, Docket No. 011109273-1273-01, at 26 (December 19, 2001); Ex Parte Letter from James Smith, SBC, to William Caton, Acting Secretary, FCC, CC Dkt 96-98, March 25, 2002.
18 unbundling standard is more lenient than that of antitrust law, the precedent of ensuring that, at a minimum, overall competition is not harmed through unbundled access, is worth importing into this proceeding. To allow for unbundling where facilities-based entry is possible and economically more beneficial would be contrary to this principle.
39. Second, antitrust law draws an important distinction between competition and competitors. The disadvantage suffered by an individual competitor is not cognizable harm under the antitrust law unless that disadvantage flows from conduct that more generally harms competition itself. A similar principle is beneficial in the UNE context. It may be the case that one or another putative entrants into the local exchange business would better be able to enter, or would only be able to enter if a particular network element were available on an unbundled basis. Such entrants might on that basis plead impairment in the absence of unbundling. But if the economic evidence and market data show that some entrants are entering with their own facilities, then that evidence also suggests that, even if the absence of unbundling would disadvantage some individual competitors, it would not impair competitive entry itself. If policy is driven by the firms pleading impairment rather than by those entering with their own facilities, then the end result maybe to replace meaningful competition with an expanded group of less meaningful competitors.
40. Third, the process of rigorously defining a market for purposes of antitrust analysis applies to the question of unbundling. It is important, in deciding whether a network element needs to be unbundled, to examine both the competitive alternatives to the ILEC’s facilities as well as the ease of entry into provision of the element at issue. This analysis may require defining markets both in terms of product and of geography. If there are competitive providers of an element, or if the evidence shows that firms, either nationwide or in particular geographic markets, are successfully providing the elements for themselves and thus entering the market for the UNE at issue, then the case that competition is impaired without access to the incumbent’s
19 facilities fails. Careful definition and analysis of the markets for individual UNEs will thus be essential to unbundling policy that best promotes true competition and the ensuing consumer benefits.
41. One essential component of defining UNE markets will, as implied above, be geographic. It might be that there is no competitive entry or competitive UNE provisions in some geographic regions, but significant entry in others. Competitors should not be able to point to regions where there is no competitive UNE provision in order to maintain unbundling in regions where such entry is proving feasible. If UNEs were maintained on that basis, unbundling obligations would last so long as CLECs decided that there were some markets they did not want to enter or where they entered solely on a UNE basis. Even if lack of entry in some regions is the result of impairment (instead of because the market has unattractive profit potential), that localized impairment should not suffice to maintain unbundling obligations in markets where such impairment does not exist.
42. A critical, related point is that the Commission’s competitive analysis should not presume that lack of competition stems from entry barriers or other impairment. Entry into some markets without recourse to UNEs may be perfectly possible, but simply unattractive. Regulated end-user rates, cross-subsidies, and the slow process of state- by-state rate rebalancing all affect entry decisions. It is indeed one advantage for CLECs that they can choose their markets while ILECs cannot. Lack of entry due to regulatory factors or opportunity costs should not be converted into evidence of impairment. In such cases the ILECs bear costs that the CLECs choose not to, and to require unbundling in such circumstances simply exacerbates the regulatory distortions.
43. Finally, inter-modal rivalry is of central importance to the analysis of competitive impairment. If firms can provide substitutes for ILEC local exchange services over networks that bypass the telephone networks by using alternative kinds of facilities, then it is hard to make a case that entry in any way depends on unbundled access to
20 the ILECs’ networks. Even were it the case that entrants into the local market could not, for example, obtain conventional wireline loops without unbundling, there would be no impairment to competition if cable or wireless loops provided an alternative way to connect to customers. The Commission has itself emphasized the importance of inter-modal competition on the ILECs in the broadband context in finding that “the ILECs’ aggressive deployment of DSL can be attributed in large part to the deployment of cable modem service.”7 Cable and wireless telephony must therefore be considered in the analysis, and the inter-modal competition they provide to ILECs counted against the case for impairment. This analysis should be dynamic and also take account of technologies, like satellite-based broadband access, that are currently entering the marketplace and that are likely to add yet further competition in the foreseeable future.
III. Empirical Evidence of Entry and Competition in UNE Markets
44. This section addresses the evidence of facilities-based competition in the provision of several network elements. I will focus my discussion on switching and inter-office transport, but I will also discuss competition in providing both standard and broadband loops. In this section, I rely on data contained in the UNE Fact Report 2002 filed in this proceeding by BellSouth, SBC, Qwest and Verizon (“Fact Report”). The evidence presented in that report convincingly demonstrates that in the case of both switching and transport, there is substantial competition to the ILECs’ facilities and that such competition will only grow with technological changes already underway in the local exchange market. The data also show that the case for impairment without unbundled access to conventional voice loops is diminishing, and that it has vanished altogether with respect to high-capacity loops. My purpose in this section is not to reproduce the Fact Report, to which I refer the reader for a full discussion of current market data. It is instead to highlight certain key developments
7 Broadband today: A Staff Report to William E. Kennard, Chairman, FCC, at 27 (October 1999), available at http://www.fcc.gov/bureaus/cable/reports/broadbandtoday.pdf.
21 that demonstrate that the case for economic impairment in local exchange entry is diminishing rapidly overall and, in several key cases, has been eliminated altogether.
A. Switching Has Become Competitive and Will Become Even More So In The Near Future
45. Determining whether CLECs have substitutes for unbundled ILEC switches, such that they are not impaired without access to those ILEC switches, requires one to look beyond conventional circuit-switching technologies for voice calls. Whether or not CLECs have access to alternative circuit switches (which they in fact do), they have alternative technologies for switching local traffic. Defining the product to be examined in assessing impairment as “circuit switching for wire-line voice telephony” fails to capture the fact that much circuit-switched traffic consists of data, not voice, and that much switching of data and voice is packet switched, not circuit switched. In defining the market in which CLECs obtain the switching component of local exchange service, an important question is whether the decision to continue to require unbundled switching should take into account only wire-line, circuit-switched voice service or whether the market should be defined more broadly to include data services, packet switching, and wireless switching. As will be discussed below, the strength of the evidence on competitive, facilities-based switching is such that, even if the most limited definition of switching is adopted, there is still a compelling case for eliminating mandatory, unbundled access to ILEC switches. That case becomes all the stronger as one uses broader, more realistic product market definitions to assess performance of the switching market.
1. Circuit Switching has Become Competitive
46. An examination of the data on circuit switching of wire-line traffic demonstrates that competitors have no need for access to the ILECs’ “voice” switches. CLECs operate at least 1300 local voice switches today, over which they serve 16 million to 23 million lines. (Fact Report at II-1). Those switches are being deployed nationwide by
22 more than 200 CLECs. Importantly, most of the top CLECs use negligible amounts of unbundled switching and instead do almost all their circuit switching with their own equipment. (Fact Report at II-1) This last fact demonstrates that switch investment is something that new entrants both can, and overwhelmingly do, undertake on their own and without resort to ILEC networks.
47. The evidence is quite clear that facilities-based, competitive switching is not confined to CLECs that serve particular kinds of customers or particular geographic markets. While the majority of CLEC lines are business lines, CLECs are serving approximately 3 million residential subscribers over their own switches. (Fact Report at II-4, Table 2). Moreover, those switches are broadly deployed throughout the country. Almost half of all ILEC wire centers, for example, are served by at least one CLEC switch. (Fact Report at II-6). Significantly, those wire centers in which CLECs are using their own switches serve about 86 percent of ILEC customers. (Fact Report at II-1). A detailed discussion of CLEC switching is presented in part II of the Fact Report.
48. The empirical evidence thus weighs strongly in favor of removing switching from the list of network elements to be unbundled pursuant to the 1996 Act. Advocates of unbundled switching might nonetheless raise several objections to the economic significance of the data discussed above. Yet there is a compelling response to each such objection.
49. First, some might contend that evidence of CLEC-owned switches does not necessarily correspond to success by CLECs in entering the local exchange market. The data contradict any such assertion, however. As the Fact Report explains, at the end of 2001 CLECs were serving about 3 million residential lines and a much larger number of business lines with their own switches. (Fact Report at II-4). The fact that there is a large number of competitive switches and that CLECs can use them to serve residential customers, defeats any claim of impairment. The evidence makes clear
23 that switching is easily obtained and that competitors are not impaired if they must proceed without access to the ILECs’ switches.
50. Moreover, it should be noted that, once CLEC switches are in place, any excess capacity they have will make the market for switching services more competitive, not less so. If a CLEC purchases a switch and then fails to capture enough retail customers to use up capacity of the switch, then the CLEC can sell its excess capacity, or even its entire switch, to other entrants. Excess CLEC switch capacity would thus create an additional source of switching services for those entrants that for whatever reason might not want to purchase their own switches. Finally, the premise that local exchange competition has not followed from the introduction of competitive switches is false. As the data show, nearly 14 million local telephone numbers have been “ported” from ILEC switches to CLEC switches since 1999. Each ported number signifies a customer that the CLEC has won from the ILEC and now serves on its own switch. (Fact Report at II-5). And this ignores the new customers that the CLEC has won and now serves through an NXX code instead of a ported local number.
51. Second, some might argue that switching itself is too narrow product market definition for purposes of deciding unbundling. Switching alone, after all, is of little value if loops cannot successfully be connected to the CLEC’s switch. If collocation in ILEC wire centers is not possible, or if “hot cuts” of loops from an ILEC’s switch to a CLEC’s switch involve prohibitive costs or delays, then new entrants might have trouble switching traffic regardless of what facilities they own. The relevant market might thus be argued to consist of switching with necessary customer-transfer services. There are two pieces of market evidence that suggest little need for concern that switching may be thwarted by poor collocation or hot-cut performance. The most important fact is that hot-cut performance and collocation availability have both improved dramatically since the Commission’s 1999 UNE review. (Fact Report at App. H) The second fact, which probably results in part from the first, is that CLECs are in fact purchasing their own switches and thus acting in a manner that is
24 inconsistent with substantial concerns about hot-cuts or collocation services. Moreover, the hot cut issue is completely irrelevant for those competitors who do not need ILEC loops.
52. The important point is that real empirical data, not conjectural or theoretical concerns, should be the guide to Commission action when it comes to unbundling. Nothing more clearly demonstrates the feasibility of UNE alternatives than the fact that they actually exist and are being used successfully. Pointing to problems that allegedly existed in the past—and the large number of CLEC switches that existed at the time of the last UNE review suggests that there was no impairment due to switching even in the past—or that could speculatively exist in the future cannot defeat the reality of the marketplace and should not be permitted to take precedence over actual developments. To favor those firms that seek strategic advantage through unbundling when other competitors are investing in facilities risks undermining true competitive investment and the greater social benefits that it creates.
53. Third, advocates of unbundling might suggest that the data do not make a case for complete removal of switching from the UNE list because some wire centers are not competitively served, making unbundling necessary in those remote areas. This argument, too, fails for several reasons. Most notably, there is no evidence that competitive switching is difficult to obtain or provide in any region in which a CLEC actually chooses to pursue customers. Indeed, the broad dispersal of competitive switches makes clear that CLECs have been able to deploy their own equipment where they wish. Moreover, switching technology is now such that even very distant customers can be served from a single switch. The CLECs themselves have heralded the ability to engage in remote switching and to avoid placing a switch in a distant wire center or one in which they anticipate few customers, while still being able to serve those few, distant customers. (See Fact Report at II-9).
54. Finally, some might argue that the very data showing growth in CLEC-owned switches is evidence of the success of unbundled access to switching. The increase in
25 facilities-based switching might be argued to constitute the very transition that unbundling was intended to foster and to thus be evidence for continuing, rather than removing, requirements to unbundled switching. The evidence firmly contradicts any such claim that a lack of unbundled switching would undermine the transition to facilities-based competition. As the data in the part II of the Fact Report demonstrate, many of the largest CLECs use no unbundled switching at all. The transition to facilities-based switching is for many competitors thus “complete,” if it ever was necessary in the first place. The fact that some CLECs might prefer to continue obtaining switching on an unbundled basis is thus likely a result of their private business strategies and calculations rather than because foreclosure of that option would impair their further entry into local switching.
55. The data on local switching thus demonstrate convincingly that, even if the Commission were to adopt the most conservative and static product market definition—that of circuit-switched “voice” switching—there is a very strong case for removing local switching from the list of required UNEs. As the next section will show, that case become even stronger once one uses a more realistic and dynamic market definition for switching.
2. The Switching Analysis Should Include Packet Technology
56. The analysis above was restricted to circuit switching. But packet switching should be included in the relevant product market for purposes of analyzing the need for unbundled switching. Packet switching directly competes for current data traffic. Packet switching by cable modem and wireless services alone now substitute for about four percent of circuit switched calls, assuming that all broadband traffic would otherwise go over dial-up lines. (Fact Report at II-3). The substitution by which data calls that would otherwise go over the switched voice network are being routed through packet switches is growing rapidly. In the past three years, the number of known CLEC packet switches has increased tenfold, from 860 to more than 1700. (Fact Report at II-2). The FCC has already declared packet switching sufficiently
26 competitive that it should not be subject to mandatory unbundling.8 As those switches have come increasingly to compete directly with circuit switching, the latter, too, face genuine competition. Given that CLECs are not impaired without access to unbundled packet switching, the case for impairment without access to circuit switching vanishes as packet switches increasingly become a substitute for circuit switches.
57. While existing competition between circuit switches and packet switches is reason enough to include both in the same product market, the case becomes even more powerful when one looks only a short time forward. Packet-switched data lines are growing very fast. Much of this growth is over cable networks and needs no access to any part of the ILECs’ systems. More and more of total telecommunications traffic is thus being packet switched.
58. This substitution of packet for circuit switching is not limited to data traffic. Many data communications substitute directly for voice, as in the case of e-mail and instant messaging. But as the Fact Report details at part II.B, packet switching is also becoming increasingly suited to voice traffic itself. For example, many businesses are converting their internal telephone systems to voice-over-IP technology that sends voice traffic over a company’s intranet. As packet technology for voice develops, the substitution will grow dramatically. Data traffic, which dwarfs voice traffic, will drive the continuing shift to packet technology and will motivate migration of voice traffic to the same, increasingly dominant, packet switched networks. All of these changes, which are already in progress and which will transform the balance of switching technology in the foreseeable future, counsel considering packet and circuit switching as technologies that compete in the same market.
3. Switching Appears Yet More Competitive in Light of Wireless Competition
8 UNE Remand Order, ¶¶ 306, 308. Despite that correct conclusion, the FCC nonetheless retained a requirement that carriers must unbundle packet switching if the ILEC has deployed DLC, there are no spare copper facilities available, the ILEC has deployed its own packet switching, and the incumbent has not permitted a requesting carrier to collocate. Id. at ¶ 313.
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59. Finally, it must be recognized for the purposes of any thorough competitive analysis that wireless services significantly reduce the need for a customer’s traffic to pass through any wireline switch, whether circuit or packet. Many residential customers who would otherwise purchase a second wired telephone line instead use wireless service, and a growing number are dispensing with wireline service altogether, relying entirely on wireless service instead. The number of wireless subscribers is fast approaching the number of wireline subscribers. There are now an estimated 130 million wireless subscribers versus about 190 million wireline subscribers. (Fact Report at II-3). Importantly, the former group is still growing fast while the latter is not. All wireless traffic is switched, and even if one eliminates from the count of wireless switches all those belonging to ILEC affiliates, there are now an estimated 950 independent wireless end-office switches deployed nationwide. Wireless already constitutes an estimated 12 percent of all phone calls in the U.S. (Fact Report at II-3), a percentage that is likely to grow as wireless data services grow and improve and as wireless subscriptions grow.
B. Inter-office Transport Has Also Become Competitive and Subject to Facilities- Based Entry
60. There are two principal reasons that inter-office transport no longer needs to be unbundled. First, there are now competitive sources of fiber transport. Second, the economics of inter-office transport are such that competitive local exchange carriers can economically build their own transport and would not be competitively impaired if they could not use the ILECs’ transport facilities. The empirical data demonstrate that CLECs have increasing options for purchasing transport from third parties and that they are also building their own transport facilities.
1. Competitive Transport Providers 61. In metropolitan areas, there is a group of firms who have entered the telecommunications market solely at the level of transport. These firms, sometimes
28 called competitive fiber providers, have constructed fiber rings that transport their end-user’s traffic both to long-distance carriers’ POPs and to ILEC central offices. Although the data is not yet clear on what percentage of customers can be served through such alternative transport networks, the fact that they are being built and expanded demonstrates that the transport market is subject to entry and that the ILECs’ transport facilities do not constitute an economic bottleneck to local exchange competition. In addition to the competitive fiber providers, a number of utility companies and interexchange carriers have substantial fiber networks that they use to supply transport to CLECs. (Fact Report part III, tables 6-7). This group of third-party fiber providers offers CLECs an important source of interoffice transport that neither obligates them to build their own facilities nor makes them dependent on the ILECs.
2. CLECs’ Transport Facilities
62. A conservative measure of whether CLECs are installing their own transport facilities can be had from the amount of fiber-based collocation in ILEC central offices. At present, ILEC data show collocated fiber in central offices serving 44 percent of all ILEC access lines. (Fact Report at III-3, table 1.) This evidence is compelling. If there is competitive transport to central offices through which an entrant can reach nearly half of the incumbents’ customers, then it is unlikely that there is any impairment to entry into those markets without access to the ILECs’ transport lines.
63. In addition to what the data show about where CLECs have already obtained fiber- based collocation, the evidence strongly suggests that entrants have the ability economically to construct transport facilities in many additional wire centers. The fact that CLECs have built competitive transport to many ILEC central offices with high concentrations of business lines suggests that they economically could do so to the rest of those offices where fiber-based collocation does not yet exist. (Fact Report at III-4, table 3). The data strongly indicate that CLECs are not impaired in their ability to obtain interoffice transport in the absence of unbundling for most of the lines they have demonstrated any intent to serve.
29
64. The conclusion that CLECs no longer face any impairment in obtaining interoffice transport becomes all the stronger when one considers that the fiber-based collocation measure of transport competition does not even account for the traffic that bypasses the ILECs’ networks altogether. There are now an increasing number of firms providing alternative points of traffic concentration in most major markets and a growing proportion of competitive transport runs between such competing interconnection points rather than through ILEC wire centers. The growth of such facilities is documented in detail in part III of the Fact Report.
65. In the end, transport has become a market populated by various, overlapping options for carriers. In addition to the incumbents’ network, there now exists a combination of CLEC fiber collocated at ILEC wire centers, CLEC fiber collocated at alternative points of traffic aggregation, and third party fiber facilities. Taken together, these alternatives demonstrate that competitive transport is no longer dependent on CLECs’ access to the ILECs’ facilities.
C. Loop Competition Reinforces Competitiveness of Other UNE Markets
66. In the three years since the Commission’s last UNE review there has been a significant increase in competitive provision of loops. The degree of such competition varies by geographical area and by type of loop and customer. Changes in the loop market have two important consequences for unbundling policy. The first is a direct effect on loop unbundling: for certain kinds of loop facilities, specifically high- capacity loops, the market data show that unbundling is no longer necessary. The second effect is less direct: loop competition, even where it is not sufficient to warrant a repeal of unbundling, adds to the proportion of traffic that is moved off of the ILECs’ other network facilities such as switches and transport links. In other words, loop competition not only weighs against unbundling of loops themselves, but strengthens the already compelling case for eliminating unbundling of switching and transport.
30
1. The Market for High-Capacity Loops is Competitive
67. The most significant facilities-based entry into customer access lines has been in the market for high-capacity loops. Numerous CLECs have constructed their own DS-1 and higher lines to serve buildings where businesses are concentrated. CLECs serve between 11 and 19 million business lines over their own last-mile facilities, many of which are high-capacity loops. (Fact Report at IV-2). The above figures understate the true state of competition in high-capacity loops. They do not count the facilities of all CLECs and do not include loops owned by third party fiber providers and leased by CLECs.
68. As in the case of competing inter-office transport, the high-capacity loops that already exist form the base off of which those facilities may be expanded incrementally and economically to areas where businesses are less concentrated and to the premises of smaller customers. Existing facilities also demonstrate the feasibility of competing loops where similar high-capacity customers exist but are not yet competitively served. In addition, special access provisions offer an alternative to unbundling for obtaining high capacity loops for those firms that do not wish to build out their own facilities.
69. Whereas CLECs have proven willing and able to construct their own high-capacity loops, they have made little use of unbundled high-capacity lines. As the Fact Report shows at IV-7, table 2), CLECs have made almost no use of unbundled loops with capacity higher than DS-1 and serve most of their DS-1 customers with their own facilities rather than over unbundled loops.
70. While the Commission also needs to carefully evaluate the need to unbundle other types of loops in circumstances where there are obvious competitive alternatives (such as in areas whose cable companies are providing telephone service over their own networks), the above facts make an especially strong case for eliminating the
31 unbundling of high capacity loops. There is clearly no difficulty in providing service over such lines even without any resort to the ILECs’ facilities. It would turn the idea of “impairment” on its head to maintain unbundling for high capacity loops; for to do so would be to maintain a back-stop alternative for CLECs that they do not need economically to provide the facilities at issue without competitive disadvantage. As part I of this paper discusses, maintaining such an option where it is not needed may have significant costs for consumers and for competition.
D. Inferences to Be Drawn From the Empirical Evidence
71. The empirical evidence presented in the Fact Report provides a clear picture of the emergence of competitive facilities in all the most important UNE markets. The evidence against impairment is extremely strong for switching, for high-capacity loops, and for interoffice transport. Yet in each of the UNE markets just mentioned, there may be some classes of end-user customers and some geographic areas that are not served over competitive facilities. In other words, some strict standard of “ubiquity” might not be met for even those network facilities that are easily supplied on a competitive basis. If unbundling policy is to be economically sound and to benefit consumers and competition, it is important that such perceived gaps in UNE competition not overshadow the competitive significance of entry where it has occurred and thereby improperly drive unbundling policy. There are two broad reasons that greater weight should be given to the evidence of where UNE competition has developed than to the evidence of where it has not.
72. First, the fact that CLECs are in some cases supplying their own facilities or procuring them from third parties demonstrates that competitive provision of the element at issue is economically feasible. That in itself weakens any argument for impairment. When a substantial number of CLECs are deploying facilities other than UNEs, and when those facilities serve or potentially serve a large proportion of access lines, then the impairment argument is not merely weakened but unsupportable. In such circumstances, the widespread use and availability of competing facilities should
32 raise a presumption that ubiquitous deployment is feasible. Under such circumstances, CLECs’ decisions not to deploy their own facilities are likely driven either by decisions not to serve certain end-user customers or by preferences for unbundled access even though lack of such access would not be a true competitive impairment. It bears emphasis that the point of unbundling is not to free CLECs from incurring the same costs as the ILECS or undertaking the same activities the ILECs must engage in to provide service. The issue is whether the CLECs are competitively impaired compared to the ILECs without unbundling, not whether unbundling is advantageous compared to other entry paths.
73. Second, an absence of competitive facilities or continued use of UNEs may be the product of many factors that have nothing to do with the ability of CLECs economically to supply their own facilities. Regulation of end-user rates will make some customers more desirable than others and affect the entry strategies of competitive carriers. As already discussed, the rates for unbundled network elements will affect the comparative advantage of entering over one’s own facilities or over the ILECs’ networks. Predictions about changes in technology or in the services that customers demand will also influence a CLECs’ investment decisions. This list is not intended to be exhaustive, but merely to point out that there are numerous forces other than impairment that can explain gaps in the provision of competitive local exchange facilities.
74. For the above reasons, the Commission should be very cautious about accepting arguments based on lack of “ubiquity” in support of continued unbundling. The existence of competing facilities unambiguously demonstrates the feasibility of facilities-based entry. The absence of such facilities in some markets or for some customers, when competing facilities are elsewhere widely available, only questionably and ambiguously suggests impairment. Where the evidence shows facilities-based entry, the logical inference is that entry is feasible in markets with similar characteristics but where CLECs may not yet have chosen to enter. The
33 burden should rest with the CLECs to demonstrate that lack of entry is indeed due to specific market characteristics that create impairment.
75. As the previous section of this declaration discussed in detail, there are potentially high social costs of unwarranted unbundling. The economic inferences that drive unbundling policy should be therefore grounded in the empirical evidence of the development of significant, even if not highly ubiquitous, competition in a network element market. As the earlier discussion explained, such evidence should presumptively counsel the repeal of mandatory unbundling of that element. The evidence surveyed in this section and set forth in detail in the Fact Report convincingly support a strong presumption against further unbundling of switching, interoffice transport, or high-capacity loops.
IV. Conclusion
76. The empirical evidence of local exchange competition and of the UNE alternatives available to CLECs soundly rebuts claims of impairment with regard to switching, inter-office transport, and high-capacity loops. Given the substantial risks that unbundling creates for telecommunications consumers and for the competitive process, the Commission should adopt a strong presumption against unbundling of these elements. It should not be enough to prove impairment for a CLEC to show that UNE alternatives are not in fact being used in a particular market. Where the empirical evidence shows that non-UNE entry could occur unimpaired in a particular market, perhaps because it has so occurred in markets with similar characteristics, the inference should be drawn against the need for unbundling. Without such reasonable inferences, unbundling will occur where impairment does not truly exist. Such an outcome will reduce the scope of competitive benefits produced by the local exchange markets, punish CLECs or third-party providers who have invested in their own facilities, and compromise the ultimate economic objectives of the 1996 Act.
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Attachment D
Declaration of
Alfred E. Kahn and Timothy J. Tardiff
December 18, 2001
I. INTRODUCTION
1. My name is Alfred E. Kahn. My business address is 308 N. Cayuga Street, Ithaca, NY
14850. I am the Robert Julius Thorne Professor of Political Economy, Emeritus, Cornell
University and Special Consultant with National Economic Research Associates, Inc.
(NERA). I received my A.B. degree summa cum laude from New York University and my
Ph.D. from Yale University, in 1942. I served as Associate Economist with the Antitrust
Division of the U.S. Department of Justice in 1941-42; came to Cornell University as
Assistant Professor in 1947 and have served successively as Chairman of the Department of
Economics, Robert Julius Thorne Professor of Political Economy, member of the Cornell
Board of Trustees and Dean of the College of Arts and Sciences. I have been Chairman of
the New York State Public Service Commission and of the (U.S.) Civil Aeronautics Board;
and in my capacity as Advisor to President Carter on Inflation, I participated actively in the
successful efforts of his Administration to deregulate both the trucking industry and the
railroads. I am the author of the two-volume The Economics of Regulation, reprinted in
1988 by MIT Press, Letting Go: Deregulating the Process of Deregulation, published in
1998 by Michigan State University Institute of Public Utilities, Whom the Gods Would
Destroy or How Not to Deregulate, published this year by the AEI-Brookings Joint Center
for Regulatory Studies, and have written and testified extensively in the area of direct
economic regulation and particularly of the public utilities. Of especial relevance to my
statement here, I am the co-author of Fair Competition, The Law and Economics of
Antitrust Policy, was a member of the Attorney General’s National Committee to Study the
Antitrust Laws and the National Commission on Antitrust Laws and Procedures in the
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Eisenhower and Carter Administrations, respectively; I have served as consultant with both
the Antitrust Division of the Department of Justice and the Federal Trade Commission; I
was recently a member of the National Research Council – Transportation Research Board
committee charged with reporting to Congress on the state of competition in the airline
industry; and I have published numerous articles, particularly in recent years, on the
requisites of efficient competition in regulated and previously regulated industries. I attach
a copy of my full resume as Attachment A.
2. My name is Timothy J. Tardiff. My business address is One Main Street, Cambridge, MA
02142. I am a Vice President at National Economic Research Associates, Inc. (NERA). I
have specialized in telecommunications policy issues for about the last 20 years. My
research has included studies of the demand for telephone services, such as local measured
service and toll; analysis of the market potential for new telecommunications products and
services; assessment of the growing competition for telecommunications services; and
evaluation of regulatory frameworks consistent with the growing competitive trends. Most
recently, I have participated in interconnection arbitrations, unbundled element
proceedings, universal service investigations, and applications by incumbent local exchange
carriers for authorization to provide interLATA long-distance pursuant to the
Telecommunications Act of 1996, in over 20 states. I attach a copy of my full resume as
Attachment B.
3. Advanced telecommunications services are being offered, and will increasingly be offered,
by firms that formerly operated in distinct markets and industries (e.g., traditional telephone
and cable television service) as well as new firms seeking to share in this apparently huge
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potential market. These new offerings include broadband services—such as high-speed
access to the Internet, currently provided mainly by cable modems and digital subscriber
lines (DSL)—which have the potential to provide new ways for consumers to acquire
information, audio and video entertainment and engage in business transactions. They also
give businesses new ways of reducing their costs and of reaching consumers with products
and services, new and old. These benefits to consumers and businesses are likely to be very
large: some research suggests hundreds of billions of dollars annually.1
4. These broadband services are truly new, especially for residential and small business
customers. By the end of 1998, the FCC counted fewer than 400,000 subscribers—a
penetration rate of well under one percent—some 350,000 using cable modems and only
25,000 DSL. 2 Thereafter, in each of the next two years, residential and small business
subscribership increased about four-fold, reaching a total of about 6 million by the end of
2000.3 4 Some analysts have projected subscribership of 30-40 million by 2005, with cable
1 See, for example, Robert E. Litan and Alice M. Rivlin, “Projecting the Economic Impact of the Internet,” American Economic Review, Vol. 91, No.2, 2001, pp. 313-317 and Robert W. Crandall and Charles L. Jackson, “The $500 Billion Opportunity: The Potential Economic Benefit of Widespread Diffusion of Broadband Internet Access,” July 2001. 2 Federal Communications Commission, Deployment of Advanced Telecommunications Capability: Second Report, CC Docket No. 98-146, August 2000. 3 The respective shares of cable modems and DSL were 71 and 29 percent at the end of 1999 (Federal Communications Commission, Office of Plans and Policy, Telecommunications @ the Millennium: The Telecom Act Turns Four, February 8, 2000) and some two-thirds and one-third, respectively, at the end of 2000, with competitive local exchange carriers constituting some 20 percent of the latter group at the end of both 1999 and 2000. The Association of Local Telecommunications Services (ALTS), The State of Competition in the U.S. Local Telecommunications Marketplace, February 2000 and The State of Local Competition 2001, February 2001. 4 Although both cable modems and DSL increased sharply during 2000, the former still enjoyed a 2:1 lead by the end of the year. Industry Analysis Division, Common Carrier Bureau, Federal Communications Commission, “High-Speed Access for Internet Access: Subscribership as of December 31, 2000,” August 2001.
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modems maintaining a narrowing lead in market share.5 The FCC’s second Advanced
Services report also describes the inroads made by wireless and satellite services. The clear
prospect is a competitive free-for-all among different suppliers and technologies, with the
ultimately victorious ones far from clear and only consumers clear winners.
5. While broadband subscribership has continued to grow in 2001, the rate of that growth has
declined markedly in not only percentage but also absolute terms. Moreover, the drop-off
has been disproportionately large in the case of DSL as contrasted with cable modems.6
While the total number of residential broadband subscribers added per quarter declined 20
percent—from 1.5 million in the fourth quarter of 2000 to 1.2 million for the first half of
2001—the decline in the new subscriptions to DSL was 35 percent (from 0.7 million to
0.45 million) and to cable modems only 7 percent (from 0.8 million to 0.75 million). The
weakening of the U.S. economy doubtless explains part of the overall deceleration; the fact
that growth rates for the more heavily regulated DSL services have experienced a much
larger decline suggests, however, that current regulations may also be part of the
explanation.
6. Whether the full potential of broadband services is realized depends on whether firms that
must make huge investments to develop and upgrade the requisite networks have the
opportunity to earn returns commensurate with the risks they will face. The amount and
type of regulation will be an important determinant of those opportunities. As we explain
in more detail below, any regulation of new services is problematic, because it increases the
5 Verizon, Broadband Fact Report, December 19, 2001. 6 Ibid., pp. 16-17.
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cost and decreases the attractiveness of offering them. By the same token, relaxing
regulation where it is no longer needed can unlock this potential. For example, as we
describe in detail below, wireless was successful—providing benefits estimated at $25-$50
billion annually—even though it was regulated through the mid-1990s; since its
deregulation at that time, subscribership has increased four-fold, with a commensurate
increase in consumer benefits.
7. While both Congress and the FCC have generally recognized that the enormous potential
will be much more rapidly and fully realized through competition in the market rather than
a regulatory regime, there is a gaping exception to this recognition. While the FCC has
generally taken a hands-off position with respect to both the Internet and most means of
providing access to it, it has at the same time extended to the broadband services of
incumbent local exchange carriers (ILECs) its regulations designed to promote competition
for traditional local exchange services. The purpose is, of course, the same as the purpose
of the Telecommunications Act in requiring ILECs to make unbundled network elements
available, at favorable wholesale prices, in the belief that competitive local exchange
carriers (CLECs) would be “impaired” in their ability to compete in downstream markets
without such access.
8. Whatever merits regulations such as these have in facilitating efficient competition for
traditional telephone services, they are both unnecessary and counterproductive when
applied to broadband. As for the former, the essential premise underlying these
requirements—namely, the necessity of CLECs having access to the facilities of the
ILECs—is invalid in the broadband market. Not only are there alternative sources, as the
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FCC has itself conceded; the ILECs are not the dominant suppliers—they have been and
remain markedly behind cable modem services. And, on the other side, maintaining,
extending, or even keeping open the option of applying regulation asymmetrically only to
ILECs will not only dampen their incentives to roll out these services quickly and to
introduce new methods of broadband access; it also risks artificially preserving the
dominant position of the incumbent cable modem providers.
9. In particular, because it is very difficult, perhaps impossible, to forecast how competition
for broadband services will evolve (what technologies will emerge, how successful each
will be, what proportion of consumers will choose to subscribe, and how frequently and for
what purposes they will use the services), basing regulatory policies on assessments of
whether the present deployment is “fast enough,” would be a fruitless exercise. No one can
possibly know the ultimate size of the market and how it will be supplied. The task of
policy is to remove all remedial hindrances to the competitive market’s giving us the
definitive answers.
7 II. ECONOMICS OF NEW SERVICES
10. New services, particularly those requiring large investments and/or new technology, offer
the prospects of large benefits, but at significant costs and with unusual degrees of risk.
The benefits are large precisely because of their novelty. For example, Crandall and
Jackson have estimated that wide scale penetration of broadband services (with broadband
7 Parts of this section are adapted from Alfred E. Kahn, Letting Go: Deregulating the Process of Deregulation, Michigan State University, Institute of Public Utilities, 1998 and Alfred E. Kahn, Timothy J. Tardiff, and Dennis L. Weisman, “The Telecommunications Act at Three Years: an Economic Evaluation of its Implementation by the Federal Communications Commission,” Information Economics and Policy, Vol. 11, 1999, pp. 319-365.
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becoming almost as ubiquitous as ordinary phone service) would provide economic benefits
of $400 billion annually in the form of new capabilities, such as shopping, commuter travel
and home entertainment.8
11. Whether the widescale penetration that delivers such benefits will become a reality depends
on potential suppliers—ILECs, cable operators, wireless broadband providers—making the
requisite large investments, with no guarantee that their particular technology will prevail in
competition with others or that consumers will sufficiently value the services it makes
possible. These will include the large investments not only in the electronic equipment
necessary to roll out more of their present DSL services over their existing copper loops but
possibly the even larger ones in both electronics, fiber optic and wireless facilities capable
of providing for greater capacity to carry information.
12. Were it not for the long legacy of telecommunications regulation—necessitated historically
by the monopoly of the ILECs in traditional telephone service generally and local access in
particular—the proper regulatory treatment of broadband services would be crystal clear:
there would be none. The newness of the service, its reliance on risky technologies, the
rapid expansion of the market and the leading position of unregulated suppliers all strongly
suggest that the FCC’s general disposition to keep its hands off the Internet has been
fundamentally correct. The investments that the Telecommunications Act seek to
encourage are not of a routine character such as may be required to provide plain old
telephone service, but extremely costly and risky, both commercially and technologically.
As for the former, it is useful to recall the exuberant expectations at AT&T about the
8 Op. cit.
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potential of Picturephone some 35 years ago. While until recently analysts had expected
broadband subscription to grow at rates resembling those of wireless a decade earlier, with
comparable enormous benefits to the public,9 the recent downturn in growth suggests that
establishing the correct broadband policy may be a prerequisite for realizing its full
potential. At the same time, there are very large risks about which technology will prevail:
it is important to remind ourselves that those benefits are much clearer in hindsight than at
the beginning of that decade, as is clearly suggested by the willingness of AT&T to
surrender this particular business to the RBOCs at the time of divestiture, its more recent,
hugely costly cable company acquisitions and its present attempts to sell them off. As for
the technological uncertainty, how many times over the last several years has the consensus
view changed about what method of transporting telecommunications signals will prove to
be the successful one?
13. Under a proper conception of effective competition, the general rule is that neither new
services nor the underlying facilities that produce them should be subject to regulation. The
conception of monopoly in the offer of truly new services is a virtual oxymoron. New
services offer customers additional alternatives not available to them previously. Their
introduction is fundamentally a competitive rather than a monopolistic phenomenon, even
though they may be distinctive and the innovator may be in a position to earn supernormal
profits from them. To deny an innovator the rewards of being first would inhibit
innovation, and it should not matter for these purposes whether the innovator is an
incumbent telephone company, an incumbent cable television provider, or a new entrant. A
9 Coincidentally, revenues for these two services per subscriber are roughly comparable, with wireless in the $55
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half-century ago, Schumpeter10 eloquently expounded—and generalized—the same
underlying principle: the “perennial gale of creative destruction” that constitutes the most
creative form of competition in a capitalist economy consists, at its essence, in the perpetual
process of creation and erosion of monopoly positions achieved by innovation, with the
prospect of the monopoly that rewards successful innovation providing the essential
incentive for innovators and imitators alike. Transient market dominance and monopoly
pricing are an essential part of the process:
The introduction of new methods of production and new commodities is hardly conceivable with perfect¾and perfectly prompt¾competition from the start. And this means that the bulk of what we call economic progress is incompatible with it. As a matter of fact, perfect competition is and always has been temporarily suspended whenever anything new is being introduced ¾automatically or by measures devised for the purpose¾even in otherwise perfectly competitive conditions (1950, p.105).
14. The more innovative the investments contemplated, the greater the uncertainties, both
technological and commercial, the greater the risks, the more important is the prospect of
the investor’s exclusive enjoyment of the fruits of the ventures that turn out successfully.
This proposition and the way in which the FCC’s sharing rules conflict with it are most
incisively spelled out by Justice Breyer, in his concurring opinion in the Iowa Utilities
Board case:
[A] sharing requirement may diminish the original owner’s incentive to keep up or to improve the property by depriving the owner of the fruits of the value-creating investment, research, or labor….Nor can one guarantee that firms will undertake the investment necessary to produce complex technological innovations, knowing that any competitive advantage deriving from those innovations will be dissipated by the sharing
to $95 dollar range from 1988 to 1994 and broadband at about $50 today. 10 Capitalism, Socialism and Democracy, 3rd ed., New York: Harper & Row, 1976, Chapter VII.
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requirement…..Increased sharing by itself does not automatically mean increased competition. It is in the unshared, not in the shared, portions of the enterprise that meaningful competition would likely emerge. Rules that force firms to share every resource or element of a business would create, not competition, but pervasive regulation, for the regulators, not the marketplace, would set the relevant terms.11
15. As in the case of broadband, the major contribution of wireless has not been its reduction in
the cost of existing ordinary telephone service,12 but its offer of a new service that allows
consumers to communicate in ways virtually unavailable previously—for which consumers
were willing to pay high prices in the early years and in explosively growing numbers as
prices declined but remained still at premium levels—every year since it was introduced.
16. Economists measure the benefits from a new product or services as the difference between
what consumers pay and what they would be willing to pay at the point that they were
indifferent between using the service and spending the money elsewhere. For example, the
early adopters of cellular service paid several hundred dollars for the phone itself and prices
considerably higher than today’s for usage.13 Now, these same subscribers can pay less for
a service that is also probably of higher quality. Accordingly, the benefit from this
phenomenon is at least as large as the difference between what they used to pay for the
amount they used and what they pay today for that old amount, and of course it is
enormously increased by the difference between the successively declining prices that
successive increments of customers would have been willing to pay and the low prices that
they more or less uniformly pay today.
11 AT&T Corp. v. Iowa Utilities Board, 119 S. Ct. 721, 752 (1999) (Breyer, J. concurring in relevant part). 12 In fact, it has been only fairly recently that prices have declined to the point where wireless service has become a substantial substitute for ordinary service.
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17. Jerry Hausman estimated the benefits of wireless services to consumers in 1994 at $25 to
$50 billion annually,14 or between 1.75 and 3.5 times the annual revenues of about $14
billion. 15 And both have exploded since then: subscribers have increased from about 25
million to over 100 million and revenues from $14 billion to over $50 billion annually.16
This explosion coincided with two events that substantially relaxed regulatory burdens on
wireless providers: (1) the Omnibus Budget Reconciliation Act of 1993, in which Congress
deregulated the industry to a great extent, and (2) the increase in the number of providers
that the availability of the new PCS spectrum permitted. Applying Hausman's calculations
to current volume shows that the annual benefits have grown to a range of $85 billion to
$170 billion.
13 The FCC reports that the average revenue-per-subscriber declined from about $97 in 1987 to about $45 in 2000. 14 Jerry A. Hausman, “Valuing the Effect of Regulation on New Services in Telecommunications,” Brookings, 1997. Similarly, Rohlfs, et al. estimated the social cost of the 10 to 15 year regulatory delay in licensing cellular systems at more than $86 billion–about 2 percent of GNP in 1983, when cellular service began. Jeffrey H. Rohlfs, Charles L. Jackson, and Tracey E. Kelley, “Estimate of the Loss to the United States Caused by the FCC’s Delay in Licensing Cellular Telecommunications,” National Economic Research Associates, November 4, 1991. 15 The major determinant of the relation between revenue and benefit is the price elasticity, with the multiple decreasing as the elasticity increases. This is explained by the fact that when elasticity is high, consumers would be willing to pay little more than the current price. 16 This expansion appears to be the result of both lower prices and competition shifting the demand curve outward by making services available to more consumers, improving the quality of services, and the like. In fact, the demand curve shift seems to be at least as powerful as the price reduction. For example, if we treat the 25 percent reduction in revenue per subscriber as a price decrease and use Hausman’s elasticity of –0.5, then over 80 percent of the growth in volume after 1994 can be attributed to the demand curve shift and less than 20 percent to the price reduction. If instead we take as a measure of the decrease in prices the drop from $0.57 in 1994 to $0.21 in 2000 (Thomas J. Sugrue, “Sixth Annual CMRS Competition Report, Opening Remarks,” June 20, 2001), the increase in demand and price reduction share equally in explaining the total expansion of sales. A ma jor benefit of the increased competition since 1994, in addition to its having reduced prices to existing consumers, has been its expansion in the reach of these new services to a much larger customer base.
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III. THE CURRENT ASYMMETRICAL REGULATION OF BROADBAND SERVICES INHIBITS INNOVATION AND HARMS CONSUMERS
18. The universal prescription of economists, we submit—other considerations aside17—would
be that regulators not impose economic regulation on the provision of risky, innovative
and/or new services such as broadband. In contrast, the present system has the anomalous
characteristic that the leading suppliers, cable operators, are not regulated, while the
competitors striving to catch up with them—in both cases endeavors that require very large
and risky investments—are still regulated on the basis of what a regulatory agency says is
“cost” plus a “reasonable” profit. In addition to the absurdity of shackling a competitor
running in second place, the injuries to consumers from perpetuating such asymmetrical
regulation are four-fold. First, by increasing the costs and risks of only one type of
competitor—in effect imposing a tax on particular sources of supply—it makes it less likely
that the services those competitors are uniquely qualified to offer will make it to the market,
depriving consumers of the possibly enormous benefits of such offerings. Second, even if
the broadband services offered by alternative providers prove to be close substitutes,
handicapping one group could prevent the lower-cost supplier from taking over the share of
the market that it would otherwise obtain. Third, the regulatory advantage enjoyed by the
cable operators could give them an advantage in the provision of services other than
broadband—such as video—thereby weakening and conceivably distorting the competition
in the supply of such complementary services. Fourth, the discouraging effect of the
17 We cannot of course ignore the fact that some economists are, nevertheless, opposing the deregulation of these services, particularly as it applies to the incumbent telephone companies, in the interest of preserving competitive opportunities for downstream rivals. We address ourselves specifically to that purpose of the Telecommunications Act in pars. 25-38, below.
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Commission’s regulation of the ILECs’ broadband offerings is not confined to risk-taking
innovations by them; it is equally destructive of the other part of the process of competitive
innovations—the efforts of rivals of the successful innovator, by their own efforts, to invent
around and surpass the originator.
19. The current broadband regulatory scheme as applied to ILECs appears to be designed not to
provide incentives for them to compete against cable modems and other facilities-based
providers but to provide CLECs an opportunity to get a piece of the action by free-riding on
their facilities. The fact is, however, that the greater public benefits flow from facilities-
based competition than from the efforts of competitors reselling the ILEC facilities, taking
advantage of regulatorily-created opportunities; and it is precisely that facilities-based
competition that the present rules both distort and discourage.
A. Cable Modems are Essentially Unregulated
20. In both its public pronouncements18 and its specific rulings, the FCC has consistently
maintained a hands-off-the-Internet position with regard to cable modem services,19 a
position it established early and articulated clearly in approving AT&T’s acquisition of
TCI, then the largest cable television company. The issues were poignantly posed by the
plans of AT&T for a multi-billion dollar upgrading of the TCI cable in order to provide
local, Internet and advanced video services; by the mounting pressures on the Commission
18 See, for example, “’Open Access’ Review Would be ‘Premature,’ Kennard Tells Dingell,” Telecommunications Reports, January 3, 2000, pp. 5-6 and Federal Communications Commission, In the Matter of Inquiry Concerning High-Speed Access to the Internet Over Cable and Other Facilities, Notice of Inquiry, GEN Docket No. 00-185, September 28, 2000, par. 4. 19 The FCC has undertaken an ongoing investigation of this policy, apparently motivated at least in part by open access rulings by local governments and differing interpretations by federal courts. Ibid., par. 14.
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by competitors and public agencies to condition its approval of the merger on AT&T’s
giving competitors access to those facilities—presumably at FCC-determined rates; and by
the equally costly and risky plans of the incumbent telephone companies to compete in
these same markets by digitalizing their subscriber access lines. AT&T strenuously resisted
the proposals to impose such a condition upon it.20 As its experts argued, in our view
correctly:
It would be against the public interest to subject the parties’ last mile broadband data transport facilities to any form of regulation at this time….There are many competitors, including the ILECs, that are actively developing broadband transport services…The xDSL services that are currently being deployed by the incumbent LECs alone constitute a significant and attractive commercial alternative to the internet cable services that TCI and others offer…The] demand to unbundle broadband transport will engender intrusive regulation of an emerging new service that requires massive entrepreneurial investments and whose marketplace success is far from assured…Forced unbundling with its attendant regulatory uncertainty would likely slow down the investment in the development of broadband last mile investment. Investing under the shadow of uncertain regulatory rules in an innovative service exacerbates the already substantial risks associated with that investment.21
The FCC concurred, presumably in the belief that imposition of such a sharing obligation
would be incompatible with Congress’s deregulation of the cable companies, with the need
to encourage costly investment in upgrading their telecommunications capabilities and,
therefore, with Schumpeterian competition. In its later approval of AT&T’s acquisition of
20 See Bryan Gruley, Must AT&T Give Internet Rivals Access To TCI’s Network? WALL ST. J., Jan. 15, 1999, at A1. 21 Declaration of Professors Janusz A. Ordover and Robert W. Willig, attached to AT&T’s and TCI’s Joint Reply to Comments and Joint Opposition to petitions to Deny or to Impose Conditions, In the Matter of Joint Application of AT&T Corp. and Tele-Communications, Inc. for Transfer of Control to AT&T of Licenses and Authorizations Held by TCI and its Affiliates or Subsidiaries, CS Docket No. 98-178, November 13, 1998. Ordover and Willig make no effort to reconcile their compelling argument here that government restrictions can stifle innovation incentives with their previous advocacy of TELRIC pricing for access to ILEC networks.
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MediaOne, the FCC once again rejected mandatory sharing, emphasizing the competition
among both broadband access providers and Internet Service Providers (ISPs) as a major
part of its rationale:
[W]e find that there is significant actual and potential competition from both broadband service providers and from unaffiliated ISPs that may gain access to the merged firm’s cable systems.22 The evidence of growing competition from both alternative broadband providers and unaffiliated ISPs gaining access to cable and other broadband networks indicates that any action taken by the merged firm to disfavor unaffiliated broadband content and applications providers is likely to threaten the networks’ ability to attract and retain customers.23
21. The FCC currently regulates the ILECs’ broadband services in two ways: (1) it requires that
the prices they charge their end-user customers and Internet Service Providers (ISPs)24 be
cost-based and (2) it requires them to make certain parts of their networks available to
competitors at prescribed wholesale prices. Indeed, if anything, these unbundling
requirements and concomitant pricing rules become even more onerous when the ILECs
contemplate upgrades to their networks that would both extend broadband services to more
customers and provide the capability for more services (e.g., video). The contrast with the
explicit exemption of the dominant cable modem services could not be more glaring.
22. While the continued application of traditional regulatory pricing standards to ILECs’ retail
broadband prices (for services offered to end-users and ISPs)25 prescribes the rate at which
22 Federal Communications Commission, In the Matter of Applications for Consent to the Transfer of Licenses and Section 214 Authorizations from MediaOne Group, Inc., Transferor to AT&T Corp., Transferee, Memorandum Opinion and Order, CC Docket No. 99-251, June 6, 2000, Par. 116. 23 Ibid., par. 123 24 Indeed, while ILECs are required to provide services to ISPs at regulated prices, the FCC has not even required that cable television providers provide access to ISPs at any price. 25 Federal Communications Commission, In the Matter of GTE Operating Companies GTOC Tariff No. 1, GTOC Transmittal No. 1148, Memorandum Opinion and Order, CC Docket No. 98-79, October 30, 1998, par. 32.
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they are permitted to recover the large investments needed to provide these services,
competitive providers are free to set prices as market conditions permit or dictate. And the
ILEC must offer any services that it sells directly to end users also to competitors, at a
prescribed resale discount.
23. To date, the FCC has considered the facilities used by ILECs to provide broadband services
to be telecommunications services, and thus potentially subject to being offered on an
unbundled basis to competitors. The requirement that the ILECs actually unbundle the
facilities that provide broadband services and make them available to competitors is subject
to the FCC’s finding that particular elements satisfy the “necessary” and “impair”
requirements of Section 251 of the Telecommunications Act. In that event, they become
subject to the pricing standard specified in Section 252, which the FCC has interpreted to be
its blank-slate total-service long-run incremental cost (TELRIC). To date, the Commission
has made the following pertinent unbundling decisions:
· Because the electronics necessary to provide broadband capability over copper loops are widely available and easy for CLECs to deploy, it declined to order that packet switching and DSLAMs be unbundled, under at least some circumstances, when customers are served by copper loops.26
Federal Communications Commission, In the Matters of Deployment of Wireline Services Offering Advanced Telecommunications Capability, Second Report and Order, CC Docket No. 98-147, November 9, 1999, par. 21. 26 Federal Communications Commission, In the Matter of Implementation of the Local Competition Provisions of the Telecommunications Act of 1996, Third Report and Order and Fourth Notice of Proposed Rulemaking, CC Docket No. 96-98, November 5, 1999, pars. 306-317. Even in this case, the Commission’s action could be viewed as tentative in that it qualified its action with the phrase “at this time (par. 306),” strongly suggesting that it reserved the right to unbundle in the future.
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· When, however, ILECs offer DSL services over loops that are part copper (distribution) and part fiber (feeder) and they are not able to offer collocation space in their remote terminals, they must unbundle their DSLAMs and packet switches.27 · Shortly after refraining from mandatory unbundling of the electronic equipment that provides DSL services, the FCC did require the ILECs to unbundle the high frequency part of a loop and offer it at low regulated prices to CLECs wishing to offer DSL—thereby sharing that line with the ILEC providing ordinary voice service.28
24. The situations in which these asymmetrical unbundling obligations impinge most heavily
on the ILECs are precisely the ones in which those obligations dampen their incentives to
upgrade their networks in order to extend broadband services to more customers and
enhance the offerings to all of them—namely, the ones involving application of
technologies other than existing copper loops. They do so: (1) by effectively allowing
CLECs to share in the rewards from the new investments while paying only bare-bones
TELRIC prices for that privilege, (2) imposing the costs of accommodating those CLECs—
for example, the costs of increasingly sophisticated operations support systems—only on
the ILECs and not on their other facilities-based competitors, and, (3), in particular,
effectively perpetuating mandatory unbundling as new technologies move potential points
of interconnection out of the central office (where space is more available than at other
27 Ibid., par. 313. At the time of the order, the most current ARMIS data (1998) showed that about 17 percent of the lines in Verizon’s (pre-GTE merger) territory had fiber feeder. In the two years since then, such lines have accounted for 75 percent of the growth in the total. 28 Federal Communications Commis sion, In the Matters of Deployment of Wireline Services Offering Advanced Telecommunications Capability and Implementation of the Local Competition Provisions of the Telecommunications Act of 1996, Third Report and Order in CC Docket No. 98-147 and Fourth Report and Order in CC Docket No. 96-98, December 9, 1999. In making that determination, the FCC employed an extremely narrow market definition—confining it to customers that want ordinary voice and DSL service over a single line (par. 39). And in determining what types of entrants would be “impaired” without line sharing, the FCC focused on special-purpose providers that choose to piggyback on ILEC voice customers. Ironically, in light of the fact that parties opposed to line sharing had argued that (1) a CLEC could choose to exploit the same economies of scope as an ILEC by buying a loop and offering both voice and DSL and (2) the DSL-only CLEC could cream-skim above cost voice services by transporting them over its packet switches, the FCC admitted
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points) and farther into the network, where collocation arrangements are decreasingly
available and/or more costly.29
B. The Impropriety and Harmful Effects of Extending Mandatory Sharing to ILEC Broadband Facilities
25. There is no disagreement with the proposition, embodied in the Act, that incumbent
telephone companies should be required to make available to their competitors at a
reasonable cost-based price preexisting facilities, inherited from their franchised
monopolies, that are truly essential if the challengers are to compete with them. To the
extent, however, that (1) it is economically feasible for competitors to obtain access to such
facilities or practical substitutes from other sources or (2) the incumbents acquired or
created them in competition with other providers, and, especially (3) if that acquisition has
involved or continues to involve costly, risky innovation, enforcement of an obligation to
share them or the advantages they confer with rivals can be anticompetitive.
26. In the case of broadband services, there is a strong case for the position that the obligation
to share should be confined to essential facilities, strictly defined. The essence of
competition is the attempt to develop and exploit the competitive advantages that
successful innovation provides; to require their sharing in instances in which that quest has
been successful, particularly where the quest involved big risks, would therefore discourage
competition itself.
that these DSL-only entrants would indeed be able to attain scope economies through the cream-skimming that the ILEC opponents had identified (par. 57) 29 This is because under the FCC’s rules the offer of collocation exempts an ILEC from obligations to unbundle their DSLAMs and packet switches; but these recent developments moving interconnection points further into the network make the collocation exemption decreasingly available to them.
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27. Some have argued for a less strict standard in the context of the introduction of competition
into public utility industries: that typically an incumbent company not only will control
some facilities truly “essential” to its rivals but will also enjoy economies of scale or scope
not because of superior enterprise on its part but merely because of its inherited franchised
monopoly, and that requiring it to share the benefit of those facilities with rivals at a
compensatory price would therefore not entail penalizing successful competitive efforts.
By exactly the same logic, however, there is no basis for applying the sharing requirement
to the subscriber access facilities of the local telephone companies and not to the access
lines of their cable competitors, whose “monopoly” of which is similarly attributable to
their historical status as franchised local monopolists.
28. Moreover, the somewhat more liberal sharing requirement of the telephone companies must
not be permitted to obscure the fundamental propositions to which it provides the
exception. First, it justifies mandatory sharing only of facilities or capabilities carried over
from and attributable to the public utility past. Second, wherever mandatory sharing, for
the sake of jump-starting the entry of competitors, would interfere with the more creative
and dynamic investment henceforward in facilities-based competitive entry and innovation
by incumbents and challengers alike, it is the latter that must take primacy. As Justice
Breyer observed in concurring with the U.S. Supreme Court’s decision overturning the
FCC’s 1996 Local Competition Order’s requirement that the ILECs provide competitors
with all network elements to which access is technically feasible, if rivals can share
whatever ILEC facilities they ask for that can feasibly be provided, at rock-bottom prices—
with their mere asking satisfying the conditions for mandatory sharing set forth in the Act—
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it cannot but have a discouraging effect on their own initiative and innovation and, equally,
on the willingness and ability of the ILECs themselves to undertake large risky investments
in developing and incorporating new technology in their networks. In particular, much of
the investment necessary for ILECs to extend broadband services to more customers and to
provide broadband services with new capabilities entail not simple electronic upgrades to
existing copper lines, but deployment of new ways to incorporate fiber optics and wireless
technologies into their networks.
29. As the foregoing reference to “rock-bottom prices” suggests, the disincentive to innovation
posed by the FCC’s standards for identifying UNEs for mandatory sharing is grossly
accentuated by the costing method it has prescribed for pricing them. This method, the
estimated total-service long-run incremental cost (TELRIC) of a hypothetical most efficient
new entrant, writing as it were on a blank slate, essentially ignores the actual incremental
costs of the incumbent suppliers.30
30. The wide differences produced by the Commission’s prescribed models, consistently lower
than estimates by the incumbent companies of their actual incremental costs, cannot be
attributed to the natural tendency of regulators to underestimate and regulatees to
exaggerate the costs on the basis of which rates are to be set. The Commission has
rationalized its endorsing of the models in part on the basis that it expected the incremental
costs of the incumbent companies to reflect inefficiencies on their part. But that rationale,
automatically assumed to explain the difference, is absurd. Not only is it irrational, in terms
30 “Why should these firms invest in new, often risky technology for delivering advanced, high-speed services if they are to be required to offer any such new facilities to their rivals at cost”—moreover, “not the Company’s
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of the entire economic case for basing efficient prices on the actual marginal costs of
incumbents; it also ignores the likelihood that an existing network, maximally efficient as
of the time of its installation, will, because of the interdependencies between its various
elements, contain some that could be replaced by more efficient elements with lower
incremental costs only as part of a totally new system. The least-cost expansion path of an
incumbent telephone company will necessarily be constrained by its inherited total
complement of facilities, so that it could take advantage of the putatively lower incremental
cost of an individual element only by taking on the additional cost of redesigning its entire
network. That neither party believes that the blank slate estimates approximate either the
ILECs’ own incremental costs or those that would actually prevail under competition is
demonstrated by the fact that neither of them actually follows the logical implications of its
results, even though it would be the obligation of the former and in the clear interest of the
latter to do so. If commissions that still regulate on a rate-base, rate of return basis believed
those results, or that they reflected inefficiencies on the part of the incumbents, they would
be derelict if they failed either to order the companies to scrap their existing facilities
forthwith and take the lower incremental cost route dictated by those models or disallow a
large portion of their rate base on grounds of imprudence. That they do not do either of
these can only be if they fail to recognize this opportunity, or recognize that the difference
between the estimated blank slate incremental costs of an individual element and those of
the incumbent need not at all reflect inefficiency on the part of the latter; that adopting the
hypothetical lowest cost expansion path for that element alone will be most unlikely to
actual cost,” but “at prices that reflect most efficient technology?” Robert W. Crandall, “The Telecom Act’s Phone-y Deregulation,” Wall Street Journal, January 27, 1999.
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represent the lowest cost expansion path actually available to even the most efficient
company. And if the companies—most of them subject to price cap regulation—believed
them, they would be derelict in their obligations to stockholders if they did not likewise do
so, abandoning all their present facilities and availing themselves of the assertedly lower
present and future costs of the TELRIC blank slate path.
31. Further, as long as broadband services are subject to regulatory pricing and unbundling
obligations, the possibility remains that an ILEC could upgrade and/or change its network
at considerable risk and, on the ground that competitors would be impaired in their offer of
services using these capabilities, be confronted with an obligation to unbundle those new
capabilities and make them available to CLECs at bare-bones TELRIC prices.
32. This possibility is by no means merely hypothetical. After all, it is extremely unlikely that
Congress had DSL services in mind when it developed the Section 251 requirements. Yet
the FCC did not hesitate to apply those requirements—presumably developed with voice
services in mind—to advanced broadband services when it ordered line-sharing. Further, as
we described earlier, even when it refrained from unbundling packet switching where
copper loops are available, the FCC qualified its action with the wording “at this time.”31
33. In light of the lead that cable modem services enjoy and the FCC’s decision to refrain from
regulating them, competitive parity would call for a corresponding relaxation with respect
to DSL services of the ILECs. The same consideration would argue for freeing them,
31 One of the facts the FCC considered was that because ILECs did not have a large market share in broadband services, a CLEC would have the benefit of similar scale economies in providing packet switching (par. 308). This reasoning leaves open the possibility that if ILECs were “too successful” in competing for DSL, they could ultimately be deemed to have a scale economy advantage that could then possibly be used to justify mandatory unbundling.
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specifically, from the obligation to share, especially at prices reflecting the FCC’s
hypothetical, ideally efficient firm standard.
34. Consider the anomaly of expecting the incumbent local telephone companies to incur these
costs and handicaps in competition with giants such as AT&T—the largest provider of
cable television and broadband services. If their new offerings lose out to that competition,
they could recover none of the costs in the FCC-dictated charges for their network
elements, because an ideally-efficient firm never fails! Should their new services instead
prevail, they would be required to make those elements available to would-be entrants at
wholesale prices based on the efficient-firm cost standard, with costs of capital typically set
at traditional public utility levels. In its recent supplement on “Innovation in Industry,” The
Economist cites an American study which found, in nice contrast, “that the overall rate of
return for some 17 successful innovations made in the 1970s averaged 56%.”32 What
incumbent telephone company would undertake costly and risky innovations in the face of
such a prospect of grossly asymmetrical treatment of successes and failures?33
35. It may appear anomalous, in view of the already manifest demand of subscribers for high-
speed Internet access and new video services, among others, to point out that the losses
consumers suffer from regulatory policies that have discouraged innovation are not directly
32 “Innovation in Industry,” Supplement to The Economist, February 20, 1999. 33 It is not only in their effect on the incentives of the ILECs to undertake costly and risky investment in modernizing their networks that the FCC’s sharing and network element pricing are likely to prove so harmful. They could also severely impair the ability of the incumbents to finance such ventures, by sharply reducing their internal cash flow: retained earnings are frequently the preferred means of financing such risky large- scale investment projects. See K.A. Froot, D.S. Scharfstein and J.C. Stein, “A Framework for Risk Management,” Harvard Business Review, November-December 1994. S. Fazzari, R.G. Hubbard, B. and Petersen, “Financing Constraints and Corporate Investment,” Brookings Papers on Economic Activity 1, 1988, report that retained earnings constitute more than 70 percent of the source of funds for corporate investment (p.
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observable. The essential evil of such policies is that they discourage or delay the
introduction of services that cannot be predicted beforehand. The costs to consumers can
be enormous.34
36. Moreover, competition alone can be relied upon to provide opportunities for CLECs
requiring access to unbundled broadband facilities of the incumbents and to offer
consumers choice among competing Internet service providers (ISPs), if their offerings can
survive the competitive test. If transport facilities are most efficiently utilized through
unbundling arrangements, providers competing with one another will not require regulatory
compulsion to enter into them. Similarly, the competition that will emerge from relying
primarily on markets rather than regulation will also provide customers with choice among
ISPs, because it will be in the competitive interest of access suppliers to provide it. The
more competitive the market is, the more sufficient are the incentives of facilities-based
providers to negotiate such arrangements. In a competitive market, with multiple platforms
available for providing service, if one provider withholds its cooperation from independent
ISPs in the hope of vertically extending its control from transport to content, the ISPs can
work with its rivals, who will thereby gain a competitive advantage. The critical point is
that where, as here, a market is competitive, market forces are sufficient to encourage
participants to reach arrangements that will maximize consumer welfare. It is strongly
preferable that all such arrangements be negotiated on mutually beneficial terms rather than
on terms set by regulators.
147, Table 1) and that on average firms reduce their capital expenditures by more than 36 cents for each $1 reduction in cash flow (p. 167, Table 4).
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37. These considerations weigh strongly against any requirement that ILECs unbundle facilities
such as access to fiber optics and electronics in remote terminals that require large new
investments. In contrast, the logic of the FCC’s requiring ILECs to make their existing
copper loops available to competitors for access to the high-frequency portion of the
spectrum may seem unexceptionable and not inconsistent with dynamic, innovative
competition: the incumbents enjoy that opportunity merely because of their inherited,
historic control of their copper-wired access networks and there is no immediately apparent
reason to permit them to deny competitors access to those capabilities.
38. The Commission’s ordering of mandatory provision of such access fails, however, to take
into account three critical facts and counter-considerations:
· In the offer of broadband services, the ILECs are not only in intense competition with many other companies offering high-speed access, most importantly to the Internet, via cable, satellite and wireless transmission; they are markedly behind their main competitors, the cable companies. · To compete in this market, the ILECs are indeed making very large risky investments—to the tune of billions of dollars a year—to incorporate DSL capabilities in their lines. The obligation to offer competitive access providers use of the high-frequency portion of those lines—thereby excluding their own use of the lines for that purpose—clearly biases the economics of that decision, because, unlike providers of cable modems, the ILECs would be forced to share potential DSL volumes with CLECs, who in turn would receive access to customers at very attractive prices (because of line sharing). It particularly skews the economics of their competition with the cable companies, which have likewise inherited from their previous monopolies the capability of using their coaxial cable for broadband access, without being subject to any such sharing obligation, and have a much larger portion of the market than the ILECs. · The FCC’s decision in effect assumes that the optimum telephone company network will remain as it is—predominantly copper subscriber loops; but in fact, to compete in this and other markets, the ILECs will have to upgrade their networks
34 Hausman, op. cit., estimated that the annual economic welfare losses associated with the delay of voice messaging were on the order of $1.3 billion.
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substantially, particularly by installing a great deal of fiber optics and associated electronics.35 To the extent they do that, it would disable the CLECs’ DSL services now provided over copper loops; so continuation of a general line-sharing obligation in effect requires the incumbents to maintain two networks—or to unbundle the fiber as well—precisely the kind of extremely expensive risky new investment to which the logic of mandatory network element sharing is least applicable and most inhibiting of dynamic competition.
IV. CONCLUSION
39. Whatever the merits of the intention of the Telecommunications Act to open local
telephone markets to competition, extending the unbundling and sharing obligations of the
incumbent telephone companies to broadband transmission of data, including Internet
access, is not conducive to efficient competition for broadband services.
40. Moreover, the underlying rationale that the incumbents enjoy monopolistic control over
facilities necessary for the challengers to compete with them in this market is simply not
correct.
41. On the contrary, extension of those requirements to the ILECs, particularly at the FCC’s
prescribed TELRIC prices, can only severely handicap them in competing with the
incumbent cable companies, who are—properly—subject to no such obligations and now
have a far greater share of that market.
42. The result can only be a severe impediment to the very large risky investments in exploiting
the almost inconceivably large potential benefits of this new technology. Far from being a
logical part of a program to encourage broadband competition—and competitive innovation
in particular—it can only discourage that process.
35 In fact, as we reported earlier, three-quarters of the recent growth in lines for Verizon is accounted for by lines with some fiber.
ATTACHMENT A
ALFRED E. KAHN
BUSINESS ADDRESS:
308 North Cayuga Street Ithaca, New York 14850 Tel: (607) 277-3007 Fax: (607) 277-1581 E-mail: [email protected]
Professor Kahn is the Robert Julius Thorne Professor of Political Economy, Emeritus, at Cornell University and a Special Consultant to NERA.
He has been Chairman of the New York Public Service Commission; Chairman of the Civil Aeronautics Board; and Advisor to the President (Carter) on Inflation and Chairman of the Council on Wage and Pric e Stability.
Professor Kahn received his Bachelor’s (summa cum laude) and Master’s degrees from New York University and a Doctorate in Economics from Yale University. Following service in the Army, he served as Chairman of the Department of Economics at Ripon College, Wisconsin. He moved to the Department of Economics at Cornell University, where he remained until he took leave to assume the Chairmanship of the New York Public Service Commission. During his tenure at Cornell, Professor Kahn served as Chairman of the Department of Economics, member of the Board of Trustees of the University and Dean of the College of Arts and Sciences.
Throughout his career, Professor Kahn has served on a variety of public and private boards and commissions including: the Attorney General’s National Committee to Study the Antitrust Laws; the senior staff of the President’s Council of Economic Advisors; the Economic Advisory Council of American Telephone & Telegraph Company; the National Academy of Sciences Advisory Revie w Committee on Sulfur Dioxide Emissions; the Environmental Advisory Committee of the Federal Energy Administration; the Public Advisory Board of the Electric Power Research Institute; the Board of Directors of the New York State Energy Research and Development Authority; the Executive Committee of the National Association of Regulatory Utility Commissioners; the National Commission for Review of Antitrust Laws and Procedures; the New York State Council on Fiscal and Economic Priorities; the Governor of New York’s Fact-Finding Panel on Long Island Lighting Company’s Nuclear Power Plant at Shoreham, L.I.; the Governor of New York’s Advisory Committee on Public Power for Long Island; the National Governing Board of Common Cause; in 1990, as Chairman of the International Institute for Applied Systems Analysis Advisory Committee on Price Reform and Competition in the USSR; in 1999, Member of the National Academy of Sciences, National Research Council/Transportation Research Board Committee for a Study of Competition in the U.S. Airline
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Industry; and in 2000, Chair of the Blue Ribbon Panel to Study Pricing in the California Electricity Market.
He has also served as a court-appointed expert in State of New York v. Kraft General Foods, Inc., et al., U.S. District Court, S.D.N.Y.; Advisor to New York Governor Carey on Telecommunications Policy; and as a consultant to the Attorneys General of New York, Pennsylvania and Illinois, the Ford Foundation, the National Commission on Food Marketing, Federal Trade Commission, Antitrust Division of the Department of Justice, the U.S. Department of Agriculture and the City of Denver on charging and financing of Stapleton Airport.
He has received L.L.D. honorary degrees from Colby College, Ripon College, Northwestern University, the University of Massachusetts and Colgate University, and an honorary D.H.L. from the State University of New York, Albany; he also received the Distinguished Transportation Research Award of the Transportation Board Forum, The Alumni Achievement Award of New York University, the award of the American Economic Association’s Transportation and Public Utilities Group for Outstanding Contributions to Scholarship, The Henry Edward Salzberg Honorary Award from Syracuse University for Outstanding Achievement in the Field of Transportation, the Burton Gordon Feldman Award for Distinguished Public Service from Brandeis University, the Wilbur Cross Medal for outstanding achievement (Yale University), The 1997 L. Welch Pogue Award For Lifetime Contributions to Aviation, the 1997 Sovereign Fund Award Honoring Vision, Commitment and Achievement in the Pursuit of Individual Freedom, and the J. Rhoads Foster Award for achievements in economic regulation; and was elected to membership in the American Academy of Arts and Sciences and Vice President of the American Economic Association. He was for 15 years a regular commentator on PBS’s “The Nightly Business Report.”
He has testified before many U.S. Senate and House Committees, the Federal Power Commission, the Federal Energy Regulatory Commission and numerous state regulatory bodies.
Professor Kahn’s publications include Whom the Gods Would Destroy, or How Not to Deregulate; Letting Go: Deregulating the Process of Deregulation; Great Britain in the World Economy; Fair Competition: The Law and Economics of Antitrust Policy (co-authored); Integration and Competition in the Petroleum Industry (co-authored); and The Economics of Regulation. He has written numerous articles which have appeared in The American Economic Review, The Quarterly Journal of Economics, The Journal of Political Economy, Harvard Law Review, Yale Journal on Regulation, Yale Law Journal, Fortune, The Antitrust Bulletin and The Economist, among others.
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EDUCATION: YALE UNIVERSITY Ph.D., Economics, 1942 UNIVERSITY OF MISSOURI Graduate Study, 1937-1938 NEW YORK UNIVERSITY M.A., Economics, 1937 A.B. (summa cum laude), Economics, 1936
EMPLOYMENT: 1961-1974 NATIONAL ECONOMIC RESEARCH ASSOCIATES, INC. 1980- Special Consultant CORNELL UNIVERSITY 1947-1989 Assistant Professor; Associate Professor; Robert Julius Thorne Professor of Economics; Robert Julius Thorne Professor of Political Economy, Emeritus, 1989-; Chairman, Department of Economics; Dean, College of Arts and Sciences; on leave 1974-80. NEW YORK UNIVERSITY SCHOOL OF LAW Spring 1989 Visiting Meyer Professor of Law UNITED STATES GOVERNMENT 1978-1980 Advisor on Inflation to President Carter 1978-1980 Chairman, Council on Wage and Price Stability 1977-1978 Chairman, Civil Aeronautics Board 1955-1957 Senior Staff, Council of Economic Advisors to the President 1943 U.S. Army, Private 1943 War Production Board 1942 Associate Economist, International Economics Unit, Bureau of Foreign and Domestic Commerce, Department of Commerce 1941-1942 Associate Economist, Antitrust Division, U.S. Department of Justice NEW YORK STATE PUBLIC SERVICE COMMISSION 1974-1977 Chairman BROOKINGS INSTITUTION 1940, 1950-1951 Staff Economist RIPON COLLEGE 1945-1947 Assistant Professor, Chairman, Department of Economics TWENTIETH CENTURY FUND 1944-1945 Research Economist COMMISSION ON PALESTINE SURVEYS
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1943-1944 Economist UNIVERSITY OF MISSOURI 1937-1938 Teaching Assistant
CONSULTANCIES AND PROFESSIONAL ACTIVITIES: 1994-1995 Antitrust Division, U.S. Department of Justice, on the application of Ameritech for waivers of the interexchange restrictions in the AT&T Modified Final Judgment 1994 American Airlines on code-sharing 1993-1994 Court-appointed expert in State of New York v. Kraft General Foods, Inc., et al., U.S. District Court, S.D.N.Y. 1992 New Zealand Telecom on the progress of competition in New Zealand telecommunications 1992 Rochester Telephone Company on corporate restructuring and deregulation 1992 Russian Government on economic reform 1991 British Mercury on terms of competition with British Telecom 1989 City of Denver on charging and financing of Stapleton Airport 1988-1990 Attorneys General, New York and Pennsylvania, on airline mergers 1985 Attorney General, State of Illinois, on Illinois Bell rates 1981-1984 City of Long Beach, California, the Coca-Cola Company and American Airlines on antitrust litigation 1981-1997 Economic commentary, Nightly Business Report (PBS) 1980-1982 Advisor to Governor Carey on Telecommunications Policy 1968 Ford Foundation 1966 National Commission on Food Marketing 1965,1974 Federal Trade Commission 1963-1964 Antitrust Division, Department of Justice 1960-1961 U.S. Department of Agriculture 1957-1961 Boni Watkins, Jason & Co. See also the list of testimony below.
MEMBERSHIPS: 2000 Chairman, Blue Ribbon Panel to Study Pricing in the California Electricity Market 1998-1999 Member, Committee for a Study of Competition in the U.S. Airline Industry, National Research Council/Transportation Research Board, National Academy of Sciences 1992-1994 Member, New York State Telecommunications Exchange 1992-1993 Member, Ohio Blue Ribbon Panel on Telecommunications Regulation 1991- Board of Editors, Review of Industrial Organization 1990-1992 Chairman, International Institute for Applied Systems Analysis Advisory Committee on Price Reform and Competition in the USSR 1986 Governor Cuomo’s Advisory Panel on public power for Long Island 1983-1989 Governor Cuomo’s Fact-finding Panel on Long Island Lighting Company’s Nuclear Power Plant at Shoreham, L.I. 1983-1990 New York State Council on Fiscal and Economic Priorities
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1982- The American Heritage Dictionary Usage Panel 1982-1985 Governing Board, Common Cause 1980-1986 Director, New York Airlines 1978-1979 National Commission for the Review of Antitrust Laws and Procedures 1975-1977 Project Committee, Electric Utility Rate Design Study, Electric Power Research Institute 1974-1975 National Academy of Science Review Commission on Sulfur Oxide Emissions 1974-1977 Public Advisory Board, Electric Power Research Institute 1974-1977 Environmental Advisory Committee, Federal Energy Administration 1974-1977 Executive Committee, National Association of Regulatory Utility Commissioners, and Chairman, Committee on Electric Energy 1968-1974 Economic Advisory Board, American Telephone & Telegraph Corporation 1965-1967 Economic Advisory Committee, U.S. Chamber of Commerce 1967-1969 Chairman, Tompkins County Economic Opportunity Corporation 1964-1969 Board of Trustees, Cornell University 1961-1964 Board of Editors, American Economic Review 1953-1955 Attorney General’s National Committee to Study the Antitrust Laws
HONORS AND AWARDS: Dec 1999 AEI-Brookings Joint Center for Regulatory Studies First Distinguished Lecturer Apr 1999 J. Rhoads Foster Award for achievements in economic regulation Jan 1998 Recipient of the 1997 Sovereign Fund Award “Honoring Vision, Commitment and Achievement in the Pursuit of Individual Freedom” Dec 1997 The 1997 L. Welch Pogue Award For Lifetime Contributions to Aviation May 1995 Wilbur Cross Medal for outstanding achievement, Yale University Mar 1989 Burton Gordon Feldman Award for Distinguished Public Service, Gordon Public Policy Center, Brandeis University Feb 1989 Distinguished Service Award, Public Utility Research Center, University of Florida Nov 1988 International Film and TV Festival of New York, Bronze Medal presented to The Nightly Business Report/WPBT2 for Editorial/Opinion Series written by Alfred E. Kahn Apr 1986 Harry E. Salzberg 1986 Honorary Medallion for outstanding achievement in the field of transportation Oct 1984 Distinguished Transportation Research Award of the Transportation Research Forum 1981-1982 Vice President, American Economic Association 1978 Richard T. Ely lecturer, American Economic Association, 1978 1978 Rejection Scroll, International Association of Professional Bureaucrats May 1985 State University of New York (Albany), DHL (Hon.) May 1983 Colgate University, LL.D. (Hon.) June 1982 Northwestern University, LL.D. (Hon.) May 1980 Ripon College, LL.D. (Hon.) May 1979 University of Massachusetts, LL.D. (Hon.) May 1978 Colby College, LL.D. (Hon.) 1977- Fellow of the American Academy of Arts and Sciences 1976 Distinguished Alumni Award, New York University 1976 American Economic Association, Section on Public Utilities and Transportation, citation for distinguished contributions
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1954-1955 Fulbright Fellowship, Italy 1935- Phi Beta Kappa 1939-1940 Yale -Brookings Fellow
BOOKS: Whom the Gods Would Destroy, or How Not to Deregulate, AEI-Brookings Joint Center for Regulatory Studies, May 2001. Letting Go: Deregulating the Process of Deregulation, Michigan State University Institute of Public Utilities, July 1998. The Economics of Regulation, 2 volumes, John Wiley, 1970 and 1971. Reprinted by The MIT Press, 1988, with a new “Introduction: A Postscript, Seventeen Years After,” pp. xv-xxxvii. Integration and Competition in the Petroleum Industry (with Melvin G. DeChazeau), Petroleum Monograph Series, Volume 3, Yale University Press, 1959. Reprinted in 1971. Fair Competition: The Law and Economics of Antitrust Policy (with Joel B. Dirlam), Cornell University Press, 1954. Reprinted by Greenwood Press, 1970. Great Britain in the World Economy, Columbia University Press, 1946. Reprinted in 1968.
MAJOR ARTICLES: “The Deregulatory Tar Baby: The Precarious Balance Between Regulation and Deregulation, 1970-2000 and Henceforward,” Journal of Regulatory Economics, forthcoming, January 2002. “Enhancing Competition for Broadband Services: The Case for Removing the Prohibition Against High- Speed InterLATA Transmission by Regional Bell Operating Companies” (with Timothy J. Tardiff), prepared for the United States Telecom Association, May 22, 2000. “The Telecommunications Act At Three Years: An Economic Evaluation of Its Implementation by The Federal Communications Commission” (with Timothy J. Tardiff and Dennis L. Weisman), Information Economics and Policy, December 1999, pp. 319-365. “Bribing Customers to Leave and Calling it ‘Competition,’” The Electricity Journal, May 1999, pp. 88- 90. “Comments on Exclusionary Airline Pricing,” Journal of Air Transport Management, Volume 5, Issue 1, January 1999, pp. 1-12. “Resisting the Temptation to Micromanage: Lessons from Airlines and Trucking,” Regulators’ Revenge: The Future of Telecommunications Deregulation, CATO Institute, August 1998, pp. 17-27. “Electric Deregulation: Defining and Ensuring Fair Competition,” Electricity Journal, April 1998. “Deregulation: Micromanaging the Entry and Survival of Competitors,” Edison Electric Institute, February 1998. “Competition and Stranded Costs Re-Revisited,” 37:1 Natural Resources Journal, Winter 1997, pp. 29- 42.
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“How to Treat the Costs of Shared Voice and Video Networks in a Post-regulatory Age,” Policy Analysis, #264, November 27, 1996, Cato Institute. “Deregulation of the Public Utilities—Transitional Problems and Solutions,” Economic Papers, Economic Society of Australia, September 1995, pp. 1-17. (Published in Réseaux nos. 72-73 Juillet/Octobre 1995 by CNET as “Déréglementation des Services Publics: Problèmes transitoires et solutions.”) “The Challenge for Federal and State Regulators: Transition from Regulation to Efficient Competition in Electric Power” (with William J. Baumol and Paul L. Joskow), Edison Electric Institute, December 9, 1994. “Competition in the Electric Industry Is Inevitable and Desirable,” The Electric Industry in Transition, Public Utility Reports, Inc. and New York State Energy Research and Development Authority, December 1994, Chapter 3, pp. 21-31. “Can Regulation and Competition Coexist? Solutions to the Stranded Cost Problem and Other Conundra,” The Electricity Journal, Volume 7, Number 8, October 1994, pp. 23-35. “The Pricing of Inputs Sold to Competitors: A Comment” (with William E. Taylor), in Yale Journal on Regulation, Vol. 11, No. 1, Winter 1994, pp. 225-240. “Airline Deregulation,” in The Fortune Encyclopedia of Economics, David R. Henderson, Ph.D., ed., New York: Warner Books, 1993, pp. 379-384. “Change, Challenge and Competition The Report of the National Commission to Ensure a Strong Competitive Airline Industry, August 1993,” Regulation, No. 3, 1993. “The Competitive Consequences of Hub Dominance: A Case Study,” in Review of Industrial Organization, Vol. 8, 1993, pp. 381-405. “Pricing of Telecommunications Services: A Comment,” in Review of Industrial Organization, Vol. 8, 1993, pp. 39-41. “The Purposes and Limitations of Economic Regulation; The Achievements and Problems of Deregulation” and “Reflections and Conclusions on British and U.S. Experience: The Future of Regulation,” in Incentive Regulation: Reviewing RPI-X & Promoting Competition, Proceedings 2, Based on papers presented at two CRI seminars in London on 4 June and 15 July 1992, CRI (Centre for the Study of Regulated Industries), October 1992, pp. 1-17 and 93-104. “Market Power Issues in Deregulated Industries,” in Antitrust Law Journal, Vol. 60, Issue 3, American Bar Association, 1992, pp. 857-866. “Regolamentazione e concorrenza nelle imprese de pubblica utilità: un <
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“An Economically Rational Approach to Least-Cost Planning For Electric Power,” The Electricity Journal, Vol. 4, Number 5, June 1991, pp. 11-20. “The Changing Focus of Electric Utility Regulation,” Research in Law and Economics, Richard O. Zerbe, Jr., Victor P. Goldberg, eds., Vol. 13, JAI Press, Inc., Spring 1991, pp. 221-231. “The Soviet Economic Crisis: Steps to Avert Collapse” (co-author), Executive Report 19, International Institute for Applied Systems Analysis, Laxenburg, Austria, February 1991. “Telecommunications, Competitiveness and Economic Development—What Makes Us Competitive?”, Public Utilities Fortnightly, Vol. 126, No. 6, September 13, 1990, pp. 12-19. “Deregulation: Looking Backward and Looking Forward,” Yale Journal on Regulation, Vol. 7, Spring 1990, pp. 325-354. “Do We Need to Curb the Investments Foreigners are Making in the United States?” in The Impact of Foreign Investment in the United States, Touche Ross & Co., June 1989. “Innovative Pricing of Electricity,” in New Dimensions in Pricing Electricity: Proceedings, Palo Alto, CA: Electric Power Research Institute, April 1989. “Competition: Past, Present and Future, Perception vs. Reality,” in Proceedings: 1988 Utility Strategic Issues Forum Planning in a Competitive Environment, Palo Alto, CA: Electric Power Research Institute, March 1988. “Thinking About The Record of Deregulation,” in The Donald S. MacNaughton Symposium Proceedings 1987, Economic Deregulation: Promise and Performance, Syracuse, NY: Syracuse University, 1988, pp. 21-35. “In Defense of Deregulation,” in Cleared For Takeoff: Airline Labor Relations Since Deregulation, Jean T. McKelvey, Editor, Ithaca, NY: Cornell University ILR Press, 1988, pp. 343-347.” “I Would Do It Again,” Regulation, 1988 Number 2, pp. 22-28. “Airline Deregulation,” The Senior Economist, Joint Council on Economic Education, Spring 1988. “Airline Deregulation - A Mixed Bag, But a Clear Success Nevertheless,” Transportation Law Journal, Volume 16, No. 2, Spring 1988, pp. 229-251. “Surprises of Airline Deregulation,” The American Economic Review, Papers and Proceedings, Volume 78, No. 2, May 1988, pp. 316-322. “Thoughts on the Past, Present, and Future of Telecommunications Regulation,” talk presented to the Current Issues in Telephone Regulation conference at the University of Texas, Austin, October 5, 1987, reprinted in Telecommunications Deregulation: Market Power and Cost Allocation Issues, John R. Allison and Dennis L. Thomas, eds., Westport, CT: Quorum Books, 1990, pp. 259-268. “The Future of Local Telephone Service: Technology and Public Policy,” Fishman Davidson Center for the Study of the Service Sector, The Wharton School of the University of Pennsylvania, Discussion Paper #22, June 1987. Reprinted in Toward The Year 2000, ITT Key Issues Lecture Series, 1986, (New York: ITT Corp. 1987), pp. 86-99. “Current Issues in Telecommunications Regulation: Pricing” (with William B. Shew), Yale Journal on Regulation, Vol. 4: 191-256, Spring 1987.
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“Deregulatory Schizophrenia,” California Law Review, Volume 75, Number 3, May 1987, pp. 1059- 1068. “A Critique of Proposed Changes,” The Future of Electrical Energy: A Regional Perspective of an Industry in Transition, Sidney Saltzman and Richard E. Schuler (eds.), Praeger Publishers, New York, 1986, pp. 340-347. “The Tyranny of Small Decisions and the Perils of Big Ones,” in Allocation, Ethics, and Innovation in Research and Public Policy, National Symposium on Science and Technology, Cornell University, Washington, D.C., May, 20, 1986. “The Theory and Application of Regulation,” Antitrust Law Journal, Spring Meeting Issue, 1986, Volume 55, Issue 1, pp. 177-184, from ABA Antitrust Section Annual Meeting. “Transportation Deregulation...And All That,” Honorary Salzberg Memorial Lecture, Syracuse University School of Management, Syracuse, New York, April 1986. Reprinted, revised, in Economic Development Quarterly, May 1987, Volume 1, Number 2, pp. 91-99. “Frontier Issues in Telecommunications Regulation,” Mountain Bell Academic Seminar, Lakewood, Colorado, August 1985. “Telecommunications Regulation: A Case Study of the Impact of a Technology on Social Institutions,” for presentation at Cornell University Electrical Engineering Centennial Symposium, Ithaca, New York, June 12, 1985. “Public Policies for Our Telecommunications Future,” in Funding the Future of Telecommunications, a conference sponsored by Rensselaer Polytechnic Institute, supported by the NYNEX Telephone Companies, Saratoga Springs, New York, June 3-5, 1985. “Industrial Policy and Deregulation,” Federal Bar News & Journal, Washington, D.C., January 1985. First Distinguished Lecture on Economics in Government, “The Macroeconomic Consequences of Sensible Microeconomic Policies,” Dallas, December 28, 1984. American Economic Association meetings. “The Regulatory Agenda,” and “Concluding Comments: The Future of Access,” in Alan Baughcum and Gerald R. Faulhaber, Telecommunications Access & Public Policy, Ablex Publishing Corporation, Norwood, New Jersey, 1984, pp. 205-210 and pp. 245-253. “The Uneasy Marriage of Regulation and Competition,” Telematics, Washington, D.C., September 1984, pp. 1-2, 8-17. “The Next Steps in Telecommunications Regulation and Research,” Public Utilities Fortnightly, Arlington, VA., July 19, 1984. “The Road to More Intelligent Telephone Pricing,” Yale Journal on Regulation, Volume 1, Number 2, 1984, pp. 139-157. “Telephone Deregulation: Two Views: A Needed Dose of Competition,” Challenge, March/April 1984, pp. 24-29. “Economic Policies For The 80s,” Oppenstein Brothers Foundation Lecture, Rockhurst College and the University of Missouri, Kansas City, April 19, 1983.
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“The Relevance of Industrial Organization,” Industrial Organization, Antitrust, and Public Policy, John V. Craven, ed., Kluwer-Nihjoff, 1983. “Some Thoughts on Telephone Access Pricing,” National Economic Research Associates, April 1983. “Deregulation: Its Meaning and Implications for Antitrust Enforcement,” New York State Bar Association, 1983 Antitrust Law Symposium, pp. 2-14. “The Passing of the Public Utility Concept: A Reprise,” in Telecommunications Today and Tomorrow, Eli Noam (ed.) Harcourt Brace Jovanovich, 1983. “Deregulation and Vested Interests: The Case of Airlines,” The Political Economy of Deregulation, Roger G. Noll and Bruce M. Owen, eds., American Enterprise Institute Studies in Government Regulation, 1983. “An Alternative to Reaganomics,” Increasing Understanding of Public Problems and Policies, 1982, Farm Foundation, January 1983. “Utility Diversification,” The Energy Journal, Volume 4, No. 1, January 1983, pp. 149-160. “The Airline Industry: Is It Time to Reregulate?” Second Annual William A. Patterson Transportation Lecture, The Transportation Center, Northwestern University. Published jointly with National Economic Research Associates, 1982. Reprinted in The World Economy, December 1982, London: Basil Blackwell, pp. 341-360. “On Changing the Consumer Price Index, A Comment,” Journal of Policy Analysis and Management, Vol. 1 (Summer 1982), pp. 512-15. “The Political Feasibility of Regulatory Reform: How Did We Do It?” Reforming Social Regulation: Alternative Public Policy Strategies, Leroy Graymer and Frederick Thompson (eds.), Sage Publications, 1982. “The Reform of Government Regulation: Recent Progress in the United States,” University of Leuven Press, Leuven, Belgium, 1981. “The New Merger Wave,” N/E/R/A Topics, National Economic Research Associates, December 1981. “Liberals Must Face Facts,” Challenge, Nov/Dec. 1981, pp. 25-32. “Is Inflation Abating?” N/E/R/A Topics, National Economic Research Associates, November 1981. “Utility Regulation Revisited,” National Economic Research Associates: New York, 1981, republished in Current Issues in Public Utility Economics: Essays in Honor of James C. Bonbright, Albert L. Danielsen and David R. Kamerschen (eds.), Lexington, MA., D.C. Heath and Company, 1983. “Must We Live With Inflation Through the 1980s?” Major Issues of the 1980s Lecture Series. Sponsored jointly by the Lowell Institute of Boston and Harvard University Extension, April 1981. “Ethical Values in a Market System,” Across the Board, The Conference Board, April 1981, pp. 57-63. “Can Liberalism Survive Inflation?” The Economist, March 7, 1981, pp. 21-25. “Health Care Economics: Paths to Structural Reform,” in Mancur Olson (ed.), A New Approach to the Economics of Health Care, Washington, American Enterprise Institute, 1981.
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“Regulation and the Imagination,” Proceedings of a Regulatory Council Conference, United States Regulatory Council, July 22, 1980, pp. 1-9. “Health Care and Inflation: Social Compassion and Efficient Choice,” National Journal, August 2, 1980, pp. 1294-97. “A Paean to Legal Creativity” (with Michael Roach), Administrative Law Review, Washington, D.C., Winter 1979, Volume 31, No. 1, pp. 97-114. “Applications of Economics to an Imperfect World,” The Richard T. Ely Lecture, The American Economic Review, Papers and Proceedings, Volume 69, No. 2, May 1979, pp. 1-13. Modified and published as “Applying Economics to an Imperfect World,” Regulation, Washington, D.C., November/December 1978, Volume 2, No. 6, pp. 17-27. “The Changing Environment of International Air Commerce,” Air Law, (Netherlands Journal), Volume 3, No. 3, 1978. “Deregulation of Air Transportation—Getting from Here to There,” Regulating Business: The Search for an Optimum, Institute for Contemporary Studies, San Francisco, California, 1978, pp. 37-63. “Load Control, Resource Conservation and King Charles’ Head,” Iowa State University Regulating Conference, Proceedings, May 19, 1977, pp. 68-74. “Recent Developments in Cost Analysis and Rate Design,” Proceedings of the Third Annual Symposium on Problems of Regulated Industries, Kansas City, Missouri, February 14, 1977, pp. 15-28. “An Economist at Work on Utility Rate Regulation,” a series of three articles, Public Utilities Fortnightly, Washington, D.C., January 5, 19, and February 2, 1978. “New Rate Structures in Communications” (with Charles A. Zielinski), Public Utilities Fortnightly, March 25, 1976, pp. 19-24 and April 8, 1976, pp. 20-23. “Efficient Rate Design: The Transition from Theory to Practice,” Proceedings of the Symposium on Rate Design Problems of Regulated Industries, February 23-26, 1975, Kansas City, Missouri, pp. 34- 51. “Between Theory and Practice: Reflections of a Neophyte Public Utility Regulator,” Public Utilities Fortnightly, January 2, 1975, pp. 3-7. “Economic Theory as a Guideline for Government Intervention and Control: Comment,” Journal of Economic Issues, Vol. VIII, No. 2, June 1974. “Market Power Inflation: A Conceptual Framework,” in The Roots of Inflation, Burt Franklin and Co., 1975. “The Economics of the Electricity-Environmental Issue: A Primer,” P.I.P. National Environmental Press Seminar, Minneapolis, Minnesota, May 31-June 1, 1972. “Evaluation of Economic Regulation: Discussion,” Ibid, LXI (May 1971) 235-237. “National Communications Policy: Discussion,” The American Economic Review, Papers and Proceedings, Volume 60, May 1970, pp. 219-20. “Dual Pricing in Southern Louisiana: A Reply,” Land Economics, XLVI (August 1970): 338-42.
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“The Combined Effects of Prorationing, the Depletion Allowance and Import Quotas on the Cost of Producing Crude Oil in the United States,” U.S. Senate, Committee on the Judiciary, Subcommittee on Antitrust and Monopoly, 91st Congress, 1st Session, Government Intervention in the Market Mechanism, Hearings, The Petroleum Industry, Part I, Washington, 1969, Reproduced in Natural Resources Journal (January 1970) X:53-61. “Incentives to Superior Performance: Pricing,” Harry Trebing (ed.), Performance Under Regulation, Michigan State University Press, 1968. “The Graduated Fair Return,” The American Economic Review, March 1968. “Cartels and Trade Associations,” Encyclopedia of the Social Sciences, MacMillan, 1968. “The Merits of Reserving the Cost-Savings From Domestic Communications Satellites for Support of Educational Television” (with Joel B. Dirlam), Yale Law Journal, Volume 77, No. 3, January 1968, pp. 494-520. “Tyranny of Small Decisions: Market Failures, Imperfections, and the Limits of Economics,” Kyklos, Volume 19, 1966. “Mergers in the Petroleum Industry and Problems of the Independent Refiner,” U.S. Senate Judiciary Committee, Economic Concentration, Part II, Washington, 1965, pp. 562-609. “The Depletion Allowance in the Context of Cartelization,” The American Economic Review, Volume 54, 1964, pp. 286-314. “Efficiency in the Use of Natural Resources: Discussion,” The American Economic Review, Papers and Proceedings, Volume 54, May 1964, pp. 221-226. “Market Power and Economic Growth: Guides to Public Policy,” Antitrust Bulletin, Volume 8, May- June 1962, p. 531. “Agricultural Aid and Economic Development: The Case of Israel,” The Quarterly Journal of Economics, Volume 76, November 1962, pp. 568-591. “The Role of Patents,” in J.P. Miller, ed., Competition, Cartels and Their Regulation (North Holland Publishing Company, Amsterdam), Chapter 8, pp. 308-346. “The Chemical Industry,” Walter Adams (ed.) The Structure of the American Industry, First, Second and Third Editions, New York, MacMillan, 1948, 1954 and 1961. “Economic Issues in Regulating the Field Price of Natural Gas,” The American Economic Review, Papers and Proceedings, Volume 50, May 1960, pp. 506-517. “Pricing Objectives in Large Companies: Comment,” The American Economic Review, Volume 49, September 1959, pp. 670-678. “Selected Papers: A.E.A. Competition: Discussion,” The American Economic Review, Papers and Proceedings, Volume 48, May 1958, pp. 600-602. “Economic and Legal Approaches to Antitrust: An Attempt to Clarify the Issues,” Antitrust Bulletin, Volume 2, January 1957, pp. 267-279. “Report on Antitrust Policy: Discussion,” The American Economic Review, Papers and Proceedings, Volume 46, May 1956, pp. 496-507.
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“My Antitrust Philosophy: Evidence of Schizophrenia or Shattering Transformation?” Antitrust Bulletin, Volume 1, November 1955, p. 355. “Regulation of Crude Oil Production in the United States and Lessons for Italy,” Banca Nazionale Del Lavoro Monthly Review, Volume 8, June 1955, pp. 67-79. “A Rejoinder” (with Joel B. Dirlam), Indiana Law Journal, Volume 29, Spring 1954, pp. 371-375. “Legal and Economic Appraisal of the ‘New’ Sherman and Clayton Acts,” Yale Law Journal, Volume 63, January 1954, pp. 293-347. “Standards for Antitrust Policy,” Harvard Law Review, Volume 67, November 1953, pp. 28-54. Also reprinted in Homewood-Irwin, Readings in Industrial Organization and Public Policy (American Economic Association, 1958), pp. 352-375. “A Reply” (with Joel B. Dirlam), Journal of Political Economy, Volume 61, October 1953, pp. 441-446. “The Integration and Dissolution of the A & P Company” (with Joel B. Dirlam), Indiana Law Journal, Volume 29, Fall 1953, pp. 1-27. “Big Business in a Competitive Society” (with A.D.H. Kaplan), Fortune, Volume 47, Supp., February 1953. “Leadership and Conflict in the Pricing of Gasoline” (with Joel B. Dirlam), Yale Law Journal, Volume 61, June-July 1952, pp. 818-855. “Price Discrimination in Law and Economics” (with Joel B. Dirlam), The American Journal of Economics and Sociology (Essays in Honor of Harry Gunnison Brown), Volume 11, April 1952, pp. 281-313. “Antitrust Law and the Big Buyer: Another Look at the A & P Case” (with Joel B. Dirlam), Journal of Political Economy, Volume 60, April 1952, pp. 118-132. “Investment Criteria in Development Programs,” The Quarterly Journal of Economics, Volume 65, February 1951, pp. 38-61. “The Burden of Import Duties, A Comment,” The American Economic Review, Volume 38, December 1948, pp. 857-867. “Patent Policy: Discussion,” The American Economic Review, Papers and Proceedings, Volume 38, May 1948, pp. 245-260. “The British Balance of Payments, and Problems of Domestic Policy,” The Quarterly Journal of Economics, Volume 61, May 1947, pp. 368-396. “Palestine: A Problem in Economic Evaluation,” The American Economic Review, Volume 34, September 1944, pp. 538-560. “Fundamental Deficiencies of American Patent Law,” The American Economic Review, Volume 30, September 1940, pp. 475-491.
U.S. CONGRESSIONAL TESTIMONY: Senate Committee on Governmental Affairs, examining the economic issues associated with the restructuring of energy industries, June 13, 2001.
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Senate Committee on Commerce, Science and Transportation, on antitrust issues in the airline industry, July 27, 2000. House of Representatives Committee on the Judiciary, on the state of competition in the airline industry, June 14, 2000. Antitrust Subcommittee of the Senate Committee on the Judiciary, on assertedly predatory airline pricing, May 2, 2000. Transportation Subcommittee of the Senate Committee on Commerce, Science and Transportation on predatory pricing in the airline industry, May 5, 1998. Aviation Subcommittee of the Senate Committee on Commerce, Science, and Transportation on predatory pricing in the airline industry, April 23, 1998. Subcommittee on Railroads of the House Committee on Transportation and Infrastructure, Public Hearing on Surface Transportation Board Reauthorization: State of the Railroad Industry, April 22, 1998. Aviation Subcommittee of the House Committee on Public Works and Transportation on international aviation policy, May 9, 1991. Subcommittee on Aviation of the Senate Committee on Commerce, Science and Transportation on airline concentration at hub airports, September 22, 1988. Subcommittee on Aviation of the Senate Committee on Commerce, Science and Transportation on airline safety and re-regulation, November 4, 1987. Subcommittee on Telecommunications and Finance, House Committee on Energy and Commerce, on competition and deregulation of the telecommunications industry, July 15, 1987. Subcommittee on Antitrust and Monopoly of the Senate Committee on the Judiciary, on competitive issues in the airline industry, March 25, 1987. Subcommittee on Monopolies and Commercial Law, Committee on the Judiciary, U.S. House of Representatives, on the Administration’s proposed amendments to Section 7 of the Clayton Act, February 26, 1986. Subcommittee on Aviation of the Senate Committee on Commerce, Science and Transportation on Computerized Reservation Systems, March 19, 1985. Joint Economic Committee, United States Senate, Hearing on the Economic Issues of a Changing Telecommunications Industry, October 3, 1983. House Subcommittee on Aviation on “Competitive Problems Raised by Computerized Reservation Systems,” June 22, 1983. House Committee on the Judiciary, on H.R. 1878, “The Shipping Act of 1983,” May 19, 1983. House Committee on Public Works and Transportation on “Coal Slurry Pipelines,” April 13, 1983. House Committee on the Judiciary, on H.J. Res. 350, A Plan to Balance the Federal Budget, August 4, 1982. Senate Committee on the Judiciary, on S. 1215, the Malt Beverage Competition Act, June 21, 1982.
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Subcommittee on Investigations and Oversight, House Committee on Public Works and Transportation, “Development, Operation and Implementation of the United States International Aviation Policy,” December 9, 1981. Joint Economic Committee, U.S. Congress on “Trucking Regulation,” November 17, 1981. Subcommittee on Monopolies and Commercial Law, House Committee on the Judiciary, “Mergers,” August 26, 1981. Senate Committee on Commerce, Science and Transportation, on S. 898, “The Telecommunications Act of 1981,” June 11, 1981. Subcommittee on Telecommunications, Consumer Protection, and Finance, House Committee on Energy and Commerce, “Telecommunications Regulation,” May 20, 1981. Subcommittee on Health, Senate Committee on Finance, on “The Health Incentives Reform Act,” March 19, 1980. House Budget Committee Inflation Task Force, on the “Treatment of Housing Costs in the Consumer Price Index,” January 24, 1980. Senate Committee on Banking, Housing, and Urban Affairs, on “The Chrysler Loan Guarantee Act,” November 15, 1979. Subcommittee on Surface Transportation, House Committee on Public Works and Transportation, on “Trucking Deregulation,” October 4, 1979. Senate Committee on Commerce, Science, and Transportation, on “Trucking Deregulation,” June 26, 1979. Subcommittee on the Legislative Process, House Rules Committee, on “Sunset Legislation,” May 23, 1979. Testimony on food prices and inflation, before: a) House Subcommittee on Domestic Marketing, Consumer Relations and Nutrition; and Subcommittee on Department Investigations, Oversight and Research, Committee on Agriculture, April 4, 1979. b) Subcommittee on Antitrust and Monopoly, Senate Committee on the Judiciary, April 6, 1979. Testimony on hospital cost containment legislation, before: a) Subcommittee on Health and the Environment, House Interstate and Foreign Commerce Committee; and Subcommittee on Health, House Ways and Means Committee, March 12, 1979. b) Health Subcommittee, Senate Finance Committee, March 13, 1979. Subcommittee on Environmental Pollution, Senate Committee on Environment and Public Works, on “Environmental Regulation and Inflation,” February 27, 1979. Testimony on authorization and appropriations for the Council on Wage and Price Stability, before: a) Subcommittee on Economic Stabilization, House Committee on Banking, Finance and Urban Affairs, February 6, 1979.
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b) Senate Subcommittee on Commerce, Consumer and Monetary Affairs, February 7, 1979. c) Senate Committee on Banking, Housing and Urban Affairs, February 9, 1979. d) Subcommittee on Treasury, Postal Service, and General Government, House Committee on Appropriations, May 24, 1979. e) House Appropriations Committee, February 6, 1980. f) Senate Committee on Banking, Housing, and Urban Affairs, March 17, 1980. g) Subcommittee on Treasury, Postal Service, and General Government, House Committee on Appropriations, March 31, 1980. h) Senate Committee on Banking, Housing and Urban Affairs, April 21, 1980. i) Subcommittee on Treasury, Postal Service, and General Government, Senate Committee on Appropriations, April 23, 1980. j) Subcommittee on Economic Stabilization, House Banking Committee, May 6, 1980. House Committee on Ways and Means, on “Real Wage Insurance,” January 30, 1979. Testimony on the President’s anti-inflation program, before: a) Subcommittee on Economic Stabilization, House Committee on Banking, Currency, and Housing. November 22, 1978. b) Subcommittee on Economic Growth and Stabilization, Joint Economic Committee, December 6, 1978. c) House Committee on the Budget, January 30, 1979. d) Subcommittee on Treasury, Postal Services, and General Government, House Committee on Appropriations, February 14, 1979. e) Senate Budget Committee, March 7, 1979. f) Subcommittee on Commerce, Consumer and Monetary Affairs, House Committee on Government Operations, June 28, 1979. g) Economic Stabilization Subcommittee, House Committee on Banking, Finance and Urban Affairs, October 10, 1979. h) Economic Stabilization Subcommittee, Senate Committee on Banking, Housing and Urban Affairs, October 11, 1979. Subcommittee on Aviation, Senate Commerce, Science, and Transportation Committee, on S. 3363, “The International Air Transportation Competition Act of 1978,” August 23, 1978. National Commission for the Review of Antitrust Laws and Procedures, on “Economic Regulation and Antitrust Exemptions and Immunities,” July 26, 1978. Senate Commerce Committee, on S. 3064, “Airline Noise Legislation,” June 14, 1978. Testimony on CAB appropriations, before: a) House Subcommittee on Appropriations, February 28, 1978.
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b) Senate Subcommittee on Appropriations, March 2, 1978. Testimony on United States international aviation negotiations, before: a) Subcommittee on Aviation, House Committee on Public Works and Transportation, September 29, 1977 b) Aviation Subcommittee, House Public Works and Transportation Committee, on H.R. 11145, March 6, 1978. House Budget Committee Task Force on Tax Expenditures, Government Organization, and Regulation, on “Airline Regulation,” July 14, 1977. Senate Antitrust and Monopoly Subcommittee, Oversight Hearings on Antitrust Enforcement, on “Enforcement of the Antitrust Laws,” May 4, 1977. Subcommittee on Investigations and Review, House Committee on Public Works and Transportation, on “The Effects of the Clean Water Act on the Electric Utility Industry,” April 19, 1977. Subcommittee on Communications, Senate Committee on Commerce, on “The Communications Act of 1934 Revisited,” March 21, 1977. Subcommittee on Communications, House Committee on Interstate and Foreign Commerce, on “The Consumer Communications Reform Act of 1976,” H.R. 12323, September 30, 1976. Subcommittee on Energy and Power, House Committee on Interstate and Foreign Commerce, on H.R. 12461, the Dingell-Moss Bill, to Prescribe Certain Rules for Federal, State and Local Agencies Regulating Electric Rates, April 7, 1976. House Subcommittee on Communications, on “Domestic Common Carrier Regulation,” November 18, 1975. Senate Committee on Finance, on H.R. 6860, “The Energy Conservation and Conversion Act of 1975,” July 18, 1975. Subcommittee on Administrative Practice and Procedure, Senate Judiciary Committee, on “Regulation of the Airlines Industry,” February 6, 1975. Senate Committee on Interior and Insular Affairs, on “Financial Problems of the Electric Utility Industry,” August 8, 1974. Joint Economic Committee, U.S. Congress on “Market Power in Relation to Economic Growth,” August 1962. Senate Subcommittee on Patents, on natural rubber cartels, May 23, 1942.
TESTIMONY BEFORE THE FEDERAL POWER COMMISSION, 1958-62 In the matters of: Area Rate Proceeding (Southern Louisiana Area), Docket Nos. AR61-2, et al. Area Rate Proceeding (Permian Basin Area), Docket Nos. AR61-1, et al. Omnibus, Docket Nos. G-9277, et al.
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Atlantic Refining Company (Catco), Docket Nos. G-11024, et al. Sohio Petroleum Company, et al., Docket Nos. G-8488, et al. Gulf Oil Corporation, Docket Nos. G-9520, et al. Amerada Petroleum Corporation, et al., Docket Nos. G-9385, et al. Union Producing Company, Docket Nos. G-18354, et al. Phillips Petroleum Company, Docket Nos. G-1148, et al. Tidewater Oil Company, Docket Nos. G-13310, et al.
MISCELLANEOUS TESTIMONY: Statement on behalf of Auckland International Airport Ltd on the treatment of land held for future construction of an additional runway in the pricing of its aviation services, in response to the New Zealand Commerce Commission’s draft report, Price Control Study of Airfield Activities at Auckland, Wellington and Christchurch International Airports. Statement submitted August 10, 2001. Testimony before the New York Public Servic e Commission on behalf of Verizon New York Inc., in the Proceeding on Motion of the Commission to Consider Cost Recovery by Verizon and to Investigate the Future Regulatory Framework (Case 00-C-1945), May 15, 2001. Statement of opinion before the New York Public Service Commission on the petition by Telergy Metro, LLC asking the Commission to rescind the license that it issued to Con Edison’s sibling corporation to construct or install fiber optic telecommunications facilities, making use of portions of Con Edison’s transmission and distribution facilities for that purpose, on behalf of Con Edison, April 5, 2001. Submission to the Australian Competition and Consumer Commission on behalf of the Sydney Airports Corporation on land valuation and “single -till” issues raised by its application in December 2000 for a revision in charges for aeronautical services. Paper submitted January 18, 2001. Declaration before the Federal Energy Regulatory Commission reviewing the Oil Pipeline Pricing Index, in response to the Commission’s Notice of Inquiry, on behalf of the Association of Oil Pipe Lines (18 CFR Part 342, Docket No. RM00-11-000), filed August 31, 2000; Rebuttal, October 2, 2000. Public Interest Affidavit before the Federal Communications Commission in the matter of Application of SBC Communications Inc., Nevada Bell Telephone Company, and Southwestern Bell Communications Services, Inc. d/b/a Nevada Bell Long Distance, for Provision of In-Region InterLATA Services in Nevada (with Timothy J. Tardiff), filed July 24, 2000. Testimony before the Delaware Public Service Commission on behalf of Delmarva Power & Light Company, Concerning the Cost Accounting Manual and the Code of Conduct, PSC Docket No. 99-582, November 1999; Rebuttal Testimony, March 29, 2000. Testimony before the Department of Transportation in support of the application of American Airlines to be designated as an authorized carrier between the United States and China under the bilateral agreement between the two countries, OST-99-6323, February 23, 2000. Brief of Evidence in the High Court of New Zealand in support of the claim of Telstra New Zealand that Telecom New Zealand has employed its dominant position in the customer access and local services
-19- Alfred E. Kahn markets to prevent or deter competition with it in a number of markets, in violation of Section 36 of the Commerce Act of 1986, CL No. 16/99, filed February 16, 2000. Public Interest Affidavit before the Federal Communications Commission in the matter of Application of SBC Communications, Inc., Southwestern Bell Telephone Company, and Southwestern Bell Communications Services, Inc., d/b/a Southwestern Bell Long Distance for Provision of In-Region, InterLATA Services in Texas, on behalf of Southwestern Bell Telephone Company (with Timothy J. Tardiff), filed January 10, 2000. Comments before the New York Public Service Commission, on behalf of Consolidated Edison Company of New York, on its request for approval of an agreement granting its affiliate Consolidated Edison Communications, Inc. (CECI), non-exclusive access to its facilities for the purposes of constructing, installing, and operating certain telecommunications facilities, Case 99-M-0811, September 10, 1999. “Relaxed Regulation of High Capacity Services in Phoenix and Seattle: The Time is Now,” before the Federal Communications Commission on behalf of U S West Communications (with Timothy J. Tardiff), July 23, 1999. Declaration before the Federal Communications Commission in response to Second Further Notice of Proposed Rulemaking in the matter of Implementation of the Local Competition Provisions in the Telecommunications Act of 1996, on behalf of GTE-Bell Atlantic, CC Docket No. 96-98, filed May 26, 1999; Reply Declaration filed June 10, 1999. “New Jersey Affiliate Relations Standards,” on codes of conduct, before the New Jersey Board of Public Utilities on behalf of Public Service Electric & Gas of New Jersey, May 4, 1999. Rebuttal Testimony before the Public Service Commission of Maryland, defending a regulated electric distribution company’s ability to offer a regulated retail electric generation service and of an unregulated affiliate offering competitive services and the sufficiency of the Maryland Code of Conduct to prevent distortions of competition and cross-subsidization; and defending Baltimore Gas and Electric’s proposed shopping credit, on behalf of Baltimore Gas and Electric Company, Case Nos. 8794/8804, March 22, 1999. “High Capacity Competition in Seattle: Reply to Comments of Intervening Parties,” before the Federal Communications Commission on behalf of U S West Communications (with Timothy J. Tardiff), March 10, 1999. Testimony before the Public Service Commission of the State of Missouri in the matter of application of SBC Communications, Inc., Southwestern Bell Telephone Company, and Southwestern Bell Communications Services, Inc., d/b/a Southwestern Bell Long Distance for Provision of In-Region, InterLATA Services in Missouri, on behalf of Southwestern Bell Telephone Company (with Timothy J. Tardiff), Docket No. TO 99-227, filed November 20, 1998; Surrebuttal Affidavit, February 1, 1999. Rebuttal Testimony before The Commonwealth of Massachusetts Department of Telecommunications and Energy on public policy considerations and principles re the Boston Edison Company/RCN joint venture (DPU 93-37), on behalf of Boston Edison Company, DTE 97-95, February 12, 1999. “Comments on Exclusionary Airline Pricing,” Submission to the Department of Transportation, September 25, 1998. “Economic Evaluation of High Capacity Competition in Phoenix,” on behalf of U S West Communications, requesting that the FCC forebear from regulating it as a dominant carrier in its sale of
-20- Alfred E. Kahn high capacity services in the Phoenix metropolitan area (with Timothy J. Tardiff), August 14, 1998 (filed August 19, 1998). Declaration before the Federal Communications Commission in the matter of Implementation of the Pay Telephone Reclassification and Compensation Provisions of the Telecommunications Act of 1996 (CC Docket No. 96-128), on behalf of the RBOC/GTE/SNET Payphone Coalition, July 13, 1998. Testimony before the Public Service Commission of Maryland evaluating the restructuring plan proposed by Baltimore Gas & Electric Company (Case No. 8794), on behalf of Baltimore Gas & Electric Company, July 1, 1998. Statement before the Public Utility Commission of Texas regarding the Proposed Rulemaking on Code of Conduct for Electric Utilities and Their Affiliates, on behalf of Texas Utilities, June 19, 1998. Affidavit Before the Federal Communications Commission in the matter of Applic ation of SBC Communications Inc., Southwestern Bell Telephone Company, and Southwestern Bell Communications Services, Inc. d/b/a Southwestern Bell Long Distance for Provision of In-Region, InterLATA Services in Arkansas (with Timothy J. Tardiff), February 24, 1998; Rebuttal Affidavit, June 12, 1998. Comments on the Pennsylvania Public Utility Commission Proposed Rulemaking Regarding the Establishment of Competitive Safeguards for the Pennsylvania Electric Industry, on behalf of the Pennsylvania Electric Association, June 9, 1998. Testimony Before the State Corporation Commission of the State of Kansas in the matter of Southwestern Bell Telephone Company – Kansas’ Compliance With Section 271 of the Federal Telecommunications Act of 1996, Docket No. 97-SWBT-411-GIT (with Timothy J. Tardiff), February 17, 1998; Rebuttal Testimony, May 27, 1998. Rebuttal Affidavit Before the Public Utilities Commission of the State of California in support of Pacific Bell’s Draft Application for Authority to Provide InterLATA Services in California (with Timothy J. Tardiff), May 20, 1998. Rebuttal Testimony Before the Oklahoma Public Service Commission, in support of the Applications of SBC Communications, Inc., Southwestern Bell Telephone Company, and Southwestern Bell Communications Services, Inc., for Provision of In-Region InterLATA Services in Oklahoma, Cause No. PUD 970000560 (with Timothy J. Tardiff), April 21, 1998. Testimony Before the State of New Jersey Board of Public Utilities, in the matter of Energy Master Plan Phase II Proceeding to Investigate the Future Structure of the Electric Power Industry, Docket Nos. EX94120585Y and EO97070463, regarding restructuring basic generation service, on behalf of Public Service Electric and Gas Company, April 16, 1998. Affidavit before the Federal Communications Commission in the matter of Application of SBC Communications Inc., Southwestern Bell Telephone Company and Southwestern Bell Communications Services, Inc. d/b/a Southwestern Bell Long Distance for Provision of In-Region InterLATA Services in Texas (with Timothy J. Tardiff), March 2, 1998; Reply Affidavit April 17, 1998. Affidavit Before the Federal Communications Commission in the matter of Application of SBC Communications Inc., Pacific Bell, and Pacific Bell Communications for Provision of In-Region InterLATA Services in California (with Timothy J. Tardiff), March 31, 1998. Affidavit Before the Illinois Commerce Commission in the matter of Implementation of Section 16-121 of the Public Utilities Act, No. 98-0035, on behalf of Ameren Services, February 17, 1998; Rebuttal Affidavit, March 12, 1998.
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Affidavit Before the Federal Communications Commission in the matter of Application of SBC Communications Inc., Southwestern Bell Telephone Company, and Southwestern Bell Communications Services, Inc. d/b/a Southwestern Bell Long Distance for Provision of In-Region, InterLATA Services in Oklahoma (with Timothy J. Tardiff), February 13, 1998. Testimony Before the Massachusetts Department of Public Utilities on public policy considerations and principles re the Boston Edison Company/RCN joint venture (DPU 93-37), December 29, 1997. Testimony Before the Massachusetts Department of Public Utilities on the Standards of Conduct for Distribution Companies and Their Affiliated Companies, on behalf of Boston Edison Company (DPU 97- 96), November 21, 1997. Statement Before the California Public Utilities Commission on Order Instituting Investigation to Establish Standards of Conduct Governing Relationships between Energy Utilities and Their Affiliates, on behalf of Edison Electric Institute (Docket No. I.97-04-012), November 17, 1997. Rebuttal Testimony Before the Delaware Public Service Commission Concerning the Cost Accounting Manual and the Code of Conduct, on behalf of Delmarva Power & Light Company. Docket No. 97-65, October 20, 1997. Verified Statement Before the Surface Transportation Board on the need for shipper protections created by the acquisition of Conrail by the Norfolk & Southern and CSX Railroads, on behalf of electric utility shippers of coal (with Frederick C. Dunbar). Finance Docket No. 33388, October 20, 1997. Testimony Before the Public Utility Commission of the State of Texas evaluating AT&T’s proposed rates for unbundled network elements, on behalf of Southwestern Bell Telephone Company. Docket Nos. 16189, et al, September 15, 1997. Affidavit Before the Public Service Commission of the State of Missouri In the Matter of AT&T Communications of the Southwest, Inc.’s Petition for Arbitration pursuant to Section 252(b) of the Telecommunications Act of 1996 to Establish an Interconnection Agreement with Southwestern Bell Telephone Company, Case No. TO-97-40, on behalf of Southwestern Bell, August 20, 1997. Rebuttal Testimony Before the Pennsylvania Public Utility Commission on the merits of stranded cost recovery, the estimation of stranded costs and competitive safeguards, on behalf of Pennsylvania Power & Light Company, Docket No. R-00973954, August 4, 1997. Affidavit Before the Federal Communications Commission In the matter of Application of SBC Communications, Inc., Southwestern Bell Telephone Company, and Southwestern Bell Communications Services, Inc., for Provisions of In-Region, InterLATA Services in Oklahoma, CC Docket 97-121 (with Timothy J. Tardiff), on behalf of Southwestern Bell, February 13, 1997 (Filed April 7, 1997); Reply Affidavit, May 28, 1997. Affidavit Before the Federal Communications Commission In the matter of Application of SBC Communications, Inc., Southwestern Bell Telephone Company, and Southwestern Bell Communications Services, Inc., for Provision of In-Region, InterLATA Services in Kansas, CC Docket 97-121 (with Timothy J. Tardiff), on behalf of Southwestern Bell, April, 1997. Statement in Support of The Southern New England Telephone Company’s Proposed Reorganization, on behalf of SNET, March 24, 1997. Statement of Professor Alfred E. Kahn and Report of Professor Jerome E. Hass on Railroad Revenue Adequacy Standards, analyzing the methods by which the Surface Transportation Board determines
-22- Alfred E. Kahn whether individual railroads are or are not “revenue adequate,” on behalf of the Alliance for Rail Competition, February 1997. Statement of Alfred E. Kahn on FCC’s Proposed Reforms of Carrier Access Charges (re proposed Order in CC Docket No. 96-488), on behalf of the United States Telephone Association, February 14, 1997. Verified Statement Before the Surface Transportation Board on behalf of the National Industrial Transportation League and the Western Coal Traffic League commenting on the joint statement submitted by the Association of American Railroads, Docket No. 41626, Docket No. 41242, Docket No. 41295, November 27, 1996. “Joint Marketing, Personnel Separation and Efficient Competition Under the Telecommunications Act of 1996” (with Timothy J. Tardiff), a statement on behalf of U S West commenting on the FCC’s NPRM of July 17th, in CC Docket No. 96-149, October 11, 1996. “Economic Competition in Local Exchange Markets” (with Kenneth Gordon and William E. Taylor), on behalf of Bell Atlantic Company, commenting on a statement by seven economists on the pricing of essential network elements submitted by AT&T in state arbitration proceedings, August 9, 1996. Declaration Before the Federal Communications Commission In the Matter of Allocation of Costs Associated with Local Exchange Carrier Provision of Video Programming Services, CC Docket No. 96- 112, July 19, 1996. Testimony before the Kansas Corporation Commission commenting on the continuing regulation and deregulation of the telecommunications industry in Kansas with reference to Competition docket HB 2728, on behalf of Southwestern Bell, Docket No. 190,492-U, June 14, 1996. Declaration before the Federal Communications Commission In the Matter of Implementation of the Local Competition Provisions in the Telecommunic ations Act of 1996, on behalf of Bell Atlantic (with Timothy J. Tardiff), CC Docket No. 96-98, May 30, 1996. Testimony before the Public Service Commission of Maryland In Support of the Petition of Bell Atlantic - Maryland, Inc. for Adoption of a Price Cap Form of Alternative Regulation, on behalf of Bell Atlantic - Maryland, February 15, 1996; Rebuttal March 14, 1996; Surrebuttal April 1, 1996. Testimony before the Public Service Commission of Pennsylvania regarding the Formal Investigation to Examine and Establish Updated Universal Service Principles and Policies for Telecommunications Services, Docket No. I-940035, on behalf of Bell Atlantic - Pennsylvania, Inc., December 7, 1995; Rebuttal, February 14, 1996. Affidavit before the Public Service Commission of Maryland In the Matter of the Petition of Bell Atlantic -Maryland, Inc. for Adoption of an Alternative Form of Regulation pursuant to Amended Public Service Commission Law, Article 78, Section 69(E), on behalf of Bell Atlantic -Maryland, December 21, 1995. Rebuttal Testimony before the State of Connecticut Department of Public Utility Control, discussing network unbundling, universal service and apportioning loop costs between telephone and video services, on behalf of the Southern New England Telephone Company, Docket No. 95-06-17, September 20, 1995. Affidavit In the United States District Court for the Eastern District of Virginia (Alexandria Division) in the matter of United States Telephone Association, et al v. Federal Communications Commission, Civil Action No. 95-533-A, on behalf of USTA (with William E. Taylor), October 24, 1995.
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“Preserving Universality of Subscription to Telephone Service in an Increasingly Competitive Industry” (with Timothy J. Tardiff), before the Public Utilities Commission of the State of California, on behalf of Pacific Bell, September 1, 1995. Rebuttal Testimony before the Commonwealth of Massachusetts Department of Public Utilities, Docket 94-185, discussing network unbundling and universality of service, on behalf of NYNEX, August 23, 1995. “Alternative Regulation for Connecticut Telecommunications Services,” before the Connecticut Department of Public Utility Control, discussing the economic principles that should guide the introduction of an alternative form of regulation for noncompetitive telecommunications services, on behalf of the Southern New England Telephone Company, Docket No. 95-03-01, June 15, 1995. Rebuttal Testimony before the New Jersey Board of Regulatory Commissioners, in the matter of the Investigation Regarding IntraLATA Toll Service Competition on a Presubscription Basis, Docket No. TX94090388, on behalf of Bell Atlantic - New Jersey, Inc., May 31, 1995. Testimony before the Connecticut Department of Public Utility Control on strandable investments, on behalf of United Illuminating, Docket 94-12-13, March 24, 1995. “Rebuttal Evidence on Rate-base Splitting, Price Caps and the Treatment of Economies of Scope in Telecommunications Regulation,” submission to Canadian Radio/television and Telecommunications Commission, Ottawa, Ontario, Canada, on behalf of AGT Limited, March 30, 1995. “Preconditions of Efficiently Competitive Local Exchange Markets,” submission to Canadian Radio/television and Telecommunications Commission, Ottawa, Ontario, Canada, on behalf of AGT Limited, March 15, 1995. Testimony before the Connecticut Department of Public Utility Control, Docket Nos. 94-10-01-02, on incremental cost standards for network unbundling, on behalf of the Southern New England Telephone Company, January 10, 1995; Rebuttal Testimony, February 13, 1995. “Comments on Competition in Electric Power,” submission to Rhode Island Division of Public Utilities and Carriers, inquiry into retail competition in the electric utility industry, on behalf of The Narragansett Electric Company, Docket D-94-9, November 18, 1994. Testimony before the State of New York Public Service Commission in the Petition of Rochester Telephone Corporation for Approval of Proposed Restructuring Plan (Panel on Public Policy Issues with Robert W. Crandall), Case Nos. 93-C-0033 and 93-C-0103, February 3, 1993; Testimony of Panel on Public Policy Issues in Support of Settlement, June 17, 1994; Rebuttal Testimony of Panel on Public Policy Issues, July 22, 1994. Affidavit before the Federal Communications Commission In the Matter of Price Cap Performance Review for Local Exchange Carriers, Notice of Proposed Rulemaking, on behalf of Bell Atlantic, filed June 29, 1994. Affidavit before the U.S. District Court for the Northern District of Alabama Southern Division on behalf of BellSouth Corporation on overturning the statutory prohibition of telephone companies carrying their own video programming, filed June 3, 1994. Reply Affidavit before the U.S. District Court for the District of Michigan (Eastern Division) on behalf of Ameritech Corporation on overturning the statutory prohibition of telephone companies carrying their own video programming, filed May 16, 1994.
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Affidavit before the U.S. District Court for the District of Columbia on behalf of Southwestern Bell in support of request for out-of-region waiver from the interLATA MFJ restrictions (with William E. Taylor), filed May 12, 1994. Reply Affidavit before the U.S. District Court for the District of Maine on behalf of NYNEX Corporation on overturning the statutory prohibition of telephone companies carrying their own video programming, filed May 6, 1994. Testimony on behalf of Bell Atlantic -New Jersey in proceeding involving the issue of opening the intraLATA toll market to competition, filed April 7, 1994; Rebuttal Testimony filed April 25, 1994. Testimony on behalf of Massachusetts Electric Company before the Federal Energy Commission on wholesale wheeling and the problem of stranded investment. FERC Docket No. ER94-129-000, filed March 14, 1994. Testimony on behalf of The Chesapeake and Potomac Telephone Company of Maryland, Case No. 8584, on the regulatory principles applicable to determining an efficient price for MFS-I’s interconnection with C&P’s network (with William E. Taylor), filed November 19, 1993; Rebuttal Testimony filed January 10, 1994; Surrebuttal Testimony filed January 24, 1994. Affidavit to the Federal Communications Commission with respect to Interstate Long Distance Competition and AT&T’s Motion for Reclassification as a Nondominant Carrier (with William E. Taylor), filed November 12, 1993. Affidavit to the High Court of New Zealand on behalf of New Zealand Rail Limited involving wharfage charges by Port Marlborough, September 27, 1993. Testimony before the Federal Energy Regulatory Commission On Behalf of a Group of Independent Refiner/Shippers on the proposed Revision to Oil Pipeline Regulations under the Energy Policy Act of 1992, Docket No. RM93-11-000, August 12, 1993. Affidavit to the High Court of New Zealand on behalf of Air New Zealand, Ltd., and others in a proceeding involving landing charges by Wellington International Airport, Ltd., June 25, 1993. Second Affidavit, August 19, 1993. Affidavit before the U.S. District Court for the Eastern District of Virginia in the matter of The Chesapeake and Potomac Telephone Company of Virginia v. United States of America, Civil Action No. 92-1751-A, June 5, 1993 and before the Federal Communications Commission In the Matter of Amendments of Parts 32, 36, 61, 64 and 69 of the Commission’s Rules to Establish and Implement Regulatory Procedures for Video Dial Tone Service, Petition for Rulemaking RM 8221, June 7, 1993. Testimony before Denver County District Court, Denver, Colorado, on behalf of Metropolitan Denver Water Authority re City of Denver water rates, May 17, 1993. “Review of Regulatory Framework: Telecom Public Notice CRTC 92-78,” on behalf of AGT (Alberta Government Telephone Company), Alberta Canada, April 13, 1993. “Major Elements of a Competitive Telecommunications Policy,” on behalf of AGT (Alberta Government Telephone Company), Alberta, Canada, February 15, 1993 Testimony on behalf of the Municipal Electric Association evaluating the soundness of Ontario Hydro’s Demand Side Management program, December 1992.
-25- Alfred E. Kahn
Rebuttal Testimony on behalf of Sithe Independence Power Partners, L.P., in response to the arguments advanced by the New York Power Authority and the County of Westchester in opposition to the proposed transmission line at issue in PSC Cases 92-T-0114 and 92-T-0252, November 1992. Affidavit before the Federal Communications Commission In the Matter of Amendment of the Commission’s Rules to Establish New Personal Communications Services, GEN Docket No. 90-314, ET Docket No. 92-100, November 6, 1992. Testimony on behalf of New Zealand Telecom in an antitrust proceeding before the High Court of New Zealand involving terms of interconnection with Clear, a competitive provider of local transport, April 27, 1992. Testimony on behalf of AMR Corporation and American Airlines, Inc., against UAL Corporation, United Airlines, Inc., UAL Acquisition, Inc., Air Wis Services, Inc., and Air Wisconsin, Inc., 91 CIV. 7773 (KMW), analyzing United Airlines’ acquisition of Air Wisconsin’s 50 O’Hare jet slots, March 2, 1991. Supplemental and Second Supplemental Testimonies, March 10 and 15, 1992. Testimony before the Illinois Commerce Commission on behalf of Illinois Power Company, Docket No. P91-0001, on certification of a competing natural gas pipeline, February 24, 1992. Rebuttal Testimony before the Florida Public Service Commission, Tampa Electric Co. Docket No. 910883EI, on electric utility company responsibilities for demand side management, November 20, 1991. Affidavit before the Federal Communications Commission In the Matter of Expanded Interconnection Between Local Telephone Facilities, CC Docket No. 91-141 ENF-87-14, August 5, 1991. Statement on behalf of United Kingdom of Great Britain and Northern Ireland in US/UK Arbitration Concerning Heathrow Airport User Charges, April 1991. Rebuttal and Surrebuttal Statements, June and July 1991; testimony before the International Court, The Hague, July 1991. “The Treatment of New Services Under Price Cap Regulation,” on behalf of BellSouth, Federal Communications Commission, June 10, 1991. Testimony on behalf of Fireman’s Fund Insurance Company before the Insurance Commissioner of the State of California re proposed action to repeal and adopt regulations concerning property and casualty insurance rates, February 20, 1991. Testimony before the Federal Energy Regulatory Commission on behalf of Conoco, Inc. Kaneb Pipeline Operating Partnership, L.P., and Kerr-McGee Refining Corporation (Williams Pipeline), February 4, 1991. Affidavit to the U.S. District Court for District of Columbia on behalf of Bell Atlantic Corporation in United States of America v. Western Electric Company, Inc. and American Telephone and Telegraph Company, re MFJ restrictions on Bell Operating Companies’ ability to offer information services, January 8, 1991. Oral testimony before the Puerto Rican Legislature on privatization and future regulation of the Puerto Rico Telephone Company, June 20, 1990. Testimony on behalf of Central Telephone Company of Florida before the Public Service Commission, June 12, 1990. Testimony on behalf of Fireman’s Fund Insurance Company on Proposition 103 Rate Regulation Hearings, February 5, 1990.
-26- Alfred E. Kahn
Testimony before Denver County District Court, Denver, Colorado, on behalf of Southgate Water District vs. Denver Water Authority on conduit extension charges, May 25, 1989. “Efficient Pricing of Congested Airport Facilities,” A Report to the Department of Transport, Great Britain, April 1989. Testimony on behalf of ETSI Pipeline Project v. Burlington Northern Inc., et al, in the United States District Court for the Eastern District of Texas, Beaumont Division, Civil Action No. B-84-979-CA, February 23, 1989. Reply Verified Statement on behalf of Concerned Shippers, In the Matter of Railroad Cost Recovery Procedures—Productivity Adjustment; Ex Parte No. 290 (Sub-No. 4), January 17, 1989. Testimony on behalf of California Coalition for Trucking Deregulation before the Public Utilities Commission of the State of California, In the Matter of the Regulation of General Freight Transportation by Truck, Case No. I-88-08-046, October 27, 1988. Testimony before the Public Service Commission of the State of New York on the application to construct the Empire State gas pipeline, Case No. 88-T-132, October 1988. Testimony before the Federal Communications Commission on behalf of Bell South on adjustment factor for local exchange companies under rate cap regulation, In the Matter of Policy and Rules Concerning Rates for Dominant Carriers (CC Docket 87-313), July 1988. Affidavit on behalf of Massachusetts Port Authority in a proceeding on the proposed structure of landing fees for Logan Airport, Boston, U.S. District Court, District of Massachusetts, June 1988. Affidavit on behalf of Financial Interchange Inc. in an antitrust arbitration proceeding on the legality of jointly set interchange fees of an electronic funds transfer network, April 1988. Verified Statement before the Interstate Commerce Commission in Coal Trading Corporation, et al. v. Baltimore & Ohio Railroad Company, et al. (Docket No. 38301S) on the computation of rail stand-alone costs, April 1988. Testimony on behalf of Public Service Electric & Gas Company, New Jersey on the used and useful doctrine in the context of utility performance standards, April 1988. Testimony on behalf of the U.S. Postal Service on the pricing of Express Mail, March 28, 1988. Testimony on behalf of Kentucky Industrial Utility Customers Case No. 9934 on the criteria for deciding whether a nuclear plant should be completed, February 8, 1988. Testimony and Rebuttal Testimony before the Iowa State Utilities Board Department of Commerce on behalf of Northwestern Bell on the regulatory treatment of depreciation reserve deficiencies, October 1987 and November 1987. Testimony before the State of Connecticut Department of Public Utility Control on behalf of the Connecticut Cable Television Association on regulating cable television rates, November 13, 1987. Testimony before the Federal Communications Commission on behalf of Bell South In the Matter of Policy and Rules Concerning Rates for Dominant Carriers (CC Docket 87-313) October 1987 and Reply Testimony, November 1987.
-27- Alfred E. Kahn
Reply Verified Statement before the Interstate Commerce Commission on behalf of McCarty Farms et. al. and Montana Department of Commerce, on the stand-alone cost constraint on railroad rates to captive shippers, October 2, 1987. Testimony before the New York State Public Service Commission on behalf of New York Telephone Company on assessing the competitiveness of telecommunications markets, April 1987. Testimony before the New Jersey Senate Energy and Environment Committee on behalf of Public Service Electric and Gas Company on draft bill, No. 2801, the “Electricity Market Pricing Act of 1986,” January 26, 1987. Testimony before Federal Energy Regulatory Commission on behalf of Interstate Natural Gas Association of America on “Competitive Implications of Natural Gas Pipeline Marketing Affiliates,” December 29, 1986. Testimony before the New York State Public Service Commission on behalf of the Owners Committee on Electric Rates, Inc., on rent-inclusion and submetering, November 19, 1986. Testimony before the Illinois Commerce Commission on behalf of Commonwealth Edison Company on standard for deciding whether Braidwood Unit 2 should be cancelled, August 4, 1986. Verified Statement on Standards for Railroad Revenue Adequacy, on Interstate Commerce Commission’s Ex Parte No. 393, Sub-No.1, July 1986. Supplemental Verified Statement before the Interstate Commerce Commission, Docket No. 38783, Omaha Public Power District v. Burlington Northern Railroad Company on behalf of Omaha Public Power District, April 1986. Statement to Federal Communications Commission on New England Telephone Company’s Proposed Interstate Access Tariff Restructure, January 30, 1986. Testimony before the Public Utilities Commission of the State of Oregon on inverted rate structures on behalf of the Pacific Power & Light company, January 1986. Rebuttal Testimony before the California Public Utilities Commission on San Onofre nuclear plants on behalf of Southern California Edison Company, January 1986 and En Banc Proceeding, February 1986. Testimony and rebuttal testimony before the Arizona Corporation Commission on behalf of Arizona Public Service Company on economic and regulatory principles applicable to entry of nuclear plants into rate base, December 1985, March 1986, December 1986 and March 1987. Testimony before the Corporation Commission of the State of Oklahoma on economic principles applicable to access charges, Cause No. 29321 on behalf of Southwestern Bell Telephone Company, September 1985. Testimony before the California Public Utilities Commission on regulatory principles applicable to prudence determinations on behalf of Southern California Edison Company, August 1985. Testimony before the Corporation Commission of the State of Oklahoma on development of intrastate access charges, Cause No. 28309 on behalf of Southwestern Bell Telephone Company, May 1985. Verified Statement before the Interstate Commerce Commission, Docket No. 38783 on behalf of Omaha Public Power District, on the grouping of captive shippers for purposes of applying a stand-alone cost test of contested rail rates, November 1984.
-28- Alfred E. Kahn
Testimony before the House Public Policy and Veterans Affairs Committee of the Indiana General Assembly on behalf of the Indiana Telephone Association, October 25, 1984. Testimony before the Iowa State Commerce Commission, Docket No. INU-84-6, Investigation into competition in communications services and facilities, October 18, 1984. Testimony and rebuttal testimony on current cash support for construction and the reorientation of regulatory policy before the Maine Public Utilities Commission, in the matter of Central Maine Power Company’s proposed increase in rates, Docket No. 84-120, August 1984 and February 1985. Testimony and rebuttal testimony for Illinois Power Company on rate base treatment of construction work in progress, before Illinois Commerce Commission, Docket No. 84-0480, August 1984 and April 1985. Verified Statement before the Interstate Commerce Commission, Docket No. 39687, on behalf of Platte River Power Authority, on the proper definition of the cost of capital for purposes of applying a stand- alone cost test of contested rail rates, July 1984. Verified Statement and Surrebuttal Verified Statement Before the Interstate Commerce Commission, Finance Docket No. 30300 on behalf of the Water Transport Association, in opposition to the application of CSX Corporation to acquire American Commercial Barge Lines, Inc., February 14, 1984 and April 19, 1984. Direct and rebuttal testimony, Federal Energy Regulatory Commission, Trans Alaska Pipeline System, on behalf of the State of Alaska, Dockets Nos. OR 78-1-014 and OR 78-1-016 (Phase I Remand) November 1, 1983 and December 23, 1983. Verified Statement, Interstate Commerce Commission, on the stand alone test for rail rates to captive shippers, on behalf of Utility Fuels, Inc., Docket No. 39002, October 3, 1983. Testimony on telephone rate structures before the Colorado Public Utilities Commission for Mountain States Telephone & Telegraph Company, May 27, 1983; the California Public Utilities Commission, for Pacific Telephone & Telegraph Company, August 18, 1983; the Missouri Public Service Commission, September 8, 1983; and Texas Public Service Commission, September 19, 1983, for Southwestern Bell Company. Testimony before the Utility Diversification Committee of the Legislature of the State of New Mexico, September 2, 1982. Testimony before the Ad Hoc Committee on Utility Diversification, National Association of Regulatory Utility Commissioners, May 6, 1982. Testimony before Motor Carrier Ratemaking Study Commission, Orlando, Florida, April 2, 1982. Testimony before the State of Connecticut Department of Public Utility Control on methods of regulating rates for basic television cable service, March 9, 1982. Testimony before the Committee of Energy and Public Utilities, The General Assembly of the State of Connecticut on regulation of cable television, March 1, 1982. Testimony before the Public Utilities Commission of the State of California, for Pacific Power & Light Company on methods of allocating aggregate revenue requirements, September 24, 1981. Verified Statement, Interstate Commerce Commission, Ex Parte No. 347 (Sub-No. 1), “Coal Rate Guidelines-Nationwide,” September 1981.
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Testimony for the Department of Justice in the U.S. v. Standard Oil Co. (Indiana) et al. Civil Suit 40212, filed July 28, 1964. (Rev. 08/01)
TIMOTHY J. TARDIFF
BUSINESS ADDRESS
National Economic Research Associates, Inc. One Main Street Cambridge, Massachusetts 02142 (617) 621-0444
Dr. Tardiff received a B.S. with honors in Mathematics from the California Institute of Technology in Pasadena and a Ph.D. degree in Social Science from the University of California, Irvine, under a National Science Foundation Pre-doctoral Fellowship and an NSF Grant for Improving Dissertation Research in the Social Sciences.
Dr. Tardiff joined the faculties of the Department of Civil Engineering and the Division of Environmental Studies at the University of California, Davis. He taught undergraduate and graduate level courses in transportation and environmental policy analysis. His research included applications of econometric models of consumer choice to transportation planning problems. Dr. Tardiff's research was funded by the National Science Foundation, the Institute of Transportation Studies and the California Department of Transportation.
Prior to joining NERA, Dr. Tardiff's work included transportation, energy, public utility and telephone industry projects for the U.S. Departments of Transportation and Energy, the California Energy Commission, and several telephone and electric utilities.
Since joining NERA, he has evaluated pricing policies for increasingly competitive telecommunications markets, including appropriate mechanisms for pricing access services to competitors; studied actual and potential competition for services provided by telephone operating companies; analyzed the demand and revenue impacts of new telephone rate structures; developed and evaluated damage studies used in major telecommunications antitrust actions; analyzed the market potential for cellular radio; evaluated the investment and marketing programs of telephone companies; and developed a demand model for analyzing the market potential for alternative employee health care plans, including health maintenance organizations.
Dr. Tardiff has published extensively in the transportation literature. He has presented and published papers on the telecommunications industry. These papers address the issues of pricing and costing policies for emerging competition in telecommunications markets; evaluating and forecasting the impacts of telephone rate plans such as local measured service; analyzing the markets for new telecommunications products and services; and local competition and the bypass issue.
EDUCATION
UNIVERSITY OF CALIFORNIA, IRVINE Ph.D., Social Sciences, 1974
CALIFORNIA INSTITUTE OF TECHNOLOGY B.S., Mathematics, 1971
EMPLOYMENT
NATIONAL ECONOMIC RESEARCH ASSOCIATES, INC. 1992 Vice President. Works on cases, mainly legal and regulatory, on issues of pricing policy, assessing demand for new and existing products and services, and economic damages. This work involves studies, often involving econometric demand analysis methods, for telecommunications, utilities and other clients. Specific areas have included: assessment of competition in the telecommunications industry; analysis of alternative approaches for regulating telephone utilities; evaluation of the benefits from telecommunication products and services; analyzing the demand for local services, toll, and carrier access; evaluation of the prudence of telephone company investments; damage studies for telecommunications antitrust cases; evaluation of methods for environmental damage assessment; and analysis of energy conservation /programs.
1984-1992 Senior Consultant
CHARLES RIVER ASSOCIATES, INC.--Boston, Massachusetts 1979-1984 Director of Marketing Research. Managed program to apply econometric customer demand models to marketing research problems in telecommunications, electric utilities, transportation and other industries.
Senior Research Associate. Performed studies on urban transportation, freight transportation, energy and telecommunications issues.
UNIVERSITY OF CALIFORNIA, DAVIS--Davis, California 1974-1979 Assistant Professor, Department of Civil Engineering and Division of Environmental Studies. Taught undergraduate and graduate course in transportation and environmental policy and quantitative research methods; conducted research on passenger transportation demand, (including econometric issues).
FELLOWSHIPS, GRANTS, AWARDS
First Place, Dissertation Contest of the Transportation Science Section of the Operations Research Society of America.
NSF Research Initiation Grant (Engineering Division), 1976-1978.
NSF Grant for Improving Doctoral Dissertation Research in the Social Sciences, 1973- 1974.
NSF Predoctoral Fellowship, 1972-1974.
Public Health Service Traineeship, 1971-1972.
AFFILIATIONS
American Economic Association International Telecommunications Society
TESTIMONY
Supplemental Rebuttal Testimony of Timothy J. Tardiff on the application of the Modified Synthesis Model for the costs of unbundled network elements, prepared for filing with the Federal Communications Commission on behalf of Verizon-Virginia, CC Docket Nos. 00-218, 00-249, and 00-251, November 16, 2001.
Declaration of Timothy J. Tardiff on the use of the HAI, Release 5.2a for deriving an unbundled switch cost reduction, prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, October 30, 2001.
Declaration of Timothy J. Tardiff on the use of the HAI, Release 5.2a for deriving an unbundled loop cost reduction, prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, October 19, 2001.
Surrebuttal Testimony of Howard Shelanski and Timothy J. Tardiff on economic principles for determining the costs of unbundled network elements, prepared for filing with the Federal Communications Commission on behalf of Verizon-Virginia, CC Docket Nos. 00-218, 00-249, and 00-251, September 21, 2001.
Rebuttal Testimony of Timothy J. Tardiff on the application of the Modified Synthesis Model for the costs of unbundled network elements, prepared for filing with the Maryland Public Service Commission on behalf of Verizon-Maryland, Case No. 8879, September 5, 2001.
Declaration of Timothy J. Tardiff on the use of the HAI, Release 5.2a and Modified Synthesis Models for unbundled loop and switch costs, prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, September 4, 2001.
Rebuttal Testimony of Timothy J. Tardiff on the application of the Modified Synthesis Model for the costs of unbundled network elements, prepared for filing with the Federal Communications Commission on behalf of Verizon-Virginia, CC Docket Nos. 00-218, 00-249, and 00-251, August 27, 2001.
Affidavit of Timothy J. Tardiff on the use of proxy costs models for unbundled network elements, prepared for filing with the Regulatory Commission of Alaska, on behalf of Alaska Communications Systems, Docket No. U-96-89, July 27, 2001.
Rebuttal Testimony of Timothy J. Tardiff on the application of the Hatfield Model for the costs of unbundled network elements, prepared for filing with the Massachusetts
Department of Telecommunications and Energy on behalf of Verizon-Massachusetts, Docket No. D.T.E. 01-20, July 18, 2001.
Rebuttal Testimony of Timothy J. Tardiff on the application of the Hatfield Model for the costs of unbundled network elements, prepared for filing with the New Jersey Board of Public Utilities on behalf of Verizon-New Jersey, Docket No. TO00060356, October 12, 2000.
Supplemental Rebuttal Testimony of Timothy J. Tardiff on the Hatfield Model of unbundled network elements, prepared for filing with the State of Maine Public Utilities Commission on behalf of Bell Atlantic-Maine, Case No. 97-505, October 10, 2000.
Public Interest Affidavit before the Federal Communications Commission in the matter of Application of SBC Communications Inc. Nevada Bell Telephone Company and Southwestern Bell Communications Services, Inc. d/b/a Nevada Bell Long Distance for Provision of In-Region InterLATA Services in Nevada (with Alfred E. Kahn), July 24, 2000.
Responsive Testimony on the HAI Model of unbundled network elements, prepared for filing with the New York Public Service Commission on behalf of Bell Atlantic-New York, Case 98-C-1357 (filed as part of panel testimony), June 26, 2000.
Affidavit of Timothy J. Tardiff on avoided cost discounts for wholesale services, prepared for filing with the Regulatory Commission of Alaska, on behalf of Alaska Communications Systems, Docket Nos. U-99-141, U-99-142 and U-99-143, April 17, 2000.
Third Affidavit of Timothy J. Tardiff on costs models for unbundled network elements, prepared for filing with the Regulatory Commission of Alaska, on behalf of Alaska Communications Systems, Docket Nos. U-99-141, U-99-142 and U-99-143, March 24, 2000.
Second Affidavit of Timothy J. Tardiff on costs models for unbundled network elements, prepared for filing with the Regulatory Commission of Alaska, on behalf of Alaska Communications Systems, Docket Nos. U-99-141, U-99-142 and U-99-143, February 25, 2000.
Rebuttal Testimony of Timothy J. Tardiff on collocation costs models, prepared for filing with the Delaware Public Service Commission on behalf of Bell Atlantic-Delaware, Docket No. 99-251, February 24, 2000.
Affidavit of Timothy J. Tardiff on costs models for unbundled network elements, prepared for filing with the Regulatory Commission of Alaska, on behalf of Alaska Communications Systems, Docket Nos. U-99-141, U-99-142 and U-99-143, February 11, 2000.
Public Interest Affidavit before the Federal Communications Commission in the matter of Application of SBC Communications Inc. Southwestern Bell Telephone Company and Southwestern Bell Communications Services, Inc. d/b/a Southwestern Bell Long Distance for Provision of In-Region InterLATA Services in Texas (with Alfred E. Kahn), January 10, 2000.
Rebuttal Testimony of Timothy J. Tardiff on collocation costs models, prepared for filing with the Pennsylvania Public Utility Commission on behalf of Bell Atlantic-Pennsylvania, Docket Nos. R-00994697 and R-00994697C0001, December 21, 1999.
“Relaxed Regulation of High Capacity Services in Phoenix and Seattle: The Time is Now,” prepared for filing with the Federal Communications Commission on behalf of US WEST Communications, Petitions of US WEST Communications for Forbearance from Regulation as a Dominant Carrier in the Phoenix and Seattle MSAs (with Alfred E. Kahn), July 21, 1999.
Rebuttal Testimony of Timothy J. Tardiff on the HAI Model of unbundled network elements, prepared for filing with the Pennsylvania Public Utility Commission on behalf of Bell Atlantic-Pennsylvania, Docket Nos. P-00991648 and P-00991649, June 15, 1999.
“High Capacity Competition in Seattle: Reply to Comments of Intervening Parties,” prepared for filing with the Federal Communications Commission on behalf of US WEST Communications, Petition of US WEST Communications for Forbearance from Regulation as a Dominant Carrier in the Seattle, Washington MSA (with Alfred E. Kahn), March 10, 1999.
Rebuttal Testimony of Timothy J. Tardiff on collocation costs models, prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, February 8, 1999.
Surrebuttal Testimony of Alfred E. Kahn and Timothy J. Tardiff, filed with the Missouri Public Service Commission, in support of the Applications of SBC Communications, Inc., Southwestern Bell Telephone Company, and Southwestern Bell Communications Services, Inc., for Provision of In-Region InterLATA Services in Missouri, Docket No. TO 99-227, February 4, 1999.
Rebuttal Testimony of Timothy J. Tardiff on the HAI Model of unbundled network elements, prepared for filing with the Rhode Island Public Utilities Commission on behalf of Bell Atlantic-Rhode Island, Docket No. 2681, January 15, 1999.
Reply Testimony of Timothy J. Tardiff on collocation costs models, prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, January 11, 1999.
“Economic Evaluation of High Capacity Competition in Seattle,” prepared for filing with the Federal Communications Commission on behalf of US WEST Communications, Petition of US WEST Communications for Forbearance from Regulation as a Dominant Carrier in the Seattle, Washington MSA (with Alfred E. Kahn), December 22, 1998.
Testimony of Timothy J. Tardiff on collocation costs models, prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, December 18, 1998.
“Measuring and Recovering the Costs of Long-Term Number Portability: Implications of Price Cap Regulation,” Prepared for Southwestern Bell for presentation to the Federal Communications Commission, December 10, 1998.
Direct Testimony of Alfred E. Kahn and Timothy J. Tardiff, filed with the Missouri Public Service Commission, in support of the Applications of SBC Communications, Inc., Southwestern Bell Telephone Company, and Southwestern Bell Communications Services, Inc., for Provision of In-Region InterLATA Services in Missouri, Docket No. TO 99-227, November 20, 1998.
“High Capacity Competition in Phoenix: Reply to Comments of Intervening Parties,” prepared for filing with the Federal Communications Commission on behalf of US WEST Communications, Petition of US WEST Communications for Forbearance from Regulation as a Dominant Carrier in the Phoenix, Arizona MSA (with Alfred E. Kahn), October 28, 1998.
“Measuring and Recovering the Costs of Long-Term Number Portability,” Prepared for Southwestern Bell for presentation to the Federal Communications Commission, October 28, 1998 (with Alfred E. Kahn).
Declaration of Timothy J. Tardiff on the economic impacts of separate subsidiary requirements for the offer of advanced services by incumbent local exchange carriers, prepared for filing with the Federal Communications Commission on behalf of Bell Atlantic, in the mater of Deployment of Wireline Services Offering Advanced Telecommunications Capability, October 15, 1998.
“An Analysis of the HAI Model Release 5.0a,” Rebuttal Testimony filed with the Florida Public Service Commission, Docket No. 980696-TP, on behalf of GTE Florida, September 2, 1998 (with Gregory M. Duncan, Karyn E. Model, Christian M. Dippon, Jino W. Kim, Francis J. Murphy, Robert P. Cellupica, and Thomas F. Guarino).
“Economic Evaluation of High Capacity Competition in Phoenix,” prepared for filing with the Federal Communications Commission on behalf of US WEST Communications, Petition of US WEST Communications for Forbearance from Regulation as a Dominant Carrier in the Phoenix, Arizona MSA (with Alfred E. Kahn), August 14, 1998.
Rebuttal Testimony of Timothy J. Tardiff on the HAI Model of unbundled network elements, prepared for filing with the New Hampshire Public Utilities Commission on behalf of Bell Atlantic-New Hampshire, Docket No. DE-97-1171, June 22, 1998.
Rebuttal Affidavit before the Arkansas Public Service Commission in the matter of the Application of Southwestern Bell Telephone Company Seeking Verification that It Has Fully Complied with and Satisfied the Requirements of Section 271 (c) of the Telecommunications Act of 1996, June 11, 1998.
Rebuttal Testimony before the State Corporation Commission of the State of Kansas in the matter of Southwestern Bell Telephone Company – Kansas’ Compliance With Section 271 of the Federal Telecommunications Act of 1996, Docket No. 97-SWBT- 411-GIT (with Alfred E. Kahn), May 27, 1998.
Rebuttal Affidavit Before the Public Utilities Commission of the State of California in support of Pacific Bell’s Draft Application for Authority to Provide InterLATA Services in California (with Alfred E. Kahn), May 20, 1998.
“An Analysis of the Hatfield Model Release 4.0,” prepared for filing with the California Public Utilities Commission on behalf of GTE California, May 1, 1998 (with Gregory M. Duncan, Karyn E. Model, Christian M. Dippon, Jino W. Kim, Francis J. Murphy, Robert P. Cellupica, and Thomas F. Guarino).
Reply Testimony of Timothy J. Tardiff on unbundled network element prices and retail service price floors, prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, April 27, 1998.
Rebuttal Testimony of Alfred E. Kahn and Timothy J. Tardiff, filed with the Oklahoma Public Service Commission, in support of the Applications of SBC Communications, Inc., Southwestern Bell Telephone Company, and Southwestern Bell Communications
Services, Inc., for Provision of In-Region InterLATA Services in Oklahoma, Case No. PUD 970000560, April 21, 1998.
Reply Affidavit before the Federal Communications Commission in the matter of Application of SBC Communications Inc. Southwestern Bell Telephone Company and Southwestern Bell Communications Services, Inc. d/b/a Southwestern Bell Long Distance for Provision of In-Region InterLATA Services in Texas (with Alfred E. Kahn), April 17, 1998.
Testimony of Timothy J. Tardiff on unbundled network element prices and retail service price floors, prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, April 8, 1998.
Affidavit before the Federal Communications Commission in the matter of Application of SBC Communications Inc., Pacific Bell, and Pacific Bell Communications for Provision of In-Region InterLATA Services in California (with Alfred E. Kahn), March 31, 1998.
“Economic Principles Governing Measurement of Nonrecurring/OSS Costs: An Analysis of the AT&T/MCI Recommendations,” prepared for filing with the California Public Utilities Commission on behalf of GTE California and Pacific Bell, March 4, 1998 (with Gregory M. Duncan).
“Analysis of the Hatfield Model Release 5.0a,” Rebuttal Testimony filed with the North Carolina Utilities Commission, Docket No. P-100, Sub 133d, on behalf of GTE South, March 2, 1998 (with Gregory M. Duncan, Rafi A. Mohammed, Christian M. Dippon, Aniruddha Banerjee, Karyn E. Model, Francis J. Murphy, Robert P. Cellupica, and Thomas F. Guarino).
“Analysis of the Hatfield Model Release 5.0a,” Rebuttal Testimony filed with the South Carolina Public Service Commission, on behalf of GTE South, March 2, 1998 (with Gregory M. Duncan, Rafi A. Mohammed, Christian M. Dippon, Aniruddha Banerjee, Karyn E. Model, Francis J. Murphy, Robert P. Cellupica, and Thomas F. Guarino).
Affidavit before the Federal Communications Commission in the matter of Application of SBC Communications Inc. Southwestern Bell Telephone Company and Southwestern Bell Communications Services, Inc. d/b/a Southwestern Bell Long Distance for Provision of In-Region InterLATA Services in Texas (with Alfred E. Kahn), March 2, 1998.
“Analysis of the Hatfield Model Release 5.0a,” Rebuttal Testimony filed with the Kentucky Public Service Commission, on behalf of GTE South, February 26, 1998 (with
Gregory M. Duncan, Rafi A. Mohammed, Christian M. Dippon, Aniruddha Banerjee, Karyn E. Model, Francis J. Murphy, Robert P. Cellupica, and Thomas F. Guarino).
Affidavit before the Federal Communications Commission in the matter of Application of SBC Communications Inc. Southwestern Bell Telephone Company and Southwestern Bell Communications Services, Inc. d/b/a Southwestern Bell Long Distance for Provision of In-Region InterLATA Services in Arkansas (with Alfred E. Kahn), February 24, 1998.
Testimony before the State Corporation Commission of the State of Kansas in the matter of Southwestern Bell Telephone Company – Kansas’ Compliance With Section 271 of the Federal Telecommunications Act of 1996, Docket No. 97-SWBT- 411-GIT (with Alfred E. Kahn), February 17, 1998.
“Analysis of the Hatfield Model Release 5.0,” Rebuttal Testimony filed with the Alabama Public Utilities Commission, on behalf of GTE South, February 13, 1998 (with Gregory M. Duncan, Rafi A. Mohammed, Christian M. Dippon, Aniruddha Banerjee, Karyn E. Model, Francis J. Murphy, Robert P. Cellupica, and Thomas F. Guarino).
Affidavit before the Federal Communications Commission in the matter of Application of SBC Communications. Inc. Southwestern Bell Telephone Company and Southwestern Bell Communications Services, Inc. d/b/a/ Southwestern Bell Long Distance for Provision of In-Region InterLATA Services in Oklahoma (with Alfred E. Kahn), February 13, 1998.
“Analysis of the Hatfield Model Release 5.0,” Rebuttal Testimony filed with the North Carolina Utilities Commission, Docket No. P-100, Sub 133b, on behalf of GTE South, January 30, 1998 (with Gregory M. Duncan, Rafi A. Mohammed, Christian M. Dippon, Aniruddha Banerjee, Karyn E. Model, Francis J. Murphy, Robert P. Cellupica, and Thomas F. Guarino).
Supplemental Rebuttal Testimony of Timothy J. Tardiff on switching costs, prepared for filing with the State of Maine Public Utilities Commission on behalf of Bell Atlantic- Maine, Case No. 97-505, December 22, 1997.
“Reply to AT&T Recommendations for Regulatory Treatment of OSS Costs,” prepared for filing with the California Public Utilities Commission on behalf of GTE California and Pacific Bell, December 15, 1997 (with Gregory M. Duncan).
Rebuttal Testimony of Timothy J. Tardiff on the Hatfield Model of unbundled network elements, prepared for filing with the Vermont Public Service Board on behalf of Bell Atlantic-Vermont, Case No. 57-13, November 21, 1997.
Reply Affidavit of Timothy J. Tardiff on the Hatfield Model, filed with the New York Public Service Commission on behalf of Bell Atlantic-New York, Case 94-C-0095 and Case 28425, November 17, 1997.
Rebuttal Testimony of Timothy J. Tardiff on the Hatfield Model of unbundled network elements, prepared for filing with the State of Maine Public Utilities Commission on behalf of Bell Atlantic-Maine, Case No. 97-505, October 21, 1997.
Rebuttal Testimony of Timothy J. Tardiff on the application of the Hatfield Model to universal service funding requirements, prepared for filing with the New Jersey Board of Public Utilities on behalf of Bell Atlantic-New Jersey, Docket No. TX95120631, October 20, 1997.
“Analysis of the Hatfield Model Release 4.0,” filed with the Pennsylvania Public Utility Commission on behalf of GTE North, October 20, 1997 (with Gregory M. Duncan, Rafi A. Mohammed, Christian M. Dippon, Francis J. Murphy, Robert P. Cellupica, and Thomas F. Guarino).
Supplemental Rebuttal Testimony of Timothy J. Tardiff on toll and carrier access demand elasticities and universal service rate rebalancing, prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, October 10, 1997.
Rebuttal Testimony of Timothy J. Tardiff on toll and carrier access demand elasticities and universal service rate rebalancing, prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, September 30, 1997.
Rebuttal Testimony of Timothy J. Tardiff on the Hatfield Model of unbundled network elements, prepared for filing with the State Corporation Commission of Virginia on behalf of Bell Atlantic-Virginia, Case No. PUC970005, June 10, 1997.
Reply Affidavit of Alfred E. Kahn and Timothy J. Tardiff, filed with the Federal Communications Commission, in support of the Applications of SBC Communications, Inc., Southwestern Bell Telephone Company, and Southwestern Bell Communications Services, Inc., for Provision of In-Region InterLATA Services in Oklahoma, May 26, 1997.
Rebuttal Testimony of Timothy J. Tardiff on the Hatfield Model of unbundled network elements, prepared for filing with the District of Columbia Public Service Commission on behalf of Bell Atlantic-DC, Formal Case No. 962, May 2, 1997.
Declaration of Timothy J. Tardiff on OANAD Cost Studies, prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, April 16, 1997.
Rebuttal Testimony of Timothy J. Tardiff on the Hatfield Model of unbundled network elements, prepared for filing with the Maryland Public Service Commission on behalf of Bell Atlantic-Maryland, Case No. 8731-II, April 4, 1997.
“Economic Evaluation of the Hatfield Model, Release 3.1,” filed with the Washington Utilities and Transportation Commission on behalf of GTE, March 28, 1997 (with Gregory M. Duncan and Rafi Mohammed).
“Economic Evaluation of the Hatfield Model, Version 2.2, Release 2,” prepared for filing with the California Public Utilities Commission on behalf of GTE California and Pacific Bell, March 18, 1997 (with Gregory M. Duncan).
Statement of Alfred E. Kahn and Timothy J. Tardiff, “Funding and Distributing the Universal Service Subsidy,” Prepared for US West for presentation to the Federal Communications Commission, March 13, 1997.
Testimony of Timothy J. Tardiff on toll and carrier access demand elasticities, prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, March 6, 1997.
Surrebuttal Testimony of Timothy J. Tardiff on the Hatfield Model of unbundled network elements, prepared for filing with the Pennsylvania Public Utility Commission on behalf of Bell Atlantic-Pennsylvania, Dockets A-310203F0002, A-310213F0002, A- 310236F0002, A-310258F0002, February 21, 1997.
Affidavit of Alfred E. Kahn and Timothy J. Tardiff, filed with the Oklahoma Public Service Commission, in support of the Applications of SBC Communications, Inc., Southwestern Bell Telephone Company, and Southwestern Bell Communications Services, Inc., for Provision of In-Region InterLATA Services in Oklahoma, February 21, 1997.
“Reply to Kravtin/Selwyn Analysis of the Gap Between Embedded and Forward- Looking Costs,” affidavit filed with the Federal Communications Commission, In the
Matter of Access Charge Reform, Price Cap Performance Review for Local Exchange Carriers, Transport Rate Structure and Pricing, on behalf of GTE, February 14, 1997.
Rebuttal Testimony of Timothy J. Tardiff on the Hatfield Model of unbundled network elements, prepared for filing with the Arkansas Public Service Commission on behalf of Southwestern Bell Telephone Company, Docket 96-395-U, January 9, 1997.
Rebuttal Testimony of Timothy J. Tardiff on the Hatfield Model of unbundled network elements, prepared for filing with the Kansas Corporation Commission on behalf of Southwestern Bell Telephone Company, Docket 97-AT&T-290-Arb, January 6, 1997.
Rebuttal Testimony of Timothy J. Tardiff on the Hatfield Model of unbundled network elements, prepared for filing with the Massachusetts Department of Public Utilities on behalf of New England Telephone and Telegraph Company, Docket 96-80/81, October 30, 1996.
Statement of Alfred E. Kahn and Timothy J. Tardiff, “Joint Marketing, Personnel Separation and Efficient Competition Under the Telecommunications Act of 1996,” Prepared for US West for presentation to the Federal Communications Commission, October 11, 1996.
Rebuttal Testimony of Timothy J. Tardiff on the Hatfield Model of unbundled network elements, prepared for filing with the Oklahoma Public Service Commission on behalf of Southwestern Bell Telephone Company, September 30, 1996.
Rebuttal Testimony of Timothy J. Tardiff on the Hatfield Model of unbundled network elements, prepared for filing with the Missouri Public Service Commission on behalf of Southwestern Bell Telephone Company, Case No. TO-97-040 & TO 97-40-67, September 30, 1996.
“Economic Evaluation of Version 2.2 of the Hatfield Model,” prepared for filing in interconnection arbitrations in Pennsylvania, California, Florida, Indiana, North Carolina, Oklahoma, Iowa, Texas, Virginia, Minnesota, Hawaii, Nebraska, Kentucky, Washington, and Missouri on behalf of GTE, September 1996 (with Gregory M. Duncan).
Testimony of Timothy J. Tardiff on the Hatfield Model of unbundled network elements, prepared for filing with the Texas Public Utility Commission on behalf of Southwestern Bell Telephone Company, Docket Nos. 16189, 16196, 16226, 16285, 16290, September 6, 1996.
“Economic Analysis of MFS’s Numerical Illustration,” prepared for filing with the Federal Communications Commission, In the Matter of Implementation of the Non- Accounting Safeguards of Sections 271 and 272 of the Communications Act of 1934, as amended and Regulatory Treatment of LEC Provision of Interexchange Services Originating in the LEC’s Local Exchange Area, on behalf of US West, August 30, 1996.
Affidavit of Timothy J. Tardiff on proxy rates for unbundled local switching, prepared for filing with the Federal Communications Commission on behalf of GTE Corporation, petition for a stay of the First Report and Order in the Matter of Implementation of the Local Competition Provisions of the Telecommunications Act of 1996, August 28, 1996.
Rebuttal Testimony of Timothy J. Tardiff on the Hatfield Model of unbundled network elements, prepared for filing with the New York Public Service Commission on behalf of New York Telephone, July 15, 1996
Reply Testimony of Timothy J. Tardiff on local exchange service price floors, prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, July 10, 1996.
“Economic Evaluation of Version 2.2 of the Hatfield Model,” attached to Reply Testimony of Timothy J. Tardiff , prepared for filing with the California Public Utilities Commission on behalf of GTE California, July 10, 1996. Also presented to the Federal Communications Commission as attachment to letter from Whitney Hatch of GTE to William F. Caton, In the Matter of Implementation of the Local Competition Provisions of the Telecommunications Act of 1996, July 11, 1996.
Testimony of Timothy J. Tardiff on local exchange service price floors, prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, June 14, 1996.
Declaration of Alfred E. Kahn and Timothy J. Tardiff, prepared for filing with the Federal Communications Commission, In the Matter of Implementation of the Local Competition Provisions of the Telecommunications Act of 1996, on behalf of Bell Atlantic, May 30, 1996.
Declaration of Timothy J. Tardiff on Round I and Round II OANAD Cost Studies, prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, May 24, 1996.
“Economic Evaluation of Pacific Bell’s Round I and Round II Cost Studies: Reply Comments,” prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, April 17, 1996.
“Incremental Cost Principles for Local and Wireless Network Interconnection,” prepared for filing with the Federal Communications Commission on behalf of Pacific Telesis, March 4, 1996 (with Richard D. Emmerson).
“Economic Evaluation of Selected Issues from the Fourth Further Notice of Proposed Rulemaking in the LEC Price Cap Performance Review: Reply Comments,” Prepared for filing with the Federal Communications Commission on behalf of the United States Telephone Association, March 1, 1996 (with William E. Taylor and Charles J, Zarkadas).
Declaration of Timothy J. Tardiff on the toll and carrier access demand stimulation caused by the January 1, 1995 price reductions (update), prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, January 19, 1996.
“Universal Service Funding and Cost Modeling,” prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, January 19, 1996.
“Changes in Interstate Price Regulation: Reply Comments,” prepared for filing with the Federal Communications Commission on behalf of Pacific Bell and Nevada Bell, January 10, 1996.
“Economic Evaluation of Selected Issues from the Fourth Further Notice of Proposed Rulemaking in the LEC Price Cap Performance Review,” Prepared for filing with the Federal Communications Commission on behalf of the United States Telephone Association, December 18, 1995 (with William E. Taylor and Charles J, Zarkadas).
“Changes in Interstate Price Regulation: An Economic Evaluation of the Pacific Bell and Nevada Bell Proposal,” prepared for filing with the Federal Communications Commission on behalf of Pacific Bell and Nevada Bell, December 11, 1995 (with Alfred E. Kahn).
“Evaluation of the Benchmark Cost Model,” prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, December 1, 1995.
Affidavit of William E. Taylor and Timothy J. Tardiff on interconnection regulation, prepared for filing with the Mexican Secretariat of Communications and Transport on behalf of Southwestern Bell International Holdings Corporation, October 18, 1995.
Participant, California Public Utilities Commission, Full Panel Hearing on Universal Telephone Service, September 29, 1995.
“Incentive Regulation and Competition: Reply Comments,” prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, September 18, 1995 (with Richard L. Schmalensee and William E. Taylor).
“Incentive Regulation and Competition: Issues for the 1995 Incentive Regulation Review,” prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, September 8, 1995 (with Richard L. Schmalensee and William E. Taylor).
“Preserving Universality of Subscription to Telephone Service in an Increasingly Competitive Industry,” prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, September 1, 1995 (with Alfred E. Kahn).
Declaration of Timothy J. Tardiff and Lester D. Taylor on the toll and carrier access demand stimulation caused by the January 1, 1995 price reductions, prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, September 1, 1995.
“Economic Evaluation of Proposed Long-Run Incremental Cost (LRIC) Methodology,” prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, July 13, 1995 (with Richard D. Emmerson).
“California Public Utilities Commission Proposed Rules for Local Competition: An Economic Evaluation,” prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, May 24, 1995.
“Benefits and Costs of Vertical Integration of Basic and Enhanced Telecommunications Services,” prepared for filing with the Federal Communications Commission, Computer III Further Remand Proceedings, CC Docket No. 95-20, on behalf of Bell Atlantic, Bell South, NYNEX, Pacific Bell, Southwestern Bell, and U S West, April 6, 1995 (with Jerry A. Hausman).
“Evaluation of the MCI’s Universal Service Funding Proposal,” prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, March 10, 1995.
“Franchise Services and Universal Service,” prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, March 10, 1995 (with Richard D. Emmerson).
Illinois Commerce Commission on behalf of GTE North: surrebuttal testimony on the benefits of intraMSA presubscription, September 30, 1994.
Illinois Commerce Commission on behalf of GTE North: rebuttal testimony on the benefits of intraMSA presubscription, September 16, 1994.
“Economic Evaluation of OIR/OII on Open Access and Network Architecture Development: Reply Comments,” prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, March 31, 1994 (with Richard D. Emmerson).
“Declaration of Timothy J. Tardiff on Pacific Bell's Productivity Under Price Caps,” prepared for filing with the Federal Communications Commission, on behalf of Pacific Bell, February 28, 1994.
“Regulation of Mobile and Wireless Telecommunications: Economic Issues,” prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, February 25, 1994
“Economic Evaluation of OIR/OII on Open Access and Network Architecture Development,” prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, February 8, 1994 (with Richard D. Emmerson).
“Access to Intelligent Networks: Economic Issues,” prepared for filing with the Federal Communications Commission, on behalf of Pacific Bell, December 1, 1993.
“The Effect of SFAS 106 on Economy-Wide Wage Rates,” prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, October 1, 1993
“Economic Evaluation of the NRF Review: Reply Comments,” prepared for filing with the California Public Utility Commission on behalf of Pacific Bell, May 7, 1993. William E. Taylor and Timothy J. Tardiff, Study Directors.
"Performance Under Alternative Forms of Regulation in the U.S. Telecommunications Industry," prepared for filing with the Canadian Radio-television and Telecommunications Commission on behalf of AGT Limited, April 13, 1993. Timothy J. Tardiff and William E. Taylor, Study Directors.
“Pacific Bell's Performance Under the New Regulatory Framework: An Economic Evaluation of the First Three Years,” prepared for filing with the California Public Utility Commission on behalf of Pacific Bell, April 8, 1993. William E. Taylor and Timothy J. Tardiff, Study Directors.
“Pricing Interconnection and the Local Exchange Carrier's Competitive Interstate Services,” prepared for filing with the Federal Communications Commission, on behalf of Pacific Bell, February 19, 1993.
“The Treatment of FAS 106 Accounting Changes Under Price Cap Regulation: Reply Comments,” prepared for filing with the Federal Communications Commission on behalf of Pacific Bell, July 1992. William E. Taylor and Timothy J. Tardiff, Study Directors.
“Costs and Benefits of IntraLATA Presubscription,” prepared for filing with the State of New York Public Service Commission on behalf of New York Telephone, May 1, 1992. Timothy J. Tardiff and William E. Taylor, Study Directors.
“The New Regulatory Framework 1990-1992: An Economic Review,” prepared for filing with the California Public Utility Commission on behalf of Pacific Bell, May 1, 1992. William E. Taylor and Timothy J. Tardiff, Study Directors.
“The Treatment of FAS 106 Accounting Changes Under Price Cap Regulation,” prepared for filing with the Federal Communications Commission on behalf of Pacific Bell, April 15, 1992. William E. Taylor and Timothy J. Tardiff, Study Directors.
“The Treatment of FAS 106 Accounting Changes Under Pacific Bell's Price Regulation Plan: Economic Analysis of the DRA Supplemental Testimony,” prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, January 21, 1992. William E. Taylor and Timothy J. Tardiff, Study Directors.
“The Treatment of FAS 106 Accounting Changes Under Pacific Bell's Price Regulation Plan,” prepared for filing with the California Public Utilities Commission on behalf of Pacific Bell, November 15, 1991. William E. Taylor and Timothy J. Tardiff, Study Directors.
California Public Utilities Commission on behalf of Pacific Bell: economic principles for pricing flexibility for Centrex service, Filed November 1990.
Expert Witness on State Transportation Energy Forecasting, California Energy Commission, Sacramento, September 1980.
SELECTED CLIENT REPORTS
Enhancing Competition for Broadband Services: The Case for Removing the Prohibition against High-Speed InterLata Transmission by Regional Bell Operating Companies, With Alfred E. Kahn, Prepared for the United States Telecom Commission, May 22, 2000 (released April 2001).
An Analysis of Resale in Long Distance Telecommunications Markets, With William E. Taylor and J. Douglas Zona (Confidential) Prepared for plaintiffs in Darren B. Swain, Inc. d/b/a U.S. Communications v. AT&T Corp., November 15, 1995.
An Analysis of Long Distance Telecommunications Markets, With William E. Taylor and J. Douglas Zona (Confidential) Prepared for plaintiffs in US WATS, Inc. and USW Corp. v. AT&T Corp., August 22, 1995.
Economic Significance of Interconnection, Prepared for Japan Telecom, June 1995.
The Effect of Competitive Entry into Local Exchange and State Toll Markets on the Revenues of Southern New England Telephone, with J.D. Zona, (Confidential), Prepared for Southern New England Telephone, February 1995.?
Long-Distance Call Alert (LDCA) Study: Customer Choice Model Findings, with C.J. Zarkadas, (Confidential), Prepared for Southwestern Bell, August 9, 1994.
Pricing Principles for LEC Services, (with R.D. Emmerson), Prepared for BellSouth Communications, July 8, 1994.
Quantifying the Handicaps of Unequal Access, (Confidential) Prepared for Japan Telecom, January 1994.
Overcoming Unequal Access: The International Experience, with S. Krom, (Confidential) Prepared for Japan Telecom, January 1994.
Market Potential For Cellular Radio And Other Personal Communications Products. (Confidential) Prepared for Pac Tel Corporation, July 1990.
Customer Demand for Local Telephone Services: Models and Applications. Prepared for South Central Bell Telephone Company, August 1987.
Evaluation Plans for Conservation and Load Management Programs. Prepared for New England Electric System, July 1987.
Telecommunications Competition for Large Business Customers in New York (Confidential). Prepared for NYNEX Corporation, June 1987.
Demand for Intrastate Long Distance Optional Calling Plans by Business and Residential Customers, with J.A. Hausman and A. Jaffe, (Confidential), Prepared for Southern New England Telephone, December 1985
“Estimation of Residential Conservation Service Program Electricity Savings,” Prepared for Southern California Edison Company, July 1984.
The Demand for Local Telephone Service Upon the Introduction of Optional Local Measured Service. In part. Final report, prepared for Southern New England Telephone, July 1982.
Transit Strategies to Improve Air Quality in the Philadelphia Region. In part. Final report prepared for the Delaware Valley Regional Planning Commission, April 1982.
Estimation of Energy Impacts of State Transportation Improvement Program Projects. In part. Final report prepared for the California Energy Commission, January 1982.
Consumer Representation for Transportation Energy Conservation. In part. Final report prepared for the U.S. Department of Energy, July 1981.
Indicators of Supply and Demand for Transportation Fuels. In part. Prepared for the California Energy Commission, December 1980.
State of the Art in Research on Consumer Impacts of Fuel Economy Policies: Recent Findings and Recommendations for Further Research. In part. Prepared for the National Highway Traffic Safety Administration, January 1980.
SELECTED PUBLICATIONS AND PRESENTATIONS
R.W. Hahn and T.J. Tardiff, “The Benefits of Broadband and the Impact of Regulation,” Prepared for the AEI-Brookings Joint Center Conference on Broadband Regulation, October 4-5, 2001
Tardiff, T.J., “Valuing the Use of Incumbent Telecommunications Networks,” Presented at the Rutgers University, Center for Research in Regulated Industries, Advanced Workshop in Regulation and Competition, 20th Annual Conference, Tamiment, Pennsylvania, May 24, 2001.
Tardiff, T.J., “State of Competition for Local Exchange Services: Implications for Telecommunications Policy,” Presented at the Law Seminars International 2nd Annual Conference on Telecommunications in the Southwest, Phoenix, Arizona, February 15, 2001.
Tardiff, T.J., “New Technologies and Convergence of Markets: Implications for Telecommunications Regulation,” Journal of Network Industries, Vol. 1, No. 4, 2000, pp. 447-468. Also presented at the Thirteenth Biennial Conference of the International Telecommunications Society, Buenos Aires, Argentina, July 3, 2000
Tardiff, T. J., “Cost Standards for Efficient Competition,” in M.A. Crew, ed., Expanding Competition in Regulated Industries, Boston: Kluwer, 2000. Also presented at the Competitive Entry in Regulated Industries Seminar, Rutgers University Center for Research in Regulated Industries, Newark, New Jersey, October 22, 1999.
Tardiff, T.J., “Demand for High-Speed Services: Implications for RBOC Entry Into InterLATA Services,” Presented at the 2000 International Communications Forecasting Conference, Seattle, Washington, September 28, 2000.
Tardiff, T.J., “Universal Access to Telephone Service and Implications of the USO,” Presented at the Rutgers University, Center for Research in Regulated Industries, 8th Conference on Postal and Delivery Economics, Vancouver, Canada, June 10, 2000
Tardiff, T.J., “Universal Access to Telephone Service: Theory and Practice,” Presented at the Rutgers University, Center for Research in Regulated Industries, Advanced Workshop in Regulation and Competition, 19th Annual Conference, Lake George, New York, May 25, 2000.
Tardiff, T.J., “The Forecasting Implications of Telecommunications Cost Models,” and “Forward-Looking Telecommunications Cost Models,” in J. Alleman and E. Noam,
eds., The New Investment Theory of Real Options and its Implications for Telecommunications Economics, Boston: Kluwer, 1999. The first article was also presented at the 1999 International Communications Forecasting Conference, Denver, Colorado, June 17, 1999.
Kahn, A.E., Tardiff, T.J., and Weisman, D.L, “The Telecommunications Act at Three Years: An Economic Evaluation of Its Implementation by the Federal Communications Commission,” Information Economics and Policy, Vol. 11, No. 4, December 1999, pp. 319-365.
Tardiff, T.J., “Effects of Large Price Reduction on Toll and Carrier Access Demand in California,” in L.D. Taylor and D.G. Loomis, The Future of the Telecommunications Industry: Forecasting and Demand Analysis, Boston: Kluwer, 1999. Also presented at the 1996 International Communications Forecasting Conference, Dallas, Texas, April 18, 1996.
W.A Grieve and T.J. Tardiff, “Universal Service in the United States and Canada: Funding High-Cost Areas,” Presented at the Telecommunications Policy Research Conference, Alexandria, Virginia, September 27, 1999.
Tardiff, T.J., “The Growth of Local Exchange Competition: Implications for Telecommunications Regulation,” Presented at the Rutgers University, Center for Research in Regulated Industries, Advanced Workshop in Regulation and Competition, 12th Annual Western Conference, San Diego, California, July 8, 1999.
Tardiff, T.J., “Trends in Local Exchange Competition,” Presented at the 25th Annual Rate Symposium, St. Louis, Missouri, April 27, 1999.
Tardiff, T.J., “Regional Bell Operating Company InterLATA Entry and the Public Interest,” Presented at the 25th Annual Rate Symposium, St. Louis, Missouri, April 26, 1999.
Tardiff, T.J., “Cost Standards for Pricing Unbundled Elements and Retail Services,” Presented at the Institute for International Research Fourth Annual Conference for Competitive Pricing of Telecommunications Services, Washington, DC, March 25, 1999.
Tardiff, T.J., Speaker: Cost of Hypothetical Providers vs. Real Providers Panel, INDETEC International, Cost and Public Policy: 1999, February 10, 1999.
Tardiff, T.J. Discussant: “TELRIC: An Overview,” Presented at The Columbia University New Investment Theory of Real Options and its Implications for the Cost Models in Telecommunications Conference, New York, New York, October 2, 1998.
Tardiff, T.J., Workshop Leader, Wholesale and Retail Pricing Workshop, Presented at the Institute for International Research Third Annual Conference for Competitive Pricing of Telecommunications Services, Chicago, IL, July 22, 1998.
Tardiff, T.J., “Pricing Essential Inputs and Efficient Competition,” Presented at the Rutgers University, Center for Research in Regulated Industries, Advanced Workshop in Regulation and Public Utility Economics, 11th Annual Western Conference, Monterey, California, July 9, 1998.
Tardiff, T.J., “Incremental Cost Basis for Interconnection Pricing,” Presented at the Institute for International Research Interconnection ’98 Conference, Washington, D.C., April 29, 1998.
Tardiff, T.J., “Regulatory Implications of Local Exchange Cost Models,” Presented at the 24th Annual Rate Symposium, Kansas City, Missouri, April 28, 1998.
Tardiff, T.J., “What’s Happening in Local Competition,” Presented at the 24th Annual Rate Symposium, Kansas City, Missouri, April 27, 1998.
Tardiff, T.J. “Pricing and New Product Options with Telecommunications Competition,” in D.R. Dolk, ed., Proceedings of the Thirty-First Annual Hawaii International Conference on Systems Sciences, Vol. V, Modeling Technologies and Intelligent Systems Track, Los Alamitos: IEEE Computer Society, January 6-9, 1998, pp. 416- 425.
Froeb, L.M., T.J. Tardiff, and G.J. Werden, “The Demsetz Postulate and the Effects of Mergers in Differentiated Products Industries,” in F.S. McChesney, ed., Economic Inputs, Legal Outputs: The Role of Economists in Modern Antitrust, New York: Wiley, 1998. Also presented at the Annual Meeting of the American Economics Association, Washington, D.C. January 8, 1995.
Tardiff, T.J., “Pricing and Product Offerings for the New Competitive Telecommunications Environment,” Presented at the Canadian Institute Competitive Strategies Telecommunications Conference, Toronto, Canada, September 29, 1997.
Tardiff, T.J., “Cost Basis for Pricing: Embedded or Incremental,” Presented at the Institute for International Research Cost Allocation Forum, Atlanta, Georgia, September 17, 1997.
Tardiff, T.J. “Costing and Pricing for Local Exchange Competition: Experience Under the U.S. Telecommunications Act,” in P. Enslow, P. Desrochers, and I. Bonifacio, eds., Proceedings of the Global Networking ’97 Conference, Amsterdam: IOS Press, June 15-18, 1997, pp. 286-292.
Tardiff, T.J., “Unbundling and Resale: Lessons from South of the Border,” presented at the Bell Canada Total Competition Briefing Session, Toronto, Canada, April 16, 1997.
Tardiff, T.J., “Unbundling and Resale Under the Telecommunications Act and the FCC’s Interconnection Order: Implications for Industry Structure and Competitive Strategies,” presented at the International Communications Group Telecommunications Business Environment Conference, Denver, Colorado, January 7, 1997.
Hausman, J. and T. Tardiff, “Valuation of New Services in Telecommunications,” in A. Dumont and J. Dryden, The Economics of the Information Society,Luxembou? rg: Office for Official Publications of the European Communities, 1997, pp. 76-80. Also? presented to the OECD Workshop on the Economics of the Information Society, Toronto, Canada, June 28, 1995.
Tardiff, T.J., “Universal Service with Full Competition,” in S.L. Hansen, ed., Universal Service with Network Competition, University of Auckland, 1996, pp. 51-64. Also presented at the Eleventh Biennial Conference of the International Telecommunications Society, Seville, Spain, June 18, 1996 and on my behalf by J. Oliver at the Telecommunications Universal Service Symposium, Wellington, New Zealand, July 2, 1996.
Tardiff, T.J., “Efficient Pricing of Competitive Local Exchange Services: Understanding the Costing Principles,” presented at the Institute for International Research Conference on Competitive Costing Strategies for Local Exchange Services, New Orleans, Louisiana, October 24, 1996.
Tardiff, T. J. and Taylor, W.E., “Revising Price Caps: The Next Generation of Incentive Regulation Plans,” in M.A. Crew, ed., Pricing and Regulatory Innovations Under Increasing Competition, Norwell, MA: Kluwer, 1996, pp. 21 - 38. Also presented at the Rutgers University Center for Research in Regulated Industries Research Seminar, May 3, 1996.
Tardiff, T.J., “New Product and Pricing Options for the Competitive Telecommunications Environment: Lessons from Consumer Choice Studies,” presented at the International Communications Group Business Opportunities in Telecommunications Conference, Denver, Colorado, July 31, 1996.
Tardiff, T.J., “Efficient Local Competition and Universal Service,” presented at the International Communications Group Business Opportunities in Telecommunications Conference, Denver, Colorado, July 31, 1996.
Tardiff, T.J., “Pricing and Product Offerings in a Competitive Environment,” presented at the Canadian Institute Conference on Telecommunications Pricing, Toronto, Ontario, Canada, March 7, 1996.
Werden, G.J., Froeb, L.M., and Tardiff, T.J. “The Use of the Logit Model in Applied Industrial Organization,” International Journal of the Economics of Business, Vol. 3, No. 1, 1996, pp. 83-105. ?
Tardiff, T.J. “Incentive Regulation and Competition: The Next Generation,” presented at the 27th Annual Conference of the Institute of Public Utilities at Michigan State University, Williamsburg, Virginia, December 12, 1995.
Tardiff, T.J., “Effects of Presubscription and Other Attributes on Long-Distance Carrier Choice,” Information Economics and Policy, Vol. 7, No. 4, December 1995, pp. 353-366. Also presented at the 1994 National Telecommunications Forecasting Conference, Boston, Massachusetts, May 24, 1994.
Tardiff, T.J. and J.D. Zona, “Effects of Competitive Entry on Capital Recovery,” presented at the United States Telephone Association Capital Recovery Seminar, Chicago, Illinois, October 19, 1995.
Tardiff, T.J. and L.J. Perl, “Price Regulation and Productivity,” presented to the Public Staff of the North Carolina Utilities Commission, Raleigh, North Carolina, September 6, 1995.
Hausman, J.A. and T.J. Tardiff, “Efficient Local Exchange Competition,” Antitrust Bulletin, Vol. 40, No. 3, Fall 1995, pp. 529-556.
Instructor, “Seminar in Current Economic Issues”, United States Telephone Association course, Orlando, Florida, April 3-5, 1995.
Tardiff, T.J., W.E. Taylor, and C.J. Zarkadas, “Periodic Review of Price Cap Plans: Economic Issues,” presented at the Telecommunications Policy Research Conference, Solomons, Maryland, October 2, 1994.
Participant in AGT International Symposium on Local Interconnection Policy, Emerald Lake, British Columbia, Canada, May 27-28, 1994.
Tardiff, T.J., “Access Charges and Toll Prices in the United States: An Economic Evaluation,” Presented to representatives of Japanese Long-Distance Companies, New York, New York, May 16, 1994.
Tardiff, T.J. and W.E. Taylor, “Telephone Company Performance Under Alternative Forms of Regulation in the U.S.,” presented at the Telecommunications Policy Research Conference, Solomons, Maryland, October 4, 1993.
Tardiff, T.J., “Interconnection and LEC Competitive Services: Pricing and Economic Efficiency,” presented at the Telestrategies Conference: The Access Charge Revolution, Washington, D.C. May 18, 1993.
Hausman, J., T. Tardiff, and A. Belinfante, “The Effects of the Breakup of AT&T on Telephone Penetration in the United States,” The American Economic Review, Vol. 83, May 1993, pp. 178-184.
Tardiff, T.J., “Assessing the Demand for New Products and Services: Theory and Practice,” presented at the NRRI Conference on Telecommunications Demand for New and Existing Services, Denver, Colorado, August 6, 1992.
Tardiff, T.J., “Price and Cost Standards for Increasingly Competitive Telecommunications Services,” presented at the Ninth International Conference of the International Telecommunications Society, Sophia Antipolis, France, June 17, 1992.
Tardiff, T.J. “Modeling The Demand For New Products and Services,’ presented at the NTDS Forum, Santa Fe, New Mexico, September 27, 1991.
Tardiff, T.J. and C. Zarkadas, “Forecasting Tutorial,” presented at the National Telecommunications Forecasting Conference, May 29, 1991.
Tardiff, T.J. and W.E. Taylor, “Pricing the Competitive Services of Regulated Utilities,” National Economic Research Associates, Working Paper No. 7, May 1991.
Hausman, J.A. and T.J. Tardiff, “Growth in New Product Demand Taking into Account The Effects of Price and Competing Products: Mobile Telecommunications,” Presented at the Massachusetts Institute of Technology Telecommunications Business and Economics Program Second Annual Symposium, Cambridge, Massachusetts, November 1990.
Tardiff, T.J., “Structuring Telecommunications in Other Countries: View from the UK, Europe and Canada,” Presented at the United State Telephone Association Affiliated Interest Issues Committee 1990 Fall Conference, Traverse City, Michigan, September 1990.
Tardiff, T.J. and M.O Bidwell, Jr., “Evaluating a Public Utility's Investments: Cash Flow vs. Revenue Requirement,” Public Utilities Fortnightly, May 10, 1990.
Tardiff, T.J. and C.J. Zarkadas, “Forecasting Demand for New Services: Who, What, and When,” Presented at the Bellcore/Bell Canada Demand Analysis Forum, Hilton Head South Carolina, April 1990.
Tardiff, T.J., “Consumer Welfare with Discrete Choice Models: Implications for Flat versus Measured Local Telephone Service,” Presented at the Bellcore/Bell Canada Demand Analysis Forum, Hilton Head South Carolina, April 1990.
Tardiff, T.J., “Telephone Regulation in California: Towards Incentive Regulation and Competition,” Presented to the Bell Canada Economic Council, Hull, Quebec, Canada, February 1990.
Tardiff, T.J., “Measuring Competitiveness in Telecommunications Markets,” in National Economic Research Associates, Telecommunications in a Competitive Environment. Proceeding of the Third Biennial Telecommunications Conference, Scottsdale, Arizona, April 1989, pp. 21-34.
Hausman, J.A., T.J. Tardiff, and H. Ware, “Competition in Telecommunications for Large Users in New York,” in National Economic Research Associates, Telecommunications in a Competitive Environment. Proceeding of the Third Biennial Telecommunications Conference, Scottsdale, Arizona, April 1989, pp. 1-19.
Perl, L.J. and T.J. Tardiff, “Effects of Local Service Price Structures on Residential Access Demand,” Presented at the International Telecommunications Society North American Regional Meeting, Ottawa, Ontario, Canada, June 1989.
Tardiff, T.J. and W.E. Taylor, “Costing Principles for Competitive Assessment,” in Telecommunications Costing in a Dynamic Environment, Proceedings of the Bellcore-Bell Canada Conference on Telecommunications Costing, 1989, pp. 497-518.
Tardiff, T.J., “Forecasting the Impact of Competition for Local Telephone Services.” Presented at the Bellcore National Forecasting Conference, New Orleans, April 1987.
Tardiff, T.J., “Is Bypass Still a Threat,” in National Economic Research Associates, Telecommunications in a Competitive Environment. Proceedings of Conference held in Scottsdale, Arizona, March 1987, pp. 27-41.
Tardiff, T.J., “Benefit Measurement with Customer Choice Models.” Presented at the Bellcore Telecommunications Demand Modeling Conferences, New Orleans, October 1985.
Tardiff, T.J., “The Economics of Bypass,” Presented at the Bellcore Competitive Analysis and Bypass Tracking Conference. Denver, March 1985.
Tardiff, T.J., “Class of Service Choice Model.” Presented at the Telecommunications Marketing Forum. Chicago, September 1984.
Tardiff, T.J., “Demand for New Telecommunications Product and Services.” Presented at the Fifth International Conference on Futures Analyses, Forecasting and Planning for Telecommunications. Vancouver, July 1984.
Tardiff, T.J., “Pricing and Marketing in the Competitive Local Access Market.” In Present and Future Pricing Issues in Electric, Gas, and Telecommunications Industry. Proceeding of the Ninth Annual Rate Symposium on Problems of Regulated Industries. Columbia: University of Missouri, 1983.
Tardiff, T.J., J. Hausman and A. Baughcum, “The Demand for Optional Local Measured Service.” In Adjusting to Regulatory, Pricing and Marketing Realities. Proceedings of the Fourteenth Annual Conference of the Institute of Public Utilities. East Lansing: Michigan State University, 1983.
Tardiff, T.J., W.B. Tye, L. Sherman, M. Kinnucan, and D. Nelson, Application of Disaggregate Travel Demand Models. National Cooperative Highway Research Program Report 253, 1982.
Tardiff, T.J., D. Wyckoff, and B. Johnson, “Shippers' Preferences for Trucking Services: An Application of the Ordered Logit Model.” Proceedings of the Transportation Research Forum, Vol. 23, 1982.
Tardiff, T.J., P. M. Allaman, and F. C. Dunbar, New Approaches to Understanding Travel Behavior. National Cooperative Highway Research Program Report 250, 1982.
Tardiff, T.J., E. Ziering, J. Benham and D. Brand, “Energy Impacts of Transportation System Improvements.” Transportation Research Record 870: 10-15, 1982.
Tardiff, T.J. and O.S. Scheffler, “Destination Choice Models for Shopping Trips in Small Urban Areas.” Proceedings of the Transportation Research Forum, Vol. 22, 1982.
Tardiff, T.J., J.L. Benham and S. Greene, Methods for Analyzing Fuel Supply Limitations on Passenger Travel. National Cooperative Highway Research Program Report 229, 1980.
Tardiff, T.J., “Vehicle Choice Models: Review of Previous Studies and Directions for Further Research.” Transportation Research 14A: 327-336, 1980.
Tardiff, T.J., “Specification Analysis for Quantal Choice Models.” Transportation Science 13: 179-190.
Tardiff, T.J., “Attitudinal Market Segmentation for Transit Design, Marketing and Policy Analysis.” Transportation Research Record 735: 1-7, 1979.
Tardiff, T.J., “Definition of Alternatives and Representation of Dynamic Behavior in Spatial Choice Models.” Transportation Research Record 723: 25-30, 1979.
Tardiff, T.J., “Use of Alternative Specific Constants in Choice Modeling.” Institute of Transportation Studies, University of California, Berkeley and Irvine, Report No. UCI- ITS-SP-78-6, December 1978.
Tardiff, T.J. and G.J. Fielding, “Relationship Between Social-Psychological Variables and Individual Travel Behavior.” Proceedings of the Transportation Research Forum, Vol. 19, 1978.
Tardiff, T.J., T.N. Lam, and B.F. Odell, “Effects of Employment and Residential Location Choices on Urban Structure: A Dynamic Stochastic Simulation.” Transportation Research Record 673: 86-93, 1978.
Tardiff, T.J., “Casual Inferences Involving Transportation Attitudes and Behavior.” Transportation Research 11: 397-404, 1977.
Tardiff, T.J., “A Note on Goodness of Fit Statistics for Probit and Logit Models.” Transportation 5: 377-388, 1976.
Tardiff, T.J., “The Effects of Socioeconomic Status on Transportation Attitudes and Behavior.” Ph.D. Dissertation, School of Social Science, University of California, Irvine, 1974. December 2001