Re: Verizon, FiOS, and CLEC/UNE orders (was AT&T diversity)

[William Herrin <bill () herrin us>]

On Wed, Mar 21, 2012 at 2:58 PM, Jay Ashworth <jra () baylink com> wrote:
> > Verizon, the copper wireline company, is removing service from
> > locations EVERY TIME VZ fiber is installed in a building. This
> > prevents other companies from providing service by leasing Verizon's
> > copper infrastructure. If there was copper at a location then VZ would
> > be required to resell it and nobody would be locked out.
>
> TTBOMK, whether Verizon has copper to a building has *no bearing at all*
> on whether a CLEC can place an order for wholesale service to that location;
> VZN is *required* to provide that wholesale service, at the regulated NRC
> and MRC rates, whether they currently happen to have the physical facilities
> in place or not -- are you alleging either that I've misunderstood that,
> or that VZN is refusing such orders *simply* because they've removed
> facilities to an address where FiOS has done an install?

Hi Jay,

They way I heard it, ILECs like Verizon are required to provide
unbundled elements of the tariffed services anywhere they accept new
orders for service which consumes those unbundled elements. They are
not required to deploy new infrastructure solely to satisfy an order
for an unbundled element but they may not deliver new
element-consuming services without also satisfying the orders for
unbundled elements.

So, if they build new POTS ports at the CO, they're required to also
fill the orders for unbundled POTS ports. And if they lay new copper
to connect those ports to customer homes they're required to also fill
the orders for unbundled pairs along the same path.

Separately, an ILEC like Verizon has a universal service obligation to
deliver a POTS line anywhere you order one. Without exception.

The hinky part is that the FCC decided that copper pairs are an
unbundled element but PONS wavelengths and Coaxial cable frequency
channels are not. So, Verizon doesn't have to share access to FIOS and
Comcast doesn't have to share access to the coax. As long as they
deliver phone service without consuming copper pairs, universal
service doesn't compel them to build any copper plant to satisfy your
unbundled element order.

I pine for the return of structural separation. If the cable plant
provider was required to be a separate company from the services
provider, we wouldn't have these shenanigans. Different shenanigans
but not these.

Regards,
Bill Herrin


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William D. Herrin ................ herrin () dirtside com  bill () herrin us
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