Wireline

摘要

The FCC’s Technology Transitions Task Force should promptly update the commission’snlast-mile access and interconnection policies for a packet-mode environment, Cbeyond, EarthLink,nIntegra Telecom, Level 3 and tw telecom told FCC officials Friday, an ex parte filing said (http:/xrl.us/bob2h3). In the process they should follow four major guidelines, the CLECs said: First,navoid redundant proceedings. Second, consider only those issues that “would not arise ‘but for’ antechnology transition,” such as, for example, wholesale access to ILEC last-mile facilities, they said.nThird, the FCC should prioritize issues based on their potential effect on consumer welfare. Finally,nthe commission should utilize “appropriate procedural mechanisms,” such as a rulemaking, to effectuatennew rules. The CLECs also encouraged the FCC to reject AT&T’s petition to launch a proceedingnon the IP transition, and its proposed wire center experiment where many of the interconnectionnrules would be lifted. Most of the issues raised in AT&T’s petition, such as service discontinuance,nnetwork change notification and federal eligible telecom carrier rules, are already the subjectnof pending FCC proceedings, the CLECs said. AT&T’s wire center tests are unnecessary,nwould divert FCC resources from updating existing competition policies, and wouldn’t help to identifynthe markets where ILECs have market power, the CLECs said. They also opposed NTCA’s petitionnfor a new omnibus rulemaking proceeding to address the IP transition, arguing the rural association’snproposed “smart regulation” approach is too broad and will unnecessarily divert FCC resources.nThe CLECs did support NTCA’s request for clarification that ILECs must provide SessionnInitiation Protocol interconnection under Section 251 of the Telecom Act.