AT&T (NYSE: T) says that as the FCC looks to analyze the data it has collected in the special access proceeding, it will see that there are plenty of alternatives to incumbent players that CLECs can choose from to purchase wholesale circuits to extend their service into areas where they can't reach today.
"The network data collected here no doubt will show that, where special access demand is concentrated, there exists an abundance of competitive alternatives to the incumbent provider," wrote Frank Simone, assistant vice president of Federal Regulatory for AT&T, in a blog post. "And while the volume of nationwide facilities data collected will be sizable due to the highly competitive market for special access services, the information provided likely can be analyzed in a reasonable period of time."
AT&T is hardly alone in its sentiment about wholesale choices. Fellow ILEC CenturyLink (NYSE: CTL) wrote in a separate filing that CLECs have a number of alternative wholesale sources to extend services into off-net business locations they don't reach today with their own facilities.
"CLECs continue to use multiple alternatives to ILEC broadband services to provide their own competing enterprise broadband services," CenturyLink wrote. "They can deploy their own facilities, use a cable provider's or other third party's wholesale services, use TDM-based DS 1 and DS3 services or use copper loops purchased at TELRIC rates, as many CLECs have successfully done."
While AT&T is happy that the FCC is moving to collect all of the relevant data before it takes action on how it should regulate special access pricing going forward, there are a number of challenges it faces in fulfilling data requests for monthly pricing information at the circuit and rate element level.
What makes this challenging for a company the size of AT&T is that the FCC's request deals with millions of circuits deployed across the telco's multiple holding companies, all of which have "similar but not the same billing systems."
"The inevitable inconsistencies in the data among the range of providers, competitive and incumbent, submitting pricing data will make any effort by the Commission to rationalize this data at the circuit level extremely difficult, if not impractical," wrote Simone.
In response to just one of the FCC's questions, AT&T said it had to create a file that exceeded 31 million records. To create this file, the telco had to engage with 44 of its own subject matter experts over an 11-month period.
Simone said that "even after this exhaustive effort, AT&T has told the Commission that this data still contains certain gaps."
Special access continues to be a thorny issue, particularly for the competitive telecom industry, which depends on purchasing wholesale services from companies like AT&T to extend services into business locations they can't economically reach on their own.
In October 2013, AT&T proposed that it would no longer support term plans longer than 36 months for tariffed TDM services, including DS1, DS3, analog private line and DS0 services.
Following vigorous protest from various competitive providers, including Sprint, Level 3 and Windstream, AT&T in January 2014 sought permission from the FCC to withdraw its proposed tariff changes on TDM-based special-access services it sells to competitive service providers. But the telco filed another proposal to increase special-access rates.
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