Granite Telecommunications and MetTel, two competitive service providers that focus on serving multi-site business customers, have asked the FCC to ensure that ILECs like AT&T (NYSE: T), CenturyLink (NYSE: CTL), and Verizon (NYSE: VZ) provide an equivalent TDM-based voice service post IP transition.
Joined by TelePacific Communications, Impact Telecom, New Horizon Communications Corp., Xchange Telecom LLC and Access Point, these competitive players have been talking to the FCC under what they refer to as Wholesale Voice Line Coalition.
Having access to traditional ILEC voice lines is important for these CLECs and other competitive providers as they rely on these voice-grade lines to serve their multi-location business customers that often require between 1-10 phone lines.
Gaining access to an ILEC's voice network facilities is crucial to CLECs that serve business customers for a number of reasons.
These CLECs serve businesses that have dispersed locations in areas where they have not built their own wired network facilities, nor is it cost effective to duplicate the existing ILEC network due to the minimal requirements for services.
Granite said that on average it serves locations with about 3.5 phone lines, but over three-fourths of its locations have "4 or fewer lines." Likewise, MetTel serves about 3.57 lines per location.
For example, Granite has an average of 3.5 lines per location and more than three-quarters of its locations have 4 or fewer lines. Similarly, MetTel has an average of approximately 3.57 lines per location. The cost of constructing competitive facilities (or extending cable facilities) to serve such small customers could not be recovered in any commercially realistic time frame. We noted that in a post-transition world in which ILECs had no obligation to provide service at wholesale, the ILECs would face no competition for such customers.
"The locations are widely dispersed, and often in suburban, exurban and rural areas where no competitive carrier has facilities and it is not economical for a CLEC to construct facilities duplicating the ILECs, given the very limited demand at each location," wrote the Wholesale Voice Line Coalition in an FCC filing.
Despite being able to access facilities from cable operators, all of which have been expanding their HFC and fiber networks to address business and wholesale customer carrier needs, their overall reach is still relatively limited.
"Moreover, the local cable company usually cannot construct facilities to reach these businesses on an economical basis," the Coalition wrote. "Granite pointed out that cable companies have facilities to only approximately 15% of its customer locations. For other locations, it is necessary to pay special construction costs to use cable facilities."
The two service providers also refuted the USTelecom trade association's suggestion that a transition from TDM to IP facilities should be limited to one or two years "to allow competitors who rely on wholesale inputs ample time to make alternative arrangements."
"We pointed out that this fails to consider what alternative arrangements can be made during the one or two years," the Coalition wrote. "If US Telecom is suggesting that members of the Wholesale Voice Line Coalition have as an economically feasible alternative constructing their own facilities to customers in stand-alone buildings who need 3 or 4 (or even 10 or 15) voice lines, it has offered no support for such an absurd proposition."
For their own part, AT&T and CenturyLink have been petitioning the FCC to gain permission to be allowed to shut down TDM-based voice services if there a number of available alternatives in a given market.
In a recent filing, CenturyLink said that if a "carrier (including an ILEC) seeking to discontinue TDM voice service certifies that all affected retail customers have access to a "reasonably comparable alternative," that discontinuance request would be granted unless it is shown that such an alternative is not actually available."
Recognizing the fact that CenturyLink's TDM to IP transition will be conducted over long period of years, the service provider has proposed a transitional process to retire its copper network while offering new IP-based services on existing facilities to existing and new wholesale CLEC customers.
- see this FCC filing (.pdf)
CenturyLink asks FCC to allow TDM voice shutdown if alternatives are available
AT&T, CenturyLink claim Granite's request to combine Section 271, wholesale services will delay IP transition