Windstream says lower-bandwidth businesses rely on incumbents' DS1, DS3 unbundled loops

Windstream, firing its latest shot in the special access market battle, has urged the FCC to grant its petition to ensure that ILECs will continue to provide unbundled DS1 and DS3 loops, in order to keep the lower-bandwidth business services market competitive.

By providing reasonable rates for these circuits, Windstream and other CLECs like Level 3 can continue to provide competitively priced services to their business customers, whose budgets remain tight.

The service provider said that one of its key customers, the University of Arkansas Medical Center, requires dedicated circuits at its locations. With competitive pricing, the center is "able to redirect the cost savings made possible through competitive offerings toward further investments in fulfilling their public service missions."

While Windstream and other competitive carriers have built out sizeable fiber networks, and will continue to build out their own facilities, the reality is they can't match the ubiquity of the ILECs' last mile networks. This means that competitive carriers will still need to rent DS1 and DS3 loops to fulfill business orders in areas where they have not built or can't make a business case to install their own facilities.

For their part, ILECs like AT&T (NYSE: T) and Verizon (NYSE: VZ) have maintained that additional regulation of special access services is "unwarranted."

Windstream countered that neither it or other competitors can "replace all current TDM special access purchases with UNEs,11 and as the Commission has recognized, unbundled DS1 and DS3 capacity loops when available supplement, but do not replace, special access services as a market-opening tool."

By making a ruling that mandates continued availability of unbundled DS1 and DS3 capacity loops, Windstream says the FCC will alleviate uncertainty and allow it to best serve current and new business customers.

"Competitive carriers are bidding today on services they will provide several years from now, and the uncertainty harms competitors' ability to ensure they can control the quality and attributes of the services they provide and to offer the lowest possible prices," Windstream said. "The ultimate result of these conditions will be less choice and higher prices for business, government, and nonprofit customers."

For more:
- see the FCC filing (PDF)

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