Windstream to FCC: Competitive choice should not be reduced in IP transition

Windstream says the FCC's plan to revise its Section 214 discontinuance and copper retirement and IP transition processes should ensure that its business customers won't be left without competitive choices for service.  

The FCC designed these copper retirement processes to give Windstream and other CLECs a set of "enduring," "core statutory values" embodied in the communications laws--"public safety, universal service, competition and consumer protection"--as service providers like AT&T (NYSE: T) and Verizon (NYSE: VZ) transition their networks from copper to fiber and TDM to IP.

Windstream will also likely be watching CenturyLink's ongoing IP transition. 

CenturyLink (NYSE: CTL) asked the FCC for permission to conduct its own TDM-to-IP trials in Las Vegas. Unlike the AT&T trial in the Southeast, CenturyLink wants to focus on how the transition would affect business customers replacing their traditional POTS voice services with VoIP.

Operating both as an ILEC and a CLEC, Windstream may have an extensive fiber network that spans 118,000 miles and a sizeable copper network in its legacy territories, but the reality is that network does not reach every business location and it can't justify the cost to wire these buildings with its own last-mile facilities outside of its own footprint.

In areas where it does not have its own last-mile network built out, Windstream, like other CLECs, has to purchase wholesale access to an incumbent telco's last-mile network.

As it has stated in earlier filings, Windstream has asked regulators to ensure that it and other competitors can get access to IP-based last-mile circuits at equivalent prices they can get today with TDM-based copper services.

If CLECs aren't able to connect their networks to incumbent last-mile facilities through and after the IP transition, it would force a number of businesses, non-profit and government agencies that have chosen competitive providers to revert back to the incumbent provider for service.

"TDM technologies would not need to be preserved with either the rule requiring at least equivalent wholesale access on equivalent rates, terms, and conditions, or reconfirmation that the obligations to unbundle DS1 and DS3 capacity loops do not terminate with the IP transition," Windstream wrote. "But in the post-IP transition world, competitors still will need equivalent access to last-mile facilities and services to continue offering business services to millions of customers."

Windstream said that migrating last-mile electronics from TDM to IP "does not alter the fundamental economics of digging trenches, installing conduit, and establishing building entries and that these "physical assets—and the rights of way they traverse—are still a competitive bottleneck, regardless of the type of signal they transmit."

Although IP-based Ethernet and fiber service are all the rage, Windstream cited a number of small business customers that still rely on copper-based T1 circuits to run their companies.

One of those customers is Greenfiber, headquartered in Charlotte, N.C., and the world's largest manufacturer of natural fiber insulation, fire and sound products, which uses T1s at its 11 plants and bonded T1s at its headquarters, as well as managed router support, network firewall, dynamic IP and Ethernet. 

"Customer service drives every dollar in and out of this place," said Tom Moran, Greenfiber's IT manager, in the FCC filing. "If we can't support the phone calls and emails coming in, and our infrastructure in, and our infrastructure is not large enough to handle it, we lose business."

Windstream has a sympathetic ear in FCC Chairman Tom Wheeler, who said during the Comptel Plus Fall 2014 Convention and Expo in Dallas in October that while he is an advocate of the IP transition, he wants to ensure it does not affect competition.

"Interestingly, while the idea of tech transition trials was warmly embraced, there hasn't exactly been a land rush to put them in place," Wheeler said. "But we are looking forward to announcements of trials later this month. Let me be clear: Transitions to IP are not a license to limit competition."

For more:
- see this FCC filing (.pdf)

Editor's Corner:  Wheeler's competition agenda, dark fiber, small cells and permitting dominated Comptel Plus Fall 2014

Related articles:
FCC's Wheeler: IP transition is not a license to limit competition
Windstream wants ILECs to price IP-based wholesale special access services fairly
Windstream asks FCC to investigate AT&T's special access increase proposals
FCC begins special-access data-collection process, but competitive carriers want fair prices

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