AT&T has offered the FCC “only make-weight arguments in defense...
AT&T has offered the FCC “only make-weight arguments in defense of the status quo” of the special access marketplace, “that do not hold up under any reasonable level of scrutiny,” tw telecom said in a letter posted Tuesday (http://xrl.us/bnqbgm). Tw…
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telecom criticized what it called “attempts to divert attention away from the incumbent LECs’ overwhelming control of the special access marketplace.” AT&T downplayed the significance of ILEC market shares, even though it is an “essential element” of the analysis, tw telecom said. AT&T also made much of the concentration of special access demand in about 1,500 buildings, and would likely argue that competitors can construct their own facilities to those buildings, tw telecom said. But that ignores the buildings that show lower levels of demand, but still need special access services, the telco said. And “AT&T offers no more than empty semantics in response to legitimate concerns about the terms of its special access discount plans,” tw telecom said. “AT&T requires a customer to commit to maintaining at least 80 percent of its volume service in order to receive the lower overall rates associated with circuit portability,” tw telecom said: “This provision is clearly problematic, as it severely limits the ability of customers that need circuit portability to purchase circuits from alternative providers."