Monday, November 15, 2004
BellSouth Forbearance
This is an out of the box thought, but given comments about
structural separation are bantered about by the competition
(CLECs), who are effected by every whim of the ILEC and
regulating bodies, perhaps BellSouth should pull a page out
of the GTE playbook. Become a CLEC.
That's right start a CLEC company.
If the CLECs indeed have such an incredible advantage over
the ILEC voice and broadband business, why then have the
ILECs not moved out of region yet? Wouldn't this prove to
be a profit maker for ILEC shareholders? Are you not doing
a disservice to your shareholders by not competing
out-of-region?
And may I add that SBC was Required to offer services in
all 48 states as part of its merger with Ameritech.
http://www.rad-info.net/fcc.htm
COMMENTS INVITED ON PETITION FOR FORBEARANCE
FILED BY BELLSOUTH TELECOMMUNICATIONS, INC.
REGARDING INCUMBENT LEC PROVISION OF BROADBAND
WC Docket No. 04-405
Comments Due: December 20, 2004
Reply Comments Due: January 19, 2005
On October 27, 2004, BellSouth Telecommunications, Inc. (BellSouth)
filed a petition for forbearance from Title II common carriage
requirements that apply to incumbent LEC broadband transmission.
Further, BellSouth seeks forbearance from the Computer Inquiry rules to
the extent they require incumbent LECs to tariff and offer the transport
component of their broadband services on a stand-alone basis and to take
service under those same terms and conditions. BellSouth argues that
these rules are unnecessary, because the market for broadband
transmission is competitive, and impose costs that inhibit innovation
and deployment of broadband. In addition, BellSouth argues that these
rules are not imposed on other providers of broadband transmission.
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-04-3507A1.doc
This essentially reiterates, and perhaps goes a bit beyond, WC 02-33, a
stalled Docket which proposed removing common carriage from broadband
transmission service. Filed as a petition for forebearance rather than
as a petition for rulemaking, I think the Commission has to actively
dismiss it, or it takes effect. It asks for forebearance on both
Computer II requirements (which made ISPs possible) and basic 1880s-era
Title II common carriage obligations (which enable someone who leases
transmission to do with it as they please, so long as they pay the bill).
ISPs really should pay attention to these sorts of things and have their
lawyers and regulatory consultants prepare good responses.
Comment intelligiently to the FCC here:
http://www.fcc.gov/cgb/ecfs
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