ILECs, Rivals Spar Over Special Access Market Analysis, Potential Regulation

from various professors that "responds to and rebuts" the declaration from Jonathan Baker filed March 2 on behalf of Level 3 and Windstream. AT&T and CenturyLink said their declaration showed the Baker declaration was flawed and shouldn't be used by the FCC to find that special access competition requires the presence of at least three CLECs with their own connections to a building. TDS Metrocom filings disagreed with AT&T and CenturyLink arguments against FCC regulation of ethernet services. "The Commission does not have to reverse its forbearance orders to affirm that the [Bells] must sell wholesale Ethernet at an avoided cost discount," TDS said. A Sprint filing said the incumbent telcos were asking the FCC "to ignore the dearth of special access competition on the promise that cable providers have upended the special access marketplace and will soon emerge as fierce competitors" to ILECs. A Comcast filing posted Monday summarized a discussion with FCC staffers in which the company's officials provided overviews of their business service offerings, including of ethernet services. A Windstream filing summarized a meeting with FCC General Counsel Jonathan Sallet in which it said "the preservation of DS1 and DS3 capacity UNEs after the transition to IP-based or fiber networks is an important component to remedies for ILEC market power in special access markets." DS1s (1.5 Mbps) and DS3 (45 Mbps) are digital special access circuits and UNEs are unbundled network elements, such as circuits, sold at wholesale discounts.