Attachment A - Federal Communications Commission
Attachment A
THE VERIZON TELEPHONE COMPANIESThe Verizon telephone companies are the local exchange carriers affiliated with VerizonCommunications Inc. These are:Contel of the South, Inc. d/b/a/ Verizon Mid-StatesGTE Midwest Incorporated d/b/a/ Verizon MidwestGTE Southwest Incorporated d/b/a/ Verizon SouthwestThe Micronesian Telecommunications CorporationVerizon California Inc.Verizon Delaware Inc.Verizon Florida Inc.Verizon Hawaii Inc.Verizon Maryland Inc.Verizon New England Inc.Verizon New Jersey Inc.Verizon New York Inc.Verizon North Inc.Verizon Northwest Inc.Verizon Pennsylvania Inc.Verizon South Inc.Verizon Virginia Inc.Verizon Washington, DC Inc.Verizon West Coast Inc.Verizon West Virginia Inc.
Attachment B
Before theFederal Communications CommissionWashington, D.C. 20554In the Matter ofReview of the Section 251 UnbundlingObligations of Incumbent LocalExchange CarriersImplementation of the Local CompetitionProvisions in the TelecommunicationsAct of 1996Deployment of Wireline ServicesOffering Advanced TelecommunicationsCapability)))))))))))))CC Docket No. 01-338CC Docket No. 96-98CC Docket No. 98-147UNE FACT REPORT 2002Prepared for and Submitted byBellSouth, SBC, Qwest, and VerizonApril 2002
TABLE OF CONTENTSI.II.COMPETITIVE OVERVIEW.I-1A.Competitive Facilities and Networks. .I-1B.Competitive Lines Served. .I-5C.Capital Investment.I-10D.Revenues. .I-12E.Outlook.I-15LOCAL SWITCHING . II-1A.CLEC Circuit Switches. . II-41. Geographic Areas Served by CLEC Circuit Switches. . II-52. Use of CLEC Switches To Serve Mass-Market Customers. II-10III.IV.B.Packet Switches as Substitutes for Circuit Switches. II-20C.Wireless Switches as Substitutes for Circuit Switches. . II-33INTEROFFICE TRANSPORT.III-1A.Fiber-Based Collocation. III-1B.CLEC Fiber. . III-6C.Wholesale Suppliers of Local Fiber. .III-8LOCAL LOOPS.IV-1A.High-Capacity Loops. .IV-11. CLEC Fiber as a Substitute for High-Capacity ILEC Loops. .IV-12. CLECs Are Making Little Use of Unbundled High-Capacity Loops. .IV-6B.POTS Loops. .IV-81. Cable Networks as Substitutes for ILEC Loops.IV-92. Mobile Wireless as Substitute for POTS Loops.IV-123. Direct Competitive Overbuild of ILEC Loops.IV-15i
C.V.Broadband Loops. .IV-18FACILITIES-BASED COMPETITION VERSUS RESALE . V-1A.Efficient Facilities-Based Entry. . V-31. Incremental Development of Facilities-Based Competition. . V-42. Economies of Scope and Scale. V-63. Emergence of Competitive Resale Markets. . V-94. Geographic Expansion . V-11B.The Failure of Non Facilities-Based Competition. . V-131. The Failure of UNE-Platform Competition. . V-142. The Failure of the DLEC Model. . V-14C.Anti-Competitive Impacts of Expanding UNEs into Competitive Markets. . V-181. Conversion of Special Access Circuits to UNEs. . V-182. Conversion of Transmission Services for Wireless Carriers. . V-203. Conversion of Broadband Services for Information Service Providers. V-22D.Facilities-Based Investment in New Broadband Infrastructure. . V-22APPENDICESAPPENDIX A.ESTIMATING CLEC LINESAPPENDIX B.CLEC CIRCUIT SWITCHESAPPENDIX C.WIRE CENTERS IN THE TOP 100 MSAS WHERE CLECS HAVEACQUIRED CUSTOMERS THROUGH PORTED NUMBERSAPPENDIX D.RATE EXCHANGE AREAS IN THE TOP 100 MSAS WHERECLECS HAVE OBTAINED NXX CODESAPPENDIX E.CLEC PACKET SWITCHESAPPENDIX F.WIRELESS SWITCHESAPPENDIX G.COMPETITIVE COLLOCATION PROVIDERS IN THE TOP 50 MSASAPPENDIX H.HOT-CUT PERFORMANCEii
APPENDIX I.CLECS PROVIDING ATM AND FRAME RELAYAPPENDIX J.ADDITIONAL INFORMATION ON SOFTSWITCHESAPPENDIX K.CLEC NETWORKS BY MSAAPPENDIX L.ESTIMATING CLEC SPECIAL ACCESS MARKET SHAREAPPENDIX M.ADDITIONAL SOURCES (including full citations for short cites used in thisreport)iii
I.COMPETITIVE OVERVIEWThe Commission conducted its last comprehensive review of local exchange competitionin 1999. Since that time, CLEC customer bases have been growing at significant rates, morethan tripling in the last three years. ILECs are losing roughly an equal number of lines towireless and cable networks as they are to wireline CLECs. At least 10 million wireline accesslines already have migrated to wireless networks, and several million more have migrated tocable networks. For three years running, the number of lines served by ILECs has declined – atrend never witnessed before in a century of growth of telephone service. And competitivealternatives are available to far greater numbers than are actually subscribing today.A.Competitive Facilities and Networks.The competitive networks of CLECs, wireless carriers, and broadband providers have allgrown significantly in the three years since the Commission conducted its last comprehensiveUNE review. See Table 1. The number of cities with CLEC networks has increased by morethan 70 percent, CLEC fiber has grown by more than 80 percent, CLEC circuit switches andpacket switches have both nearly doubled, and buildings served by CLECs have more thantripled. See id. CLECs now serve more lines using entirely their own facilities (including theirown local switches and loops) than they do by relying entirely on ILEC networks (through resaleor the UNE Platform). See Figure 1. All of these figures are conservative, because they aredrawn from public sources or from the necessarily limited data available to the BOCs.Table 1. Competitive NetworksWirelineCLECsCities with Voice Networks5409307001,300Packet Switches8601,700100,000184,000Average Number of CLEC Networks in Top 100 MSAs1016106,000330,000 2,000,000 10,000,000% of population in counties with 3 or more wireless operatorsn/a 91% of population in counties with 5 or more wireless operatorsBuildings Served (on- and off-net)Homes with access to cable telephony serviceBroadbandYE 2001Circuit SwitchesRoute Miles of Fiber (local and long-haul)WirelessYE 1998n/a 75Wireless Carriers Offering Data Services27% of homes with access to cable modem service2066-77% of homes with access to two-way satellite0 90Markets with MMDS058Sources: See Appendix M.I-1
Figure 1. Breakdown of CLEC Lines by Mode of Entry*Resale13%Entirely OverCLEC Facilities52%UNE Platforms23%Using CLEC Switchesand UNE Loops12%*The number of lines provided entirely over CLEC facilities and using CLEC switches is based on the number of E911 listingsCLECs have obtained. Because the actual number of lines that CLECs are serving with their own switches is likely much higher,this method will, if anything, understate the percentage of all lines that CLECs are serving in whole or in part over facilities theyhave deployed themselves. The number of lines that CLECs are serving entirely over CLEC facilities was derived by subtractingthe total number of stand-alone POTS loops from the total number of CLEC E911 listings.Switches.1 At the time of the last UNE review, CLECs had deployed approximately 700traditional local circuit switches. Today, CLECs operate approximately 1,300 known localcircuit switches. CLECs are now using their switches to serve no fewer than 16 million locallines, and likely closer to 23 million local lines, a more than three-fold increase since 1998.CLEC switches are now so geographically widespread that they are being used to serve actuallocal customers in wire centers that contain approximately 86 percent of the Bell companies’access lines.CLECs are using their switches to serve mass-market customers as well as large businesscustomers. As of year-end 2001, CLECs were serving at least three million residential linesusing their own switches, and were offering service to millions more. Circuit-switched cabletelephony has been deployed in 20 states and is now available to more than 10 million U.S.homes – approximately 10 percent of the mass market. Cable telephony is now availableubiquitously in some smaller states (e.g., Cox service in Rhode Island) and to a large andgrowing fraction of homes in a number of larger states (e.g., AT&T service in and aroundPittsburgh, Boston, Chicago, and the Bay Area, and Cox service in San Diego, Orange County,and the Tidewater area of Virginia).Packet and wireless switches are now placing significant, additional competitive pressureon the ILECs’ traditional circuit switches. Some eight million users now have broadband cableor wireless data links that terminate directly on a competitive packet switch, bypassing ILECcircuit switches altogether. Since the last UNE review, the installed base of the CLECs’ knownpacket switches has nearly doubled, from 860 to more than 1,700. The number of wirelesssubscribers has increased from about 69 million as of year-end 1998, to an estimated 130 milliontoday. A rapidly growing number of subscribers are using wireless service as a substitute forsecond and additional lines, and some consumers have abandoned wireline service entirely infavor of wireless. And wireless switches are displacing usage on wireline switches even more1See Section II.I-2
rapidly. Wireless carriers have deployed hundreds of switches, which handle an estimated 12percent of all U.S. phone calls.Interoffice Transport.2 It is clearly economical for competitors to run fiber-opticnetworks to a large fraction of ILEC wire centers. Since the time of the last UNE review,CLECs have increased their fiber networks from approximately 100,000 route miles to at least184,000 route miles, and the majority of this fiber is used for local transport. The number ofCLEC networks in the 150 largest MSAs – which encompass nearly 70 percent of the U.S.population – has grown from approximately 1,100 to approximately 1,800 in the last three years.Local fiber also is now being supplied to CLECs by carrier-agnostic wholesale suppliers, utilitycompanies, and interexchange carriers. CLECs are now using their own fiber networks tocapture between 28 and 39 percent of all revenues for special access services, which are providedthrough a combination of transport and high-capacity loops.CLECs that provide competitive transport typically do so by collocating transmissionequipment in an ILEC central office and connecting that equipment to their own fiber-opticnetwork. This “fiber-based collocation” supplies the simplest and most unambiguous indicatorof the extent of competition in the transport market. As of year-end 2001, one or more CLECshad obtained fiber-based collocation in BOC wire centers that contain more than half of allbusiness lines served by the Bell companies. As of that same date, one or more CLECs hadobtained fiber-based collocation in more than 60 percent of all BOC wire centers with more than10,000 business lines. These figures are highly conservative because, with all the competitivefiber that has been deployed, a considerable amount of traffic also now bypasses ILEC wirecenters completely.High-Capacity Loops.3 CLEC fiber networks now pass through a large number ofcommercial office buildings, which contain an even larger number of high-volume customers.CLECs now serve at least 156 million voice-grade equivalent circuits, the majority of which areprovided over high-capacity lines. And CLEC fiber networks are now so extensive that theyreadily can be – and routinely are – extended as needed to pick up additional traffic from new,off-net customers. CLECs accordingly serve the vast majority of their customers using their ownlast-mile facilities. For example, CLECs serve between four and seven times more businesscustomers over high-capacity fiber that the CLECs own themselves, than they do over loopsobtained from ILECs. CLECs have purchased only 70,000 high-capacity loops in the fourBOCs’ regions combined. Virtually all of the high-capacity loops that CLECs have purchasedare DS-1 loops; CLECs have purchased only 140 DS-3 loops, and not a single loop above theDS-3 level.POTS Loops.4 Technologies that compete directly against traditional POTS loops arerapidly being deployed across the country. Cable telephony services were available in only afew markets at the time of the last UNE review. Today, they have been expanded to the pointwhere they are now offered to more than 10 percent of all U.S. homes; that figure is projected to2See Section III.3See Section IV.A.4See Section IV.B.I-3
rise rapidly over the next few years. As noted above, cable telephony is now availableubiquitously in some smaller states and to a large and growing fraction of homes in a number oflarger states.Wireless services compete much more significantly against wireline than they did at thetime of the last UNE review. The quality of wireless services has improved significantly in thelast three years, and prices have dropped dramatically. More than 90 percent of the U.S.population now lives in counties served by three or more mobile wireless operators; more thanthree-quarters of the population live in counties served by five or more. Two in five Americanshave a mobile phone.Broadband Loops.5 Broadband loops represent an increasing share of all loops providedto mass-market customers – more than 6 percent as of year-end 2001. Broadband cable modemservice is now available to more than two-thirds of the residential population. Cable operatorsserve more than twice the number of broadband subscribers as ILEC networks, and satellite andfixed wireless providers offer additional competition. Two satellite providers now offer two-waybroadband service nationwide. Broadband wireless services also are much more widelyavailable today than they were three years ago.Interconnection of Competitive Networks and ILEC Networks. Since the last UNEreview, CLECs have significantly increased the level of interconnection between their networksand ILEC networks, and the amount of traffic exchanged between them. See Table 2. Thenumber of CLEC collocation arrangements has grown nearly six-fold since the Commissionconducted the last UNE review. See id. End offices serving more than 80 percent of all BOCaccess lines now have one or more CLEC collocators.6 The number of CLEC interconnectiontrunks has more than quadrupled since the last UNE review. See Table 2. Minutes of trafficexchanged on these trunks have increased by about five-fold. See id.Table 2. Interconnection of CLEC and ILEC FacilitiesCollocation ArrangementsInterconnectionTrunksMinutes 0663,0003.4 million32 billion193 billionSBC**2,0009,900541,0003.1 million23 billion125 billionBellSouth8704,700326,0001.3 million21 billion98 billionQwest2403,300285,000927,00020 billion78 billion4,30024,9002 million9 million96 billion493 billionTotalTotals may not equal sum of parts due to rounding. *1998 collocation arrangements exclude the former GTE service area. Minutesexchanged data exclude CLEC-terminated minutes for the former GTE service area. **1998 minutes exchanged data exclude theAmeritech service area.5See Section IV.C.6See Section II.A, Table 10.I-4
B.Competitive Lines Served.Since the last UNE review, CLECs, wireless, and broadband providers have verysignificantly increased the number of customers and lines that they serve. See Table 3. Therehas been especially large growth in the number of lines that CLECs serve with their ownfacilities. By contrast, ILEC access lines have steadily declined in each of the last three years, anunprecedented trend in a century of steady annual growth. See Figure 2.CLECs serve no fewer than 16 million lines and likely closer to 23 million lines –including approximately three million residential lines – wholly or partially over facilities theyhave deployed themselves, facilities that invariably include their own local switches.7 These linetotals represent a more than three-fold increase since 1998, and a more than thirty-fold increasein facilities-based residential lines. Many of the lines that CLECs serve are high-capacity lines;CLECs now serve at least 156 million voice-grade equivalent circuits.8 CLECs also serve morethan 9 million lines – including more than 5 million residential lines – via resale of ILEC serviceor through the UNE Platform. The corresponding figures three years ago were approximately2.7 million CLEC lines, including 1.5 million residential lines. Today, the largest CLECs servemore than one million access lines each, and large numbers of CLECs serve 500,000 or more.See Figure 3.Table 3. Competitive Lines/SubscribersWireline CLECsWirelessBroadbandFacilities-Based Business LinesFacilities-Based Residential LinesResale/UNE-P Business LinesResale/UNE-P Residential LinesWireless Subs.Wireless Data Subs.Cable Modem Subs.Fixed Wireless/Satellite Subs.YE 19985-6 million 80,0001.2 million1.5 million69 millionn/a 300,0000Sources: See Appendix M.7See Section II.A.8See Sections II.A & IV.A; see also Table 4, infra, and Appendix A.I-5YE 200113-20 million3 million3.8 million5.6 million130 million6.7 million7.5 million 200,000
Figure 2. Decline of BOC Access LinesAccess Lines (in millions)200Trend (based on 1996-1998 average annual growth rate of urces: Credit Suisse First Boston; FCC. See Appendix M.Figure 3. CLEC Access Line DistributionNumber of CLECs12101111199810988200186544320050,000 - 99,999100,000 - 249,999250,000 - 499,999500,000 - 999,9991 million or moreSource: New Paradigm Resources Group. See Appendix M.The CLECs’ share of access lines in BOC regions is at least 16 percent, and likely closerto 20 percent. See Figure 4. Their share of BOC residential lines is approximately 9 percent,and their share of BOC business lines is at least 26 percent, and likely closer to 33 percent. Insome BOC regions, the CLECs’ share of lines is even higher. And, as noted above, at least twothirds of all CLEC lines are provided wholly or partially over facilities they have deployedthemselves.I-6
Figure 4. Percentag
network. This “fiber-based collocation” supplies the simplest and most unambiguous indicator of the extent of competition in the transport market. As of year-end 2001, one or more CLECs had obtained fiber-based collocation in BOC wire centers that contain more than
To: Metalogix International GmbH ( kathleen@ansarilaw.com ) Subject: U.S. TRADEMARK APPLICATION NO. 85255200 - METALOGIX - N/A Sent: 3/14/2013 12:13:23 PM Sent As: ECOM112@USPTO.GOV Attachments: Attachment - 1 Attachment - 2 Attachment - 3 Attachment - 4 Attachment - 5 Attachment - 6 Attachment - 7 Attachment - 8 Attachment - 9 Attachment - 10 .
Attachment 2: Principal Candidate Resume Attachment 3: School Administrator Resume Attachment 4: Governance Documents Attachment 5: Statement of Assurances Attachment 6: Board Members Information Attachment 7: Conflict of Interest Attachment 8: Scope and Sequence Attachment 9: Academic E
BUDGET, FINANCE, AND INFRASTRUCTURE COMMITTEE March 23, 2022, TIME: 10:15 AM to 12:15 PM THE CAROLINA INN OPEN SESSION FOR ACTION Attachment A Attachment B . Attachment C . Attachment D Attachment E Attachment F Attachment G . Attachment H. 1. All-Funds Budget Model. Nathan Knuffman, Vice Chancellor for Finance and Operations 2.
To: Metalogix International GmbH (kathleen@ansarilaw.com) Subject: U.S. TRADEMARK APPLICATION NO. 85255200 - METALOGIX - N/A Sent: 1/6/2015 11:03:38 PM Sent As: ECOM117@USPTO.GOV Attachments: Attachment - 1 Attachment - 2 Attachment - 3 Attachment - 4 Attachment - 5 Attachment - 6 Attachment - 7 Attachment - 8
Federal Communications Commission FCC 21-58 3 section 7402 of the Act, which established a 7.171 billion Emergency Connectivity Fund in the Treasury of the United States.5 Section 7402 directed the Federal Communications Commission (Commission) to promulgate rules providing for the distribution of funding from the Emergency Connectivity Fund to
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Federal Communications Commission FCC 19-80 Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Implementation of Section 621(a)(1) of the Cable Communications Policy Act of 1984 as Amended by the Cable Television Consumer Protection and Competition Act of 1992))))) MB Docket No. 05-311 THIRD REPORT AND ORDER
The Federal Communications Commission (FCC) is an independent federal agency established by the Communications Act of 1934 (1934 Act, or "Communications Act"). The agency is . Overview of Federal Regulations and the Rulemaking Process, by Maeve P. Carey, and CRS Report RL32240, The Federal Rulemaking Process: An Overview, coordinated by .
