Scott; I apologize. You could very well sincerely not realize you are wrong. Obviously, erroneous thinking is not the same as making things up. However, it is not good that bad information is out there and it should be corrected. First you refer to them as "dry copper" or "dry pair" which has no regulatory meaning. I don't know if using the wrong term is part of the reason you have had difficulty ordering them. The proper term is Unbundled Network Elements(UNE) copper loops. UNEs are the elements the ILECs are required to sell to CLECs. There are a variety of different types of UNE loops. The most accurate way to identify them is probably referring to an ILEC wholesale tariff filed on a state-by-state basis. The FCC defines Section 251 requirements, but individual state PUCs administer the tariffs for their locations. Second, going to any document by the NTCA, an advocacy organization, for information on this topic is a mistake for obvious bias reasons. The controlling documents are the Telecommunications Act of 1996 (Telco Act), the FCC's Triennial Review Order[s](TRO), various ILEC tariffs and the individual InterConnection Agreements(ICA) between ILECs and CLECs. Under the Telco Act, UNE loops are a Section 251 requirement. The FCC has primary responsibility for administering Section 251 requirements and the FCC's rules for doing so are put forth in the TROs. The last TROs were released in 2004, so that would be the last time "the rules changed" as you put it. So there has not been a recent change in the rules resulting in residential CLEC demise. Third, it is true that an ILEC is not required to add capacity. However, it is hard for me to believe anyone would say with a straight face that any residential CLECs went out of business primarily because ILECs are not required to add copper. In a period where there is steady erosion of landlines resulting in a lot of unused copper loops, lack of copper loops is a small issue. Some residential CLECs went out of business because they had broken business models. Some residential CLECs became successful business CLECs as well, check out Earthlink (NASDAQ: ELNK). The controlling issues are more financial than regulatory. We have had the same regulatory regime for almost a decade. Any prudent DSL provider, ILEC or CLEC, should have plans for a transition to copper, but the copper network still has useful life in it for residential CLECs as well as other markets. Fletcher On Sun, Feb 3, 2013 at 9:53 PM, Scott Helms <khelms@zcorum.com> wrote:
Fletcher,
Your specific case may vary, but I am most certainly _not_ "making stuff up". In many territories, especially outside of major metro areas, you cannot order dry pairs. This has been because of a combination of relaxed rules (if you really want I can dig up the NTCA reports on this) and because the rules never required the ILEC to add capacity once they were used up.
On Sun, Feb 3, 2013 at 9:29 PM, Fletcher Kittredge <fkittred@gwi.net>wrote:
In this particular post, your making stuff up. There are still "residential focused" CLECs and ordering Unbundled Network Elements(UNEs) is not more difficult than in the past. The rules haven't changed.
What is certainly true is that many CLECs have found that it is more lucrative to sell to businesses, but I don't think there is a correlation with residential getting more difficult. We used to be 75%/25% residential/business and are now 45%/55% business, but that reflects the *rapid* growth of the business market.
regards, Fletcher
On Sun, Feb 3, 2013 at 3:42 PM, Scott Helms <khelms@zcorum.com> wrote:
Joe,
I'm assuming from your domain that you're in Canada where yes dry pairs are still generally available. I apologize for not making it clear that my comment was specifically about the US where dry pairs are nearly impossible to order today and the CLEC market has almost entirely abandoned the residential space. In fact, the only state in the US that I still see any residentially focused CLECs is Texas which tells me there is something about the regulations in that state that makes it more feasible.
On Sun, Feb 3, 2013 at 3:32 PM, Joe Abley <jabley@hopcount.ca> wrote:
On 2013-02-03, at 14:39, Scott Helms <khelms@zcorum.com> wrote:
Dry pairs are impossible to order these days for a reason.
Dry pairs are trivial to order round these parts. Generalisations are always wrong, no doubt including this one.
Joe (putting the N back in NANOG)
-- Scott Helms Vice President of Technology ZCorum (678) 507-5000 -------------------------------- http://twitter.com/kscotthelms --------------------------------
-- Fletcher Kittredge GWI 8 Pomerleau Street Biddeford, ME 04005-9457 207-602-1134
-- Scott Helms Vice President of Technology ZCorum (678) 507-5000 -------------------------------- http://twitter.com/kscotthelms --------------------------------
-- Fletcher Kittredge GWI 8 Pomerleau Street Biddeford, ME 04005-9457 207-602-1134