Also sprach Owen DeLong
And, of course, we all know how well BOCs (Bell Operating Companies) and other incumbent LECs (Local Exchange Carriers) follow such rules.
Indeed...BellSouth was operating BellSouth.Net for several *years* before they filed a CEI plan for that service. Yes, the CEI for Internet Services was filed by BellSouth in August of 2000! When did BellSouth.Net first role out? ONA reports aren't worth the paper they're printed on (check the comment filings in the FCC consideration of Computer III requirements for some humorous comments about the usefulness, or rather lack thereof, of ONA reports). Cost accounting only serve to force the BOCs to be a bit more creative in their tariffing in order to screw ISPs. Again, BellSouth was found guilty of providing preferential and discriminatory pricing in Kentucky based on the tariff that they filed that followed the letter of the law. Furthermore, BellSouth has *yet* to fully comply with *any* of the KY PSC orders in our case. Then add to all of this that the BOCs often flat out lie to regulatory bodies. I've personally heard representatives of BellSouth claim multiple times (as late as last week) that they are fully in compliance with FCC accounting guidelines. This in spite of an FCC audit report showing that BellSouth's accounting over-states their costs by as much as 18% (!) because BellSouth can't find a significant amount of their hard-wired equipment (read: equipment that is not easily transportable...ie, stuff that's bolted to the ground!). This is "full compliance?"
The problem is that most of these safeguards are not really enforceable, and the telecom providers violate them at will. Heck, look at how easily Pac Bell was able to drive MCI out of the local telco business in California by dragging their feet on service/install requests, making repeated mistakes in the process, etc. (Yes, Pac Bell makes mistakes with their own customers as well, but these were mistakes that looked suspicious, even compared to Pac Bell's usual level of incompetence).
SBC is one of the scariest, slimiest, sleaziest organiziations I've ever run up against. They truly fit the definition of Telco someone posted a while back (A law firm with a side business in telecommunications). They have certainly violated most, if not all, of the safeguards mentioned below, and their new contract certainly violates the spirit, if not the letter, of said same safeguards.
Owen
Robert Cannon of cybertelecom.org asked I submit this re: the SBC Contract thread....
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In proceedings going back to 1966 known as the Computer Inquiries, the FCC established a series of safeguard rules that create ISP rights to telecommunications. The Computer Inquiries first divided the world into Enhanced Service Providers (aka computer networks, ISPs, information service providers) and basic telecom. Enhanced service providers are unregulated by the FCC. But acknowledging the dependency of ESPs on the underlying telecom monopoly (remember this is 1970s and 1980s), the FCC created a series of safeguards.
The safeguards require all facilities based telecom carriers who offer ISPs services to unbundle the services and offer them to independent ISPs on the same terms and conditions. BOCs have added requirements; they can elect to have an ISP through a separate subsidiary (Computer II) or they can have an integrated ISP if they file a comparably efficient interconnection plan (Computer III). BOCs, regardless of whether they have an ISP, were also required to create Open Network Architecture plans, breaking their networks down to basic building blocks for the benefit of ISPs.
Additional safeguards that generally fall on all carriers include prohibitions against discrimination, requirements that line provisioning be completed in the same time frame, cost accounting rules, prohibitions against cross subsidization, requirements for network information disclosure, and restrictions on the use of customer information.
I have created a white paper entitled "Where ISPs and Telephone Companies Compete: A Guide to the Computer Inquiries, Enhanced Service Providers and Information Service Providers." It is available at http://www.cybertelecom.org/ci/ciii.htm#guide It explains these rules as they exist today.
-B __________________________________________________
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