Subject: Response to John Schwartz' Questions
Maureen Lewis (mlewis@apt.org)
Date: Thu, 02 Jul 1998 12:01:02 -0700
Message-Id: <359BD8EE.AEB@apt.org> Date: Thu, 02 Jul 1998 12:01:02 -0700 From: Maureen Lewis <mlewis@apt.org> To: roundtable@cni.org Subject: Response to John Schwartz' Questions
John:
I'm sorry that I haven't responded to you within the timeframe you
thought appropriate, but as APT's sole employee, I've been very busy
during the last month advancing the proposals in our petition, in
addition to my many other responsibities. Like many small nonprofits,
APT's resources are meager. Consequently, while we appreciate the
listserve exchange, understand that we are doing our best to maximize
both our resources and our impact. For the past 10 years, APT has, and
will continue, to work to ensure that everyone, particularly members of
traditionally underserved communities, receive the benefits of advanced
telecom. Although there may be disagreement on the best approach to
achieve that end, I hope that we can at least agree on that goal as a
basis for moving forward.
In that regard, I am attaching a response to issues you raised from Don
Vial, Chair of APT's policy committee.
"Your selective questioning of APT's recommendations to remove
barriers to advanced telecommunications infrastructure, such as ADSL,
has us somewhat puzzeled as our recommendations to remove those
barriers appear to be read by you in splended isolation of our
recommendations (p.28-41 of filing) to promote pro-actively
infrastructure investments for advanced capablilities, partilcular to
bring marginalized communities into the orbit of the digital age.
These latter recommendations are ignored by virtually everyone, yet
they are the key to understanding our policies on removing current
barriers to infrastructure investments.
When we support incentives for the ILECs to upgrade their networks, we
want those incentives to be linked to pro-active policies which foster
deployment that confronts the "electronic redlining" of the
"competitive" marketplace--that is, the great digital divide that is
advancing a new infrastructure base for another round of economic and
social polarization of the society. Also, when we support the opening
up of ILEC networks for the CLECs, we want the same pro-active
policies to apply to them. We have no desire to support competition
for the sake of competition when competitors piggyback with their
incremental investments on existing infrastructure investments to milk
the high end of the market, leaving behind disincentives to upgrade
the network they are riding. We want the CLECs to have access to the
local loop that will be compatible with Section 706, and we see our
recommendations relating to proactive policyies to be an
integral part of the policy.
Thus you might want to rephrase your question in that context. Are the
Colorado CLECs which you reference in your question interested in ADSL
deployment to marginalized communities as well as the high end of
the market? We believe that the ILECs should be held to that objective
and hope that you would want the same for the CLECs you reference.
In any event, we would want to make it clear that the CLECs should
have access to dry copper for ADSL, the same as a subsidiary of an
RBOC that rolls out ADSL on a competitive basis with others that have
access to the same dry copper. If conditioning of the copper is to be
involved, the price for the dry copper should reflect the conditioning
to the subsidiary as well as the competitors. Further, as to the DSLAM
in the central office, APT supports colocation of the competitor's
DSLAM. As far as switching for voice that is separated from data by
the DSLAM is concerned, a competitor's voice switch can be located
anywhere and they are free to invest in such switches to go with their
co-located DSLAM. In this way, ADSL investments by ILECs can be
separated from the unbundling that is required for the existing
telephone network.
The devil may be in the detail of regulation, but we believe we have
advanced a framework for encourgaging ADLS roll out that is
compatible with the interests of CLECs as well as the ILECs. The
convergent technolgies are driving network reconfiguration and
are rendering obsolete much of the regulatory framework that
seeks to determine how the products and services of the digital age
are delivered. We hope that current efforts to increase bandwith
through various technolgies will help to focus some of your interests
in how the competitors are going reach out to the full spectrum of
society. If you read pages 28-41 of our 706 filing you'll see that we
are far ahead of the pack in looking for viable options in public
policy...."
Maureen Lewis
<mlewis@apt.org>
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