Special Access, Part 2: No Longer Special?

Note - This was originally posted on the Overtones blog site (http://www.overturenetworks.com/connect-with-overture/overtones-blog/special-access-part-2-no-longer-special/) on the Overture Networks web site. This site is no longer available.

Please see last week's entry on "How Did We Get Here?" for a recap of the history of AT&T and the breakup of the Bell System.

Timeline for Special Access

After the breakup of AT&T, one of the assets that the new BOCs (now ILECs) owned was the copper plant that had been constructed under monopoly conditions. Part of the deal to enable competitive carriers (CLECs) was providing access to this copper plant and services under the umbrella of "special services".

Over time special services access has included the following options:

• "Finished" services such as T1s and DS3s
• Access to ports on the ILEC switch as an unbundled Network Element Platform (UNE-P) .
• Access to the raw wiring plant as an unbundled network element loop (UNE-L), also known as "unbundled copper" or "dry copper." This involves the CLEC deploying a switch at the central office (CO) where the copper pairs land.

Here is a timeline:

• 1974: DOJ files antitrust lawsuit against AT&T
• 1982: AT&T Settlement finalized
• 1984: AT&T Breakup effective
• 1999: FCC provided rules for deregulation for special access under certain conditions
• 2009: FCC Notice of Inquiry - start of National Broadband plan
• 2010: FCC issues National Broadband plan
• 2011-2012: Filings by ILECs to change rules.

Currently the majority of CLEC access is via finished services or dry copper. Finished services have the advantage of not requiring the CLE to deploy equipment in the CO. However, the cost per Mbit is much higher for finished services that it is when the CLEC leases dry copper and deploys their own equipment.

Since the original breakup there has been jockeying between the ILECs, CLECs and FCC about the structure, pricing and lifetime for special access. In particular, the ILECs have been pushing for deregulation of special access. The filings to the FCC [1] have focused on a couple of points, both of which I feel are weak. Here are some arguments that we at Overture made in our Ex Parte filing to the FCC [2].

Argument #1: The National Broadband Plan is pushing for a transition from TDM to IP

One of the ILEC filings makes the point that the FCC's National Broadband Plan [3] emphasizes the need for IP services rather than traditional TDM offerings. The filing argues that copper should be retired because it is primarily used for TDM. This position ignores the fact that that Ethernet over Copper is a significant and widely deployed next generation technology that is critical to the National Broadband Plan and the migration from legacy to Ethernet/IP services. In particular Ethernet over Copper is a means to deliver IP, and not a legacy TDM technology.

Argument #2: Fiber is now available

It is true that fiber is now more widely deployed than ever before. The fact remains that fiber is deployed to only 31% of business locations with greater than 20 people, according to Vertical Systems and as shown in the nearby figure.

Regardless of whether it is a single location or multi-location business, a business that cannot get Ethernet/IP to all of its sites will not make the change to next generation services and will stay with the legacy services. Because Ethernet over Copper can fill in the gaps for 69% of business locations, having access to copper loops is critical for accelerating the adoption of IP-based services. Ethernet over Copper is the way to bring IP to the mass market, excelling in the delivery of Ethernet/IP in the range of 10 Mbps to 100 Mbps.

Competitive carriers / CLECs have recognized this opportunity and acted. According to Infonetics Research, the number of ports deployed for Ethernet over Copper services has been growing at over 20% per year, and this will continue to grow at this pace at least through 2016 (last year of survey). In fact, each year more copper ports are deployed than fiber ports at a ratio of almost 2:1, as shown in the nearby diagram.

This phenomenon of more copper ports than fiber ports for Ethernet is easy to explain. A company decides to transition to Ethernet/IP based services but only 31% of its buildings have access to fiber. Rather than sign another 3 year contract to keep its legacy services, the enterprise learns that it can get Ethernet /IP services to all of its locations from a carrier deploying a combination of both fiber and copper technologies. The result is that 2 out of every 3 buildings have the new services delivered by copper.

What's Next?

Some of the ILECs have petitioned the Commission to allow the retirement of TDM services and copper facilities based on the availability of residential class IP services in some locations. The FCC should distinguish legacy TDM services from modern Ethernet over Copper services that use unbundled copper. Based on the statistics shown above, a premature retirement of unbundled copper loops would have a devastating impact on the availability of advanced IP services for a large portion of the U.S. population.

Ethernet over Copper is growing just as fast outside the U.S. In the U.K., British Telecom has been deploying Ethernet over Copper for wholesale services for a number of years and has more than 11,800 endpoints installed. In Mexico, TelMex has begun a large-scale Ethernet over Copper deployment. Overture is familiar with similar rollouts throughout Europe, Asia and Australia. All of these countries recognize the need to complement their fiber initiatives with copper in order to make available the most bandwidth to the most people in the shortest amount of time.

At Overture, we believe that Ethernet over Copper is a significant and widely deployed next generation technology that is critical to the National Broadband Plan and the migration from legacy to Ethernet/IP services. Any ILEC plan to decommission or retire legacy services which may run on copper (or fiber) should not impact access to copper in feeder facilities or distribution facilities by other service providers. This copper can be and will be used for next generation Ethernet over Copper services and will accelerate achievement of the Commission's broadband goals.

This issue is a good example of how regulatory policy can help or hinder the goal of modernizing access to the network. Regulatory bodies must tread carefully to avoid unintended consequences.

References:

[1] AT&T, "Petition to Launch a Proceeding Concerning the TDM-to-IP Transition", http://www.att.com/Common/about_us/files/pdf/fcc_filing.pdf
[2] Overture Networks, Ex Parte Notice to FCC, http://apps.fcc.gov/ecfs/comment/view?id=6017148225
[3] FCC, "National Broadband Plan," http://www.broadband.gov/plan/

Special Access, Part 1: How Did We Get Here?

Note - This was originally posted on the Overtones blog site (http://www.overturenetworks.com/connect-with-overture/overtones-blog/special-access-part-1-how-did-we-get-here/) on the Overture Networks web site. This site is no longer available.

This blog is the first of a two part series on regulated or "special access" for copper. This discussion is particular to the US, especially regarding the breakup of the Bell System. However, there are similar regulatory considerations worldwide, especially regarding shared access to new fiber facilities.

Before we get to the details of special access, it's worth taking a look at how we got to the current situation. For those who came in late (and as a reminder for the rest of us), let's fire up the WABAC machine and revisit the composition and breakup of the Bell System and the original AT&T, along with the beginnings of the CLECs.

Ma Bell - 107 years in the making, 8 years in the breaking

The Bell Telephone company was born in 1877 and was the parent of what became the Bell System [1]. There was an initial breakup in 1956 when some international holdings were divested, including some other international companies such as Bell Canada, Nortel, NTT and NEC.
In 1984 the Bell System had four main constituents in the US:

• AT&T Long Lines: The long distance business
• Western Electric: The equipment manufacturing business
• Bell Labs: the R&D arm
• The Bell Operating Companies (BOCs): the 21 regulated utility monopolies providing local phone service.

The BOCs or "Baby Bells" are essential to part 2 regarding special access. Like other regulated utilities, the BOCs made significant investments in capital, building out the copper infrastructure that would eventually provide universal access. The local access fees charged by the BOCs were augmented by universal access subsidies from the government along with subsidies from the very high long distance fees.

Over time some there was some competition to AT&T, including some equipment manufacturers and innovations such as modems for transporting data. Overall, the competitive pressures on AT&T were low, as would be expected from a regulated monopoly.

The Bell System had been in place for over 100 years when the US DOJ filed an antitrust suit against AT&T in 1974 [2]. The suit ground on for 8 years until a settlement was reached on January 8, 1982. Under the settlement the Bell System agreed to divest its BOCs, and received the right to go into the computer business in return. The breakup became effective January 1, 1984 [2].

As a result of the breakup there was increased competition in the long distance market from companies like MCI and Sprint. In addition, there emerged a new class of company - the Competitive Local Exchange Carrier or CLEC. These new CLECs were enabled by the rules for special access, which will be discussed in part 2. However, the local access market was still dominated by the BOCs.

Back to the Future

Over time the BOCs started to re-coalesce into larger companies. The figure below was adapted from [3] and [4] to show the evolution after the breakup.

What was once two entities (AT&T Long Lines and the collection of BOCs) went to eight (AT&T and the seven BOCs) and has now shrunk back to three (AT&T, Verizon and CenturyLink). Are we back where we started? Not exactly. Changes from 1984 include much stronger competition in the local markets from cable and wireless providers, as well as from new facilities-based carriers. However, the copper infrastructure built during the regulated monopoly phase is still critical for reaching business subscribers. In fact, only about 30% of business locations are reachable by fiber.
Part 2 of this discussion will discuss the topic of special access in more detail.

References

[1] Wikipedia, "Bell System," http://en.wikipedia.org/wiki/Bell_System
[2] Wikipedia, "Breakup of AT&T," http://en.wikipedia.org/wiki/Breakup_of_AT%26T
[3] Wall Street Journal, "A tangled family tree," http://online.wsj.com/article/SB10001424052748704471904576229250860034510.html?mod=WSJ_hp_LEFTTopStories#articleTabs%3Dinteractive
[4] Long or Short Capital, "The Regulatory Inefficiency Theorem," http://longorshortcapital.com/regulatory-efficiency-theorem.htm