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/