|
|
Enron Mail |
EBS Government Affairs wanted to give you an update on our meeting at the
FCC last Thursday, April 26. Also contained is a brief discussion of current FCC proceedings, what we are doing to be better informed and some suggested actions. Sue Nord, Stephen Burns (DC Office), Lara Leibman and I met with the following people from the Common Carrier Bureau of the FCC: Jane Jackson, Chief, Competitive Pricing Division Rich Lerner, Deputy Chief, Competitive Pricing Division Jay Atkinson, Chief Economists, Common Carrier Bureau Tom Beers, Deputy Chief, Industry Analysis Division Michelle Carey, Chief, Policy and Program Planning Division Tim Peterson, Deputy Chief, Accounting Safeguards Division The purpose of the meeting was to do an introduction of EBS and explain our overall business strategy, to establish a point of contact with the various divisions of the FCC Common Carrier Bureau, and to solicit some information relative to the pending proceedings at the FCC. The biggest take-away from the meeting was that we impressed upon them the effect the issues before them (EELs, Access to High Capacity Circuits) will have on carriers entering the market who want to provide high-speed data and content services to large customers, as well as to the development of a bandwidth trading environment. Because of the appointment of the new chairman, Powell, and the pending appointments of three new commissioners, the division heads were very uncertain about policy direction at the FCC in the near term. They seemed interested in Enron as different than most carriers. They suggested that we pursue filing ex-parte written comments in the EELs proceeding specifically addressing how the usage restrictions on EELs would affect Enron's ability to provide the referenced services. We will be developing a draft of the EELs ex-parte communication this week. They also informed us of an EELs Task Force at the FCC, with whom we will make contact within the week to arrange a meeting. They didn't seem to discourage us from requesting the elimination of the usage restrictions, although they did indicate that Powell favors the usage restrictions. With that, we should regard the elimination of usage restrictions as a long-shot. In addition to EELs, there are other FCC proceedings about which we are gathering information. They include the ILEC's (Bell South, Verizon and SBC) petition to remove high capacity circuits as UNEs, a collocation proceeding and a new intercarrier compensation proceeding. The ILEC petition for a declaratory ruling by the FCC that high-capacity circuits (loop and transport) are no longer required to be provided as UNEs is pending. There has been a motion to dismiss filed, but we haven't obtained a copy as of yet. There is an opportunity to file comments by June 10. We will be doing some background on whether we will want to file in conjunction with other groups or singularly. We will definitely be soliciting your feedback on the substance of the comments. We will keep you informed of important developments. There is an open collocation proceeding. We were told at the meeting that there is still an opportunity to file comments. This proceeding will address CLEC cross-connections within the central office, types of equipment that can be collocated within the CO, and varieties of collocation that must be offered (i.e. caged, cageless, virtural, etc.). We will have to examine the importance of this case relative to the outcome of the EEL proceeding and our current analysis of special access versus UNEs. On Friday, the FCC issued a notice of proposed rulemaking (NPRM) dealing with intercarrier compensation. This will deal with the compensation that ILECs and CLECs pay to one another to terminate local voice traffic on the other's network. It will also address the access charges that local carriers (ILECs and CLECs) charge long-distance providers to terminate long-distance traffic. It is possible that special access pricing may also be at issue. The focus may be the disparity in pricing between UNEs and special access service. If the usage restrictions on EELs are removed, I would think that the importance of addressing pricing disparities between special access and UNEs will be elevated. We will monitor this proceeding for opportunities to weigh in as well. Finally, we expect the Industry Analysis Division to come out with report about the penetration of internet access in the US. This may be of interest, but may not require any involvement. If you have any questions or comments on this memo, feel free to contact me.
|