On 11/14/2011 07:56 PM, Douglas Mortensen wrote:
I think that you actually should be looking to your state. I’m
pretty sure that even if CLEC is an FCC designation, it is
implemented either on a per-state or per-LATA basis. Here in NM
there’s only 1 LATA, which is why I’m not completely sure. But I
believe that the CLEC qualifications & designation is actually
managed by the State of NM where I am. One of the state departments
had all of the info & seemed to be in charge.
CLECs are certified on the state level, by state public utility
regulators, in most states known as the state PUC ("public utilities
commission").
Being creatures of the local loop, interconnection with the ILEC is
something that takes place separately in every LATA, often on somewhat
different terms even within the same state.
Negotiating a viable ICA (interconnection agreement) with the ILEC is
one of the most important elements of success or failure, and is a
massive endeavour of both personal scholarship and legal expenditure.
The details of the agreement - most opt-in agreements are hundreds
of pages long - are ones by which CLECs live or die, especially if
they are doing a lot of local access, intra-LATA origination, or UNE
facilities.
And even if there is more paperwork, reporting, red tape, etc.
there are also some MAJOR discounts to be had on circuits due to
the regulation that is placed on the ILECs to foster competition.
They hate it. But it’s not going to change any time in the
foreseeable future.
Yeah, discounts are nice. UNE DS1s in LATA 438 are $44/mo. Many
people lick their chops at such a prospect.
What these prices don't take into account is the up-front and
recurring cost of:
- CO backhaul (usually dark fiber of your own, sometimes ILEC fiber).
- CO colocation - expensive, requires third-party vendors, and plenty
of insurance.
- CFA (circuit facilities assignment) - your cross-connects for UNE
handoff in the CO.
- EELs for dragging circuits out of COs in which you aren't colocated;
you won't go into all of them, it's expensive.
- COs where UNE pricing discipline is suspended because of the ILEC's
finding of "sufficient competition", in favour of special access.
Amortise the up-front and recurring monthly cost of all those pain
points and see what your new "discounted" rates are.
--
Alex Balashov - Principal
Evariste Systems LLC
260 Peachtree Street NW
Suite 2200
Atlanta, GA 30303
Tel: +1-678-954-0670
Fax: +1-404-961-1892
Web: http://www.evaristesys.com/
--
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