Washington, D.C., February 17, 2000 - The Competitive Telecommunications Association (CompTel), the leading industry association of competitive telecommunications providers and their suppliers, in comments to be filed today with the Federal Communications Commission (FCC), urged the FCC to reconsider certain provisions of its Third Report and Order and Supplemental Order in the Local Competition docket that are inconsistent with the 1996 Telecommunications Act because those provisions let incumbent local exchange carriers (ILECs) impair the ability of competitive local exchange carriers (CLECs) to provide service in both residential and business markets.

"CompTel urges the FCC to reconsider several crucial provisions in its Third Report and Order and its Supplemental Order; these provisions could have a profoundly negative impact on efforts by competitive local service providers to enter the market and to provide businesses and consumers with the competitive choice intended by the architects of the '96 Telecom Act," said CompTel President H. Russell Frisby, Jr.

Specifically, CompTel stated that:

• the FCC should reconsider the four-line cut-off for exemption from the unbundling requirement for local switching, which is not based on the Act's "impair" standard or supported by the facts. Moreover, four lines ignores the reality of serving today's small business market. CompTel has submitted ample evidence showing that ILECs' failure to provide access to local switching to customers with less than a DS-1 interface "impairs" a requesting carrier by materially diminishing that carrier's ability to provide the services it seeks to offer.
  
  
• the FCC should require the ILECs to unbundle interoffice packet transport and interoffice packet switching functionalities. Packet-switched services consist not only of packet switching network elements -- which include both digital subscriber line access multiplexers (DSLAMs) and interoffice packet switching -- but also combinations of packet transport and switching elements that have unique characteristics which justify their definition as unbundled network elements (UNEs).
  
  
• the FCC should clarify that Rule 315 entitles requesting carriers to provide any service to any customer through a UNE combination if the ILEC provides or uses that combination anywhere in its local network. Furthermore, the FCC should define the Enhanced Extended Link (EEL) as a UNE rather than as a UNE combination.
  
  
• the FCC should reconsider its decision to impose usage restrictions on UNEs; any such use restrictions -- even temporary restrictions -- are unlawful under the Act.

Copies of CompTel’s filing are available online at CompTel’s Web site, www.comptel.org, or by contacting the association’s public relations office.

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Last Minute Reminder: Registration for media who wish to attend CompTel’s Annual Convention and Trade Exposition Feb. 20-23 in Long Beach, CA is free. See CompTel’s Web site home page, Long Beach Press Info for information at www.comptel.org or, contact Pam Small (psmall@comptel.org) or Kathleen Franklin (kfrankln@erols.com), 202/296-6650.

Based in Washington, DC, CompTel is the leading trade association representing approximately 350 U.S. and international competitive communications firms and their suppliers who offer a variety of local, long distance, Internet and wireless services. The association’s members include global and national firms, regional carriers and emerging local competitive companies.