The FCC has been wrestling with several proposals for the availability of a network element configuration commonly referred to as an extended link, or "EEL." EELs enable competitors to serve a broader number of customers in the local market through additional monopoly-owned central offices, without incurring higher costs or lengthy delays normally associated with establishing multiple collocation arrangements with the local monopoly.

"CompTel’s member companies consider the unrestricted availability of EELs as one of their highest priorities in the FCC’s proceeding on UNEs," said Carol Ann Bischoff, CompTel’s Executive Vice President and General Counsel in a letter sent to the Commission on behalf of CompTel’s members. "To bring the benefits of local telephone competition to all Americans, the FCC can – and should -- define EELs as a separate network element to be provided by the ILECs."

The ILECs have claimed, however, that the availability of EELs will erode their revenues. CompTel has challenged the ILECs’ claim that unrestricted access to EELs would erode revenues and negatively affect support of universal service. Under CompTel’s proposed framework, ILECs would be required provide transport facilities from a ICP’s first point of connection to the ILEC’s network (also known as the "entrance facility") as an unbundled network element (UNE) until the following conditions are met:

• The ILEC has fully implemented the FCC’s collocation rules, with cageless collocation arrangements being available at state-approved TELRIC-based rates;
• The ILEC must provide the EEL as a UNE without restriction. The EEL would be provided by the ILEC to an ICP’s collocated facilities, at which point the ICP would carry its traffic to its network using competitively-provided entrance facilities;
• The FCC determines that the ILEC must continue to provide all other transport facilities, and those facilities can be used by competitors without restriction. This would allow ICPs to efficiently aggregate traffic at their collocation and entrance facilities.

CompTel has consistently advocated the wide availability of UNEs without customer- or use-related restrictions. CompTel believes such limitations are "contrary to the pro-competitive, pro-consumer goals of the 1996 Act and are inconsistent with said Bischoff. "It is critically important to the competitive industry that the FCC hold firm and remain committed to a restriction-free UNE environment," Bischoff added.