-- Qwest impermissibly includes non-facilities-based lines in its
competitive analysis. Qwest's line count often includes competitors'
services that rely on Qwest's own loops and transport. These are not
permissible within the Commission's framework.
-- Qwest's estimates of carriers' line counts cannot substitute for
actual line count data. Qwest's line counts are drawn from white pages
directory listings and are, by its own admission, only "estimates of CLEC
and cable telephony facilities-based lines." Qwest, in fact, urges the
Commission to rely on competitors' own analysis as being more reliable.
-- Qwest misinterprets the Commission's discussion of cut-the-cord
wireless lines in the Verizon 6-MSA Order. Qwest includes so-called
"wireless substitution" in its line counts of competitors' facilities.
Wireless services should be completely excluded from the Commission's
competitive analysis. The Commission did not make a sweeping ruling that
wireless service is always a substitute for wireline local telephone
service in every product market. Further, recent research by Economists
Incorporated shows that residential wireless services are not a substitute
for wireline service, at all, and even if they are substitutes in the
narrow residential voice market, research by Gillan Associates shows that
Qwest improperly calculates the level of cut-the-cord lines.
Broadband Market Overlooked
The competitive telecom companies argued that consideration of successful
competition in the mass and enterprise markets is not sufficient, and that
the Commission also must consider the state of competition in another key
segment -- broadband. In the same way that it omitted analysis of
competition in the small business market, Qwest similarly had not addressed
competition levels in the broadband segment.
Angela Simpson, director of government affairs for Covad Communications,
said, "Qwest has overlooked any examination of competition levels in the
broadband marketplace. Given the growing importance of broadband, it is
essential that the Commission review the state of competition in this vital
marketplace."
New GeoResults Data Show Low Competition Levels in Enterprise Markets
In previous forbearance proceedings, assessment of competition levels in
the enterprise market has been incomplete, relying on estimates of
qualitative measures such as fiber network deployments that do not prove
the existence of actual, successful facilities-based competition.
A new study by GeoResults Inc. provides the first comprehensive analysis of
enterprise competition in the four markets where Qwest seeks forbearance.
The study shows that competition levels in the enterprise market fall far
short of the threshold established by the Commission.
The GeoResults study reviews: (1) percentage of commercial buildings served
by facilities-based competitors; (2) the percentage of competitive
facilities in any wire center; (3) the number of wire centers in each MSA
in which competitors have no facilities; and, (4) "addressable demand"
share for competitors in each MSA -- the percentage of total market demand
that competitors have the ability to serve in each wire center. Among the
key findings:
-- The percentage of commercial buildings served by facilities-based
competitors is no higher than 0.26% in any of the four Qwest markets.
-- The highest percentage of commercial buildings served by facilities-
based competitive providers in any wire center is 3.62%.
-- The number of wire centers with no buildings served by competitors
range from 43% in Denver and Seattle, to 51% in Phoenix and 60% in
Minneapolis/St. Paul.
-- Refuting incumbents' claims that CLECs have a significant presence in
the enterprise market with high-capacity facilities, CLEC "addressable
demand" share is, in fact, small. In none of the four markets does it
exceed 12.43%.
Contact Information: Contact: Jim Crawford Crawford Public Relations T: 703-753-4480 M: 703-498-7315