WorldCom

WorldCom's comments focused on the need to have Ameritech unbundle its Project Pronto. The Project Pronto is used to deploy next-generation remote terminal technology, which is designed to eliminate loop length and network conditions. WorldCom argued that no carrier other than Ameritech will be able to provide DSL services to residential customers who live more than 18,000 feet from a central office if the unbundling of Project Pronto is not ordered. They stated that the only hope for competition in broadband Internet access is with the unbundling, not resale. Their arguments are based on the following reasons:

• No effective competition against Ameritech for broadband Internet access under present regulations.

  Those companies who were viewed as having the greatest likelihood of success in competing against Ameritech and other ILECs in the provisioning of DSL service have filed for bankruptcy, are facing financial difficulties or have signed settlement agreement with Ameritech. It has been shown that under present regulation, trying to compete against SBC in the provisioning of DSL service is literally a bankrupt idea. A fundamental change is needed.

• SBC dominance in broadband Internet access harms voice competitors.

  The problem of SBC's dominance in provisioning DSL is not limited to broadband Internet access but affects the ability of CLECs to compete in basic local exchange service. Ameritech refuses to process customers' orders to switch to WorldCom for voice when Ameritech is serving them for voice and has DSL services on the line. Customers would prefer not to change their basic local exchange service in order to keep their DSL service. Thus, SBC is now using unfair advantage in DSL service to keep competitors out of the voice market.

• Threat of real competition leads SBC to complain

  SBC announced that the company was abandoning its commitment to deploy high-speed Internet access to Illinois customers when the ICC ordered SBC to unbundle Project Pronto. If the market is competitive, SBC would not be able to unilaterally halt the deployment of DSL infrastructure and deny Illinois consumers advanced telephone services.

• No effective competitive alternative of wireline broadband Internet access

  SBC is so dominant in broadband Internet access that it has the proven ability to withhold further deployment of broadband Internet access and to increase its rates at the same time. SBC has also admitted that DSL service is superior to cable modems in its website. While cable modems took the initial lead in deployment, this appears to be because SBC refused to deploy DSL for a number of years after the technology was developed.

  WorldCom suggested that prompt action by the commission to require SBC to unbundled Project Pronto at TSRLIC rates is the only way to provide theopportunity for competition. Moreover, from the lessons learned from the Illinois experience, SBC should also be ordered not to cease deployment of any network change where the reason to cease deployment would be to deny or limit the opportunity of competitors to purchase unbundled network elements.

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