To: Frank A. Coluccio who wrote (2742 ) 1/19/1999 12:32:00 PM From: WTC Read Replies (1) | Respond to of 12823
RE: "unbundling" HFC networks for common carrier access, As you note, this is technically awkward at best, but perhaps not significantly more "awkward" than many of the CLEC proposals for unbundling ILEC networks, e.g., subloop unbundling, spectrum unbundling, etc. I seriously doubt that ease of implementation will suddenly become a material factor in FCC rules for network operations. The strong traditional argument that the MSOs usually fell back upon -- the finite capacity of their coaxial-based systems -- begins to look a bit obsolete as the technical imperative precluding unbundling. Blair Levin, who many will remember as Reed Hundt's Chief of Staff not so very long ago, made some comments on the liklihood of MSO network unbundling requirements at a conference last October. I doubt if the situation has changed enough to make obsolete his observations: Levin commented on the Unbundled Cable Proceeding: Predicted the FCC would take no action, even with the ATT/TCI merger (no impact from the AOL petitions.) Basically, the FCC sees the proposals for cable unbundling as "very intrusive" and inappropriate. I asked Mr. Levin during a Q&A if "intrusive" was likely to become a part of the FCC's standard for taking action, noting that the FCC's (CC docket 98-188) proposals for CLEC access to ILEC databases, sub-loop unbundling, and cageless collocation could hardly be more "intrusive." Levin agreed with the irony, but noted that he was not defending the comparative logic of actions to be taken, just simply reporting on his view of the future direction of each proceeding. That prediction: The FCC would not require any cable unbundling, but they would require cageless collocation plus further loop unbundling (by the ILECs.) Three months later, Levin's predictions seem to me to be right on target.