June 4, Special Access for Price Cap Local Exchange Carriers, WC Docket No

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1 June 4, 2014 Ex Parte Ms. Marlene Dortch Secretary Federal Communications Commission th Street, SW Washington, D.C Re: Special Access for Price Cap Local Exchange Carriers, WC Docket No Dear Ms. Dortch: This is to inform you that on June 2, 2014, Frank Simone and Robert Barber of AT&T, Maggie McCready and Curtis Groves of Verizon, Melissa Newman and Jeff Lanning of CenturyLink and Pat Brogan and the undersigned on behalf of USTelecom met with Jonathan Sallet, Linda Oliver and Stephanie Weiner of the Office of General Counsel, in connection with the above-referenced docket. During the meeting, we discussed the competitive nature of the high-capacity services marketplace and presented specific facts rebutting assertions Comptel and others have made in recent ex partes. 1 We distributed the attached presentation, which includes representative examples of those facts, and it formed the basis of our discussion. In this meeting, we reviewed the history of the Commission s special-access proceeding. In particular, we emphasized the importance of the pending mandatory comprehensive data request and that the regulatory outcomes for which Comptel advocates would require the Commission to prejudge the results of that data collection effort. As the Commission itself has concluded, there currently is insufficient evidence upon which to base general or categorical conclusions as to the competitiveness of the special access market. 2 The Commission also has determined that it could not evaluate claims of competitive harm related to special access terms and conditions including incumbent local exchange carriers voluntary discount plans because of insufficient record evidence. 3 The Commission has noted that although it has 1 See, e.g., Ex parte Letter from Angie Kronenberg, Comptel, WC Docket No , et al. (April 2, 2014) ( Comptel Ex Parte ); Ex parte Letter from Charles McKee, Sprint, WC Docket No , et al. (May 9, 2009) ( Sprint Ex Parte ). 2 Special Access for Price Cap Local Exchange Carriers, Report and Order and Further Notice of Proposed Rulemaking, 27 FCC Rcd 16318, 69 (2012). 3 Special Access for Price Cap Local Exchange Carriers, Report and Order, 27 FCC Rcd 10557, 3 (2012).

2 Ms. Marlene Dortch June 4, 2014 Page 2 attempted to compile a record, [its] efforts have been impeded by the failure of some parties to produce information clearly documenting their claims that special access rates are unreasonable. 4 And the Commission specifically noted that the vast majority of [Comptel s] service provider members did not provide any data in response to the October 2010 voluntary data request. 5 In contrast to Comptel and its unsupported allegations, USTelecom members already have submitted into the record substantial facts and analysis that demonstrate that the high-capacity service marketplace is highly competitive and is growing more so. 6 We explained that the publicly available information shows that the marketplace for business services is only getting more and more competitive over time and that competitors are experiencing tremendous success in all segments of that market. In particular, we noted the vigorous competitive presence of cable companies in this marketplace. We fully expect that the results of the comprehensive data collection will confirm this. We also discussed that competition to provide high-capacity services for wireless backhaul has exploded in recent years. The extraordinary rise in demand for data-intensive wireless services has fueled enormous Ethernet growth in this area. This has created significant opportunities for expansion and new entry, and the marketplace is rife with a large array of operators, including incumbent local exchange carriers (ILECs), competitive local exchange carriers (CLECs), cable multiple system operators (MSOs), fiber-based providers, microwave operators, and resellers. 7 Verizon has provided information regarding its experience bidding to provide Sprint with wireless backhaul within Verizon s region to support Sprint s aggressive network expansion. Verizon won fewer than six percent of the sites within its region, and Sprint 4 Opposition of the Federal Communications Commission to Petition for Writ of Mandamus, In re COMPTEL, No , at 2 (DCC filed Oct. 6, 2011). 5 Id. at See, e.g., CenturyLink Petition for Forbearance Pursuant to 47 U.S.C. 160(c) from Dominant Carrier Regulation and Computer Inquiry Tariffing Requirements on Enterprise Broadband Services, Attachments 1 32, WC Docket No (filed Dec. 13, 2013); Comments of Verizon at Appendix A, Petition of Ad Hoc Telecommunications Users et al., To Reverse Forbearance from Dominant Carrier Regulation of Incumbent LECs Non-TDM-Based Special Access Services, WC Docket 05-25, RM (filed April 16, 2013); Reply Comments of Verizon and Verizon Wireless at Attachment A, Special Access for Price Cap Local Exchange Carriers, WC Docket 05-25, RM (filed March 12, 2013). 7 Roopashree Honnachari, Frost & Sullivan, U.S. Mobile Backhaul Services Market: Wireless Service Provider Spending Trends, BCS5-8, at 6 (Oct. 2011); see also Jennifer Pigg, Yankee Group, Wholesale Mobile Backhaul: There s Gold in Them There Hauls, at 4 (June 2011); Colby Synesael & Jonathan Charbonneau, Cowen and Company, Telecom and Data Services, Industry Overview, Fiber: A Sector Evolves, at (Oct. 29, 2010), available at

3 Ms. Marlene Dortch June 4, 2014 Page 3 announced that it had selected 25 to 30 other significant providers including cable operators and fixed wireless providers to provide backhaul. 8 One of the most important developments in this marketplace has been the success of the cable industry as aggressive competitors for high-capacity services to business customers. Yet in the many filings Comptel and others have made in the past couple months urging additional regulation of incumbent LECs, no one has mentioned cable s role in this marketplace. Such advocacy is not new Comptel and its member companies have long urged the Commission to ignore cable in the special access proceeding asserting on multiple occasions that cable companies do not offer competitive alternatives to ILEC special access services because, Comptel claims, their facilities are technologically inadequate or that they lack the business acumen to serve such customers. For example, tw telecom has claimed (without substantiation) that cable networks are not capable of providing the level of service (e.g., reliability, service guarantees) demanded by most business customers and delivered by special access. 9 And in a filing urging the Commission to ignore cable companies when defining the market for the provision of high-capacity services to businesses, a group of CLECs asserted that cable broadband service does not satisfy the needs of small and mid-sized business customers, simply stating that cable networks are simply not up to the task. 10 Indeed, Cable s role in the high-capacity services marketplace has been one of the most debated questions in connection with the ongoing proceeding on ILEC special access regulation and, in particular, the development of the pending data request. USTelecom previously has highlighted dozens of independent reports, press accounts, and analyses of cable s highly successful participation in the business services marketplace. Further, USTelecom has filed detailed information showing that cable companies expressly market their business services as alternatives to traditional ILEC DS-1 and DS-3 services. Additionally, USTelecom submitted conclusive evidence concerning the ability of cable companies to offer service-level agreement ( SLA ) business services over their existing cable plant, not just over fiber. We emphasized that much discussion had occurred prior to the adoption of the data request concerning this question because of opposition from both cable companies and CLECs to proposals to collect information on the location of cable network facilities. But as the Commission stated in a different proceeding more than a year ago, although many cable operators are relatively new entrants competing in the marketplace for the provision of telecommunications services to business customers, cable operators have expansive and in some areas ubiquitous network facilities that can be upgraded to compete in telecommunications services markets at relatively low incremental cost. 8 See Letter from Kathleen Grillo, Verizon, to Marlene H. Dortch, FCC, Special Access for Price Cap Local Exchange Carriers, WC Dockets 13-5 and RM (Sept. 12, 2012). 9 Comments of tw telecom, WC Docket (Jan. 19, 2010). 10 Workshop Response of tw telecom, One Communications, Cbeyond and Integra, (WC Docket 05-25, at 2-7 (Sep. 15, 2009).

4 Ms. Marlene Dortch June 4, 2014 Page 4 Evidence in both the public domain and in the record of this proceeding, however, reinforce cable s success in this marketplace. Indeed, the cable industry will exceed $10 Billion in business services revenues this year. The largest cable companies which include companies that are much larger than many of the ILECs subject to special access regulation had approximately $8.5 Billion in business services revenues in For the sake of comparison, in its order suspending further grants of pricing flexibility, the Commission found that the 4 largest ILECs had combined revenues from the sale of DS1s and DS3s of approximately $12 Billion in a figure which by all accounts has been dropping. Indeed, with respect to Ethernet services the technology that business customers are rapidly adopting to replace traditional Time Division Multiplexing ( TDM ) services it is estimated that cable companies already have fully one-quarter of these service revenues nationally, 13 and that their share will grow to approximately one-third in the next few years. 14 Moreover, given that cable companies already have facilities passing more than three-quarters of business locations and growing 15, analysts are bullish that the cable companies business services revenues will continue to grow at double-digit rates, as it has in recent years. 16 Similarly, Bloomberg/BNA, for example, has projected that by 2017 cable companies will control: more than 40% of US small businesses; 30% of US Ethernet services revenues; and one-third of the wireless backhaul market. 17 And Bernstein Research put it this way more than a year ago: 11 Light Reading, Heavy Reading: Cable Biz Sales to Hit $8.5B (Dec. 4, 2013), available at ( Major US cable operators are on track to reach $8.5 billion in commercial service revenues this year, up more than 20% from nearly $7 billion a year ago. ) 12 Special Access for Price Cap Local Exchange Carrier, WC Docket No , Report and Order, at p. 3 (rel. Aug 22, 2012). 13 Light Reading, Cable Commands Major Slice of Ethernet (Sept. 5, 2013), available at 14 Heavy Reading Cable Industry Insider, Cable Operators & Ethernet: Serious Market Share (Vol. 8, No. 4, August 2013) at p See, e.g., Light Reading, Cable s Cut of the Biz Services Pie to Eclipse $7B (Nov. 29, 2012)(cable HFC networks already pass more than 75 percent of small and medium-sized business locations); Frost & Sullivan, Cable MSO Ethernet Strategy: Moving Up-Market for New Opportunities, Vol. 6, No. 3 at p. 13 (March 2012) (noting that Comcast Business Class, the commercial services division of Comcast, had facilities to at least 80% of the businesses in its territory). 16 See, e.g., Light Reading (Nov. 29, 2012) (projecting growth of at least $1 Billion per year for the next several years). 17 Bloomberg BNA, Cable Commercial Services Business Forecast 2012, p.3 (2012).

5 Ms. Marlene Dortch June 4, 2014 Page 5 By now, the cable operators growth story in commercial services is a familiar one. Collectively, Cable is adding $1 billion per year in incremental commercial revenue. On an organic basis, Comcast, Time Warner Cable, and Charter are collectively growing their commercial revenue stream at a 30% clip So where are those revenues coming from? The TelCos obviously. 18 USTelecom also referenced the most recent Vertical Systems Group ( VSG ) analysis of the changing competitive landscape of the business services market. While CLEC tw telecom continues to be the third largest Ethernet provider in the country, behind only AT&T and Verizon (but ahead of regulated ILECs such as CenturyLink, Frontier, Fairpoint etc.), three of the next five largest Ethernet service providers are cable companies: Time Warner Cable, Cox and Comcast. Additionally, VSG's second tier of providers, its "Challenge Group," consists of 3 cable providers (Brighthouse, Charter and Cablevision) along with three CLECs. VSG explains that "cable companies have developed a winning formula for the U.S. business Ethernet market. They are successfully leveraging their on-net fiber footprints to offer aggressive pricing and rapid service provisioning." 19 Finally, USTelecom noted in this meeting that the proposed Comcast acquisition of TWC would even further upend the rankings of the largest providers of business services. Comcast's business services revenues alone increased more than 25% in 2013, to approximately $3.24 Billion despite having not seriously entered the business until Even before this proposed merger was announced, one leading industry analyst predicted that Comcast is virtually certain to become one of the market s largest players (very likely the largest) 20 With TWC having more than 860,000 on-net buildings and an 8,700-mile regional fiber-based network, 21 the combined companies would have more end-user connections nationwide than 18 Craig Moffett, Senior Analyst, Bernstein Research, U.S. Telecom, Cable & Satellite Monday Chart of the Week: The Flip Side of Cable s Growth in Commercial Services, (Dec. 10, 2012). 19 Fierce Telecom, Vertical Systems Group: 2013 U.S. Carrier Ethernet Leaderboard Aggressive service pricing intensifies in metro markets and Cable MSOs gain ground (Feb. 13, 2014), available at 20 Heavy Reading Cable Industry Insider, Cable Operators & Ethernet: Serious Market Share, (Aug. 2013), available at [] (italics in original); See also, Fierce Telecom, Comcast Business gets MEF Carrier Ethernet 2.0 certification, (Feb. 18, 2013), available at ( Despite being a bit later to the Ethernet game than its MSO brethren Comcast has quickly established itself as a threatening player in the business services market. ) 21 Fierce Telecom, Comcast s TWC deal will deepen its medium business Ethernet niche, (Feb. 13, 2014), available at

6 Ms. Marlene Dortch June 4, 2014 Page 6 any other telecom provider and have incumbent networks in 43 of the top 50 MSAs more than any other provider including AT&T and Verizon. Pursuant to Commission rules, please include this ex parte notice in the docket of the above-reference proceeding. Respectfully submitted, Glenn Reynolds Vice President, Policy Attachment: (1) c: Jonathan Sallet Linda Oliver Stephanie Weiner

7 Current State of High Capacity Services US Telecom FCC Meeting June 2, 2014

8 Special Access Proceeding Proceeding s Recent History In 2011, the FCC informed the DC Circuit that the Commission s efforts have been impeded by the failure of some parties to produce information clearly documenting their claims that special access rates are unreasonable. The Commission specifically emphasized that the vast majority of [Comptel s] service provider members did not provide any data in response to the agency s October 2010 request. The Commission s second voluntary request in 2011 was met with a similar response. The Commission correctly concluded in 2012 that it lacked data. The Commission specifically noted that its previous voluntary data collection efforts failed because Comptel members didn t provide information.

9 Special Access Proceeding The Current Situation High-capacity services have long been robustly competitive and are quickly growing more so. Cable companies and others have established themselves as major providers of high-capacity services to enterprise customers. Competition has exploded in wireless backhaul. Data will demonstrate that the marketplace is highly competitive. Any Commission action to increase ILEC regulatory burdens in this area necessarily prejudges the pending data request. Any significant retrenchment from the current request for data from competitors will undercut its usefulness.

10 Cable s Presence By now, the cable operators growth story in commercial services is a familiar one. Collectively, Cable is adding $1 billion per year in incremental commercial revenues. On an organic basis, Comcast, Time Warner Cable, and Charter are collectively growing their commercial revenue stream at a 30% clip So where are these revenues coming from? The TelCos, obviously. Craig Moffett, Bernstein Research (Dec. 10, 2012)

11 Cable Business Services Largest cable companies will exceed combined $10 Billion in business services revenue in FCC estimated that top 4 ILEC DS1 and DS3 total revenues in 2010 was $12 Billion and evidence is clear this has been rapidly dropping. Bloomberg/BNA projects that by 2017, cable companies will control more than 40% of US small business revenues; 30% of all US Ethernet service revenues; and one-third of all wireless backhaul revenues. ( Cable Commercial Services Business Forecast 2012 ).

12 Cable Business Services Cable facilities today serve 75-80% of all business locations. (Light Reading, 11/29/12; Frost & Sullivan, 3/2012). Cable companies can and do provide high-bandwidth, managed services over traditional coax-fiber facilities. (Light Reading, 2/19/14). Cable companies have massive campaigns marketing their business services as better alternatives to telco DS1s/DS3s.

13 Ethernet Services Are Highly Competitive ILECs today have less than half of Ethernet services revenues (Light Reading, 12/4/13). Top 9 Ethernet providers includes 3 ILECs, 3 cable companies and 3 CLECs. (Vertical Systems Group, 2/2014). Cable companies have developed a winning formula for the U.S. business Ethernet market. They are successfully leveraging their on-net fiber footprints to offer aggressive pricing and rapid service provisioning. (Vertical Systems Group, 2/12/14).

14 Fiber Deployment Growing Rapidly 40% of US commercial buildings with 20 or more employees are served by fiber facilities. (Vertical Systems Group, 4/2014). Cox Business has 28,000 fiber-lit buildings and 400,000 fiber near-net buildings. (Fierce Telecom, 4/2/2014). TW Cable has 58,000 buildings connected with fiber more than all but 2 ILECs. (TW Cable Operational & Financial Plan, 1/30/14). Level 3 says there are more than 100,000 buildings within 500 feet of its fiber network. (Fierce Telecom, 1/10/14). twtelecom has more than 20,000 fiber lit buildings. (VSG, 4/2014). Zayo has more than 14,000 fiber lit buildings adding more than 500 on-net buildings in Q42014 alone. (Fierce Telecom, 2/6/14). Cbeyond recently announced an extension of fiber to SMBs in commercial buildings in 6 new markets. (Fierce Telecom, 5/22/2014). Lightpath recently reported that it had added over 1,000 new fiber-lit buildings on its network in the previous 6 months alone. (Fierce Telecom, 4/17/2014).

15 Comcast / TWC Even before the merger was announced, one industry analyst predicted that Comcast is virtually certain to become one of the [business services] market s largest players (very likely the largest) (Heavy Reading Cable Industry Insider, 8/2013). TWC has over 600,000 business customers and 860,000 on-net buildings and added 55,000 on-net commercial buildings in 2013 alone. TWC also has more than 14,000 on-net cell towers. TWC has committed to double its business services revenues to $5 Billion by 2018 (TWC 4Q2013 Earnings Call). Comcast and TWC had combined business services revenues of nearly $6 Billion in 2013 growing at 20-30% per year. (Fierce Telecom; Light Reading). Combined company will have incumbent operations in approximately 43 of the top 50 MSAs significantly more than any ILEC which Comcast asserts will make it a much stronger competitor in the enterprise business market.

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