SBC Issue 3: Loops
XO recommends the Commission adopt language from the Illinois Amendment regarding the retirement of copper loops or subloops and the provision of alternative services. According to XO, FCC rules provide that if an ILEC replaces or retires a copper loop or subloop with "fiber to the home" (FTTH), an ILEC must ensure continued access so that competitors may provide narrowband services.
SBC accepts XO's proposal on this issue, but offers two modifications. The first involves elimination of language regarding "house and riser cables" from Section 3.1.3 because the TRO does not provide a basis for this language. The second modification involves new language proposed by SBC based on FCC revisions to fiber loop rules.6 XO agrees to SBC's proposed modifications.
Therefore, the agreement should incorporate XO's recommendation, as modified by SBC in its Reply Brief in Section 1.3.1(xi), Section 2.18, and Section 3.1 through 3.1.3.
6 See Order on Reconsideration, In re Review of the Section 251 Unbundling Obligation of Incumbent Local Exchange Carriers, CC Docket Nos. 01-338 et al., FCC 04-191 (rel. Aug. 9, 2004) ("MDU Reconsideration Order"). See also Order on Reconsideration, In re Review of the Section 251 Unbundling Obligation of Incumbent Local Exchange Carriers, CC Docket Nos. 01-338 et al., (rel. Oct. 18, 2004) ("Order on Reconsideration").
