II. The Problem

AT&T has two valid interconnection agreements with Verizon. Pursuant to those agreements, Verizon currently provides AT&T with unbundled Local Switching and Common Transport network elements. These two network elements are part of the unbundled network elements platform (UNE-P) by which AT&T provides local service to many California consumers in Verizon's service territory.

This complaint arises from a June 15, 2004 Verizon letter to AT&T which stated that, beginning September 17, 2004, Verizon will convert its Class 5 circuit switches to packet switches in two of its five central offices. In so doing, Verizon will eliminate AT&T's access to the Local Switching and Common Transport network elements. Verizon has stated it will serve AT&T's customers through a resale platform, as opposed to the UNE-P.