|FCC Adopts Unbundling Order
12/15. The Federal Communications Commission
(FCC) adopted, but did not release, an Order on Remand regarding incumbent local
exchange carriers' (ILECs) obligations under
47 U.S.C. § 251 to make their network elements available on an unbundled basis.
The FCC issued only a short
[2 pages in PDF], and four Commissioners wrote brief separate statements.
This item is FCC 04-290 in WC Docket No. 04-313 and CC Docket No. 01-338.
Background. This Order on Remand is the FCC's fourth set rules
regarding the unbundling requirements of ILECs. The previous three were
overturned in part by the federal courts.
The FCC announced its third set of rules on February 20, 2003, but did not
release the text of this
triennial review order [576 pages in PDF] until August 21, 2003, six
months later. See, story titled "Summary of FCC Triennial Review Order" in
TLJ Daily E-Mail
Alert No. 725, August 25, 2003. See also, stories titled "FCC Announces UNE
Report and Order", "FCC Order Offers Broadband Regulatory Relief", "FCC
Announces Decision on Switching", "Commentary: Republicans Split On FCC UNE
Order", and "Congressional Reaction To FCC UNE Order" in
TLJ Daily E-Mail
Alert No. 609, February 21, 2003.
On March 2, 2004, the U.S. Court of
Appeals (DCCir) issued its
opinion [62 pages in PDF] in USTA v. FCC, overturning key parts of
the FCC's triennial review order (TRO), and remanding the proceeding to the FCC.
story titled "Appeals Court Overturns Key Provisions of FCC Triennial Review
Order" in TLJ Daily
E-Mail Alert No. 848, March 3, 2004.
The just announced item is the FCC's order on remand.
Section 251. This order addresses the Section 251 unbundling
obligations of ILECs. Unbundled network
elements (UNEs) are those portions of telephone networks that the ILECs, such as
SBC and Qwest, must make available to
competing carriers seeking to provide telecommunications services. The
Telecommunications Act of 1996 provides that ILECs must provide access to
certain of their network elements at regulated rates.
47 U.S.C. §
251(c)(3) provides that ILECs have "The duty to provide, to any requesting
telecommunications carrier for the provision of a telecommunications service,
nondiscriminatory access to network elements on an unbundled basis at any
technically feasible point on rates, terms, and conditions that are just,
reasonable, and nondiscriminatory in accordance with the terms and conditions of
the agreement and the requirements of this section and section 252 of this
title. An incumbent local exchange carrier shall provide such unbundled network
elements in a manner that allows requesting carriers to combine such elements in
order to provide such telecommunications service."
Section 251 unbundling requirements were created by the 1996 Act. 47 U.S.C. §
251(d)(1) requires that "Within 6 months after February 8, 1996, the Commission
shall complete all actions necessary to establish regulations to implement the
requirements of this section."
Section 251(d)(2) requires the FCC, in establishing unbundling requirements,
to "consider, at a minimum, whether ... the failure to provide access to such
network elements would impair the ability of the telecommunications carrier
seeking access to provide the services that it seeks to offer." The
interpretation of the work "impair" has been central the FCC's unbundling
orders, and the Court opinions overturning them.
Just Announced Order on Remand. The FCC has not released the text of the
Order on Remand. It has only issued a press release describing the Order on Remand.
This FCC release states that "We clarify the impairment standard
adopted in the Triennial Review Order in one respect and modify its application in
three respects. First, we clarify that we evaluate impairment with regard to the
capabilities of a reasonably efficient competitor. Second, we set aside the
Triennial Review Order’s “qualifying service” interpretation of section
251(d)(2), but prohibit the use of UNEs for the provision of telecommunications
services in the mobile wireless and long-distance markets, which we previously
have found to be competitive. Third, in applying our
impairment test, we draw reasonable inferences regarding the prospects for
competition in one geographic market based on the state of competition in other,
similar markets. Fourth, we consider the appropriate role of tariffed
incumbent LEC services in our unbundling framework, and determine that in the
context of the local exchange markets, a general rule prohibiting access to UNEs
whenever a requesting carrier is able to compete using an incumbent LEC’s
tariffed offering would be inappropriate."
The FCC release further states that "Competing
carriers are impaired without access to DS1 transport except on routes
connecting a pair of wire centers, where both wire centers contain at least four
fiber-based collocators or at least 38,000 business access lines. Competing
carriers are impaired without access to DS3 or dark fiber transport except on
routes connecting a pair of wire centers, each of which contains at least three
fiber-based collocators or at least 24,000 business lines. Finally, competing
carriers are not impaired without access to entrance facilities connecting an
incumbent LEC’s network with a competitive LEC’s network in any instance. We
adopt a 12-month plan for competing carriers to transition away from use of DS1-
and DS3-capacity dedicated transport where they are not impaired, and an
18-month plan to govern transitions away from dark fiber transport. These
transition plans apply only to the embedded customer base, and do not permit
competitive LECs to add new dedicated transport UNEs in the absence of
impairment. During the transition periods, competitive carriers will retain
access to unbundled dedicated transport at a rate equal to the higher of (1)
115% of the rate the requesting carrier paid for the transport element on June
15, 2004, or (2) 115% of the rate the state commission has established or
establishes, if any, between June 16, 2004 and the effective date of this
The release further states that "Competitive
LECs are impaired without access to DS3-capacity loops except in any building
within the service area of a wire center containing 38,000 or more business
lines and 4 or more fiber-based collocators. Competitive LECs are impaired
without access to DS1-capacity loops except in any building within the service
area of a wire center containing 60,000 or more business lines and 4 or more
fiber-based collocators. Competitive LECs are not impaired without access to
dark fiber loops in any instance. We adopt a 12-month plan for competing
carriers to transition away from use of DS1- and DS3-capacity loops where they
are not impaired, and an 18-month plan to govern transitions away from dark
fiber loops. These transition plans apply only to the embedded customer base,
and do not permit competitive LECs to add new high-capacity loop UNEs in the
absence of impairment. During the transition periods, competitive carriers will
retain access to unbundled facilities at a rate equal to the higher of (1) 115%
of the rate the requesting carrier paid for the transport element on June 15,
2004, or (2) 115% of the rate the state commission has established or establishes,
if any, between June 16, 2004 and the effective date of this Order."
Finally, the FCC release states that "Incumbent LECs have no obligation
to provide competitive LECs with unbundled access to mass market local circuit switching.
We adopt a 12-month plan for competing carriers to transition away from use of unbundled
mass market local circuit switching. This transition plan applies only to the embedded
customer base, and does not permit competitive LECs to add new switching UNEs. During the
transition period, competitive carriers will retain access to the UNE platform (i.e.,
the combination of an unbundled loop, unbundled local circuit switching, and shared
transport) at a rate equal to the higher of (1) the rate at which the requesting carrier
leased that combination of elements on June 15, 2004, plus one dollar, or (2) the rate
the state public utility commission establishes, if any, between June 16, 2004, and the
effective date of this Order, for this combination of elements, plus one dollar."
The Commissioners split three to two, along party lines. The Democratic Commissioners,
Michael Copps and Jonathan Adelstein, dissented.
FCC Chairman Michael
Powell wrote in a separate
[PDF] that "The rules have also been carefully designed to pass judicial
muster, for I hope we have learned that illegal rules, no matter their other
merits, are no rules at all."
Said Powell, "We can only hope that the fourth time is the charm."
Kathleen Abernathy wrote in a separate
[PDF] that "I have great sympathy for carriers that crafted business plans in
compliance with our rules, only to have the rug later pulled out from under them. The
only responsible solution to this problem is to adopt rules that comply faithfully with
the decisions of the D.C. Circuit and the Supreme Court, so that we can finally
move forward with stable rules in place."
Abernathy (at right)
wrote too that the proposals of the two dissenting Commissioners are "flatly
inconsistent with the D.C. Circuit’s decision in USTA II. That decision is
unquestionably the law of the land, and we are duty-bound to adhere to it."
FCC Commissioner Michael
Copps wrote in a separate
[PDF] that "What we have in front of us effectively dismantles
wireline competition. Brick-by-brick, this process has been underway for some
time. But today’s Order accomplishes the same feat with all the grace and
finality of a wrecking ball. No amount of rhetoric about judicially sustainable
rules and economically efficient competitors can hide the blockbuster job this
Commission has done on competition. During its tenure, the largest long distance
carriers have abandoned the residential market. And as a result of today’s
decision, other carriers will follow suit. In their wake we will face
bankruptcies, job losses and customer outages. Billions of dollars of investment
capital will be stranded. And down the road consumers will face less
competition, higher rates and fewer service choices."
Jonathan Adelstein wrote in a separate
[PDF] that this order "officially cuts the cord on the local competition" and
"relegates consumers to an inevitable future of higher rates and fewer choices."
Adelstein added that "Most stark is the Commission’s treatment of local
loops, which carry telephone traffic from customers’ locations to a service
provider’s network. These local loops act as the on and off ramps to reach the
alternative facilities-based networks that competitors have constructed at
considerable expense. In this Order, the Commission adopts unbundling rules for
these elements that are strangely disconnected from the operational and economic
barriers a competitor would face if it had to duplicate the incumbent’s legacy
network. This blow to competition and choice comes with a certain slight of
hand, couched by the majority as “inference tests” compelled by the courts. But
“inferences” aside, there should be little doubt about the real-world
implications of this Order."
|FCC Announces NPRM on Cellphones in
12/15. The Federal Communications Commission
(FCC) adopted, but did not release, a Notice of Proposed Rulemaking (NPRM)
regarding rules prohibiting the use of cellular telephones on airlines.
The FCC issued only a short
[2 pages in PDF], and
Chairman Michael Powell and Commissioner
Michael Copps wrote brief statements. This item is FCC 04-288 in WT Docket No. 04-435.
Chairman Powell wrote in a separate
[PDF] that "Although operation of wireless devices aboard
aircraft remains subject to Federal Aviation Administration (FAA) rules and
policies that restrict their use to ensure against interference to onboard
communications and navigation equipment, the adoption of this NPRM will help
ensure that the Commission’s rules do not unnecessarily restrict the
availability of airborne wireless services should the FAA and aircraft operators
permit the use of airborne wireless devices."
(at right) wrote in a separate
[PDF] that "the way the FCC has decided to launch this new
service risks creating a monopoly for broadband air-to-ground services. The
Order creates an auction where one company can lock up the only license that can
support a true broadband air-to-ground service. That means that if a company
bids enough, it can exclude all other competitors, leaving airlines with only
one possible supplier and passengers with no choice. Experience shows that if a
company has the chance to buy a monopoly license, it will pay a premium for it.
That is because it allows them, with one fell swoop, to ensure that competitors
will not be able to keep prices down or force them to innovate."
The FCC's release states that this NPRM proposes "to permit the
airborne operation of ``off the shelf´´ wireless handsets and other devices so long as
the device operates at its lowest power setting under control of a ``pico cell´´ located
on the aircraft, and the operation does not allow unwanted radio frequency
emissions to interfere with terrestrial cellular systems."
The release states that the FCC seeks comments on
"whether the proposal should apply only to devices operating in 800 MHz cellular
spectrum, or whether devices operating on other spectrum bands, such as the PCS
band or Advanced Wireless Services bands, should be included". The FCC also
seeks comments on "ways that the 800 MHz cellular spectrum could be used to
provide a communications ``pipe´´ between
airborne aircraft and the ground", and on "whether to allow cellular carriers to
provide service on a secondary basis to airborne devices subject to technical
limitations aimed at preventing harmful interference".
|FCC Adopts UWB Second
Report & Order
12/15. The Federal Communications Commission
(FCC) adopted, but did not release, a Second Report and Order and Second
Memorandum Opinion and Order pertaining to Part 15 of its rules regarding
ultra-wideband (UWB) transmission systems.
The FCC issued only a short
[2 pages in PDF]. None of the Commissioners wrote separate statements. This item is
FCC 04-285 in ET Docket No. 98-153.
Gallagher, head of the Department of Commerce's (DOC)
National Telecommunications and Information
Administration (NTIA), stated in a
that "President Bush has charged us with creating an environment where entrepreneurs
and innovators can flourish -- and today's FCC order does just that. The United States
continues to lead the world in ultrawideband technology."
left) added that "Ultrawideband devices have the power to change people's lives
whether they are in their living rooms or their automobiles. Today's ruling
speeds the arrival of the day when passenger cars come equipped with radars that
prevent accidents. The FCC has provided the certainty new technologies need for
growth and development, and at the same time maintains protection for restricted
bands that serve vital and sensitive purposes, such as earth exploration and
The FCC release states that the FCC "previously established regulations
that permit the marketing and operation of certain types of new products incorporating
ultra-wideband (UWB) technology." The FCC adopted its
First Report and Order [119 pages in PDF] in 2002.
The FCC then received petitions for reconsideration of the First R&O. The
FCC addressed these in its
Memorandum Opinion and Order and Further Notice of Proposed Rulemaking [91 pages in
PDF] adopted on February 13, 2003. The MO&O portion largely reaffirmed the procedures
adopted in 2002 to authorize the unlicensed operation of UWB, but made some changes to
further facilitate the operation of imaging devices. The FNPRM portion proposed numerous
new rules. See also, story titled "FCC Announces UWB Report and Order and Further
NPRM" in TLJ Daily
E-Mail Alert No. 604, February 14, 2003, and
release [2 pages in PDF], and story titled "NTIA Submits Comment to FCC in
UWB Proceeding" in
TLJ Daily E-Mail Alert No. 819, January 20, 2004.
The FCC release states that the present item amends "its rules for
general Part 15 unlicensed operations that
use wide bandwidths but are not classified as UWB devices under its rules. It
increased the peak power limits and reduced the unwanted emission levels for 3
frequency bands that were already available for unlicensed operation: 5925-7250
MHz, 16.2-17.2 GHz, and 23.12-29 GHz, and indicated that higher peak power
limits in these bands would facilitate wideband operations such as short range
communications, collision avoidance, inventory control and tracking systems. The
Commission also amended its measurement procedures to permit frequency hopped,
swept frequency, and gated systems operating within these bands to be measured
in their normal operating mode."
The release adds that the FCC "did not make any
major changes to the current UWB technical requirements".
The release also states that the FCC dismissed the Petition for Reconsideration
filed by the Satellite Industry Association (SIA).
|Washington Tech Calendar
New items are highlighted in red.
|Thursday, December 16
The House will next meet on January 4, 2004 at 12:00 NOON. See,
Republican Whip Notice.
The Senate will next meet on January 4, 2005 at 12:00 NOON.
The Supreme Court will next
meet on Monday, January 10, 2005. See,
List [9 pages in PDF] at page 9.
11:00 AM. The Federal Communications Bar
Association's (FCBA) Legislation Committee will host an event. The speaker will
be Gregg Rothschild (Democratic Counsel, House Commerce Committee). He will
speak on legislative issues. RSVP to Helene Marshall at
Wiley Rein & Fielding, 1776 K St., NW.
12:00 NOON - 1:30 PM. The DC
Bar Association's Intellectual Property Law Section and Legislative Committee will
host a program titled "Update On Justice Department Enforcement Of Intellectual
Property Laws". The speakers will be
Daniel Bryant (Assistant Attorney General
in charge of the DOJ's Office of Legal Policy, and Vice-Chair of the DOJ's Intellectual
Property Task Force) and Barbara Berschler. See,
Prices vary from $15 to $30. For more information, call 202 626-3463. Location: D.C.
Bar Conference Center, B-1 Level, 1250 H St., NW.
1:30 - 4:30 PM. The Executive Office of the
President's (OEP) Office of Science and
Technology Policy's (OSTP)
National Science and
Technology Council's (NSTC) Committee on Technology, Committee on Homeland
and National Security's Infrastructure Subcommittee will hold a meeting that
is closed to the public. For more information, contact John Hoyt at
email@example.com or 202 772-9959.
Location: White House Conference Center (Truman Room).
Day two of a two day workshop hosted by the
Federal Trade Commission (FTC) titled "Peer
to Peer File-Sharing Technology: Consumer Protection and Competition Issues".
See, FTC release and
notice [13 pages in
PDF] to be published in the Federal Register. Location: FTC Satellite Building, 601
New Jersey Ave., NW.
|Friday, December 17
9:30 AM - 12:00 NOON. The U.S. China
Policy Foundation will host an event titled "Prospects for U.S.-China
Relations in Bush Administration". For more information, contact Chi Wang at
202 547-8615. Location: Murrow Room, National Press
Club, 529 14th St. NW, 13th Floor.
12:00 NOON. Deadline to submit comments to
the Office of the U.S. Trade Representative
(USTR) regarding various trade related telecommunications issues. The
USTR seeks comments on "Whether any WTO member is acting in a manner that is
inconsistent with its commitments under the WTO Basic Telecommunications
Agreement or with other WTO obligations", "Whether Canada or Mexico has failed
to comply with their telecommunications commitments or obligations under
NAFTA", "Whether Chile or Singapore or any other FTA partner with an Agreement
that comes into force on or before January 1, 2005 has failed to comply with
their telecommunications commitments or obligations under the respective FTAs",
"Whether other countries have failed to comply with their commitments under
additional telecommunications agreements", and "Whether there remain
outstanding issues from previous Section 1377 reviews". See, notice in the
Federal Register, Vol. 69, No. 226, Wednesday, November 24, 2004, at Page
|Tuesday, December 21
12:00 NOON. The Federal
Communications Bar Association's (FCBA) Executive Committee will meet.
Location: Wiley Rein & Fielding, 1776 K
Extended deadline to submit reply comments to the
Federal Communications Commission (FCC) in response to
its Notice of
Proposed Rulemaking and Declaratory Ruling (NPRM & DR) [100 pages in PDF] regarding
Assistance for Law Enforcement Act (CALEA) obligations upon broadband internet
access services and voice over internet protocol (VOIP). This NPRM is FCC 04-187 in ET
Docket No. 04-295. The FCC adopted this NPRM at its August 4, 2004 meeting, and released it
on August 9. See, story
titled "Summary of the FCC's CALEA NPRM" in
TLJ Daily E-Mail Alert No. 960,
August 17, 2004. See,
notice in the Federal Register, September 23, 2004, Vol. 69, No. 184, Pages
56976 - 56987. See also,
notice of extension [PDF].
|Saturday, December 25
|7th Circuit Rules on Removal of WorldCom
Related Securities Case
12/2. The U.S. Court of Appeals
(7thCir) issued its
[14 pages in PDF] in Illinois Municipal
Retirement Fund v. Citigroup, affirming the District Court's remand of a
1933 Securities Act case to the state court.
The defendants in the trial courts, and appellants on appeal, were underwriters
of debt securities issued by WorldCom. In
2002, WorldCom, which is not a party to this action, announced that it had
improperly treated $3.8 Billion in ordinary costs as capital expenditures and
that it would have to restate its financial statements. This led to the filing
of numerous individual and class action lawsuits in state and federal courts. The Judicial Panel on Multidistrict Litigation
(JPML), pursuant to
28 U.S.C. § 1407, the multidistrict litigation statute, ordered that actions
pending in federal courts be centralized in the U.S. District Court for the
Southern District of New York (SDNY)
WorldCom went on to file for bankruptcy protection in U.S. Bankruptcy Court.
The plaintiff and appellee in this action, the Illinois Municipal Retirement
Fund (IMRF), filed a complaint in state court in Illinois on June 18, 2003, alleging
violation of the Securities Act of 1933 only (not the Securities and Exchange Act of
1934). The 1934 Act provides for exclusive federal jurisdiction, while the 1933 Act
allows for concurrent federal and state jurisdiction and has an anti-removal provision.
The Securities Act of 1933 provides in Section 22(a), which is codified at
15 U.S.C. § 77v(a),
that "no case arising under this subchapter and brought in any State court of
competent jurisdiction shall be removed to any court of the United States."
On July 16, 2003, the defendants removed this action to federal District Court
in Illinois on the grounds
that this action is related to the bankruptcy action. The Bankruptcy Code
28 U.S.C. § 1452(a), that claims that are "related to" a bankruptcy case may
be removed to the Bankruptcy Court. The defendants also requested that the case
be transferred to the SDNY.
The JPML issued a conditional transfer order on September 3, 2003.
On September 9, 2003, the District Court in Illinois nevertheless remanded
this action to Illinois state court.
The Court of Appeals affirmed. It wrote that the issue is "whether 28 U.S.C.
§ 1407, the multidistrict litigation statute, prohibits a district court from
issuing a remand order in contravention of a potential transferee court’s
earlier jurisdictional ruling." It held that it does not.
The Appeals Court wrote that "In this case, the district court
remanded after the JPML issued a conditional transfer order but before
transmittal of a final transfer order to the previously designated transferee,
Judge Cote in the Southern District of New York. Therefore, the transfer had not
become effective and the conditional order did not “in any way limit the
pretrial jurisdiction” of the district court.". (The quote is from JPML Rule
1.5, which the Court of Appeals declined to invalidate.)
The Court concluded that "We will not require a district court
that believes that it lacks subject matter jurisdiction over a case to
facilitate a transfer under § 1407, a statute that does not itself confer
jurisdiction. Rule 1.5, as applied in this case, does not conflict with the
text, structure, or purpose of § 1407, and the district court did not exceed its
authority in issuing a remand order."
It should be noted that on May 11, 2004, the
U.S. Court of Appeals (2ndCir) issued
opinion [32 pages in PDF] in CalPERS v. WorldCom, a securities
case involving the conflict between the removal provisions of the Bankruptcy Code and the
Securities Act of 1933. The 2nd Circuit held that the bankruptcy removal
provision controls. See also, story titled "2nd Circuit Affirms in CalPERS v.
WorldCom" in TLJ
Daily E-Mail Alert No. 896, May 12, 2004.
This case is Illinois Municipal Retirement Fund v. Citigroup,
Inc., J.P. Morgan Securities, Inc., and Banc of America Securities, LLC, App.
Ct. No. 03-3703, an appeal from the U.S. District Court for the Southern
District of Illinois, D.C. No. 03 C 465, Judge Patrick Murphy presiding. Judge
Flaum wrote the opinion of the Court of Appeals, in which Judges Cudahy and
|1st Circuit Affirms
Insider Trading Judgment
12/10. The U.S. Court of Appeals
(1stCir) issued its
opinion in SEC v. Robert Happ, a civil enforcement action
involving allegations of securities fraud for alleged insider trading by
a former Director of Galileo Corporation, a manufacturer of fiber optic and
electro optic products.
The Securities and Exchange Commission
(SEC) filed a civil complaint in U.S.
District Court (DMass) alleging violation of § 10b of the Securities
Exchange Act and § 17 of the Securities Act of 1933, and rules thereunder, in
connection with his alleged trading in the stock of Galileo on material,
Happ, in his capacity as a Director, learned that Galileo would not meet its
previous forecast for a net profit. He sold 4,000 shares. After the company
announced a loss, its stock price dropped 64%. Happ then purchased 5,000
shares. These transactions did not escape the attention of the SEC.
Following a jury trial, the District Court entered judgment against Happ, and
denied motions by Happ. The Court of Appeals affirmed.
This case is Securities and Exchange Commission v. Robert Happ, App. Ct. Nos.
04-1406, 04-1461, an appeal from the U.S. District Court for the District of
Massachusetts, Judge Robert Keeton presiding.
|More Court Opinions
12/15. The U.S. Court of Appeals
(9thCir) issued its
opinion [35 pages in PDF] in Grupo Gigante v. Dallo, a
trademark dispute between supermarket chains, involving the territoriality
principle and the exception for famous or well known marks. This case is
Grupo Gigante SA DE CV, et al. v. Dallo & Co., Inc., et al., App. Ct. No.
00-57118, an appeal from the U.S. District Court
for the Central District of California, D.C. No. CV-99-07806-DDP-MAN, Judge Dean
12/10. The U.S. Court of Appeals (10thCir)
opinion in Bastien v. Sen. Campbell, a case regarding the
scope of the Speech or Debate Clause of the U.S. Constitution. Article I,
Section 6 provides that "for any Speech or Debate in either House, they shall
not be questioned in any other Place." Rita Bastien, a former a member of
Sen. Ben Campbell's (R-CO) staff,
filed a complaint in U.S. District Court (DColo) against Sen. Campbell alleging
employment discrimination. He asserted that the suit is barred by the Speech or
Debate Clause. The District Court dismissed the complaint. The Court of Appeals
reversed, holding that the Speech or Debate Clause does not bar this claim,
because it does not question the conduct of official Senate
legislative business by Sen. Campbell or his aides. This case is Rita Bastien
v. Office of Sen. Ben Campbell, App. Ct. No. 02-1343, an appeal from the
U.S. District Court for the District of Colorado, D.C. No. 01-WY-799-CB(OES).
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