Special Access Rate Investigation

FCC_New_LogoThere is an investigation going on at the FCC that is probably long overdue involving looking at special access rates. Special access rates are rates used by telephone companies to charge for TDM data circuits such as T1s.

You might think that T1s and TDM technology would be fading away, but the large telcos are still making a fortune by requiring other carriers and large businesses to interface with them using TDM circuits and then charging a lot of money for the connections. As an example, the connections between a large telco like AT&T and CLECs or long distance carriers are still likely to be comprised of DS-3s (28 T1s).

There are also still a lot of businesses that use T1s. There are still a lot of older phone systems sitting at small businesses that need a T1 interface to connect back to the phone company. And in very rural markets where there is no last mile fiber the telcos are still selling T1 data connections to businesses and delivering the paltry 1.544 Mbps of data that it can deliver.

The main thrust of the investigation are the prices being charged. In places with no competition the telcos might still charge between $400 and $700 per month for a T1 connection. And it’s not unusual for carriers to have to pay thousands of dollars per month to interface with the large carriers at a regional tandem switch.

There was a time when the prices charged for TDM circuits were somewhat cost-based, even though as somebody who did some of the cost studies behind the rates, I can tell you that every trick in the books was used to justify the rates at the highest possible cost. But in a 100% copper network there was some logic behind the charges. For example, if a business bought a T1 the phone company had to dedicate two copper pairs throughout the network for that service plus provide fairly costly electronics to supply the T1. I remember when T1s first hit the market and they were a big step forward in telco technology.

But technology has obviously moved forward and we now live in an Ethernet world. The FCC has been working on a transition of the public switched telephone network from TDM to all-IP and this investigation is part of that process.

The prices for TDM special access are all included in tariffs, and for the most part the rates have not changed in years, or even in decades. Where it used to be a big deal, for example, for a telco to send a DS3 between its offices, the bandwidth on a DS3, at 45 Mbps, is barely a blip today inside of the huge Ethernet data pipes the phone companies use to connect their locations. Even if the cost for a DS3 was justified at some point in time, when those same circuits are carried today inside much large data pipes the cost of transporting the data has dropped immensely.

It’s good that the FCC is investigating this, but to a large degree it’s their fault that the rates are so high. It’s been decades now since either the FCC or the state regulatory commissions required cost studies for TDM circuits. And without the prodding by the regulatory agencies the telcos have all let the old rates stand in place and have been happily billing them year after year. This investigation should have been done sometime soon after the Telecommunications Act of 1996, because the rise of competitive telecom companies created a boom in special access sales, all at inflated prices.

Special access rates matter a lot to small carriers. For example,special access is one of the largest expenses for any company that wants to provide voice services. It’s not unusual for a company to spend $100,000 or more per year buying special access services even if they deliver only a tiny volume of voice traffic to the world. As would be expected, the high costs adversely affect small carriers to a much greater extent than large carriers who can better fill up the pipe between them and the large telco.

For years the telcos have hidden behind the fact that these rates are in a tariff, meaning that they are not negotiable for other carriers. But at the same time, the telcos routinely drop rates significantly when selling special access circuits in a competitive market. The high special access rates apply only to those small carriers and businesses who are too small to negotiate or who do not operate in a competitive part of the network. It’s definitely time for these rates to be brought in line with today’s costs, which are a small fraction of what the telcos are charging. It would not be shocking for the FCC to determine that special access rates are 70% to 90% too high, particularly when you consider that most of the network and electronics that support them have been fully depreciated for years.

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