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On March 19, 2020, the Cloud Communications Alliance (“CCA”) filed Reply Comments in the Federal Communications Commission’s (“FCC”) rulemaking proceeding, Modernizing Unbundling and Resale Requirements in an Era of Next-Generation Networks and Services (WC Docket No. 19-308).  The FCC is considering rules that would further limit Unbundled Network Elements (“UNEs”) and other measures that will reduce competition and increase network costs to the community of Competitive Local Exchange and other Network Access carriers that rely on ILEC’s for last mile services (many Over-the-Top VoIP service providers depend on competitive carriers offering competitively priced access services to reach their customers).

In its Reply Comments, the CCA opposes the further elimination of access to UNEs and resale services, arguing that adopting the proposed rules would harm consumers.  Furthermore, the CCA challenges the factual basis on which the FCC claims sufficient competition already exists, thus justifying forbearance from UNE and resale rules on ILECs, contending that the broadband data and maps referenced by the FCC are woefully inaccurate.

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