Intel letter to FCC

[Dhruv Khanna <Dhruv_Khanna@ccm2.hf.intel.com>]

  Faxed to FCC today in connection with the Interconnection Docket
  
  Intel Corporation
  5200 N. E. Elam Young Parkway 
  HF3-03 
  Hillsboro, OR 97124 
  (503) 696-7162
    
  
   By FAX                                         July 25, 1996
  
  The Honorable Reed E. Hundt
  Chairman, Federal Communications Commission
  Room 814, 1919 M Street, N.W.
  Washington D.C. 20554
  
  Re:   CC Docket No. 96-98  Ex Parte Comments of Intel Corporation
  
  Dear Chairman Hundt:
  
  The Commission should adopt rules in the above docket that facilitate 
  the competitive provision of higher bandwidth telecommunications 
  services.*    Specifically, this is to request that the FCC require the 
  unbundling of the local loop in any and all feasible parts and subparts, 
  and also require that the local exchange carriers ("LECs") permit a 
  competitor to provide data over voice services on the same loop.  The 
  Commission should require the LECs to establish reasonable rates for any 
  unbundled facility requested by a competitor.
  
  Cries of "harm to the network" should not be allowed to delay 
  competition or the provision of new services by competitors.  The 
  incumbent LECs should not be set up as the arbiters of technical 
  feasibility, or otherwise be allowed to use their custody of the loops 
  or their superior bargaining power to delay or thwart the provision of 
  new services by competitors.  The LECs should be required to cooperate 
  with a competitor's attempts to conduct market or technical trials of 
  new services over unbundled loops or parts of such loops.  A competitor 
  will constrained by the marketplace if it fails competently to deliver a 
  promised service.  Thus, the Commission should rule that the LECs must 
  provide interconnection and collocation to competitors at any point and 
  for any equipment, and access to any unbundled facility, a competitor 
  requests and must establish reasonable rates therefor.
  
  The above measures are critical to ensure that consumers enjoy the full 
  benefits of the computer industry's hardware and software products and 
  the rich content that the Internet community stands ready to provide.
  
  Sincerely,
  
  
  Dhruv Khanna
  Senior Communications Attorney
  
  cc. Commissioners Chong, Ness and Quello; and William Caton, Acting 
  Secretary
  
  *The incumbent local exchange carriers have not been driven by 
  competition to maximize the use of, and deliver higher bandwidth over, 
  the local loop.  With about a third of our population and a quarter of 
  our total access lines, Germany today has more than twice the number of 
  ISDN subscribers.  In addition, DSL (Digital Subscriber Line) 
  technologies are capable of delivering digital transmissions 100 times 
  faster than the speeds that can be derived by today's fastest POTS 
  modems.