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WC 16-143, WC 05-25, RM-10593: USTelecom Ex Parte on Business Data Services to Reject Wholesale Discount Structure

Ex Parte

The Commission should reject demands to force a mandatory “wholesale” discount structure on the business data services (“BDS”) marketplace. Under the volume and term-based discount structure that has evolved under Commission supervision, competing carriers already had 51% of the market in 2013. Grafting a new “wholesale” discount on to the current structure does not reflect how BDS is sold and provisioned and would be counter to the Commission’s longstanding goals of facilities-based competition. As Chairman Wheeler recently noted, “if you're going to get competition, competition is a facilities-based issue, it is not an ersatz unbundling issue.”3 Similarly, the May Further Notice in this proceeding concludes “we do not consider competition over resold lines as a material competitive restraint.”  At the end of the day, making resale artificially more attractive by mandating a special discount (“ersatz unbundling”) for a favored class of resellers will result in more resale and less investment in the real facilities-based competition that matters.