******************************************************** NOTICE ******************************************************** This document was converted from WordPerfect to ASCII Text format. Content from the original version of the document such as headers, footers, footnotes, endnotes, graphics, and page numbers will not show up in this text version. All text attributes such as bold, italic, underlining, etc. from the original document will not show up in this text version. Features of the original document layout such as columns, tables, line and letter spacing, pagination, and margins will not be preserved in the text version. If you need the complete document, download the WordPerfect version or Adobe Acrobat version, if available. ***************************************************************** March 18, 1999 Separate Statement of Commissioner Gloria Tristani Re: Deployment of Wireline Services Offering Advanced Telecommunications Capability, First Report and Order and Further Notice of Proposed Rulemaking. I strongly support the Commission's decision to adopt stronger collocation rules. These new rules will lower costs and reduce delays currently involved in the collocation process. By simplifying collocation for competitors, I hope we will hasten the deployment of advanced services. In many areas, it has been new entrants that have been most responsive to end users' demand for bandwidth. And where competitors have gone, incumbents have quickly followed. So I am convinced that eliminating costly and time-consuming collocation requirements will accelerate the deployment of high-speed services by competitors and incumbents alike. I am also pleased with the Commission's tentative conclusion that we should require line sharing by incumbent LECs. Line sharing refers to the practice of two carriers providing different services over a single loop. In the typical example, one carrier would provide voice-grade service while a second carrier, using a different frequency, would be able to transmit data over that same loop. Today, if a competitor wants to provide high-speed data service to a customer, the competitor must purchase a separate line from the incumbent LEC and use it just for data. The competitor's purchase of stand-alone lines is a cost that the incumbent LEC does not incur if it seeks to win a customer for high-speed data service. Consequently, competitors today are at a potentially significant competitive cost disadvantage in the high-speed data market. My strong support for both parts of today's decision is based largely on my desire to encourage the deployment of high-speed service to residential markets. Today, the business market is starting reap the benefits of competition among providers of high-speed data service. Residential markets, unfortunately, are much farther behind. The steps we take today could greatly enhance competitors' ability to serve residential markets. I am told that, if high-speed data offerings are to gain a foothold in residential markets, the service must be priced lower than in business markets. Better collocation rules and line sharing, if ultimately adopted, will go far toward lowering the input costs for new providers of advanced services. I hope that a cost structure that is free of unreasonable impediments will accelerate competition in business markets and allow competitors to expand their footprints to include residential areas.