Federal Communications Commission DA 08-1171 Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of ) ) Petition of BellSouth Telecommunications, ) Inc. for Phase I and/or Phase II Pricing Flexibility ) for Dedicated Transport and Special Access Services ) in the Albany, GA; Athens, GA; Macon-Warner Robins, ) WCB/Pricing File No. 08-02 GA; Alexandria, LA; Pascagoula, MS; Anderson, SC; ) and Florence, SC Metropolitan Statistical Areas, and ) Phase I and/or Phase II Pricing Flexibility for Channel ) Terminations in the Albany, GA; Athens, GA; ) Alexandria LA; Anderson, SC; Charleston-North ) Charleston, SC; and Florence, SC Metropolitan ) Statistical Areas ) ORDER Adopted: May 16, 2008 Released: May 16, 2008 By the Chief, Wireline Competition Bureau: I. INTRODUCTION 1. On January 25, 2008, BellSouth Telecommunications, Inc. (BellSouth) filed a petition for pricing flexibility pursuant to sections 1.774 and 69.701 et seq. of the Commission’s rules1 seeking: (1) Phase I relief for certain special access and dedicated transport services other than end user channel terminations in the Albany, GA, Athens, GA, Macon-Warner Robins, GA, Alexandria, LA, Pascagoula, MS, Anderson, SC, and Florence, SC Metropolitan Statistical Areas (MSA); (2) Phase II relief for certain dedicated transport and special access services other than end user channel terminations in the Albany, GA, Athens, GA, Alexandria, LA, Anderson, SC and Florence, SC MSAs; (3) Phase I relief for end user channel terminations in the Albany, GA, Athens, GA, Alexandria, LA, Anderson, SC, Charleston-North Charleston, SC, and Florence, SC MSAs; and (4) Phase II relief for end user channel terminations in the Albany, GA, Athens, GA, Anderson, SC, Charleston-North Charleston, SC and Florence, SC MSAs.2 On January 31, 2008, the Commission issued a public notice seeking comments on the Petition,3 and 1 47 C.F.R. §§ 1.774, 69.701 et seq. 2 See Petition of BellSouth Telecommunications, Inc. for Pricing Flexibility Under § 69.727 of the Commission’s Rules for the Specific MSAs (filed Jan. 25, 2008) (Petition). A list of the specific services for which BellSouth seeks pricing flexibility can be found in the Appendix to this order. 3 Pleading Cycle Established for BellSouth Petition for Pricing Flexibility for Special Access Services and Dedicated Transport Services, WCB/Pricing File No. 08-02, Public Notice, DA 08-269 (Wireline Comp. Bur. rel. Jan. 31, 2008). Federal Communications Commission DA 08-1171 2 SouthernLINC Wireless and Sprint Nextel filed oppositions.4 As detailed below, the Commission established the rules for granting pricing flexibility for special access and dedicated transport services in its Pricing Flexibility Order.5 In doing so, the Commission recognized the importance of granting pricing flexibility to incumbent local exchange carriers (LECs) as competition develops in the market for interstate access services “to ensure that our own regulations do not unduly interfere with the operation of these markets.”6 For the reasons that follow, we grant BellSouth’s petition. II. BACKGROUND 2. To recover the costs of providing interstate access services, incumbent LECs charge interexchange carriers (IXCs) and end users for access services in accordance with the Commission’s Part 69 access charge rules.7 In the Access Charge Reform First Report and Order, the Commission adopted a market-based approach to access charge reform, pursuant to which it would relax restrictions on incumbent LEC pricing as competition emerges.8 At that time, the Commission deferred resolution of the specific timing and degree of pricing flexibility to a future order.9 Subsequently, in the Pricing Flexibility Order, the Commission provided detailed rules for implementing the market-based approach.10 3. The framework the Commission adopted in the Pricing Flexibility Order grants progressively greater flexibility to LECs subject to price cap regulation as competition develops, while ensuring that price cap LECs: (1) do not use pricing flexibility to deter efficient entry or engage in exclusionary pricing behavior; and (2) do not increase rates to unreasonable levels for customers that lack competitive alternatives.11 In addition, the reforms are designed to facilitate the removal of services from 4 See Comments of Southern Communications Services, Inc. d/b/a SouthernLINC Wireless, WCB/Pricing File No. 08-02 (filed Feb. 15, 2008) (SouthernLINC Opposition); Comments of Sprint Nextel Corporation, WCB/Pricing File No. 08-02 (filed Feb. 15, 2008) (Sprint Nextel Opposition). 5 See Access Charge Reform, CC Docket No. 96-262, Fifth Report and Order and Further Notice of Proposed Rulemaking, 14 FCC Rcd 14221 (1999) (Pricing Flexibility Order), aff’d, WorldCom, Inc. v. FCC, 238 F.3d 449 (D.C. Cir. 2001). 6 Pricing Flexibility Order, 14 FCC Rcd at 14224, para. 1. 7 47 C.F.R. Part 69. Part 69 establishes two basic categories of access services: special access services and switched access services. Compare 47 C.F.R. § 69.114 with 47 C.F.R. § 69.106. Special access services employ dedicated facilities that run directly between the end user and an IXC point of presence (POP), the physical point where an IXC connects its network with the LEC network. Charges for special access services generally are divided into channel termination charges and interoffice facility charges. Channel termination charges (which can include a flat-rated charge and a mileage component) recover the costs of facilities between the customer’s premises and the LEC end office and the costs of facilities between the IXC POP and the LEC serving wire center. See 47 C.F.R. § 69.703(a). Interoffice facility charges recover the costs of facilities between the LEC serving wire center and the LEC end office serving the end user. See Pricing Flexibility Order, 14 FCC Rcd at 14226-27, paras. 8-10. For the interoffice facility, carriers often have separate termination and mileage charges. 8 Access Charge Reform, CC Docket No. 96-262, First Report and Order, 12 FCC Rcd 15982 (1997) (Access Charge Reform First Report and Order), aff’d, Southwestern Bell Tel. Co. v. FCC, 153 F.3d 523 (8th Cir. 1998). 9 Access Charge Reform First Report and Order, 12 FCC Rcd at 15989, para. 14. 10 Pricing Flexibility Order, 14 FCC Rcd at 14225, para. 4. 11 Id. at 14225, para. 3. The Commission instituted price cap regulation for the Regional Bell Operating Companies (RBOCs) and GTE in 1991, and permitted other LECs to adopt price cap regulation voluntarily, subject to certain conditions. Policy and Rules Concerning Rates for Dominant Carriers, CC Docket No. 87-313, (continued….) Federal Communications Commission DA 08-1171 3 price cap regulation as competition develops in the marketplace, without imposing undue administrative burdens on the Commission or the industry.12 4. In keeping with these goals, the Commission established a framework for granting price cap LECs greater flexibility in the pricing of interstate access services once they make a competitive showing, or satisfy certain “triggers,” to demonstrate that market conditions in a particular area warrant the relief they seek. Pricing flexibility for special access and dedicated transport services13 is available in two phases, Phase I and Phase II, based on an analysis of competitive conditions in individual MSAs or non-MSA parts of the study area.14 Pricing flexibility for channel termination services15 is also available in two phases, based on an analysis of competitive conditions in individual MSAs or non-MSA parts of the study area.16 5. Phase I Pricing Flexibility. A price cap LEC that obtains Phase I relief is allowed to offer, on one day’s notice, contract tariffs17 and volume and term discounts for qualifying services, so long as the services provided pursuant to contract are removed from price caps.18 To protect those customers that may lack competitive alternatives, a price cap LEC receiving Phase I flexibility must maintain its generally available, price cap-constrained, tariffed rates for these services.19 To obtain Phase I relief, a price cap LEC must meet triggers designed to demonstrate that competitors have made irreversible, sunk investments in the facilities needed to provide the services at issue.20 In particular, to receive pricing flexibility for dedicated transport and special access services (other than channel terminations to end users), a price cap LEC must demonstrate that unaffiliated competitors have collocated in at least 15 percent of the LEC’s wire centers within an MSA, or have collocated in wire (Continued from previous page) Second Report and Order, 5 FCC Rcd 6786, 6818-20, paras. 262-79 (1990). The Pricing Flexibility Order applies only to LECs that are subject to price cap regulation. Pricing Flexibility Order, 14 FCC Rcd at 14224, para. 1 n.1. 12 Pricing Flexibility Order, 14 FCC Rcd at 14225, para. 3. 13 For purposes of pricing flexibility proceedings, “dedicated transport services” refer to services associated with entrance facilities, direct-trunked transport, and the dedicated component of tandem-switched transport. Id. at 14234, para. 24 n.54. These services are defined in 47 C.F.R. § 69.2(oo) (direct-trunked transport), § 69.2(qq) (entrance facilities), and § 69.2(ss) (tandem-switched transport). 14 See 47 C.F.R. § 22.909(a) (definition of MSA). See also Pricing Flexibility Order, 14 FCC Rcd at 14261, para. 76 (pricing flexibility will be granted to price cap LECs within the non-MSA parts of a study area if they satisfy the applicable triggers throughout that area). 15 For purposes of pricing flexibility proceedings, a channel termination between a LEC end office and a customer premises is defined as a “dedicated channel connecting a LEC end office and a customer premises, offered for purposes of carrying special access traffic.” 47 C.F.R. § 69.703(a)(2). 16 See supra note 13. 17 A contract tariff is a tariff based on an individually negotiated service contract. See Competition in the Interstate Interexchange Marketplace, CC Docket No. 90-132, Report and Order, 6 FCC Rcd 5880, 5897, para. 91 (1991) (Interexchange Competition Order); 47 C.F.R. § 61.3(o). See also 47 C.F.R. § 61.55 (describing required composition of contract-based tariffs). 18 Pricing Flexibility Order, 14 FCC Rcd at 14287-88, para. 122. 19 Id. at 14234-35, para. 24. 20 Id. at 14234-35, 14274, paras. 24, 94. Federal Communications Commission DA 08-1171 4 centers accounting for 30 percent of the LEC’s revenues from these services within an MSA.21 In both cases, the price cap LEC also must show, with respect to each wire center used to satisfy the trigger, that at least one collocator is relying on transport facilities provided by an entity other than the incumbent LEC.22 6. Higher thresholds apply for obtaining Phase I pricing flexibility for channel terminations between a LEC’s end office and an end user customer. A competitor collocating in a LEC end office continues to rely on the LEC’s facilities for the channel termination between the end office and the customer premises, at least initially, and thus is more susceptible to exclusionary pricing behavior by the LEC.23 As a result, a price cap LEC must demonstrate that unaffiliated competitors have collocated in at least 50 percent of the LEC’s wire centers within an MSA, or have collocated in wire centers accounting for 65 percent of the LEC’s revenues from these services within an MSA.24 Again, the LEC also must demonstrate, with respect to each wire center used to satisfy the trigger, that at least one collocator is relying on transport facilities provided by an entity other than the incumbent LEC.25 7. Phase II Pricing Flexibility. A price cap LEC that receives Phase II relief is allowed to offer dedicated transport and special access services free from the Commission’s Part 69 rate structure and Part 61 price cap rules.26 The LEC, however, is required to file, on one day’s notice, generally available tariffs for those services for which it receives Phase II relief.27 To obtain Phase II relief, a price cap LEC must meet triggers designed to demonstrate that competition for the services at issue within the MSA is sufficient to preclude the incumbent from exploiting any individual market power over a sustained period. To obtain Phase II relief for dedicated transport and special access services (other than channel terminations to end users), a price cap LEC must demonstrate that unaffiliated competitors have collocated in at least 50 percent of the LEC’s wire centers within an MSA, or have collocated in wire centers accounting for 65 percent of the LEC’s revenues from these services within an MSA.28 The LEC also must demonstrate, with respect to each wire center used to satisfy the trigger, that at least one collocator is relying on transport facilities provided by an entity other than the incumbent LEC.29 8. Higher thresholds apply for obtaining Phase II pricing flexibility relief for channel terminations between a LEC end office and an end user customer. To obtain such relief, a price cap LEC must demonstrate that unaffiliated competitors have collocated in at least 65 percent of the LEC’s wire centers within an MSA, or have collocated in wire centers accounting for 85 percent of the LEC’s revenues from these services within an MSA.30 To obtain Phase II relief for channel terminations to end 21 Id. at 14274-77, paras. 95-98; 47 C.F.R. § 69.709(b). 22 47 C.F.R. § 69.709(b). 23 Pricing Flexibility Order, 14 FCC Rcd at 14278-79, paras. 102-103. 24 Id. at 14280-81, paras. 105-06; 47 C.F.R. §§ 69.711(a), (b). 25 47 C.F.R. §§ 69.711(a), (b). 26 See Pricing Flexibility Order, 14 FCC Rcd at 14301, para. 153. 27 Id.; 47 C.F.R. § 69.727(b)(3). 28 Pricing Flexibility Order, 14 FCC Rcd at 14299, paras. 148-49; 47 C.F.R. § 69.709(c). 29 47 C.F.R. § 69.709(c). 30 Pricing Flexibility Order, 14 FCC Rcd at 14235, 14299-300, paras. 25, 150; 47 C.F.R. § 69.711(c). Federal Communications Commission DA 08-1171 5 users, the LEC also must demonstrate, with respect to each wire center used to satisfy the trigger, that at least one collocator is relying on transport facilities provided by an entity other than the incumbent LEC.31 9. Competitive Showing. Pricing flexibility may be granted upon the satisfaction of certain competitive showings. An incumbent LEC bears the burden of proving that it has satisfied the applicable triggers for the pricing flexibility it seeks for each MSA.32 For special access and dedicated transport services and channel termination services the incumbent must identify: (1) the total number of wire centers in the MSA; (2) the number and location of the wire centers in which competitors have collocated; and (3) in each wire center on which the incumbent bases its petition, the name of at least one collocator that uses transport facilities owned by a provider other than the incumbent to transport traffic from that wire center. 33 In addition to these three requirements, the petitioner must show either: (A) that the percentage of wire centers in which competitors have collocated and use competitive transport satisfies the trigger the Commission adopted with respect to the pricing flexibility sought by the incumbent LEC;34 or (B) that the percentage of total base period35 revenues that are attributable to the wire centers upon which the petitioner relies satisfies the applicable pricing flexibility triggers.36 III. DISCUSSION 10. BellSouth seeks: (1) Phase I relief for certain special access and dedicated transport services other than end user channel terminations in the Albany, GA, Athens, GA, Macon-Warner Robins, GA, Alexandria, LA, Pascagoula, MS, Anderson, SC, and Florence, SC Metropolitan Statistical Areas (MSA); (2) Phase II relief for certain dedicated transport and special access services other than end user channel terminations in the Albany, GA, Athens, GA, Alexandria, LA, Anderson, SC and Florence, SC MSAs; (3) Phase I relief for end user channel terminations in the Albany, GA, Athens, GA, Alexandria, LA, Anderson, SC, Charleston-North Charleston, SC, and Florence, SC MSAs; and (4) Phase II relief for end user channel terminations in the Albany, GA, Athens, GA, Anderson, SC, Charleston- North Charleston, SC and Florence, SC MSAs. As noted above, pricing flexibility may be granted upon the satisfaction of certain competitive showings. An incumbent LEC bears the burden of proving that it has satisfied the applicable triggers for the pricing flexibility it seeks for each MSA.37 11. BellSouth has demonstrated compliance with the requirements for Phase I and Phase II pricing flexibility. BellSouth has provided sufficient information to demonstrate that it meets the applicable pricing flexibility triggers for the relief it has requested. As explained in greater detail below, to make this showing, BellSouth assigned wire centers to individual MSAs and identified wire centers within each MSA where service providers have obtained collocation with alternative facilities other than 31 47 C.F.R. § 69.711(c). 32 Pricing Flexibility Order, 14 FCC Rcd at 14309, para. 172. 33 47 C.F.R. § 1.774(a)(3)(i)-(iii). 34 47 C.F.R. § 1.774(a)(3)(iv)(A). 35 For price cap LECs, the “base period” is the 12-month period ending six months before the effective date of the LECs’ annual access tariffs. 47 C.F.R. § 61.3(g). 36 The revenues applicable to this requirement are those generated by the services for which the incumbent seeks relief. 47 C.F.R. § 1.774(a)(3)(iv)(B). 37 Pricing Flexibility Order, 14 FCC Rcd at 14309, para. 172. Federal Communications Commission DA 08-1171 6 BellSouth-provided transport.38 BellSouth also gathered revenue data and assigned it either to dedicated transport and special access services (other than channel terminations to the end user), or to channel terminations between an end user’s premises and the BellSouth end offices.39 12. BellSouth identified the MSAs that qualify for pricing flexibility by: (1) identifying wire centers within each MSA; (2) identifying wire centers within each MSA where service providers have obtained collocation with alternative transport facilities other than BellSouth-provided transport, and identifying service providers collocated with alternative transport facilities other than BellSouth-provided transport; (3) identifying revenue attributable to qualifying dedicated transport and special access services (other than channel terminations to end user premises) for each wire center within the MSA; and (4) identifying revenue attributable to channel terminations between an end-user’s premises and the BellSouth end offices for each wire center within the MSAs.40 13. To identify wire centers with collocation, BellSouth examined its billing records to determine those customers that were billed monthly recurring charges for collocation floor space and other applicable collocation rate elements.41 BellSouth then performed physical inventories to validate the accuracy of the billing information and to confirm that the collocation was operational.42 To confirm that the competitors were using transport facilities owned by a transport provider other than BellSouth, BellSouth used information supplied previously by the competitors or physically verified that the competitor had transport facilities owned by a non-BellSouth provider.43 In accordance with the Commission’s rules, BellSouth served a copy of its petition on each of the collocating carriers upon which it relied, including, for each collocator, the information about that party upon which BellSouth relied in its petition.44 14. To ascertain revenue associated with: (1) dedicated transport services and special access services other than end user channel terminations; and (2) end user channel terminations, BellSouth gathered data for the twelve-month period ending December 31, 2006, from its internal databases.45 BellSouth first attributed the revenues to the appropriate wire center and then determined if the revenue was POP side or end user side.46 For entrance facilities and channel terminations between an IXC POP and a serving wire center, BellSouth assigned 100 percent of the associated revenue to the BellSouth wire 38 Petition, App. D at 1-2. 39 Id., App. D at 1, 3-7. 40 Id., App. D at 1; see also App. C, App. D. 41 Id., App. D at 2. 42 Id. 43 Id. 44 Id., App. E; see also 47 C.F.R. § 1.774(e)(1)(ii). 45 Petition, App. D at 1. The billing system used for this process was the Billed Carrier Access Tracking System (BCATS), which runs internal validation checks on each BCATS bill for accuracy and completeness on a monthly basis. Id. The revenue data was extracted from the BCATS bill information database and, according to BellSouth, accurately reflects billed revenue. Id. 46 Id., App. D at 3. Federal Communications Commission DA 08-1171 7 center.47 For channel terminations between a BellSouth end office and a customer premises, 100 percent of the associated revenue was assigned to the BellSouth end office.48 BellSouth states that, after the revenue was attributed to the appropriate wire center, it was then assigned to the POP side and end user side “based upon a combination of service class, rate element, and CKL [Circuit Location].”49 15. The oppositions filed by Sprint Nextel and SouthernLINC do not dispute that BellSouth meets the applicable triggers for a grant of pricing flexibility. Rather, these parties raise a number of collateral challenges related to the state of competition in the special access and dedicated transport marketplace. For instance, Sprint Nextel opposes the petition because it believes the applicable triggers “fail to measure accurately the true state of competition in the special access and dedicated transport markets.”50 Similarly, SouthernLINC urges the Commission to “defer consideration of BellSouth’s Petition until it takes prompt and decisive action to address the marked failure in the special access marketplace,” and asks that the Commission “require BellSouth to submit record evidence demonstrating that grant of its Petition will serve the public interest and not, in fact, harm the special access marketplace.”51 We have stated repeatedly that we will not consider collateral challenges to the adequacy of the pricing flexibility rules when reviewing a pricing flexibility petition.52 The only issue appropriately before us is whether the Petition satisfies the current requirements for pricing flexibility set forth in the Commission’s rules.53 16. After reviewing BellSouth’s verification method as described in the Petition and the data provided in the public and confidential versions of the Petition, we find that BellSouth has met the applicable triggers in section 1.774 and Part 69, Subpart H of the Commission’s rules.54 Based upon a review of the information submitted, and having received no opposition challenging BellSouth’s 47 Id., App. D at 4-6. 48 Id. 49 Id., App. D at 6-7. 50 Sprint Nextel Opposition at 1. 51 SouthernLINC Opposition at 1. 52 See Petition of Ameritech Illinois, Ameritech Indiana, Ameritech Michigan, Ameritech Ohio, and Ameritech Wisconsin for Pricing Flexibility, Petition of Pacific Bell Telephone Company for Pricing Flexibility, Petition of Southwestern Bell Telephone Company for Pricing Flexibility, CCB/CPD Nos. 00-23, 00-25 and 00-26, Memorandum Opinion and Order, 16 FCC Rcd 5889, 5894, para. 13 (Com. Car. Bur. 2001); Verizon Petitions for Pricing Flexibility for Special Access and Dedicated Transport Services, CCB/CPD Nos. 00-24, 00-28, Memorandum Opinion and Order, 16 FCC Rcd 5876, 5881, para. 11 (Wireline Comp. Bur. 2001). See also BellSouth Pricing Flexibility Order, 15 FCC Rcd 24588, 24597, paras. 22-23 (Com. Car. Bur. 2000). 53 In its opposition, Sprint Nextel also contends that BellSouth “has retained its market power in the provision of special access and dedicated transport services, as evidenced by its astonishingly high returns and excessively priced interstate rates” and further claims that BellSouth increased its special access rates in areas where it has received pricing flexibility. Id. at 2-4. Because the current requirements for pricing flexibility do not involve a consideration of BellSouth’s special access and dedicated transport service rates and returns, we find such an analysis unnecessary and irrelevant under the existing rules. 54 47 C.F.R. §§ 1.774 and 69.701 et seq. Federal Communications Commission DA 08-1171 8 compliance with the pricing flexibility triggers,55 we conclude that BellSouth has satisfied its burden of demonstrating that it has met the applicable requirements for each of the various services in the MSAs for which it requests relief. IV. ORDERING CLAUSE 17. Accordingly, IT IS ORDERED that, pursuant to section 1.774 of the Commission’s rules, 47 C.F.R. § 1.774, the Pricing Flexibility Order, and the authority delegated by sections 0.91 and 0.291 of the Commission’s rules, 47 C.F.R. §§ 0.91 and 0.291, the petition filed by BellSouth Telecommunications, Inc. IS GRANTED to the extent detailed herein. FEDERAL COMMUNICATIONS COMMISSION Dana R. Shaffer Chief, Wireline Competition Bureau 55 As discussed above, none of the oppositions filed claim that BellSouth failed to meet the applicable triggers for a grant of pricing flexibility. In fact, Sprint Nextel concedes that “BellSouth may technically have satisfied the triggers that allow pricing flexibility.” Sprint Nextel Opposition at 1. Federal Communications Commission DA 08-1171 9 APPENDIX Services Qualifying for Pricing Flexibility Trunking Services Basket (Includes entrance facilities, direct trunked transport, flat-rated portion of tandem-switched transport, and the optional features and functions associated with these services.) BellSouth SWA VG BellSouth SWA DS0 BellSouth SWA DS1 BellSouth SWA DS3 BellSouth SWA Dedicated Ring BellSouth SWA Managed Shared Network Service BellSouth SWA Managed Shared Ring Service CCS7 Signaling Connection and CCS7 Signaling Termination Dedicated Network Access Lines (DNALs) Exchange Access Frame Relay Service (199 Kbps and below) a.k.a BellSouth Exchange Access Frame Relay Service Exchange Access Connectionless Data Service (199 Kbps and below) a.k.a BellSouth Exchange Connectionless Data Service BellSouth SPA Managed Shared Frame Relay Service (199 Kbps and below) BellSouth SWA SONET Transport Components BellSouth Wavelength SWA Dedicated Ring Service Components BellSouth Wavelength SWA Channel Service Components Special Access Basket (Includes channel terminations between the serving wire center and end user’s premises, and the optional features and functions associated with these services.) Metallic a.k.a BellSouth SPA Metallic Telegraph Grade a.k.a BellSouth SPA Telegraph Voice Grade a.k.a. BellSouth SPA VG WATS Access Line (WAL) a.k.a BellSouth SPA WATS Lines Program Audio a.k.a. BellSouth SPA Program Audio Broadcast Quality Video a.k.a BellSouth SPA Broadcast Quality Video Commercial Quality Video a.k.a BellSouth SPA Commercial Quality Video DS3 Digital Video Service a.k.a BellSouth SPA DS3 Digital Video Service BellSouth SPA Modular Video Transport Service Uncompressed Switched Video a.k.a BellSouth SPA Uncompressed Switched Video Wideband Analog a.k.a BellSouth SPA Wideband Analog Wideband Data a.k.a BellSouth SPA Wideband Data DS1 a.k.a BellSouth SPA DS1 LightGate DS3 svc. a.k.a BellSouth SPA Point to Point SMARTGate svc. a.k.a BellSouth SPA Managed Shared Ring SMARTPath svc. a.k.a BellSouth SPA DS1 & DS3 Shared Ring BellSouth Customer Network Management Service Dry Fiber BellSouth SPA Managed Shared Network Service BellSouth Customer Network Management Network Visibility Service (CNM-NVS) Federal Communications Commission DA 08-1171 10 High Cap & DDS – Special Service Category Derived Data Channel a.k.a BellSouth SPA Derived Data Channel Digital Data Access Service a.k.a BellSouth SPA Digital Data Access Service High Capacity a.k.a BellSouth SPA High Capacity