UNE rates are currently so high in Massachusetts that competitive entry into the local exchange market is not economically viable. Massachusetts UNE rates make it impossible for CLECs to do the same here. If one takes into account the additional costs that a CLEC must incur for its own operations, one realizes that the unfair price squeeze resulting from current rates is even greater. Thus, CLECs could not offer competitive service in Massachusetts without losing money. Under these circumstances, today's excessive UNE rates are a significant barrier to the development of robust retail competition in the Massachusetts local exchange market.
Time is of the essence.
It is very important that the Department correct this rate imbalance as soon as possible, and in any case that it do so before Bell Atlantic is permitted to offer interLATA long-distance services to Massachusetts customers. Improperly Set Based on the Cost of Switching Upgrades, and Not on the Much Lower Cost of New Switches. This approach to developing recurring UNE rates for switching was incorrect. The FCC has carefully considered the issue, and in a decision issued in November 1999 it determined that when estimating the forward-looking economic cost of switching, one must look to the cost of installing new switches to serve anticipated demand, and must not factor in the much higher cost of providing the same switching services by purchasing and installing switching equipment upgrades. As a result, the switch investment prices that Bell Atlantic used as inputs to its switching cost analysis are approximately 7.5 times higher than they should be.