Should SWBT provide Digital Cross-Connect Systems (DCS) in accordance with the FCCs rules?
This issue centers around whether SWBT is required to provide Digital Cross‑Connect Systems (DCS) as a UNE. WCOM argues that the answer is yes, while SWBT alleges that pursuant to the terms of the FCCs UNE Remand Order, cross‑connects are a means of interconnection and not a separate UNE. Staff states that the FCC concluded that ILECs must provide cross‑connect facilities between an unbundled loop and a requesting carriers collocated equipment. The FCC has defined the cross‑connect as a means of interconnection, not as part of a UNE or as a separate UNE in and of itself. Staff recommends that the language of both parties should be combined and incorporated into the Agreement. The Commission agrees with Staffs analysis and finds the language of both parties should be combined and incorporated in the Agreement as recommended by Staff. Issue 21: Is SWBT required to provide WCOM access to proprietary AIN features developed by SWBT? WCOM proposes language that requires SWBT to provide acces
