The Saga of Getting DSL in Verizon
Territory,
Bucks County Pennsylvania
In about
February of 2002 I contacted a number of Internet providers to attempt to have
xDSL service provided at my residence in Bucks County, PA. The providers I contacted
turned me down due to my distance from my central office (CO). I quickly
learned however that is was NOT an ISP issue but rather the apparent absolute
rule of Verizon to limit xDSL connections to less than 18K feet. I am well
aware that I cannot qualify for ADSL or even SDSL at my location but a
variation of ISDN called IDSL is available and being used elsewhere in the
nation at distances up to 36K feet or more. There is also another version of
DSL – RADSL that is often used at distances beyond the capabilities of ADSL or
SDSL.
After
studying this for months and reading pages and pages of documentation it
appears that IDSL (which is just DSL from repackaged ISDN) is a technology,
which is available, and being used to loop distances of over 40K feet and
through fiber. For some reason Verizon seems to deny it’s existence and/or it’s
capabilities.
The following
pages describe my formal complaint to the PUC and their response as well as
documents from Pennsylvania legislators and supplier information documenting
the availability of these services elsewhere.
Some quotes taken from supplier web pages –
QUEST -
“Qwest
Integrated Service Digital Network Digital Subscriber Line (IDSL) service is an
extension of the existing Qwest Digital Subscriber Line (DSL) services product
and is another variety of the xDSL family of products. It extends the service
reach, resulting in more potential sites, to get broadband technology. Customers who are
served by selected types of Digital Loop Carriers (DLC) or who are farther than
15,000 feet but no greater than 36,000 feet from their corresponding central
office, MAY qualify for this "flavor" of DSL.”
SPEAKEASY -
IDSL - IDSL
is based on ISDN, an older technology that was designed to work well with existing
ISDN transmission methods. SDSL, and ADSL travel over regular copper lines and
cannot have any electronics on them (such as, for example, amplifiers or
repeaters - commonly used to "boost" the voice signal on conventional
telephone lines). Some ADSL, and SDSL orders cannot be fulfilled because of
electronics or distance issues that are uncovered during the ordering process.
In that case, IDSL may be the best solution. IDSL has the ability to work over
great distances, and through certain types of electronics. If you are very far
away from a Central Office, or there are electronics on the copper line you are
given by your phone company, you may still be able to get broadband service
using IDSL.
NETOPIA -
IDSL is the "always-on" version of dial-up ISDN, without
the per minute usage charges. IDSL typically delivers maximum symmetric speeds
at 144 Kbps, but with DSL Bonding IDSL can deliver maximum bandwidth of up to
576 Kbps. IDSL has a much farther reach compared to other types of DSL. IDSL is
an affordable service for businesses located up to 36,000 feet (6.8 miles) from
the CO, and is a particularly good option for those too far from the CO to get
SDSL service.
IDSL Speeds |
Best Applications |
Maximum IDSL Speeds with DSL Bonding * |
Maximum Distance from CO |
128 Kbps |
Always-on Internet access and email, Web surfing and transmission of large files (smooth video streaming requires at least 384 Kbps) |
Up to 512 Kbps |
36,000 feet or 6.8 miles |
144 Kbps |
All of the above, plus slightly more speed. Users can upgrade to a small voice and data network when VoDSL is available. |
Up to 576 Kbps |
36,000 feet or 6.8 miles |
DSL AMERICA
Distance The speed that can be obtained using DSL is dependent on the distance (length of cable) between the user and the telephone company central office (C.O.) and the thickness of wire used by the telephone company. Typical maximum distances are as follows:
1.5Mbps - 10,500 feet (2 miles) 1.0Mbps - 12,300 feet (2.3 miles) 768Kbps - 13,500 feet (2.5 miles) 384Kbps - 22,500 feet (4.3 miles) 144Kbps - 35,000 feet (6.6 miles)*
*In many areas 144 Kbps (IDSL) is provided over digital carrier and fiber optic cable allowing unlimited distances to be obtained.
As new technologies and equipment are placed into service, speed and distance will continue to increase.
TENFORWARD –
IDSL |
Price |
Max. Distance from CO |
Up to 144 kbps |
$119.95/mo |
30,000 ft. |
XSPEED –
What is IDSL? ISDN Digital Subscriber Line. IDSL is based on the ISDN interface. This allows the Xpeed 200 IDSL Adapter to work with existing ISDN infrastructure, including repeaters and DLCs.
Why is IDSL better than ISDN?
• |
IDSL is always-on so there is no inconvenient dial-up. |
• |
IDSL is connected directly to the digital data network, whereas ISDN goes through the Public Switched Telephone Network. |
• |
IDSL uses all available channels, 2B+D. So not only is the connection always on, but it utilizes the maximum 144 Kbps. |
CROSSLINK –
This chart tells it all! Even Bell Atlantic, predecessor to Verizon had the limitation!
DSL Wiring Distance Limitations Average distance from telephone company CO Actual distance varies by quality and gauge of copper wire circuit |
|
144Kbps IDSL circuit - Bell Atlantic areas* |
3.2 miles |
144Kbps IDSL circuit - GTE areas |
7 miles |
256Kbps SDSL circuit |
3 miles |
384 Kbps SDSL circuit |
3 miles |
768 Kbps SDSL circuit |
2.5 miles |
1.1 Mbps SDSL circuit |
2 miles |
1.5 Mbps / 384 Kbps SDSL circuit |
2.5 miles |
1.5 Mbps / 1.5 Mbps SDSL circuit |
2 miles |
*Bell Atlantic will only provide DSL circuits up to18,000 wiring feet from their equipment offices. |
|
NETPIPE –
IDSL (ISDN Digital Subscriber Line): IDSL is a symmetric service that can deliver high-speed data communication up to 128 Kbps. New Edge Networks IDSL is an ideal high-speed service alternative for users living or working outside of the metropolitan periphery, beyond the reach of traditional SDSL and ADSL services. In many non-urban areas, the distance between a telephone company's central office and a user's business or home can be substantial. IDSL's strongest asset is its ability to reach up to 30,000 feet for the telephone central office. This is twice the distance of SDSL.
IDSL IDSL (ISDN DSL) A hybrid of ISDN and DSL; it’s an always on alternative to dial up ISDN. Does not support voice connections on the same line. Speed - 144 Kbps Max. Distance From CO - 35,000 ft. (6.6 miles)* Key Applications - As an alternate solution: it has a longer range than other DSLs, and is more affordable than dial-up ISDN.
See this Lucent press release
–
http://www.lucent.com/press/1099/991019.nsa.html
BTI plans to offer a heavy concentration of IDSL services, plus SDSL services, in conjunction with its existing Digital Loop Carrier (DLC) network. IDSL provides symmetric bandwidth of 144 kbps over distances of up to 36,000 feet with the use of a mid-span repeater, and maximizes BTI's geographic range and service coverage by reaching subscribers located long distances from serving central offices or beyond digital loop carriers. SDSL maximizes service speeds and loop reach, with symmetric transmission up to 1.5 Mbps and reach up to 28,000 feet.
See http://www.dslcenter.com/glossary.htm for a
glossary of DSL terms.
Links with important IDSL
information
http://www.qwest.com/dsl/learn/idsl.html
http://dslcenter.netopia.com/netopia/idsl.html
http://www.nwfusion.com/news/0817copper.html
http://dsl-america.net/dsl/Business/dsl_facts.html
http://www.tenforward.com/dsla.htm
http://www.xpeed.com/faq.html
http://www2.crosslink.net/whatisdsl.cfm
http://208.12.71.4/netpipedsl/overview.htm
http://www.broadbandforwork.com/dslinfo.htm
http://www.pbs.org/cringely/pulpit/pulpit19991202.html
http://www.dsl-warehouse.com/index.html
This
is my formal complaint to the PUC
PUC Formal Complaint Form (continuation Items 3,4)
Doug Crompton
1269 2nd St Pike
Richboro, PA 18954-2021
3. The problem is the CO to customer distance restrictions applied to Digital Subscriber Line (DSL) by Verizon. Currently Verizon in the Pennsylvania area limits the distance to an 18,000-foot loop from the central office. This restriction is arbitrary and limits current technology. IDSL and RADSL technology reliably extend this distance to at least 24,000-foot limits and further with repeaters. This technology is being used in other parts of the county with other phone carriers successfully.
Various competitor DSL suppliers, including DCANet and Speakeasy, are willing to supply this service in the PA Verizon territory but are limited by Verizon’s current restrictive regulations.
I have found this to be a “blame game”, the state PUC says it is a Verizon limit and that they have no jurisdiction over DSL. Verizon claims that the limit is controlled by the state. Which is correct?
As many as 50% of Verizon customers are being denied DSL service or at least the ability to let a competitor try to make it work by this arbitrary limit.
DSL is being advertised heavily but almost half of the telephone customers do not qualify due to distance from the CO.
I am well aware that ADSL and SDSL have loop limits that prevent their use beyond 15000 to 18000 feet but newer technologies – IDSL, RADSL do not have these limitations and ARE being used throughout the world NOW successfully
This limit clearly limits the advancement of technology in Pennsylvania and also the consumer’s ability to make a competitive choice for high-speed Internet access.
4. I would like to have the ability to have DSL service or the attempt to see if the service would work at my location, based upon proven newer technology. I would like a clear understanding of why this limit is set, who is setting it, and how it can be changed?
And
the Verizon Lawyers response:
BEFORE THE
PENNSYLVANIA PUBLIC UTILITY COMMISSION
DOUG CROMPTON,
Complainant
v. Docket No. C-20027309
VERIZON PENNSYLVANIA INC.,
. Respondent
ANSWER OF
VERIZON PENNSYLVANIA INC.
Verizon Pennsylvania Inc., ("Verizon PA" or "Company") by its attorneys in this proceeding, Malatesta Hawke & McKeon LLP, hereby submits its Answer to the Complaint filed by Doug Crompton ("Complainant"). In support thereof, Verizon PA avers and represents as follows:
1. ADMITTED in part DENIED in part. Verizon PA agrees that the customer's physical location is as stated. However, Verizon PA's records list the customer's home phone number as 215.355.5307. The number listed in the Complaint is assigned to Sprint and may be a cellular phone number.
2. ADMITTED. By way of further response, the company's full name is Verizon Pennsylvania Inc.
3. ADMITTED in part DENIED in part. It is ADMITTED that digital subscriber line ("DSL") effectiveness is limited to an equivalent distance of 18,000-foot loop length from the central office on non-loaded copper facilities. It is DENIED that this restriction is "arbitrary" or that customers are unfairly being denied DSL service. Further, it is DENIED that Verizon PA is limiting the advancement technology or limiting customers' ability to make a competitive choice. It is DENIED that Verizon PA is limiting the ability of DCANet or Speakeasy to deploy technology in Pennsylvania. To the extent that DCANet or Speakeasy are resale or UNE-based carriers, it may be that they are not willing to provide the facilities themselves.
By way of further response, Verizon PA states that the Complainant is served out of the Verizon PA's Churchville central office located in Bucks County, Pennsylvania and is located 21,300 equivalent feet from the central office. Currently, voice service is provided to the customer at 215.355.5307 via a digital loop carrier (Lucent Series 5 Subscriber Line Carrier), a fiber based technology upon which DSL service physically cannot be offered and, to the Company's best understanding, is not being developed by Lucent.
Cooper facilities are located in the area, but have three different repeaters (load coils) installed over that distance in order to boost the signal for the purposes of voice service. DSL is not available on loaded lines and, if the load coils were removed, customers' voice service would be impaired.
Verizon PA cannot offer a service which does not technologically exist for this application. The technology for the provision of DSL service is evolving and improving over time. Along with it, Verizon PA is evolving its network to provide faster Internet speeds to its more remote customers. In this matter, a proven and installed technical solution is not yet available at this distant location to provide DSL.
4. This paragraph is a request for relief to which no response is required. However, Verizon PA will welcome the opportunity to further discuss with the Complainant the current limitations upon Internet speeds at his location.
WHEREFORE, for all of the reasons set forth above, Verizon Pennsylvania Inc. respectfully requests that the Formal Complaint filed by Doug Crompton at Docket No. 020027309 be dismissed or denied in its entirety.
Respectfully s b ' ,
ames Kennard alatesta Hawke & McKeon LLP Harrisburg Energy Center 100 North Tenth Street P.O. Box 1778 Harrisburg, PA 17105-1778 (717) 236-1300
Counsel for
Verizon Pennsylvania Inc.
DATED: April 24, 2002
Rural Telcos
Pushing DSL to Low Densities
In
their push to gain deregulation, the major incumbent telcos argue that
regulatory burdens hike the cost of providing DSL service beyond the point
where it is feasbile for them to bring high-speed service to low population
density towns and rural areas. It’s a
simple matter of economics – the high upfront cost of delivering DSL, a cost
inflated by interconnection unbundling requirements, makes only high density
areas, rich as they are with a greater number of potential customers, realistic
from a financial perspective.
But,
according to data obtained from the Pinkham
Group, a consultancy which continuously tracks DSL deployment on a central
office-by-central office basis, small telcos that serve primarily rural
territories have made solid strides in bringing DSL to underserved areas. According to the Pinkham Group data, as of
year-end 2001, small, independent telcos installed DSL gear in central offices
that cover 50% of their service areas, compared to the former Regional Bell
Operating Companies (RBOCs, which include Bell South, Verizon, Qwest and SBC,
and for the purpose of Pinkham Group’s calculations, Sprint’s local exchange
areas), which have installed gear in CO’s that cover approximately 80% of their
collective service territories.
[Note: simply because the central office has been
DSL-equipped doesn’t mean that all homes or offices service by that CO are able
to buy DSL Distance limitations
significantly restrict the reach of DSL around the CO and line conditions and
other factors can handicap the true service area around a DSL-enabled CO.]
Of
the total 7,500 COs owned by small independent telcos, around 2,000, or 27%,
have been retrofitted for DSL, predominately in the most dense areas served by
these tiny telcos. This ratio is only
slightly lower than the corresponding percentage for the major telcos. The RBOCs (and Sprint) have deployed DSL to
slightly more than 4,600, or 37%, of their 12,500 COs.
As
the table below shows, the average density of DSL-deployed COs differs
dramatically between the major telcos (15,899 households per DSL-deployed CO)
and their smaller brethren (2,239 households per DSL-deployed CO). The data clearly shows that the small
telcos have been willing to deploy DSL in CO’s that serve as little as 500 or
fewer homes – in Wyoming, the average number of households per DSL-deployed CO
for the small telcos is 374. In New
Mexico, the independent telcos have rolled out the high-speed service in CO’s
that reach an average of only 421 COs.
What
the data doesn’t reveal is how many homes and businesses in the small towns and
rural communities are actually able to receive, much less buying, the
service. But the fact that independent
telcos are now pushing DSL to the kinds of communities that the RBOCs say are
unprofitable gives rise to the hope that even in the absence of deregulation,
sooner or later DSL could become available to most every home in the country.
DSL Coverage Q4 2001 |
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Central Office Densities Analysis of RBOC vs Independent Telcos |
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Courtesy of Pinkham Group |
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Central Office Density (Hhlds/CO) |
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State Avg |
Avg Density of DSL-deployed COs |
|
State |
Total Hhlds (M) |
Hhld Served by Independents |
Hhlds/CO |
RBOCs* |
Independents Telcos |
AK |
235 |
100% |
1,655 |
na |
9,845 |
AL |
1,659 |
11% |
4,712 |
10,886 |
1,675 |
AR |
980 |
34% |
2,553 |
12,277 |
1,872 |
AZ |
1,821 |
7% |
8,165 |
27,306 |
4,381 |
CA |
11,313 |
2% |
12,087 |
21,423 |
4,208 |
CO |
1,572 |
5% |
5,802 |
25,923 |
1,216 |
CT |
1,227 |
1% |
9,741 |
12,051 |
na |
DC |
240 |
0% |
17,147 |
17,147 |
na |
DE |
287 |
0% |
8,698 |
21,187 |
na |
FL |
5,732 |
2% |
12,249 |
16,761 |
4,536 |
GA |
2,789 |
20% |
6,738 |
16,127 |
5,125 |
HI |
394 |
1% |
4,686 |
7,846 |
na |
IA |
1,126 |
37% |
1,577 |
15,933 |
749 |
ID |
458 |
10% |
2,726 |
15,579 |
817 |
IL |
4,340 |
7% |
4,502 |
20,464 |
1,892 |
IN |
2,240 |
5% |
4,014 |
13,009 |
2,170 |
KS |
991 |
8% |
1,852 |
15,042 |
428 |
KY |
1,517 |
20% |
3,919 |
9,412 |
4,899 |
LA |
1,609 |
9% |
4,920 |
10,904 |
1,602 |
MA |
2,384 |
.13% |
8,828 |
11,595 |
1,390 |
MD |
1,914 |
0% |
9,245 |
14,367 |
na |
ME |
498 |
17% |
2,000 |
11,140 |
931 |
MI |
3,730 |
4% |
5,421 |
19,920 |
1,737 |
MN |
1,773 |
23% |
2,783 |
18,212 |
1,068 |
MO |
2,070 |
11% |
3,058 |
16,969 |
2,283 |
MS |
984 |
9% |
3,755 |
8,335 |
3,395 |
MT |
344 |
30% |
1,447 |
14,948 |
896 |
NC |
2,847 |
15% |
5,682 |
10,200 |
2,889 |
ND |
271 |
41% |
987 |
25,748 |
820 |
NE |
649 |
45% |
1,492 |
17,134 |
3,018 |
NH |
472 |
6% |
3,347 |
14,657 |
1,372 |
NJ |
2,894 |
0% |
12,474 |
14,583 |
1,787 |
NM |
636 |
16% |
3,719 |
18,709 |
421 |
NV |
648 |
5% |
7,708 |
18,012 |
6,197 |
NY |
6,812 |
11% |
8,472 |
24,219 |
2,744 |
OH |
4,322 |
19% |
5,133 |
12,970 |
8,645 |
OK |
1,283 |
20% |
2,507 |
11,393 |
778 |
OR |
1,282 |
9% |
4,836 |
16,600 |
1,618 |
PA |
4,634 |
11% |
5,597 |
15,747 |
2,501 |
RI |
512 |
0% |
17,060 |
26,093 |
na |
SC |
1,410 |
20% |
5,280 |
9,711 |
4,255 |
SD |
275 |
37% |
1,182 |
24,733 |
774 |
TN |
2,118 |
14% |
5,915 |
11,748 |
3,581 |
TX |
7,193 |
8% |
5,246 |
17,822 |
1,831 |
UT |
672 |
9% |
4,871 |
14,101 |
917 |
VA |
2,577 |
3% |
5,640 |
14,830 |
3,280 |
VT |
258 |
13% |
2,113 |
5,791 |
1,017 |
WA |
2,195 |
7% |
6,714 |
16,137 |
1,729 |
WI |
2,004 |
28% |
3,313 |
15,353 |
1,883 |
WV |
731 |
17% |
3,192 |
10,113 |
4,219 |
WY |
189 |
13% |
2,336 |
23,566 |
374 |
US Total |
101,110 |
10% |
5,149 |
15,899 |
2,239 |
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* Note RBOC coverage includes US Sprint Local Exchanges. |
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DSL - Here, There & Everywhere
By William Rodey
This Article first appeared in OUTSIDE PLANT Magazine January 2002
Digital Subscriber
Line (DSL) service infrastructure has grown exponentially, yet demand among
the residential and business user community is outpacing that growth. A
significant portion of the community has been unable to get the service
because they are located beyond the service footprint of their local Internet
Service Provider (ISP), or on loops that are not copper and cannot support
DSL. Fortunately, that service provider footprint is expanding due to newer
and more efficient ways to deploy and service DSL over long loops and
non-copper facilities. |
William Rodey is
president and chairman of DSL Forum, a non-profit DSL interest group made up
of more than 330 companies worldwide. Rodey is also senior vice president,
marketing & engineering for HyperEdge Corp. |
A very comprehensive report on rural xDSL in
Kentucky
http://www.rural.org/publications/Hartell01-03.pdf
GoLong - A
solution for extending DSL
http://www.symmetricom.com/GoLong/UniversalDSLService.pdf
The following is
an important ruling which clearly shows that Verizon must allow competition
even though they do not supply the end services. Interesting reading!
http://puc.paonline.com/Telephone/Global/Final%20Order/VII.doc
In contrast, BA-PA indicated
that its DSL service offering is limited to customers served by relatively
short loops[1] that require no conditioning.[2] This
testimony indicates that BA-PA has no intention of serving a significant
portion of the Pennsylvania market -- the portion that is not presently served
by an “ideal” loop, including loops over 12,000 feet.[3] We cannot
permit BA-PA to deny these customers the substantial benefits of DSL from CLECs
simply because BA-PA has made the strategic decision to ignore this substantial
market segment.
Under FCC rules, ILECs cannot use, as a basis for refusing to provision
DSL-capable loops of any type, the argument that they do not yet provide
certain DSL services themselves.[4] The FCC
expressly concluded that “section 251(c)(3) [of TA-96] does not limit the types
of telecommunications services that competitors may provide over unbundled
elements to those offered by the incumbent ILEC.”[5] In
addition, the FCC’s Advanced Services Order specifies that “incumbent LECs should not unilaterally determine what technologies LECs, both
competitive LECs and incumbent LECs may deploy.”[6]
(Emphasis added.) In conformity with these determinations, we
direct BA-PA to provision DSL-capable loops that are free of intrusive devices
as requested by CLECs. By grafting
these federal mandates onto the 1648 proposal the Commission can best ensure
the rapid, widespread deployment of DSL.
The FCC has further directed that, “incumbent LECs must ‘take affirmative steps to condition existing loop facilities to enable requesting carriers to provide services not currently provided over such facilities’” including, for example, “a loop free of loading coils, bridged taps, and other electronic impediments.”[7] The information BA-PA proposes to provide in its loop qualification database is insufficient because this database was developed to support the specific needs of BA‑PA’s more limited ADSL retail offering and does not include crucial loop information needed for other xDSL services.
(My
Comments on the above ruling)
In essence this ruling states that Verizon must make
available for competitors a “clean line”
for the transmission of xDSL technology whether or not they themselves
supply the service end service.
Status
as of 5/26/2002
On Friday May 24, 2002 I spoke at length with a Verizon
attorney in Harrisburg. The PUC directed them to meet or talk with me to
resolve the complaint. As you can see from their written response (above),
which I received prior to my telephone contact, they denied much of the
original complaint based on technical aspects. I wholeheartedly disagree with
much of the response. I expressed that to the Verizon lawyer on the phone. He
obviously was taken back because I think he thought I was just an irate
customer without any real knowledge. He did NOT have a technical background and
was not able to answer any of my questions or respond to any great degree to my
statements. He is going to arrange for a Verizon representative with more
technical knowledge to speak with me.
From his comments it appears that Verizon is going
to roll-out RADSL sometime in the near future.
[1] Tr. 1027-1028.
[2] Id.
[3] Id.
[4] Deployment of Wireline Services Offering Advanced
Telecommunications Capability, CC Docket 98-147, Memorandum Opinion
and Order, FCC 98-188 ¶ 53 (rel. Aug. 7, 1998).
[5] Id., quoting First Report and Order, 11 FCC
Rec. at 15,691-92 ¶ 379.
[6] Advanced Services Order ¶ 63.
[7] Advanced Services Order ¶ 53.