WASHINGTON -- Calling the UNE-Platform policy "devastating," SBC Communications Inc. today urged the FCC to abolish regulations that force incumbent local exchange carriers (ILECs) to sell portions of their telecommunications facilities that are available from other sources to competitors at bargain prices and to use the so-called UNE-P to cherry-pick only the most profitable customers without investing any capital and without deploying any facilities or networks. In its comments, SBC urged the Commission to adopt policies regulating unbundled network elements (UNEs) that will encourage true facilities-based competition and help improve the health of the telecommunications industry. While the FCC may have adopted the UNE-P regulations with the best of intentions, it "has had devastating, if unintended consequences," SBC said in the filing. "It gives the appearance of competition, but the so-called UNE-P competitors rely entirely on a cherry-picking strategy intended to serve only the most profitable customers. The UNE-P is, at the end of the day, simply a wealth transfer from incumbent facilities-based providers to companies that deploy and maintain no facilities or networks [and] that bring no competitive benefits to typical residential consumers," SBC said in its comments. "More than ever, the telecommunications industry needs policies that promote investment and facilities-based competition," said Priscilla Hill-Ardoin, SBC's senior vice president-FCC. "Unfortunately, the industry continues to brought down by unbundling policies that have no sound economic, legal or policy rationale." In its comments, SBC recommended that the FCC: 1. Free all LEC broadband network investment from unbundling obligations since this is a competitive market and cable currently dominates this market; 2. Reject efforts to expand UNE rules into already competitive markets, including broadband, long distance and wireless; 3. Eliminate UNE requirements and the UNE-P at artificially low wholesale rates where competitors have available alternatives, such as switching, to incumbent LEC provided networks; and 4. Prevent states from adding their own unbundling obligations beyond those approved by the FCC, since additional rules in 50 different states would jeopardize the benefits of a coherent, balanced regulatory framework. SBC Communications Inc.Federal Communications Commission (FCC)