You are correct in pointing out that this is not "pure" VoIP. The UNE loop will be TDM, just as if it were connected to a Class 5 switch. It will be converted to VoIP at Covad's equipment within the CO.

This is analogous to AT&T's conversion of traffic to VoIP at its Class 4 switches - and we learned that the regulatory bodies don't consider that to be a VoIP service exempt from access charges and other regulatory fees and tariffs.

The good news is that, if this works, Covad will have introduced a new way for CLECs to offer competitive local services to residential customers. It is especially heartening to see that the service, unlike DSL, is not distance-limited. This could be a much-needed boost to a beaten-down sector.