FCC Record, Volume 1, No. 7, Pages 1267 to 1368, December 22, 1986 - January 2, 1987 Page: 1,288
ii, 1267-1368, ii p. ; 28 cm.View a full description of this book.
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Federal Communications Commission Record
FCC 86-534
used exclusively for either interstate or intrastate calling,
it cannot be reconciled with this Commission's abandonment
of a relative use allocation factor for common
lines.15 MCI contends further that the costs of special
access lines, which are directly assigned, are allocated not
on the basis of jurisdictional use (because these lines
carry mixed traffic), but on the basis of the jurisdiction of
the tariff from which the service is purchased.'6
6. Based on these assertions, MCI argues that this Commission
must either clearly set forth concrete and factually
accurate features that differentiate common lines
and WATS access lines in order to escape a serious
discrimination problem, or apply consistent allocation
mechanisms to all NTS plant.'7 It suggests as alternative
allocation factors: (1) frozen SPF, or (2) the direct
assignment of costs to either the interstate or the intrastate
jurisdiction based on either predominant use or the jurisdiction
of the tariff from which the service is purchased.18
7. Argo, in its Petition, addresses only the statement in
the WATS Direct Assignment Order that WATS access
lines are used exclusively for either intrastate or interstate
toll service. It alleges that this statement could be incorrectly
viewed as expressing a Commission policy to
prohibit the use of dedicated access lines for both interstate
and intrastate WATS-like services,19 a result that
would. in its view, be contrary to the public interest and
lead to unnecessary duplication of facilities and substantially
higher costs for end users.20 It asks this Commission
either to reconsider this statement or clarify that the
statement does not apply to facilities used by OCCs to
provide WATS-like services.21
B. Oppositions and Replies
8. A number of OCCs support the reconsideration
petitions. ALC agrees with MCI that this Commission's
decision to directly assign the costs of WATS access lines
is based on the false premise of jurisdictional purity.22 It
notes that its own WATS-like services and its resold
AT with the development of these
tariffs, this use is no longer appropriate. In reply MCI
rejects NYNEX's contentions that access services or tariffs
preempt the use of intrastate WAIS services to carry
interstate telephone calls.34
11. A number of parties argue that, contrary to MCI's
assertion, common lines and WATS access lines are not
identical.35 For example, Southwestern Bell argues that
MCI ignores the clear distinction between common lines,
which provide unrestricted originating and terminating
local, intrastate, and interstate access, and WATS lines,
which provide restricted, one-way access.36 The costs of
WATS access lines should be directly assigned, according
to those opposing MCI's petition, because these lines are
just like the dedicated access lines used to access OCC
"WATS-like" services, the costs of which are directly
assigned rather than allocated between jurisdictions.37
12. A number of commenters disagree with MCI's assertion
that the direct assignment of WATS access lines is
inconsistent with our decision freezing SPF. Bell Atlantic
finds nothing inconsistent in these actions. It says that the
order freezing SPF applies only to switched access services
carrying both interstate and intrastate traffic.38 NYNEX
faults MCI's suggestion that the costs of all lines be
directly assigned based on the tariff from which the access
service is ordered, claiming that such an approach would
legitimize "tariff shopping" and result in rate increases.39
13. In opposing Argo's Petition, AT
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United States. Federal Communications Commission. FCC Record, Volume 1, No. 7, Pages 1267 to 1368, December 22, 1986 - January 2, 1987, book, January 1987; Washington D.C.. (https://digital.library.unt.edu/ark:/67531/metadc1579/m1/27/?rotate=270: accessed April 24, 2024), University of North Texas Libraries, UNT Digital Library, https://digital.library.unt.edu; crediting UNT Libraries Government Documents Department.