FCC Record, Volume 1, No. 7, Pages 1267 to 1368, December 22, 1986 - January 2, 1987 Page: 1,292

Federal Communications Commission Record

3s AT NYNEX Comments at 3, 15;
National Data Comments at 4.
36 Southwestern Bell Comments at 4; see also National Data
Comments at 4-6.
37 See, e. g., AT see also NYNEX Comments
at 3. NYNEX argues that MCI erroneously contends that
this Commission's rationale for direct assignment of WATS
access line costs is inconsistent with the separations treatment
of the costs of non-WATS special access lines. NYNEX maintains
that the costs of private lines are directly assigned to the
interstate jurisdiction because measurement of relative jurisdictional
usage on those lines is not feasible, while direct
assignment of WATS access lines was adopted solely because the
nature of WATS precludes "mixed" jurisdictional use. Id. at 14.
38 Bell Atlantic Comments at 6. See also NYNEX Comments
at 13 (MCI's argument about inconsistency with SPF is premised
on its assertion that WATS access lines carry mixed intrastate
and interstate traffic).
39 NYNEX Comments at 15. NYNEX also contends that MCI's
request to reconsider the separations treatment of toll terminal
lines should be rejected because it presents no facts to rebut
this Commission's finding that toll terminal line costs should
be allocated based on relative use. Id. at 12, n. 22. Application
of the common line separations factor to toll terminal lines,
which do not carry local exchange traffic, would clearly be
inaccurate, according to NYNEX. Id. at 15.
40 AT Midyear 1986 Tariff Filing,
Memorandum Opinion and Order, Mimeo No. 4867, para. 17
(released May 30, 1986). These questions are discussed in a
companion order.
47 Smith v. Illinois Bell, 282 U.S. 133, 150 (1930). See also MCI
Telecommunications Corp. v. FCC, 730 F.2d 135, 141 (D.C. Cir
1984)("(c)ost allocation is not purely an economic issue--it
necessarily involves policy choices ... . . ").
48 MCI has not asserted that OCCs can complete interstate
calls on an intrastate WATS line (or intrastate calls on an
interstate WATS line) without combining the underlying service,
through their own switching facility, with other services.
For pro-competitive reasons we have allowed carriers like MCI
to resell WATS services and configure their networks as they
see fit, but it does not necessarily follow that we must now
change the separations treatment of the access lines used to
provide the underlying WATS service to reflect OCC resale of
this service.
49 In addition to the OCC WATS resale configurations, MCI
also points to the lack of screening on interstate 800-service
access lines as a basis for modifying our direct assignment
decision. MCI asserts that these lines are not jurisdictionally
pure because they are capable of, and cannot be prevented
from, terminating intrastate telephone calls. However, as MCI
itself notes, 800-service calls are screened by jurisdiction at the
originating end. MCI Reply Comments at 11, n.33. Moreover,
even when intrastate and interstate 800 services share a single
telephone number, separate access lines are required for each
service. AT