FCC Record, Volume 2, No. 1, Pages 1 to 409, January 5 - January 16, 1987 Page: 29
iii, 409, v p. ; 28 cm.View a full description of this book.
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Federal Communications Commission Record
6. Additional guidelines and requirements were adopted
that applied to IXC capacity charge plans and direct end
user charge plans. For example, under the IXC capacity
charge model, a LEC would be able to impose a charge
on IXCs based on monthly measurement of IXCs' units of
capacity, a surcharge on certain special access lines, or
both. LECs proposing this type of plan also would be
required to include in their supporting materials studies
detailing the impact its plan would have had on IXCs in
the two years prior to the filing of the proposal.12
7. Under the direct end user charge model, a LEC
would be able to levy a usage-sensitive NTS charge on
each end user according to a tapered rate schedule, and to
levy a surcharge on certain special access lines. In addition,
LECs proposing end user charge plans would be
required to include peak/off-peak rates in their rate schedules,
and provide detailed billing of end user charges to
allow customers to cross-check their LEC and IXC bills.
LECs also would be required to provide end users the
option of designating willing third parties, such as IXCs,
as agents for the ordering and billing of interstate access,
which would allow the end user to receive one bill for
interstate toll calls.13
III. CONTENTIONS OF THE PARTIES
8. The five petitions seeking reconsideration of the
Guidelines Order fall into two general categories. Pacific
seeks reconsideration of our decision to deny its petition
for a waiver to implement an interim NTS plan conforming
to the IXC capacity charge model. The remaining four
petitions relate more generally to the Guidelines Order,
and raise issues concerning our guidelines for both IXC
capacity charge and direct end user charge plans. In the
interest of clarity, the following summary of the pleadings
is organized to reflect these two categories of petitions.
A. Pacific Petition
9. Pacific contends that this Commission's rationale for
rejecting its interim NTS proposal is flawed in two respects.
Specifically, Pacific argues that its plan would
neither (1) unreasonably shift the risk of NTS recovery
from LECs to IXCs, nor (2) unreasonably discriminate
among IXCs.
10. Pacific claims that this Commission's concerns
about risk shifting under the Pacific plan are unwarranted.
It alleges that our concern relates exclusively to
situations in which, "in the event of an economic downturn,
(IXCs) would suffer the consequences of reduced
calling volumes, therefore requiring (IXCs) to bear the
burden of acting as guarantor a Pacific's NTS costs."14
Pacific argues that this concern is unwarranted because,
regardless of general economic conditions, call volumes
can be expected to increase, not decrease. Pacific also
asserts that residential calling is unaffected by general
economic conditions, and that any decreased business
usage that might be expected to occur during an economic
downturn would not affect NTS recovery because
business users generally are served by WATS and other
services that carry a reduced NTS burden or none at all.
In support of its contentions, Pacific supplied a chart
showing steady annual increase in total telephone messages
during 1970-1983, a period marked by several economic
downturns.s1 Pacific claims there is no basis for
concluding that its interim NTS plan will significantly
shift the risk of NTS cost recovery to IXCs. Pacific statesfurther that the "guarantee" embodied in its plan is no
different than the guarantee that would be established if
NTS costs were recovered in full from end users through
subscriber line charges.16
11. Pacific also "disagrees" with this Commission's conclusion
that the Pacific interim NTS plan would negatively
affect competition in the market for interexchange
services.17 To the contrary, Pacific asserts, its plan would
enhance IXC competition because it would afford IXCs a
known, fixed cost that they then could plan to recover
according to their own decisions about service offerings
and pricing policies. Pacific claims that its plan would be
particularly desirable for growth-oriented IXCs.
12. All pleadings filed in response to Pacific's request
for reconsideration urge this Commission to reject Pacific's
petition. Western Union, Ad Hoc, and ARINC
contend that rejection is appropriate on procedural
grounds because Pacific's petition presents no new arguments
or facts for this Commission's consideration8
The California PUC asks us to defer our consideration of
Pacific's petition until the California PUC completes its
examination of Pacific's proposed intrastate capacity
charge plan. By deferring our action, the California PUC
contends, we will be able to evaluate a fully developed
record on the feasibility and desirability of implementing
Pacific's plan on the state level.19
13. Various parties take issue with Pacific's claims regarding
risk shifting and IXC discrimination. AT
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United States. Federal Communications Commission. FCC Record, Volume 2, No. 1, Pages 1 to 409, January 5 - January 16, 1987, book, January 1987; Washington D.C.. (https://digital.library.unt.edu/ark:/67531/metadc1597/m1/36/: accessed April 25, 2024), University of North Texas Libraries, UNT Digital Library, https://digital.library.unt.edu; crediting UNT Libraries Government Documents Department.