FCC Record, Volume 1, No. 7, Pages 1267 to 1368, December 22, 1986 - January 2, 1987 Page: 1,291
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Federal Communications Commission Record
l Amendment of Part 67, Decision and Order, CC Docket
Nos. 78-72 and 80-286, FCC 85-655 (released Jan. 7, 1986).
2 A "WATS access line" is a dedicated access line from the
customer's premises to the local exchange carrier's WATS serving
office. This line is found at the "closed end" of the WATS
service (the originating end of OUTWATS and the terminating
end of INWATS, or "800 service"). The WATS serving office
may or may not be the same central office that provides local
exchange service to the WATS customer. See generally WATSRelated
and Other Amendments of Part 69, Notice of Proposed
Rulemaking, CC Docket No. 86-1, FCC 86-1, paras. 2-4
(released Jan. 6, 1986).
3 That allocation factor has changed over time. During the
1971-81 period, most of this investment was apportioned on the
basis of the Subscriber Plant Factor (SPF) that was adopted in
the "Ozark" Separations plan. During the 1982-85 period, SPF
was been frozen at the 1981 average level. See section 67.124(d)
of the Commission's Rules, 47 C.F.R. 67.124(d)(1985). As of
January 1, 1986, we have begun replacing frozen SPF with a
nationwide, uniform 25% allocation factor, which is being
phased in over an eight-year period. MTS/WATS Market Structure
and Amendment of Part 67, Decision and Order, 50 Fed.
Reg. 939, paras. 1, 15 (1984), aff d on recon. , FCC 86-56
(released Jan. 30, 1986), appeal docketed, Rural Telephone Coalition
v. FCC, No. 84-1110 (D.C. Cir. March 22, 1984). The
Ozark plan assigned the portion of a WATS access line from
the end office that normally serves the end user to the end
office that functions as a WATS serving office to a different
separations category. The WATS Direct Assignment Order modified
the "exchange trunk" classifications to achieve the direct
assignment of this portion of a WATS access line as well.
4 Amendment of Part 67, Second Recommended Decision and
Order, 48 Fed. Reg. 46,554, para. 81-82 (1983).
5 Amendment of Part 67, Decision and Order, 96 FCC 2d 781,
para. 61 (1984). Pending the outcome of this further study, we
modified our access charge treatment of WATS access lines,
which had initially been included in the special access category
in anticipation of direct assignment, and treated them like
ordinary subscriber lines. MTS/WATS Market Structure,
Memorandum Opinion and Order, 97 FCC 2d 834, paras.
6 Amendment of Part 67, Recommended Decision and Order,
CC Docket No. 78-72 and 80-286, Mimeo No. 139 (released Oct.
7 Id. at para. 28.
8 See WATS Direct Assignment Order at paras. 6-7. Consistent
with this separations change, we amended the access charge
rules to provide that the costs of interstate WATS access lines
be recovered through flat monthly special access charges, beginning
June 1, 1986. See WATS-Related and Other Amendments
of Part 69, Report and Order, CC Docket No. 86-1, FCC 86-115
(released March 21, 1986) (hereinafter cited as WATS Access
Charge Order ). In the WATS Direct Assignment Order, we also
adopted the Joint Board recommendation that the costs of toll
terminal lines, which carry no local exchange traffic, be allocated
based upon relative toll minutes of use. WATS Direct
Assignment Order at para. 6-7.
9 MCI Petition at 3-4.
10 Id. at 5-6. As an additional point, MCI contends that
because screening is not available with terminating WATS access
lines (those used with 800 service), these lines are capable
of, and cannot be prevented from, terminating both interstate
and intrastate telephone calls. Id. at 6; MCI Comments on Argo
Petition at 6.
11 MCI asserts that many OCCs provide travel card services
through this type of arrangement. MCI Reply Comments at 5.
12 MCI Petition at 4-5.
13 Id. at 6-7.
14 See supra note 3.
s1 Id. at 7-8.
16 Id. at 2, n. 1 and 9.
17 MCI asserts that the same allocation factor should apply to
toll terminal lines as well. Id. at 9-10.
18 Id. at 10. MCI maintains that the most consistent treatment
of all NTS plant would be the direct assignment of each line
based on the tariff from which the access service is purchased.
19 Argo does not describe the specific configuration it employs
in providing its "WATS-like" service. As we stated in the
WATS Access Charge Order, "OCCs have generally provided
their WATS-like services by using special access lines from
their customers' premises to their facilities, which has allowed
them to avoid any CCL changes on the closed end of those
services." Id. at para. 16, n.64. By contrast, AT see also GTE Sprint Comments at 3.
23 ALC Comments at 2.
24 Id. at 3-4.
25 Id. at 3.
26 GTE Sprint Comments at 3.
27 Id. at 3.
28 Id. at 3-4.
29 AT Ad Hoc Comments at 2,
4; ARINC Comments at 2; Bell Atlantic Comments at 2-3;
National Data Comments at 2-3.
30 Bell Atlantic Comments at 3-4; NYNEX Comments at
10-11; Pacific Bell and Nevada Bell Comments at 2-3. National
Data maintains that MCI is "simply wrong" in its assertion that
interstate 800-service access lines can be used to receive calls
from within the same state. National Data Comments at 5-6 and
31 AT see also National Data Comments at
5, Southwestern Bell Comments at 3. See also Ad Hoc Comments
at 5-6 (carriers providing WATS access lines do so only
in accordance with the operational restrictions set forth in
applicable interstate or intrastate WATS tariffs, notwithstanding
an IXC's subsequent unconventional cross-jurisdictional use of
the WATS service.)
32 AT see also Bell
Atlantic Comments at 4-5. MCI rejects reliance on the
entry/exit surrogate in determining the jurisdictional nature of
a call, asserting that the surrogate is applied only when the
reseller is unable to determine the point of origination and/or
termination, which is not the case for WATS resellers. MCI
Reply Comments at 13, n.38.
33 NYNEX Comments at 7-10.
34 MCI Reply Comments at 12, n.35.
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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.. (digital.library.unt.edu/ark:/67531/metadc1579/m1/30/: accessed March 25, 2017), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.