FCC Record, Volume 2, No. 1, Pages 1 to 409, January 5 - January 16, 1987 Page: 66
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Federal Communications Commission Record
38. In response to opponents' arguments on the ordering
of access, NYNEX contends that IXCs will be able to
order access if designated by an end-user as its ordering
and billing agent. NYNEX also claims that IXCs will be
able to resell access under its plans.
2. Customer Confusion
39. A number of IXCs, consumer groups, state commissions,
and large users contend that implementation of the
NYNEX plans will cause significant customer confusion.42
They point first to the fact that NYNEX and IXC billing
cycles are not synchronized, which will require end users
to compare several months of NYNEX and IXC bills in
order to reconcile their long distance charges. This process
will be further complicated, opponents assert, because
of NYNEX's intention to begin billing calls over
lines without answer supervision 30 seconds after the call
reaches the facilities of the end users' IXC. Because end
users sometimes wait more than 30 seconds before giving
up on an incomplete call, this practice will result in
many end users being billed for calls they never complete.
Even when a particular call is completed, the end user
may not be able to reconcile two bills for that call
because the call measurement methodologies of NYNEX
and the IXC may differ. In all such situations, opponents
contend, the end user will have to make two more calls to
straighten out the confusion, one to NYNEX and another
to the IXC. Opponents also note that the NYNEX tariffs
do not explain NYNEX's procedure for handling billing
errors. They do contain, however, a "hold harmless"
provision exempting NYNEX from any liability arising
from billing disputes between end-users and IXCs.
40. Several IXCs question whether NYNEX is capable
of accurately rendering millions of separate bills for access
charges. MCI notes that NYNEX recently instructed
it to ignore all June 1986 FGA bills because they were
incorrect.43 AT (2) TS services
should be priced in reference to the long run marginal
cost of providing such services; and (3) some CAT 6 COE
costs are NTS in nature and should not be recovered in
TS charges, as they are today. We turn now to an examination
of these assumptions.
47. Our first major concern relates to NYNEX's proposal
to recover its TS revenue requirement directly from
end users. It is not obvious that recovering TS costs in
this manner is more economically efficient than the current
practice. To the contrary, it would seem that
NYNEX's proposal to recover TS costs from end users
might represent, not an improvement over the current
rules, but a step away from economic efficiency, in at
least two respects. First, it appears that under NYNEX'S
plan, IXCs will continue to order, but will have no
responsibility to pay for, transport facilities for originating
access.51 Rather, end users of IXC services will pay for
those facilities, and the charges assessed end users would
not vary depending on the IXC it uses. This would appear
to give IXCs an incentive to over-order access facilities,
both in terms of quantity and quality, since they do not
pay for such facilities and their customers pay only an
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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.. (digital.library.unt.edu/ark:/67531/metadc1597/m1/73/: accessed August 20, 2017), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.