FCC Record, Volume 2, No. 1, Pages 1 to 409, January 5 - January 16, 1987 Page: 71
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Federal Communications Commission Record
21 Ad Hoc Comments at 15-16, citing New York Telephone
Transmittal No. 775, Description and Justification, Vol. 3, filed
June 26, 1986, at 1-34.
22 Southwestern Bell Comments at 4-5.
23 Bell Atlantic Comments at 3-6; GTE Comments at 1-2.
24 SNET Comments at 7.
25 Ameritech Comments at 7.
26 NYNEX Opposition at 7-8.
27 Id. at 9-15.
28 NYNEX Opposition at 13, n.15.
29 New York D ICA Petition at
2, 4; ALC Petition at 17-19; Dow Jones Petition at 7-9; ARINC
Comments at 8-10.
31 AT MCI Comments at 13; Sprint
Comments at 16; ALC Comments at 9-10.
32 Southwestern Bell Comments at 5.
33 Ameritech Comments at 7.
34 NYNEX Opposition at 21, n.31.
35 See, e. g., Sprint Comments at 12-13.
36 NYNEX Opposition at 15, n.18.
37 See, e. g., Sprint Opposition at 21-24; MCI Opposition at
38 MCI Petition at 29.
39 See, e. g., Pay Telephone Association Reply at 3-4; Sprint
Comments at 28-29.
40 Guidelines Order at 72 Joint Comments of
Consumer Groups at 3; Comments of the Massachusetts Department
of Public Utilities at 2-3; Ad Hoc Comments at 23.
43 MCI Opposition at 18.
44 AT MCI Petition at 22.
46 Southwestern Bell Comments at 5-6.
48 Supplemental Comments of the Vermont and New Hampshire
Public Utility Commissions, filed Oct. 10, 1986.
Accompanying this filing was a motion to accept a late-filed
pleading. We grant this motion because no party will be
49 NYNEX Opposition at 42, n.72.
0s NYNEX Opposition at 40, n.69.
51 It is not clear from NYNEX's proposed tariff revisions
whether IXCs would continue to pay existing non-recurring
charges (NRCs) and minimum nonthly usage charges
(MMUCs). As a conceptual matter, it would appear that
MMUCs assessed upon IXCs are incompatible with plans in
which originating access costs are recovered directly from end
users. Future waiver requests and related filings should address
52 For example, consider two IXCs (Carrier A and Carrier B),
each with the same amount of transport capacity and the same
level of traffic -
100,000 MOUs/month. While each carrier
would generate the same amount of transport costs, under the
NYNEX plan, these costs would be recovered directly from end
users according to a tapered rate schedule. If Carrier A's 100,000
MOUs are divided equally between two customers, and Carrier
B's 100,000 MOUs are divided equally among 40 customers,
Carrier B's customers will be paying more for transport than
Carrier A's, even though the cost of providing transport to each
group of customers is the same.
53 We also note that the NYNEX plan could result in efficiency
losses relating to the placement of IXC points of presence
(POPs). Our current policies generally require LECs to
develop distance-sensitive local transport rate structures when
the cost of providing such service varies according to distance.
See Investigation of Access and Divestiture Related Tariffs, 97
FCC 2d 1082, 1098-99 (1984). NYNEX's currently effective local
transport rates are distance sensitive. See, e. g., New York
Telephone Company Tariff F.C.C. No. 41, at Section 6.8.2. By
bundling transport costs into an averaged charge billed to end
users, however, the NYNEX plan may reduce IXC incentives to
weigh cost control and economic efficiency considerations in
their decisions regarding POP placement and operations.
54 Guidelines for Dominant Carrier's MTS Rates and Rate
Structure Plans, CC Docket No. 84-1235, FCC 85-540, released
Oct. 17, 1985; AT AT see
generally Areeda Comments of the Vermont Public
Service Board at I (Vermont PSB); Comments of the Rhode
Island Consumers' Council at 1-2 (Rhode Island); Comments of
the Attorney General of the State of New York at 3-4 (NYAG);
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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/m1/78/: accessed November 25, 2017), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.