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INTRODUCTION ă " X- pr"x` ` 1.  On October 31, 1994, Alltel Telephone Systems ("Alltel") filed a cost  X- xallocation manual ("CAM") pursuant to the Joint Cost Order.s k ~J:- x>Ѝ See Separation of Costs of Regulated Telephone Service from Costs of Nonregulated Activities,  ~J- xReport and Order, CC Docket No. 86111, 2 FCC Rcd 1298 ("Joint Cost Order") recon.,2 FCC Rcd 6283  ~J- x@(1987) ("Joint Cost Reconsideration Order"), further recon., 3 FCC Rcd 6701 (1988) ("Further  ~J-Reconsideration Order"), aff'd sub nom. Southwestern Bell Corp. v. FCC, 896 F. 2d 1378 (D.C. Cir.1990).s Subsequently, Alltel filed  X- xlrevisions to this CAM.k ~J -Ѝ See Alltel filings dated December 29,1994, March 31, 1995, and August 16, 1995. On November 14, 1994, the Common Carrier Bureau ("Bureau")  X- x=released a public notice seeking comments on Alltel's initial CAM. @k ~J -Ѝ Comments Sought on Alltel Telephone System's Cost Allocation Manual, 9 FCC Rcd 6695 (1994). MCI Telecommunications  xCorporation ("MCI") filed comments and Alltel filed a reply. On August 29, 1995, the Bureau  Xe- xreleased a public notice seeking comments on Alltel's revised CAM.ek ~J#- xЍ Comments Sought on Alltel Telephone System's Revised Cost Allocation Manual, 10 FCC Rcd 9358 (1995). No comments were  xjreceived pursuant to this notice. In this order we find that Alltel's revised CAM contains cost  x\accounting procedures that are adequate to meet our requirements, except where additional  xinformation or clarification is required as discussed below. Moreover, we believe that Alltel's CAM will provide an adequate basis for Commission audits. "( 0*0*0*Z"Ԍ X-ԙ x` `   II. BACKGROUND ă  X- pcx` ` 2.  In the Joint Cost Order, the Commission established a mechanism for  xseparating the costs of regulated telephone services from the costs of nonregulated services. The  X- xpurpose of the Joint Cost Order was to assure that regulated operations do not improperly  xsubsidize nonregulated activities. The Commission established two separate but complementary  xlsets of rules, one which governs how carriers allocate their costs between regulated and  xnonregulated activities and the other which governs transactions between carriers and their  xaffiliates. The Commission required that carriers file CAMs setting out in detail the manner in which they propose to implement those cost allocation and affiliate transaction rules.  X - px` ` 3.  The Joint Cost Order promulgated standards and guidelines for carriers to  x[follow in developing their cost allocation practices. That Order established a hierarchy of cost  xapportionment methods with emphasis on the direct assignment of costs and the use of cost X - xcausative allocation methods. First, whenever possible, costs in each Part 32 Bj ~J7-#hxP7P#э 47 U.S.C. Part 32 Uniform System of Accounts for Telecommunications Companies. account must be  xdirectly assigned to either regulated or nonregulated activities. If costs in an account cannot be  xdirectly assigned, they are considered common costs and they must be placed in cost pools which  xare homogeneous categories designed to facilitate the allocation of costs. The costs in these  xpools must then be allocated between regulated and nonregulated activities using a factor or  XK- xformula which is called an allocator. Although the Joint Cost Order did not prescribe specific  xallocators for each cost pool, it established guidelines for the use of costcausative allocation  x\methods. Whenever possible, common costs must be directly attributed based upon direct  xanalysis of the origin of the costs themselves. Common costs that cannot be directly attributed  xmust be indirectly attributed based on an indirect, costcausative linkage to another cost pool or  xgroup of cost pools for which a direct assignment or attribution is available. If direct or indirect  xmeasures of costcausation are not available, the cost pool must be allocated using a prescribed  x-general allocator. The general allocator is the ratio of all expenses directly assigned or attributed  X-to regulated and nonregulated activities.XBj ~J-#hxP7P#э 47 C.F.R. 64.901(b); see Joint Cost Order, 2 FCC Rcd at 131819. #XP\  P6Q DXP#  Xe- px` ` 4.  Section 64.903 of the Commission's rules, requires that a CAM include the  xkfollowing elements: (a) a description of each carrier's nonregulated activities; (b) a list of all  xincidental activities and the justification for treating each activity as incidental; (c) a chart  xKshowing all of the carrier's corporate affiliates; (d) a statement that identifies affiliates that engage  xin or will engage in transactions with the carrier and that describes the nature, terms, and  x.frequency of such transactions; (e) for each Part 32 account, a detailed description of the cost  xjpools to which amounts in the account will be assigned and the basis on which each cost pool  xwill be allocated, and (f) a description of the carrier's time reporting procedures including the  X!- xmethods used to allocate nonproductive time.o!Bj ~JF'-#hxP7P#э 47 C.F.R. 64.903.o In addition, ten of the accounts must be assigned"!x0*(( "  xto cost pools and allocated using specific procedures prescribed by the Common Carrier Bureau  X-in the CAM Uniformity Order. Bj ~Jb- x#hxP7P#Ѝ Implementation of Further Cost Allocation Uniformity, Memorandum Opinion and Order, 8 FCC Rcd  ~J*-4664 (1993) (CAM Uniformity Order).   X- p x` ` 5.  The Bureau established uniform filing requirements for the CAMs.  Bj ~J-#hxP7P#Ѝ Responsible Accounting Officer Letter No. 19, 6 FCC Rcd 7536 (1991)(RAO Letter 19). In  xaccordance with these requirements, a CAM must include the following information: (a) a list  xof all nonregulated products and services that the carrier provides; this list must indicate the  x/accounts that are associated with each product or service; (b) a list of each type of affiliate  xtransaction in which the carrier engages; this list must indicate which affiliate is involved with  xeach type of transaction; and (c) a list of each type of time reporting method which the carrier  xyuses, this list must indicate which groups of employees use each type of reporting method. In  xaddition, a CAM must describe the procedures used to train employees, monitor, and enforce  x]accurate time reporting, as well as the methods for capturing and allocating the costs of  X -nonproductive time.e Bj ~JM-Ѝ Joint Cost Order at 132122.e  X -x` `  T III. DISCUSSION ă  X-x` `  A. Nonregulated Activities.  Xb- p&x` ` 6.  Alltel's CAM includes a table that describes six nonregulated, revenue xproducing activities. These activities are: direct sales of customer premise equipment and  xancillary equipment; lease/purchase of customer premise equipment and ancillary equipment;  xlease of customer premise equipment and ancillary equipment; maintenance of customer premise  xequipment and ancillary equipment; inside wire installation and maintenance; and voice mail  xservices. Alltel's CAM provides adequate descriptions of these nonregulated services and their  X-accounting treatment.L @Bj ~J-Ѝ Alltel CAM at Section II.L  X-x` `  B. Incidental Activities.  X|- p x` ` 7.  Alltel's CAM contains a list of nonregulated activities that it proposes to  Xe- xcategorize as incidental activities. In the Joint Cost Order, the Commission permitted carriers  xto account for incidental activities as regulated activities, provided the activities meet the  xfollowing quantitative and qualitative tests: (a) each activity must be an outgrowth of the  xkcarrier's regulated operations; (b) the activities, individually or combined, cannot constitute  xseparate lines of business; (c) each activity must have traditionally been treated as regulated for  xaccounting purposes, and (d) the revenues from all of these activities must not exceed one percent" 0*((Z"  X- x.of the carrier's total revenues.  R Bj ~Jy-Ѝ Joint Cost Order at 1308.R   Alltel's CAM lists several activities that it treats as incidental,  xbut it provides no description of these activities. We direct Alltel to provide a description of each incidental activity listed in its CAM.  X- px` ` 8.  We believe that Alltel's mobile cellular sales agency activity, cable TV  x<service, and Alltel long distance service activity do not meet the qualitative tests specified in the  Xv- x<Joint Cost Order for inclusion as incidental activities because these activities constitute separate  xlines of business. Therefore, Alltel is directed to remove them from the Incidental Activities  x>section of its CAM and include them in the Nonregulated Activities section of its CAM, or explain its failure to do so.  X - x` `  C. Affiliate Transactions.  X - p x` ` 9.  The Joint Cost Order established rules that govern the provision of assets  x1and services to and from affiliates. These rules were created to prevent carriers from  xxcircumventing the cost allocation rules and engaging in transactions in which they provide assets  xjor services to affiliates, or obtain assets or services from affiliates, at prices that result in unfair  xrates being charged to ratepayers. Section 32.27 of the Commission's rules defines how carriers  Xb- xare to record affiliate transactions in their books of account. FbXBj ~Jk-Ѝ 47 C.F.R. 32.27F These rules distinguish between  xZtransactions involving the transfer of assets and the provision of services. The transfer of assets  xbetween affiliates must be recorded at the prevailing prices established through third party arms xlength transactions. If no prevailing price is available, asset transfers from an affiliate to the  xcarrier must be recorded at the lower of net book cost or fair market value, and asset transfers  xto an affiliate from the carrier must be recorded at the higher of net book cost or fair market  xvalue. The provision of services must be recorded at the tariff rate, or prevailing price if one  xzexists. Absent a prevailing price, the costs of the service must be recorded at costs that are  xdetermined in a manner consistent with the cost allocation requirements of Section 64.901 of the  X-Commission's rules.DBj ~J,- xLЍ On October 20, 1993, the Commission released a Notice of Proposed Rulemaking to reevaluate its  xjaffiliate transaction rules. When a final rule is adopted, the Commission's affiliate transaction rules could  ~J- xLbe extensively modified. See Amendment of Parts 32 and 64 of the Commission's Rules to Account for  ~J - xTransactions Between Carriers and Their Nonregulated Affiliates, CC Docket 93251, 8 FCC Rcd 8071 (1993).D  Xe- pS x` ` x` `  10.  We find three deficiencies in the Affiliate Transaction section of Alltel's  xCAM. First, it does not contain a narrative describing sales from its telephone companies to its  xother affiliates. To rectify this, Alltel must revise its CAM to include such a narrative. Second,  xyit does not adequately describe the services provided to affiliates or specify to which affiliates  xthese services are provided. Alltel must revise its CAM to provide this information. Third, in  xLsome cases, it specifies terms of affiliate transactions that are apparently inconsistent with our"0*((<"  xrules. For example, the CAM specifies the use of lease rates, contract rates, and lowest sales  xprices while our rules specify the use of tariff rates, prevailing market prices, or fully distributed  xcosts. Alltel must either revise its CAM to comply with the terms specified by our rules or clarify how the terms it uses in the CAM do comport with our rules.  X-x` `  D. Cost Allocation Tables  X_-x` `  hh(1) Apportionment Methods  X1- pDx` `  11.  In its CAM, Alltel describes its apportionment methods and provides a  xtable, organized by Part 32 account, that describes how it proposes to use its apportionment  xmethods to isolate nonregulated costs. We have three concerns with respect to Alltel's definitions  x.of its apportionment methods. First, it is unclear which apportionment procedures are used to  x<divide costs into pools and which are used to allocate costs between regulated and nonregulated  x>operations. Alltel must revise its "definition of apportionment basis" to clearly distinguish  xibetween apportionment methods used to divide costs into pools and allocators used to apportion costs between its regulated and nonregulated activities.  Xy-  Xb- px` `  12.  Second, Alltel has failed to provide the level of detail necessary to  x/determine whether particular apportionment methods are sound. For example, Alltel uses a  xbusiness office study as an apportionment method for costs incurred in establishing and serving  x=customers, but does not include sufficient information for us to determine if this study is valid  xand reliable. Alltel must revise this description to include: the criteria it uses to determine  x-whether it would perform time and motion studies or surveys of customer service representatives  xktime reporting, and the criteria it would use for selecting a study period and what statistical  xsampling techniques it would employ. Also, Alltel's description of its business office study  xcontains a reference to jurisdictional separations pools. We are unsure how the jurisdictional  xyseparations pools relate to the allocation between regulated and nonregulated activities. Alltel  xymust either explain this relationship or eliminate the reference to jurisdictional separations. We  xdirect Alltel to review its description of the business office activity study and all of the  xapportionment procedures in its CAM to ensure that the CAM provides a complete and accurate description of each of these apportionment procedures.  X - pDx` `  13.  Third, in its "Definition of apportionment basis," Alltel describes how it  x.allocates Headquarters/Regional Costs and Information Services Costs from its affiliates to its  xytelephone operating companies. The description indicates that these activities involve affiliate  xtransactions. Therefore, they should also be included in the Affiliate Transaction section. If  xAlltel's cost apportionment methods include specific allocators that apportion these costs between  xregulated and nonregulated activities, the allocators should also be included as part of its definition of allocators. "#0*((G""  X- x ` `  (2) Cost Apportionment Tables  X- px` `  14.  Alltel lists several accounts, each of which are assigned to one cost pool.  xIn the CAM these accounts are directly assigned. However, Alltel does not state whether these  xaccounts are directly assigned to its regulated or its nonregulated operations. Alltel must revise its CAM to clarify the assignment for these accounts.  X_- px` ` 15. For some accounts in the Cost Allocation Tables, Alltel does not list the  xspecific method it uses to allocate costs between its regulated and nonregulated activities. For  xexample, Alltel lists indirect attribution as the allocator for Account 2115, Garage work  xequipment. However, indirect attribution is a type of allocation method, not a specific allocator.  x Alltel must revise the Cost Allocation Tables section of its CAM and specify an allocation method for each cost pool.  X - x` `  (3) Official Communications  X- px` ` 16.  The Commission's rules require that nonregulated activities be 3'3'Standard3'3'Current Windows FormShx݌ charged tariff  Xy- x-rates for services that are offered under tariff.uywJ ~J-#hxP7P#э 47 C.F.R. 64.901(a)(1).u Although the Affiliate Transaction section of the  xCAM states that Alltel provides services to its affiliates at tariff rates, it is unclear whether Alltel  XK- xproposes to apply tariff rates to determine the "official communications"KXwJ ~JT- x[#hxP7P#Ѝ The term "official communications" applies to telephone service and other communications systems that the company uses for internal purposes. costs of its  xnonregulated activities. Assuming that official communications services are identical to services  xoffered under tariff, the Commission's rules require the application of the tariff rate. In  xLamendments to its CAM, Alltel must explain its proposed treatment of official communications costs and how that treatment is consistent with the Commission's rules.  X-x` `  E. Time Reporting  X- pax` ` 17.  The Joint Cost Order permits carriers to select from among several methods  xof recording employee time. The Commission reasoned that, since the use of wages and salaries  xwould serve as an important allocator, it was imperative that carriers use accurate methods of  xrecording employee time. The Commission found that no single time reporting system would provide accurate results in all situations. Carriers were, therefore, permitted to propose the use"70*(({"  X- x!of positive time reporting or exception time reportingwJ ~Jy- x#hxP7P#Ѝ In positive time reporting, an employee's day is parcelled into increments of time, typically six minutes  xLto one hour in length. The employee then accounts for all or most of the time worked during a given day  xMby dividing the total amount of hours worked among the specific jobs or functions performed. Under  xzexception time reporting, an employee's time is assumed to be devoted entirely to one or more jobs or  xjfunctions in which the employee is normally engaged. The employee actively reports only the time spent on activities that depart from the expected schedule., or to develop special studies of employee time.  X- px` ` 18.  We have several concerns regarding Alltel's description of its time reporting  xprocedures. First, although the CAM identifies the reporting systems the various employee  xZsegments use to record their time, it does not describe these systems and it does not demonstrate  xhow they are used to ensure a proper apportionment of labor costs between regulated and nonregulated activities. Alltel must revise its CAM to provide this information.  XH-x` `  X1- px` ` 19.  Our rules require that time be reported in increments of one hour or less.u1@wJ ~J"-Ѝ Joint Cost Order, 2 FCC Rcd at 1321.u  x.For Alltel's positive time reporting system, the CAM states that time is recorded in increments  xof no less than quarter hours, but the CAM does not set a limit on how large the reporting  xincrement can be. Thus, Alltel has not addressed our concern that reporting in increments of  xKgreater than one hour would be unacceptably inexact and result in the misallocation of labor cost. Alltel's CAM must be revised to state that time is reported in increments of one hour or less.  X- px` ` 20.  CAMs must describe the methods used to train employees, monitor, and  xenforce accurate time reporting, as well as the methods for capturing and allocating the costs of  Xb- xnonproductive time.LbwJ ~J-Ѝ See Supra para. 7.L Alltel's CAM states that all employees are instructed on policies and  xprocedures concerning time reporting at the time of hiring. This statement provides insufficient  xdescription of the training procedures. Alltel must provide more information. For example, it  x[should state whether employees are provided with written time reporting instructions, whether  x[training sessions are held and, if so, how often, and how changes in time reporting procedures are communicated to employees.  X-T  IV. PROCEDURAL ISSUES T 3'3'Current Windows FormShx3'3'Current Windows FormShx݌ P  X- pԊ x` ` 21.  In this Order, we have required Alltel to amend its CAM clarifying many  xjof its cost pool apportionment and cost allocation procedures. We have also directed Alltel to  xsubmit additional information concerning its incidental activities, affiliate transactions, and time  xireporting mechanisms. Alltel must submit a revised CAM that incorporates the changes we have"N` 0*(("  X- xrequired. These revisions will be subject to notice and comment as required by the Joint Cost  X-Order.y ~Jb-#hxP7P#э Joint Cost Order at 1327.y All revisions that are approved or ordered shall be made retroactive to January 1, 1996.  X- px` ` 22.  When filing CAM revisions, Alltel must adhere to RAO Letter 19 and  xlSection 64.903 of the Commission's rules. RAO Letter 19 and the rules specify that CAM  x=revisions be accompanied by a transmittal letter and a complete description of changes. Alltel  xymust specify each change to the CAM and state the reasons for each change. The description  x=must contain a sufficient level of detail for us to analyze Alltel's response to each issue raised  x0in this Order. All revised language in the CAM must be in boldfaced type and must be  xindicated by a vertical line in the right margin. Alltel must file four copies of its revised CAM  xwith the Office of the Secretary and one copy must be delivered to the Chief, Accounting and Audits Division, Common Carrier Bureau.  X -W V. ORDERING CLAUSE STP  X - p) x` ` 23.  Accordingly, IT IS ORDERED, pursuant to Section 4(i) of the  x\Communications Act of 1934, as amended, 47 U.S.C. Section 154(i), and Section 0.291 of the  xCommission's rules, 47 CFR Section 0.291, that the Cost Allocation Manual filed by Alltel Telephone Systems IS APPROVED, subject to the conditions noted in this Order.  X4- px` ` 24.  IT IS FURTHER ORDERED, that revised copies of the Cost Allocation  X-Manual shall be submitted within 60 days of the release date of this Order.xx x` `  hh@FEDERAL COMMUNICATIONS COMMISSION x` `  hh@Kenneth P. Moran x` `  hh@Chief, Accounting and Audits Division x` `  hh@Common Carrier BureaX01Í ÍX01Í ÍuX01Í ÍX01Í Í