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I.   2C3a7TechnicalTechnical Document Style(@D i) . a8TechnicalTechnical Document Style(D a) . Doc InitInitialize Document Stylez   0*0*0*  I. A. 1. a.(1)(a) i) a) I. 1. A. a.(1)(a) i) a)DocumentgPleadingHeader for Numbered Pleading PaperE!n    X X` hp x (#%'0*,.8135@8:><q*"xxxxWWxxxWWkkxxx Yy- xyԍ Bell Atlantic Telephone Companies, Centel Telephone Company, Southwestern Bell  xZTelephone Company, United Telephone Companies Zone Density Pricing Plans, 8 FCC Rcd  YK-5529 (Com. Car. Bur. 1993) (Second Zone Density Order).> On September 28 and November 30, 1993, the Bureau released Orders approving the zone density pricing plans of three more  X-LECs.M Y- xԍ Ameritech Operating Companies Zone Density Pricing Plan, 8 FCC Rcd 7267 (Com. Car.  Y- xJBur. 1993) (Third Zone Density Order); US West Communications and Southern New England  xTelephone Company Zone Density Pricing Plans, 8 FCC Rcd 8466 (Com. Car. Bur. 1993)  Y -(Fourth Zone Density Order). The Bureau found in each of these Orders that the zone plans reflected costrelated  X-characteristics based on traffic density, as the Commission intended in the Special Access  X-Physical Collocation Order. The Bureau thus concluded that the zone plans reasonably implemented the zone density pricing scheme that the Commission envisioned in the Order.  Xc-x4. On July 19, 1993, ALTS and TCG each filed an application for review of the First  XN-Zone Density Order.HN Y- xԍ On August 2, 1993, GTE Service Corporation (GTE) and Rochester Telephone  xCorporation (Rochester) filed oppositions to the ALTS and TCG applications, while BellSouth  xTelecommunications Inc. (BellSouth), the NYNEX Telephone Companies (NYNEX), and Pacific  xBell (Pacific) filed oppositions to those applications on August 3. Also on August 3, Lincoln  xZTelephone and Telegraph Company (Lincoln) filed its opposition to TCG's application. The  xCompetitive Telecommunications Association (CompTel) filed a reply to oppositions to the  x,ALTS application for review on August 13, 1993, and ALTS and TCG filed replies on August 18, 1993. These same parties filed an application for review of the Second Zone  X9-Density Order on September 3, 1993. 9 Y- xԍ The Bell Atlantic Telephone Companies (Bell Atlantic), Southwestern Bell Telephone  xCompany (Southwestern Bell), and the United and Central Telephone Companies (United/Centel)  xopposed the ALTS and TCG applications in separate filings made on September 20, 1993. ALTS and TCG did not file replies to these oppositions. On September 20, 1993, Bell Atlantic filed a motion to dismiss ALTS' application for review. Finally, ALTS filed an application for review of  X -the Third Zone Density Order on October 28, 1993,  9 Y - xhԍ The Ameritech Operating Companies (Ameritech) opposed this application for review on November 12, 1993. ALTS did not file a reply to Ameritech's opposition. and on December 30, 1993, sought  X -review of the Fourth Zone Density Order.   Y|$- x<ԍ US West Communications, Inc. (US West) and the Southern New England Telephone Company (SNET) filed oppositions on January 14, 1994. ALTS did not file a reply. " m 0*(( "Ԍ X-ԙ  III. BELL ATLANTIC MOTION TO DISMISS ă  X-  X-x5. Bell Atlantic urges dismissal of the ALTS application for review of the Second  X-Zone Density Order, which approved Bell Atlantic's zone density pricing plan. Bell Atlantic contends that ALTS was not a party to the zone density proceeding. It asserts that ALTS cannot participate in the proceeding because its application does not contain a statement  Xz-justifying its earlier lack of participation, as required by Section 1.115(a) of the Commission's  Xc-rules. Jc Y- xԍ Bell Atlantic Motion To Dismiss at 1, citing Section 1.115(a) of the Commission's rules, 47 C.F.R.  1.115(a). That rule states in relevant part:  XxAny person filing an application for review who has not previously participated  in the proceeding shall include with his application a statement ... showing good  @reason why it was not possible for him to participate in the earlier stages of the  ?proceeding. Any application for review which fails to make an adequate showing in this respect will be dismissed. Ɯ Bell Atlantic argues that ALTS did not participate directly in the zone density  XL-proceeding, but asserts that other ALTS members, like TCG, could file their own applications  X5-for review. 5 Y- xԍ Id. at 2. For the same reasons, several other LECs seek dismissal of ALTS' applications  Y- xfor review of the Bureau Orders approving their zone plans in their oppositions. See Ameritech  xOpposition at 12; BellSouth Opposition at 3; Southwestern Bell Opposition at 3; US West  Y-Opposition at 23.Ĺ Contrary to Bell Atlantic's assertions, however, ALTS is a party to the zone density proceeding. ALTS actively participated in an earlier phase of the Commission's  X -expanded interconnection proceeding, CC Docket No. 91141.; J  Y- x.ԍ ALTS filed comments on August 6 and November 5, 1991, and reply comments on  Y- xSeptember 20 and December 10, 1991 in CC Docket No. 91141 regarding, inter alia, the Commission's proposal to establish zone density pricing plans.; It is this docketed proceeding that established the framework for the filing of zone density pricing plans. We see no reason to deny ALTS' participation in this phase of a proceeding in which it has already been active.  X -We therefore deny Bell Atlantic's motion to dismiss the ALTS application for review.  X -  X-z  IV. APPLICATIONS FOR REVIEW ă x6. In their applications for review of the Bureau's four zone density Orders, both ALTS and TCG make the same general arguments.  X8-  X!- A. Whether the Bureau Erred by Prematurely Approving  X -the LECs' Zone Density Pricing Plans. x  X-  X-"0*((S"Ԍ X-x1. Pleadings  X-x7. Applications for Review. ALTS and TCG contend that the Bureau erred by  X-approving prematurely the LECs' zone density pricing plans.X Y6-ԍ ALTS Application at 913; TCG Application at 2.X They claim that the Commission intended to grant the LECs greater pricing flexibility through the use of zone  X-density plans provided that the LECs first filed collocation tariffs that would encourage the  Xx-development of local exchange competition. ALTS and TCG argue that the collocation tariffs filed by the LECs in fact will not engender viable competition because the tariffs allegedly do not offer reasonable, costbased rates and terms to interconnectors. They assert that the  X3-Bureau's suspension of the LECs' collocation tariffs substantiates their position.3y Y] - xԍ ALTS Application at 12 and TCG Application at 2, citing Physical Collocation Suspension  WH -Order.Ĺ ALTS and TCG further contend that the Bureau should have known that the collocation tariffs, as filed, would not fulfill the Commission's intent to "reduce the barriers to competitive entry in the  X -interstate special access market."  Y- xԍ ALTS Application at 712, citing First Zone Density Order, 8 FCC Rcd at 4443; TCG Application at 15.  X -x8. Oppositions. Ameritech, GTE, and NYNEX argue that the Commission found that  X -current market conditions justified granting them greater pricing flexibility.  Y - xԍ Ameritech Opposition at 45 and GTE Opposition at 5, citing Special Access Physical  Y-Collocation Order, 7 FCC Rcd at 7451 and 745354; NYNEX Opposition at 23. Several other  X-LECs claim that the Commission required LECs to file and obtain approval of their zone  X}-plans prior to filing changes to their zone tariffs,}O  Y}- x.ԍ Ameritech Opposition at 3; BellSouth Opposition at 45; Pacific Opposition at 67;  Yf- x;Southwestern Bell Opposition at 67; see also GTE Opposition at 29 (Commission did not tell  xxthe Bureau to reexamine the facts upon which the Commission relied to permit zone density pricing).  which could take effect only after  Xf-expanded interconnection becomes operational.f Y - xԍ Pacific Opposition at 9; SNET Opposition at 4, citing Special Access Physical Collocation  Y!-Order, 7 FCC Rcd at 745455; United/Centel Opposition at 2. United/Centel asserts that the Commission  XO-permits LECs filing zone plans to implement zone density pricing only as a response to  X8-competition.G8[ YD%-ԍ United/Centel Opposition at 2.G Still other LECs argue that there are more appropriate administrative procedures other than an application for review by which a party can seek to correct any"! 0*((G" alleged inconsistencies with the Commission's policies that may exist in the LECs' collocation  X-tariffs. Yb- xԍ Bell Atlantic Opposition at 34; Lincoln Opposition at 23; SNET Opposition at 45; US West Opposition at 3.  X-  X-x9. Replies. ALTS and TCG contend that a delay in approving the zone density plans is essential to correcting the alleged regulatory imbalance that the LECs created by filing  X-unreasonable collocation tariffs.Mb Y -ԍ ALTS Reply at 4; TCG Reply at 12. M TCG asserts that the Commission did not want the zone  Xx-plans to take effect prior to the existence of final, rather than interim, collocation tariffs that  Xa-are fully operational.a Y% - x,ԍ TCG Reply at 24, citing Special Access Physical Collocation Order, 7 FCC Rcd at 7454 n.411. TCG further claims that the Commission defined a tariff to be "operational" when an interconnector takes the crossconnect element from a final, not an interim, collocation tariff. It contends that the tariffs are not yet "operational" because the  X -LECs' crossconnect elements are part of the collocation tariff investigation.8  Y|-ԍ Id. at 3.8 ALTS similarly argues that the Bureau's approval of the LECs' zone density plans prior to the implementation of collocation tariffs containing rates that would facilitate increased local competition was contrary to the Commission's intent. x 10. ALTS further asserts that the Bureau possesses delegated authority to carry out Commission policies, but does not have authority to implement those policies in a manner that produces results that are inconsistent with the Commission's policy objectives. It contends that its application for review is entitled to consideration because the Commission's rules permit an application for review to be based on a need for a policy revision, an erroneous  X6-finding, or an incorrect application of relevant facts.6b  YI- xZԍ ALTS Reply at 5, citing Sections 1.115(b)(2)(ii) and (iii) of the Commission's rules, 47 C.F.R.  1.115(b)(2)(ii), (iii).  X- x2. Discussion  X-x 11. The Special Access Physical Collocation Order directed LECs to file and obtain approval of their zone density pricing plans before filing tariffs to implement those plans. After their plans were approved, the LECs' "zone tariffs" could contain different rates in each  X-zone for the LECs' high capacity DS1 and DS3 service offerings.l  YF&-ԍ Special Access Physical Collocation Order, 7 FCC Rcd at 7455.l A LEC was allowed to file its zone tariff, however, only after the Bureau approved its zone plans and only after its" 0*((P" collocation tariff was "operational" that is, after at least one interconnector subscribed to the  X-crossconnect element in the LEC's collocation tariff. As we stated in the Special Access  X-Physical Collocation Order, permitting implementation of additional LEC pricing flexibility at this point was reasonable, since an interconnector would be able to compete to serve a LEC's  X-customers by subscribing to the crossconnect element.L Y!-ԍ Id. at 7454 and n.411.L  Xz-x 12. The Bureau followed this sequence in approving the zone density pricing plans at issue in these applications for review. The Bureau first approved the zone density plans of 13 LECs, finding that the proposed plans reflected costrelated characteristics based on traffic density. The Bureau thus concluded that the zone plans reasonably implemented the zone  X -density pricing scheme that the Commission envisioned in the Special Access Physical  X -Collocation Order. Several of these LECs then filed tariffs containing different DS1 and DS3  X -service rates in each zone established in their plans; { Y - xԍ See, e.g., Ameritech Tariff F.C.C. No. 2, Transmittal No. 756, filed Nov. 30, 1993;  xiGTE Tariff F.C.C. No. 1, Transmittal No. 931, filed Apr. 16, 1994; NYNEX Tariff F.C.C.  xJNo. 1, Transmittal No. 270, filed Jan. 24, 1994; SNET Tariff F.C.C. No. 39, Transmittal No. 604, filed Mar. 31, 1994. these zone tariffs subsequently took effect with no formal opposition.  X -x 13. We conclude that the Bureau's approval of the zone density pricing plans  X-conformed to the sequence of events established in the Special Access Physical Collocation  X-Order. We therefore deny the claims of TCG and ALTS that the Bureau prematurely  Xn-approved the LECs' zone density pricing plans. In the Special Access Physical Collocation  XY-Order, we did not require the Bureau to delay approval of the LECs' zone density pricing plans, pending completion of the investigation of the special access collocation tariffs. Rather, we stated that the LECs could not file their tariffs implementing their zone density pricing plans until (1) after their zone density pricing plans have been approved and (2) after at least one interconnector subscribed to the crossconnect element in each of the LECs'  X-operational collocation tariffs. X-#Xj\  P6G;XP#э Special Access Physical Collocation Order, 7 FCC Rcd at 745455. In fact, in order to facilitate review of zone density pricing plans, the Commission stated that LECs that intended to file zone density pricing plans should  X-do so no later than the date it filed expanded interconnection tariffs.B Y"-ԍ Id. at 7455 n.418.B Therefore, the Commission contemplated that the Bureau would begin reviewing and approving zone density pricing plans of some LECs before an interconnector had subscribed to the crossconnect element of an "operational" physical collocation tariff. "^O 0*(("Ԍ X-x 14. TCG has also misinterpreted our "operational tariff" requirement.G  Yy-ԍ See TCG Reply at 24. G In the Special  X-Access Physical Collocation Order, we stated that "an expanded interconnection offering will be deemed to be operational for this purpose [implementing trafficdensityrelated rate zones]  X-when an interconnector has taken the expanded interconnection crossconnect element."u!{ Y-ԍ Special Access Physical Collocation Order, 7 FCC Rcd at 7454 n.411. u While we stated, as TCG argues, that purchase of a crossconnect from an "interim" tariff did  X-not satisfy our "operational tariff" requirement, we also clearly defined "interim" tariffs to be those we required of LECs that had existing intrastate expanded interconnection tariffs in  Xc-effect when the Special Access Physical Collocation Order was adopted.?"c. YB -ԍ Id. at 749192.?  XN-  X7-B. Whether the Bureau Erred by Approving Plans That Were Not CostBased .  X - x1. Pleadings  X -x15. Applications for Review. ALTS argues that the Bureau erred by approving the LECs' zone density pricing plans because the plans were not costbased, as the Commission  X -intended.#  YA- xԍ ALTS Application at 1315, citing Special Access Physical Collocation Order, 7 FCC Rcd at 7454 (purpose of Commission was to "bring special access rates more in line with costs"). ALTS contends that the Bureau instead relied on evidence that the plans were  X-"primarily traffic density based."@$} Y-ԍ ALTS Application at 14.@ It claims the Bureau erroneously approved plans that proposed higher rates for offices that have less traffic and lower rates for offices that have more traffic. ALTS further alleges that the Bureau's decision permitted LECs to shift central offices among zones on the basis of "competitive" criteria, rather than using costbased criteria  X<-alone.%<.  Y-ԍ ALTS Application at 1415, citing First Zone Density Order, 8 FCC Rcd at 444647.  X-x16. Oppositions. Several of the LECs respond that the Bureau properly found their  X-plans met the Commission's requirement that the plans be costbased.g&  Y"- xԍ Ameritech Opposition at 3; Bell Atlantic Opposition at 5; BellSouth Opposition at 6; GTE  Yt#- xOpposition at 7, citing First Zone Density Order, 8 FCC Rcd at 4447; Lincoln Opposition at 23; NYNEX Opposition at 3; Rochester Opposition at 12; US West Opposition at 45.g They claim that the"f&0*(("  X-Commission required the LECs to use traffic density data as a surrogate for cost data.' Yy- xԍ Ameritech Opposition at 3; GTE Opposition at 9, citing First Zone Density Order, 8 FCC Rcd at 4444; SNET Opposition at 5.  X-Pacific argues that the Commission's Special Access Physical Collocation Order reasoned that higher traffic density results in lower perunit costs, because the costs are largely nontraffic sensitive. It adds that "competitive criteria" were not used; rather, geographic contiguity and community of interest were permitted considerations, albeit to a lesser extent than traffic  X-density.(d Y - x ԍ Pacific Opposition at 1214; Rochester Opposition at 45, citing First Zone Density Order, 8 FCC Rcd at 4447.  Xa- x2. Discussion  X3-x17. In the Special Access Physical Collocation Order, we found traffic density significantly affects the cost of providing special access services. The Commission stated, for example, that traffic density is greater, and costs per unit of traffic are lower, in most areas containing large concentrations of high volume customers and on routes that involve a high  X -level of traffic aggregation.l)  Y-ԍ Special Access Physical Collocation Order, 7 FCC Rcd at 7452.l We also required the LECs to show in their zone density plans that the assignment of central offices to each zone reflects "costrelated characteristics, such as  X -traffic density or some measure of traffic through each office.";*  Y-ԍ Id. at 7455.; LECs were not instructed to use "competitive criteria." Rather, when assigning central offices to a pricing zone, a LEC was permitted to assign an office to the same pricing zone as the central office adjacent if the assignment reflected exchange area boundaries, or if both offices shared similar, noncost based characteristics. These conditions, however, were permitted only as minor  X8-considerations.3+8f  YO-ԍ Id. 3  X -x18. In its zone density plan Orders, the Bureau described the process by which the LECs' plans were developed as follows. First, the LECs developed a unit measure of traffic density through each central office or wire center. This measurement was based on historical data reflecting the amount of interstate traffic that passed through each of these central offices  X-or wire centers.[,  Yx$-ԍ First Zone Density Order, 8 FCC Rcd at 4444.[ Next, after ranking each central office or wire center in order of decreasing traffic density, the LECs divided the offices into three groups. These groups were designated zones one, two, and three, with zone one containing the wire center group having the highest" ,0*((P"  X-traffic density.2- Yy-ԍ Id.2 Finally, to reflect communities of interest or exchange area boundaries, some LECs moved some central offices to zones that were higher or lower than the zone to which  X-the offices were originally assigned.2.{ Y-ԍ Id.2  X-x19. The Bureau's analyses of the LECs' zone density plans are consistent with the  X-criteria we set forth in the Special Access Physical Collocation Order. After analyzing the LECs' assignment methodology, the Bureau properly concluded that the LECs had assigned  Xa-central offices to each zone using "costrelated characteristics, such as traffic density."/a. Y@ - xԍ See, e.g., First Zone Density Order, 8 FCC Rcd at 4446, citing Special Access Physical  Y+ -Collocation Order, 7 FCC Rcd at 7455. Therefore, ALTS is incorrect in arguing that, because the Bureau relied on traffic density evidence, it approved plans that were not costbased. ALTS' contention that the Bureau approved zone density plans that assigned central offices to zones on the basis of "competitive" criteria also lacks merit. The Bureau concluded that the LECs shifted certain  X -central offices from one zone to another on the basis of geographic contiguity. The Special  X -Access Physical Collocation Order expressly authorized LECs to take into account the geographic location of central offices as a secondary factor in assigning central offices to particular zones.  X-x20. Finally, ALTS' contention that the Bureau approved plans that proposed higher rates for offices with less traffic and lower rates for offices with more traffic mischaracterizes the Bureau's action in the orders under review, because the zone plans did not contain rates. LECs were permitted to file tariffs establishing different rates in each zone only after the  X#-plans were approved.o0# Y-ԍ Special Access Physical Collocation Order, 7 FCC Rcd at 745556.o The rate levels proposed in these tariff filings are subject to the tariff review process, and ALTS and other parties were free to file petitions opposing such tariff filings pursuant to our procedures for tariff review. In sum, we find that the Bureau correctly  X-applied the criteria established by the Commission in the Special Access Physical Collocation  X-Order in evaluating and approving the zone density pricing plans proposed by the 13 LECs. " 00*((R"  X- C. The Commission Should Revise the "Trigger Point" for Zone Plan Approval To  X-Ensure Viable Competition Exists When Zone Tariffs Take Effect .  X- x1. Pleadings  Xv-x21. Applications for Review. ALTS argues that the Commission should revise the effective competition "trigger point" to ensure that there will be actual competitive opportunity  XJ-when the LEC zone tariffs take effect.Z1J Y -ԍ ALTS Application at 1518; TCG Application at 2.Z ALTS and TCG argue that intervening facts since  X3-the Special Access Physical Collocation Order require the Commission on its own motion to revisit the "trigger point" for effective competition. They contend that effective competition cannot be assumed from the ordering of a single interconnection element by one carrier, particularly when the carrier is an interexchange carrier, that has no plans to offer local  X -competition.22 y Y-ԍ Id.2  X -x22. Oppositions. Several LECs urge the Commission to dismiss the ALTS and TCG  X-applications on this issue as belated requests for reconsideration of the Special Access  X-Physical Collocation Order.3, Y^- xԍ Bell Atlantic Opposition at 3; BellSouth Opposition at 12; GTE Opposition at 910;  YG- xNYNEX Opposition at 12; Pacific Opposition at 1415; Rochester Opposition at 12; SNET  xOpposition at 2; Southwestern Bell Opposition at 46; United/Centel Opposition at 5; US West Opposition at 34. Pacific contends that the Commission established the proper  Xl-"trigger point" for zone density pricing flexibility.F4l Y-ԍ Pacific Opposition at 1518. F United/Centel claims that ALTS is merely attempting to prolong the pricing umbrella created by the LECs' use of averaged rates  X>-throughout a single study area, despite lower costs of providing service in urban areas.I5>I  Y8-ԍ United/Centel Opposition at 34.I  X- x2. Discussion  X-x23. These objections by ALTS and TCG raise an issue that is unrelated to our determination of whether the Bureau erred in approving the LECs' zone density plans. Their  X-arguments attempt to revisit a decision made in the Special Access Physical Collocation Order and are thus untimely requests for reconsideration of our earlier Order. Alternatively, they  X-could have raised their concerns in a request for reconsideration of the Commission's Virtual  2TV  "\ 50*(("Ԍ X- 2TV Collocation Order.m6 Yy-ԍ Virtual Collocation Order, 9 FCC Rcd 5154 (1994).m In either event, these arguments are irrelevant to our review of the Bureau orders before us in this proceeding. Accordingly, we do not consider those arguments here.  X- V. CONCLUSION ă  X-Xx ` ` (#  Xx-x24. In this Order, we have reviewed the ALTS and TCG applications for review, the oppositions, and the replies. We find that the Bureau properly evaluated and approved the zone density pricing plans in a timely manner. We also find that the Bureau correctly applied  X3-the standards established in the Special Access Physical Collocation Order for using traffic  X -density criteria as a surrogate for costs. Finally, we reject the argument raised by ALTS and TCG that the Commission should revisit the "trigger point" for approval of the zone plans as an untimely reconsideration request. We therefore deny the applications for review of the Bureau's four Orders approving the LECs' zone density pricing plans and affirm the Bureau's approval of those plans.  X- VI. ORDERING CLAUSES ă  Xf-x25. IT IS ORDERED that the motion filed by the Bell Atlantic Telephone Companies to dismiss the Association for Local Telecommunications Services application for review of the Common Carrier Bureau's June 18, 1993 OrderIS DENIED.  X -x26. IT IS FURTHER ORDERED that the applications for review of the Common Carrier Bureau's June 18, 1993 Order, filed by the Association for Local Telecommunications Services and Teleport Communications Group, Inc., ARE DENIED.  X-x27. IT IS FURTHER ORDERED that the applications for review of the Common Carrier Bureau's August 4, 1993 Order, filed by the Association for Local Telecommunications Services and Teleport Communications Group, Inc., ARE DENIED.  XR-x28. IT IS FURTHER ORDERED that the application for review of the Common Carrier Bureau's September 28, 1993 Order, filed by the Association for Local Telecommunications Services, IS DENIED. "l$ {60*((F#"Ԍ X-x29. IT IS FURTHER ORDERED that the application for review of the Common Carrier Bureau's November 30, 1993 Order, filed by the Association for Local Telecommunications Services, IS DENIED. x` ` hhFEDERAL COMMUNICATIONS COMMISSION x` ` hhWilliam F. Caton  X -x` ` hhActing Secretary #Xw PE37