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If you need the complete document, download the WordPerfect version or Adobe Acrobat version, if available. ***************************************************************** Before the Federal Communications Commission Washington, D.C. 20554 ) In the Matter of ) ) Petitions for Reconsideration and ) AAD 92-86 Applications for Review of RAO 21 ) ) ) ) ) ) ORDER ON RECONSIDERATION Adopted: July 3, 1997 Released: July 9, 1997 By the Commission: TABLE OF CONTENTS Paragraph No. I. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . .1 II. BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . .2-4 III. RAO LETTER 21. . . . . . . . . . . . . . . . . . . . . . . . . . .5-8 IV. DISCUSSION . . . . . . . . . . . . . . . . . . . . . . . . . . . 9-29 Issue 1: Consistency of Revised RAO Letter 21 and Part 32 of the Commission's rules. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9-15 Issue 2: Consistency of Revised RAO Letter 21 with Part 36 of the Commission's rules and the Communications Act . . . . . . . . . . . . . . . .16-20 Issue 3: Whether the Administrative Procedure Act Requires a Notice and Comment Rulemaking . . . . . . . . . . . . . . . . . . . . . .21-23 Issue 4: Whether RAO 21 was Issued Under a Proper Delegation of Authority . . . . . . . . . . . . . . . . . . . . . . . . . .24-27 Issue 5: Whether Revised RAO Letter 21 Should Have Been Applied Prospectively . . . . . . . . . . . . . . . . . . . . . . . . .28-29 V. ORDERING CLAUSES . . . . . . . . . . . . . . . . . . . . . . . .30-34 APPENDIX A: List of Parties Filing Petitions, Comments and/or Replies I. INTRODUCTION 1. On August 7, 1992, the Common Carrier Bureau (Bureau), issued a responsible accounting officer (RAO) letter clarifying how carriers must account for certain remote central office equipment. Shenandoah filed a petition for reconsideration and the National Exchange Carrier Association (NECA) filed a request for clarification of the letter. On September 8, 1992, the Accounting and Audits Division (Division) released a revised letter that limited the application of the earlier letter. The revised letter also dismissed, without prejudice, the pleadings filed by Shenandoah and NECA. Nine parties filed pleadings opposing or appealing the Revised RAO Letter 21. The Division released a public notice on October 23, 1992, seeking comments on the pleadings opposing the RAO letter. Six parties filed comments and four parties filed replies. This Order upholds the interpretations in the Division's revised letter and, thereby, denies the petitions for reconsideration and applications for review. II. BACKGROUND 2. In 1992, the Division conducted a preliminary investigation that revealed that incumbent local exchange carriers (ILECs) were accounting for certain equipment inconsistently with Part 32 of the Commission's rules. Some ILECs were classifying certain types of remote central office equipment as switching equipment, while others were classifying identical equipment as circuit equipment. The Division subsequently released RAO Letter 21 and Revised RAO Letter 21 to provide guidance as to how this equipment should be classified in the Uniform System of Accounts. ILECs made substantial reclassifications of remote units to implement Revised RAO Letter 21. 3. Costs recorded in Part 32 accounts are the basis for allocation of investment between regulated and nonregulated activities, jurisdictional separations, and universal service support. It is essential that the ILECs record their investments in network plant in the proper Part 32 accounts so that the Commission's regulatory processes can operate as the Commission intended. Serious distortions can result if ILECs apply our accounting rules inconsistently. For example, if, under our rules, a certain type of equipment should be recorded in a switch account but a number of ILECs record this equipment in a transmission account, the nationwide average loop cost may be overstated. This average cost is the basis for sizing the Commission's Universal Service Fund (USF) program. Overstating the average loop cost could reduce the USF draws of many small ILECs, potentially jeopardizing their ability to provide quality service at reasonable rates. 4. The Commission delegated to the Bureau the responsibility for providing guidance to ILECs to achieve uniform application of the Uniform System of Accounts. The Bureau provides such guidance in a number of ways, including participation in industry fora, interpretive orders, and in RAO letters. When the Bureau perceives that consistent application of the Commission's Part 32 rules is in jeopardy, it prepares an RAO letter, signed by the Chief of the Division, clarifying the appropriate application of the accounting rules. The Bureau notifies all ILECs by publishing the RAO letter in the Federal Register. III. RAO LETTER 21 5. On August 7, 1992, the Division issued RAO Letter 21. That letter clarified the proper classification of certain remote central office equipment, i.e., remote switches and remote concentrator terminals. The Division had determined that, apparently, some ILECs were classifying remote switching equipment as circuit equipment, and concluded that ILECs were having difficulty in distinguishing between certain types of remote central office equipment. For this reason, the Division released RAO Letter 21 to clarify the difference between remote switching equipment and circuit equipment. In the initial RAO Letter 21, the Division stated that the primary factor distinguishing a remote concentrator terminal from a remote switch was that a remote switch has stand-alone switching capability while a concentrator does not have that capability. The stand-alone switching capability enables a remote switch to connect local calls, either routinely or when the lines connecting the remote to the "host" switch are not functioning. 6. Revised RAO Letter 21 addresses problems that occur when ILECs "improperly classify remote switches as circuit equipment rather than switching equipment." Revised RAO Letter 21 defines a remote switch as a unit that performs some, but not necessarily all, of the basic switching functions. It also states that calls between subscribers served by the same remote switching unit can be switched in the remote unit and that, when this occurs, the voice path does not extend to the host switch although a link may be required to the host switch for control purposes. 7. Revised RAO Letter 21 also clarifies the meaning of a "remote terminal of a concentrator." It states that a concentrator consolidates subscriber lines and thereby facilitates the use of less loop plant to serve a given number of subscribers. Revised RAO Letter 21 states that a concentrator has a terminal located at the central office and a remote terminal. It states that all calls are switched by the central office switch to which the concentrator is connected and that the voice path always extends to the host switch even for calls between subscribers served by the same remote terminal of a concentrator. That letter further states that the Commission's rules require that the cost of equipment used to reduce the amount of loop plant otherwise required to serve a given number of subscribers by utilizing carrier systems, concentration stages, or combinations of both is to be included in Account 2232, Circuit equipment. 8. Repeating the observation made in RAO Letter 21, Revised RAO Letter 21 states that the attribute distinguishing a remote switch from a remote terminal of a concentrator is that a remote switch can provide the switched path for calls between its directly connected local subscribers and a remote terminal of a concentrator cannot. That letter further states that a remote terminal of a concentrator depends on the host switch to switch all calls and the voice path always extends to the host switch. IV. DISCUSSION Issue 1: Consistency of Revised RAO Letter 21 and Part 32 of the Commission's rules 9. Positions of the Parties: Six petitioners contend that the definitions in Revised RAO Letter 21 are inconsistent with the existing Part 32 rules. They argue that Section 32.2(b) of the Commission's rules requires that the assets be classified solely based upon the functions they perform. Alltel contends that Revised RAO Letter 21 goes beyond mere interpretation and establishes definitions that classify equipment based on its technical capabilities rather than the functions performed. Staurulakis contends that the letter is inconsistent with RAO Letter 6, which, the petitioner contends, requires that the "actual usage" of equipment be the basis for its classification. 10. Alltel and NTCA also argue that the Division erred by picking a single feature, intranodal switching, as the factor that determines whether a particular remote will be classified as switching or circuit equipment. They generally contend that the switching feature is optional, has to be activated and is generally only used in emergencies. Several petitioners argue that the Revised RAO Letter 21 classifies equipment for accounting and cost allocation purposes based on arbitrary technical attributes, rather than the actual uses to which the equipment is put. NTCA contends that this would represent a significant change in policy that would result in mismatches between use, cost allocation, and cost recovery from different classes of customers. Staurulakis contends that Revised RAO Letter 21 classifies equipment based on its "capability" rather than its "recurring function" or "actual usage" and is unaware of any Commission decision that supports the standard for classification used in this RAO letter. As an alternative, some petitioners suggest that a remote unit should only be classified as a switch when NECA Tariff F.C.C. No. 4 lists that location as an end office or when a location has been given V&H coordinates. 11. Discussion: We disagree with petitioners' contention that the interpretation of the rules in Revised RAO Letter 21 is inconsistent with Section 32.2(b) of the Commission's rules, which states that the Part 32 accounts shall reflect, to the extent feasible, the functions of the equipment being classified. We reaffirm that Revised RAO Letter 21 classifies remote equipment on the basis of function. We recognize that both concentrators and remote switches often provide similar functions and that this may cause confusion in determining to which accounts the equipment should be assigned. For example, under certain configurations, both can perform a number of functions historically associated with switches, such as attending, information receiving, and alerting. Of the switch functions listed in footnote 27, however, interconnection, i.e., the actual connection of lines and trunks, is the characteristic that distinguishes switches from other central office equipment. We note that, under Part 32, the switch accounts, Accounts 2210 through 2212, exist specifically for recording switches' costs, whereas the accounts for circuit equipment make no mention of switching at all. If, therefore, a piece of remote equipment is capable of interconnecting lines or trunks, i.e., if it has the switching matrix required for call interconnection, the costs of that investment should be classified in Accounts 2210 through 2212 of our Part 32 rules. 12. Alltel and NTCA contend that some remote units only perform the switching function on an emergency basis. They argue that a remote unit must perform as a stand-alone switch at all times in order to be classified as a switch. We do not find this argument persuasive. Virtually all remote units that contain a switching matrix routinely perform the interconnection function locally and rely on the host unit for the control function, except in the event of an emergency, when the control function is also transferred to the remote. As discussed in the previous paragraph, remote units that interconnect lines and trunks contain the switching matrix and are capable of providing all of the essential features and capabilities of a switch and should be classified as such. 13. Even if our classification of remote units based on their ability to switch were not based on function, it would be consistent with the rules. Manufacturers had, through technological innovations, developed new types of equipment that had some of the capabilities of both switching and circuit equipment. The clarification contained in Revised RAO Letter 21 was a response to precisely this type of situation. Section 32.2(b) of the Commission's rules provides that, because of the anticipated impact of future innovations, the Part 32 plant accounts are intended to permit technological distinctions. Thus, to the extent that Revised RAO Letter 21's use of the existence of switching capacity is a classification based on a technological distinction, it is permitted by the rules. 14. We also disagree with the contention that the Division deviated from the precedent in RAO Letter 6 when it adopted Revised RAO Letter 21. RAO Letter 6 did not adopt the rigid "actual use" standard that Staurulakis contends. RAO Letter 6 stated that "the proper classification in each instance must be determined "by the text of the account and the actual usage of the equipment" (emphasis added). In the present case, the text of the rule specifically provides that the cost of remote switches must be included in the switching account, but does not define a remote switch. Another rule defines circuit equipment without specifically mentioning remote terminals. In both instances, the rule creates general classifications for switching and circuit equipment, but does not specifically define which remote units should be placed in each classification. Revised RAO Letter 21 gives ILECs specific guidance about how to classify remote equipment within those general classifications and is consistent with both Section 32.2(b) and RAO Letter 6 because its interpretation of the rules does not conflict with the text of the rules and is also based on the actual use of the equipment. 15. Finally, we disagree with those petitioners that claim that we should base our Part 32 classifications of remote equipment on that equipment's status under NECA Tariff F.C.C. No. 4 or on whether that location is assigned V&H coordinates. Those classifications are generally assigned for billing purposes and are at least partially within the control of the ILEC. We find no reason to substitute such private decisions for the classification standards that are contained in our Part 32 rules. Issue 2: Consistency of Revised RAO Letter 21 with Part 36 of the Commission's rules and the Communications Act 16. Positions of the Parties: Some petitioners contend that Revised RAO Letter 21 is not merely a clarification of the Commission's Part 32 accounting rules, but constitutes a significant change in the Commission's Part 36 rules. Specifically, Roseville argues that ILECs subject to the Part 36 rules have categorized plant in service on the basis of the predominant functionality of that equipment in each company's individual network. Roseville contends that the Revised RAO Letter 21, if applied literally, would significantly alter or actually eliminate the concept of functionality as reflected in Part 36 of the Commission's rules. 17. Staurulakis contends that the issuance of Revised RAO Letter 21 violates Section 410(c) of the Communications Act and that not referring the issue to the Joint Board is reversible error justifying recision of Revised RAO Letter 21. In support of this contention, Staurulakis argues that applying the definitions propounded in Revised RAO Letter 21 would, under current Part 36 rules, change the amount of costs that carriers assign to different Part 36 categories and consequently, the carrier's investment in the remote terminal equipment would be separated using different allocators than would have been applicable before the issuance of Revised RAO Letter 21. NTCA notes, however, that the Joint Board has expressly refused to consider NTCA's request that it clarify the definitions of "host," "remote" and "concentrator." Staurulakis also contends that Section 220(i) of the Act requires the Commission to notify each state commission and provide opportunity for comments and replies. 18. Discussion: We disagree with petitioner's contention that, simply because it has sought to clarify the rules and to classify equipment differently from the way some carriers initially selected, the Division's action in issuing Revised RAO Letter 21 constitutes a change in Part 36. The Division has not amended any of the language in Part 36 nor has it clarified or redefined any portion of Part 36. The fact that its action in clarifying definitions under Part 32 may consequently affect some ILECs' allocations of costs under Part 36 does not constitute an amendment of Part 36. Costs flow through a series of processes before they are subject to the jurisdictional allocations process under Part 36. They are initially classified in accounts as Part 32 directs and then divided into regulated and nonregulated costs according to the requirements of Part 64. Then, and only then, are costs separated according to the Part 36 rules. 19. Section 410(c) of the Act requires the Commission to refer "any proceeding regarding the jurisdictional separation of common carrier property instituted pursuant to a notice of proposed rulemaking." There are two reasons why this statutory provision does not require the Commission to refer the proper classification of remote switches and remote terminals of a concentrator to a Joint Board. First, as discussed in paragraph 14, above, the issuance of Revised RAO Letter 21 offers only a clarification of our Part 32 rules. It does not amend, interpret or otherwise change our Part 36 requirements. It is not, therefore, a proceeding regarding the jurisdictional separation of common carrier property subject to the requirements of Section 410(c) of the Act. Second, the fact that the Joint Board specifically considered this issue and refused to make a recommendation supports our conclusion that the Commission was not obligated to refer this issue to the Joint Board because that board has already determined that it need not rule on the issue. Although Revised RAO Letter 21 did not interpret the Commission's Part 36 rules, such interpretation is permitted under Commission precedent. In Reservation Telephone Cooperative v. AT&T, the Commission interpreted some existing Part 36 rules to require the use of five-day separations studies, rather than the seven-day separations studies that some carriers had been using. For some carriers, this reduced the portion of their expense that was allocated to the interstate jurisdiction and affected the amount they received in settlements from AT&T. In affirming the Bureau's decision, the Commission stated that it has always viewed the interpretation of existing Separations Manual provisions as a Commission function. 20. Section 220(i) only obligates the Commission to notify state commissions when the Commission prescribes requirements relating to accounts, records or memoranda. In the present case, the Commission has not prescribed any such requirements, it has merely, through the Division's actions, clarified the meaning of pre-existing requirements and therefore, Section 220(i) is inapplicable. Issue 3: Whether the Administrative Procedure Act requires a notice and comment rulemaking 21. Positions of the Parties: Many of the petitioners contend that, in this instance, Section 553 of the Administrative Procedure Act (APA) requires the Commission to conduct a notice and comment rulemaking rather than issue definitions of these terms in Revised RAO Letter 21. These petitioners contend that Revised RAO Letter 21 goes beyond mere "explanation, interpretation, or resolution" and instead formulates substantive rule changes to the Uniform System of Accounts. Staurulakis contends that the letter violates Section 553 of the APA because it effectively amends Sections 32.2(b) and 32.2232 of the Commission's rules without the opportunity for notice and comment. Further, NTCA contends that the use of temporary technical attributes in Revised RAO Letter 21 means that the rules will be in constant need of clarification or modification. Roseville, without explanation or discussion, cites cases in support of its contention the APA requires the Commission to conduct a notice and comment rulemaking on this issue. 22. Discussion: The Division found that remote equipment that was physically and functionally identical was being placed in the switching account by some ILECs and in the circuit equipment account by others. The Division adopted Revised RAO Letter 21 to clarify under what circumstances this equipment should be placed in one pre-existing category rather than another. Section 553(b)(A) of the APA states that notice and comment procedures are not required for "interpretative rules." Interpretative rules are agency statements of general effect in which the agency announces an interpretation of a statute or of another rule. Interpretative rules thus serve an advisory function by explaining the meaning the agency attaches to a particular word or phrase in a statute or rule that the agency administers. Revised RAO Letter 21 is clearly "interpretative;" it does not change the language of any of the Part 32 rules but merely clarifies ambiguities created by the availability of this new equipment that has some characteristics of circuit equipment and some characteristics of switching equipment. The interpretative definitions contained in Revised RAO Letter 21 may have resulted in changes in how individual carriers classify their remote equipment but do not change the rules and, therefore, Section 553 (b)(A) of the APA does not require the Commission to conduct a notice and comment proceeding in this instance. 23. In both of the cases cited by Roseville, the agency, to the detriment of the plaintiff, suspended a pre-existing regulation without notice or opportunity for comment. In both cases, the courts stated that the exceptions to the publication requirement for "interpretative rules" did not apply because the respective agencies had terminated rights under pre-existing rules. These cases are clearly distinguishable from Revised RAO Letter 21 in which the Bureau has not suspended, altered, or amended the existing regulation. ILECs have the same rights under the rules, both before and after the release of Revised RAO Letter 21. Issue 4: Whether RAO 21 was Issued Under a Proper Delegation of Authority 24. Positions of the Parties: Alltel contends that Section 0.291 of the Commission's rules delegated authority to the Bureau Chief, not the Division Chief, and that the Division therefore lacked the authority to issue Revised RAO Letter 21 on behalf of the Bureau. Staurulakis argues that Revised RAO Letter 21 exceeds the authority delegated to the Bureau Chief because, he contends, the letter involves a question of policy not previously resolved by the Commission. 25. Discussion: Section 0.91(a) of the Commission's rules provides that one of the functions of the Common Carrier Bureau is the "administration of Commission accounting and reporting requirements." Section 0.291 delegates to the Bureau Chief the authority to perform all of the functions listed in Section 0.91 of the Commission's rules. While Section 0.291 imposes specific limitations on that delegated authority, none of those limitations apply in the present case. Section 0.291 states that the Bureau Chief shall not have the authority to issue notices of proposed rulemaking. Revised RAO Letter 21 neither amends nor proposes to amend any rules. The letter simply interprets existing rules, clarifying the proper application of the rules in an area where the carriers were inconsistently classifying new types of equipment. Additionally, Section 32.17 of the Commission's rules provides that the Chief of the Common Carrier Bureau shall be responsible for explanation, interpretation, or resolution of significant questions about the Uniform System of Accounts that are not clearly provided for in the rules. Under these grants of authority, the Chief of the Common Carrier Bureau clearly has the authority necessary to issue interpretations of the Part 32 rules contained in Revised RAO Letter 21. 26. Contrary to Alltel's contention, the Division Chief was acting within his authority when he issued Revised RAO Letter 21. As discussed above, the rules clearly give the Bureau Chief the authority to issue interpretations of the Commission's accounting rules. Those rules also grant a Division Chief the authority to issue such interpretations; Section 0.204(b) provides that a grant of authority to the Chief of the Common Carrier Bureau can be exercised by a subordinate acting on behalf of the Bureau Chief. Contrary to Alltel's contentions, the Chief of the Accounting and Audits Division has acted within the authority delegated to him under the rules when he issued the Revised RAO Letter 21, and, in any event, the issue of who should take a particular action is a matter of the Commission's internal functions. 27. Section 0.291 also states that the Chief of the Common Carrier Bureau shall not have authority to act on any requests that "present novel questions of fact, law or policy which cannot be resolved under outstanding precedents and guidelines." This limitation does not apply to Revised RAO Letter 21 because there are no novel questions involved in this matter. The Division has merely issued an interpretation of the existing rules to clarify how certain equipment should be classified. Additionally, the Bureau has specific authority under Section 32.17 of the Commission's rules to issue rule interpretations. Issue 5: Whether Revised RAO Letter 21 Should Have Been Applied Prospectively 28. Positions of the Parties: Various petitioners contend that Revised RAO Letter 21 should only apply to prospective accounting period data or should only take effect after a specified date. Southwestern and USTA contend that the ILECs need time to alter their accounting practices and otherwise conform to what they characterize as the new requirements imposed by Revised RAO Letter 21. Further, Southwestern claims that the carriers had no advance notice of the RAO letter. 29. Discussion: As a general rule, declaratory rulings that interpret, but do not change, obligations under existing Commission rules have the effective date of the rule. Petitioners' arguments against retroactivity are rooted in the perception that Revised RAO Letter 21 represents a new policy. We disagree. The RAO letter corrects misinterpretations but does not change the purpose or operation of the underlying rules. Similarly, petitioners' claims that the RAO letter's interpretation was unexpected are unpersuasive. This proceeding does not involve an unforeseen application of a rule, but rather the exact fact situation the rules are designed to address: the classification of investment costs into either the circuit or switching accounts. Because it interprets, but does not change, our rules, Revised RAO Letter 21 could have had the effective date of the rules. In fact, the Bureau, in its discretion, made the interpretation effective for reports filed after the release date of the RAO letter. The Bureau, therefore, acted within its authority. V. ORDERING CLAUSES 30. Accordingly, IT IS ORDERED pursuant to Sections 4(i), 4(j), and 220 of the Communications Act of 1934, as amended, 47 U.S.C.  154(i), 154(j), 220 and Section 553(b)(A) of the Administrative Procedure Act, 5 U.S.C.  553(b)(A), and Section 1.106 of the Commission's rules, 47 C.F.R.  1.106, that the Petitions for Reconsideration filed by Alltel, NECA and Southwestern Bell against the Revised RAO Letter 21 ARE DENIED. 31. IT IS FURTHER ORDERED, pursuant to Sections 4(i), 4(j), and 220 of the Communications Act of 1934, as amended, 47 U.S.C.  154(i), 154(j), 220 and Section 553(b)(A) of the Administrative Procedure Act, 5 U.S.C.  553(b)(A), and Section 1.106 of the Commission's rules, 47 C.F.R.  1.106, that the Petitions for Reconsideration and/or Clarification filed by NTCA and OPASTCO against the Revised RAO Letter 21 ARE DENIED. 32. IT IS FURTHER ORDERED, pursuant to Sections 4(i), 4(j), and 220 of the Communications Act of 1934, as amended, 47 U.S.C.  154(i), 154(j), 220 and Section 553(b)(A) of the Administrative Procedure Act, 5 U.S.C.  553(b)(A), and Section 1.106 of the Commission's rules, 47 C.F.R.  1.106, that the Petition for Limited Reconsideration filed by USTA against the Revised RAO Letter 21 IS DENIED. 33. IT IS FURTHER ORDERED, pursuant to Sections 4(i), 4(j), and 220 of the Communications Act of 1934, as amended, 47 U.S.C.  154(i), 154(j), 220 and Section 553(b)(A) of the Administrative Procedure Act, 5 U.S.C.  553(b)(A), and Section 1.115 of the Commission's rules, 47 C.F.R.  1.115, that the Applications for Review filed by Lexington, Roseville, and Staurulakis against the Revised RAO Letter 21 ARE DENIED. 34. IT IS FURTHER ORDERED, pursuant to Sections 4(i), 4(j), and 220 of the Communications Act of 1934, as amended, 47 U.S.C.  154(i), 154(j), 220 and Section 553(b)(A) of the Administrative Procedure Act, 5 U.S.C.  553(b)(A), and Section 1.106 of the Commission's rules, 47 C.F.R.  1.106, that the letters filed by Pond Branch and Shenandoah against the Revised RAO Letter 21 ARE DENIED. FEDERAL COMMUNICATIONS COMMISSION William F. Caton Acting Secretary Appendix A List of Commenters Applications for Review or Petitions for Reconsideration Alltel Service Corporation Alltel Lexington Telephone Company Lexington National Exchange Carrier Association NECA National Telephone Cooperative Association NTCA Organization for the Advancement and Preservation of Small Telephone Companies OPASTCO Roseville Telephone Company Roseville Southwestern Bell Telephone Company Southwestern John Staurulakis, Inc. Staurulakis United States Telephone Association USTA Letters Pond Branch Telephone Company Pond Branch Shenandoah Telephone Company Shenandoah Comments National Telephone Cooperative Association NTCA Reed, Veach, Wunderman and Assoc., Inc. Reed Veach Roseville Telephone Company Roseville Union Telephone CompanyUnion United Telephone Company (Sprint) United Shenandoah Telephone Company Shenandoah Replies GTE Service CorporationGTE National Telephone Cooperative Association NTCA National Exchange Carrier Association NECA John Staurulakis, Inc. Staurulakis