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INTRODUCTION ă  X 4 e 1.` ` On August 7, 1992, the Common Carrier Bureau (Bureau), k zP ' "^ԍAs explained in paragraph 4, infra, the Chief of the Accounting and Audits Division signs RAO letters on behalf of the Chief of the Common Carrier Bureau. issued a responsible  xVaccounting officer (RAO) letter clarifying how carriers must account for certain remote central  X 4 xoffice equipment.  "k zP' "gԍClassification of Remote Central Office Equipment for Accounting Purposes, Responsible Accounting  zP'Officer Letter 21, DA 921091 (Com.Car.Bur. Aug. 7, 1992) (RAO Letter 21).  Shenandoah filed a petition for reconsideration and the National Exchange  xCarrier Association (NECA) filed a request for clarification of the letter. On September 8, 1992,  x~the Accounting and Audits Division (Division) released a revised letter that limited the  X 4 xapplication of the earlier letter. ~k zP' "*ԍClassification of Remote Central Office Equipment for Accounting Purposes, RAO Letter 21, 7 FCC Rcd  zP'6075 (Com.Car.Bur.1992) (Revised RAO Letter 21). The revised letter also dismissed, without prejudice, the  xpleadings filed by Shenandoah and NECA. Nine parties filed pleadings opposing or appealing  X{4 xthe Revised RAO Letter 21. {k xP' "ԍThree parties filed Petitions for Reconsideration, Alltel, NECA and Southwestern Bell, two parties filed  x Petitions for Reconsideration and/or Clarification, NTCA and OPASTCO, one party filed a Petition for Limited  x Reconsideration, USTA, three parties filed Applications for Review, Lexington, Roseville and Staurulakis and two parties filed letters, Pond Branch and Shenandoah. The Division released a public notice on October 23, 1992, seeking  Xf4 xcomments on the pleadings opposing the RAO letter. Six parties filed commentsmf k xP'ԍNTCA, Union, United, Shenandoah, Roseville, and Reed Veach. m and four  XO4 xparties filed replies.ROR k xPR 'ԍStaurulakis, NTCA, GTE and NECA. R This Order upholds the interpretations in the Division's revised letter and, thereby, denies the petitions for reconsideration and applications for review.  X 4 g< II. BACKGROUND ă   X4 e 2.` ` In 1992, the Division conducted a preliminary investigation that revealed that  xincumbent local exchange carriers (ILECs) were accounting for certain equipment inconsistently",W)W)QQK"  X4 xVwith Part 32 of the Commission's rules.k xPy' "xԍ47 C.F.R. Part 32. Part 32 contains the Uniform System of Accounts for Telecommunications Companies. It specifies the accounts that ILECs must use to record their costs, including their investments in network plant.  Some ILECs were classifying certain types of remote  X4 x4central office equipment as switching equipment,N k zP' "*ԍSee 47 C.F.R.  32.2211 and  32.2212. The analog electronic switching account includes the original  xcost of stored program control analog circuitswitching and associated equipment, as well as the cost of remote  xanalog electronic circuit switches. The digital electronic switching account includes the original cost of stored  xprogram control digital switches and their associated equipment, as well as the cost of remote digital electronic switches.N while others were classifying identical  X4 x&equipment as circuit equipment. k zPU ' "ԍSee 47 C.F.R.  32.2232. The circuit equipment account includes the original cost of equipment that is  x used to reduce the number of physical pairs otherwise required to serve a given number of subscribers by utilizing  x!carrier systems, and/or concentration stages. This account also includes equipment that is used for the amplification,  x3modulation, regeneration, circuit patching, balancing or control of signals transmitted over interoffice  xcommunications transmission channels. This account includes equipment that uses the message path to carry  x signaling information or that uses separate channels between switching offices to transmit signaling information  xs independent of the subscribers' communication paths or transmission channels. Circuit equipment may be located  x in central offices, in manholes, on poles, in cabinets or huts, or at other company locations. It does not include,  xhowever, equipment that is an integral component of a major unit classifiable to other accounts, such as the  xP_'switching equipment accounts.  The Division subsequently released RAO Letter 21 and Revised  X4 xRAO Letter 21 to provide guidance as to how this equipment should be classified in the Uniform  x_System of Accounts. ILECs made substantial reclassifications of remote units to implement  X4Revised RAO Letter 21. "lk zP' "ԍSee, e.g.,  Letter from Carol L. Bjelland, Director, Regulatory Matters, GTE Service Corporation, to Bob  xHHall, Accounting and Audits Division, Common Carrier Bureau, FCC (May 7, 1993); letter from William J.  xHStern, Vice President Tariff Cost and Regulatory Matters, NECA to Kenneth Moran, Chief, Accounting and Audits Divsion, Common Carrier Bureau, FCC (Nov. 17, 1992).  Xe4 e 3.` ` Costs recorded in Part 32 accounts are the basis for allocation of investment  xbetween regulated and nonregulated activities, jurisdictional separations, and universal service  x support. It is essential that the ILECs record their investments in network plant in the proper Part  x32 accounts so that the Commission's regulatory processes can operate as the Commission  x"intended. Serious distortions can result if ILECs apply our accounting rules inconsistently. For  xVexample, if, under our rules, a certain type of equipment should be recorded in a switch account  xpbut a number of ILECs record this equipment in a transmission account, the nationwide average  X 4 xAloop cost may be overstated.H Vk xP"'ԍ47 C.F.R.  36.622. H This average cost is the basis for sizing the Commission's  x Universal Service Fund (USF) program. Overstating the average loop cost could reduce the USF  xEdraws of many small ILECs, potentially jeopardizing their ability to provide quality service at reasonable rates. "h ,W)W)QQ "Ԍ X4 e 94.` ` The Commission delegated to the Bureau the responsibility for providing guidance  X4 xEto ILECs to achieve uniform application of the Uniform System of Accounts.{ k zPb'ԍ47 C.F.R.  32.17. See also 47 C.F.R.  0.91 and 0.291. { The Bureau  xVprovides such guidance in a number of ways, including participation in industry fora, interpretive  xorders, and in RAO letters. When the Bureau perceives that consistent application of the  x/Commission's Part 32 rules is in jeopardy, it prepares an RAO letter, signed by the Chief of the  xDivision, clarifying the appropriate application of the accounting rules. The Bureau notifies all ILECs by publishing the RAO letter in the Federal Register.  XH4&7 III. RAO LETTER 21 ă  X 4 e 5.` ` On August 7, 1992, the Division issued RAO Letter 21. That letter clarified the  X 4 xproper classification of certain remote central office equipment, i.e., remote switches and remote  xhconcentrator terminals. The Division had determined that, apparently, some ILECs were  xclassifying remote switching equipment as circuit equipment, and concluded that ILECs were  xphaving difficulty in distinguishing between certain types of remote central office equipment. For  X 4 xthis reason, the Division released RAO Letter 21 to clarify the difference between remote  X4 xswitching equipment and circuit equipment. In the initial RAO Letter 21, the Division stated that  x<the primary factor distinguishing a remote concentrator terminal from a remote switch was that  xa remote switch has standalone switching capability while a concentrator does not have that  x"capability. The standalone switching capability enables a remote switch to connect local calls,  X=4either routinely or when the lines connecting the remote to the "host" switch are not functioning. x=Zk xPH' "ԍA common way for an ILEC to serve a large, sparsely populated area is through a host/remote switch  x architecture. When this configuration is used, a host switch is installed in a populous area and remote terminals  xare installed in less populous areas. The remote switches are connected to the host by trunk facilities. The host  xL is equipped with an advanced processor that controls various aspects of the remote switches, thereby providing a  xHwide range of features to customers in the entire area. The remote switches are equipped with less expensive  x processors that control some aspects of the local operation, including switching among customers connected to the same remote, especially when the facilities between the host and the remote are severed.   X4 e 6.` ` Revised RAO Letter 21 addresses problems that occur when ILECs "improperly  X4 xclassify remote switches as circuit equipment rather than switching equipment."bk zPE'ԍRevised RAO Letter 21, 7 FCC Rcd at 6075. b Revised RAO  X4 xLetter 21 defines a remote switch as a unit that performs some, but not necessarily all, of the  x3basic switching functions. It also states that calls between subscribers served by the same remote  xswitching unit can be switched in the remote unit and that, when this occurs, the voice path does  xnot extend to the host switch although a link may be required to the host switch for control  X4purposes.:, k zPh%'ԍId.:  X]4 e 7.` ` Revised RAO Letter 21 also clarifies the meaning of a "remote terminal of a  x/concentrator." It states that a concentrator consolidates subscriber lines and thereby facilitates"H ,W)W)QQ8"  X4 xthe use of less loop plant to serve a given number of subscribers.  Revised RAO Letter 21 states  xthat a concentrator has a terminal located at the central office and a remote terminal. It states  xthat all calls are switched by the central office switch to which the concentrator is connected and  X4 xcthat the voice path always extends to the host switch even for calls between subscribers served  xcby the same remote terminal of a concentrator. That letter further states that the Commission's  xrules require that the cost of equipment used to reduce the amount of loop plant otherwise  xrequired to serve a given number of subscribers by utilizing carrier systems, concentration stages,  Xa4or combinations of both is to be included in Account 2232, Circuit equipment.Sak zP'ԍSee 47 C.F.R.  32.2232. S  X34 e z8.` ` Repeating the observation made in RAO Letter 21, Revised RAO Letter 21 states  xthat the attribute distinguishing a remote switch from a remote terminal of a concentrator is that  xEa remote switch can provide the switched path for calls between its directly connected local  xRsubscribers and a remote terminal of a concentrator cannot. That letter further states that a  xremote terminal of a concentrator depends on the host switch to switch all calls and the voice path always extends to the host switch.  X4D IV. DISCUSSION ă  Xf4 Issue 1: Consistency of Revised RAO Letter 21 and Part 32 of the Commission's rules  X94 e 9.` ` Positions of the Parties: Six petitioners contend that the definitions in Revised  X$4 xRAO Letter 21 are inconsistent with the existing Part 32 rules.$Zk xP/' " ԍAlltel Petition at 1 & 5; Staurulakis Petition at 2; NTCA Petition at 7 and Comments at 5; OPASTCO Petition at 2; Roseville Comments at 1; NECA Petition at 3, n.7. They argue that Section 32.2(b)  X4 xcof the Commission's rulesIk xPr'ԍ47 C.F.R.  32.2(b). I requires that the assets be classified solely based upon the functions  X4 xthey perform. Alltel contends that Revised RAO Letter 21 goes beyond mere interpretation and  xestablishes definitions that classify equipment based on its technical capabilities rather than the  X4 xfunctions performed.JBk xP'ԍAlltel Petition at 1 & 5.J Staurulakis contends that the letter is inconsistent with RAO Letter 6,k xPO ' "ԍResponsible Accounting Officers Letter 6, Part 32, Uniform System of Accounts for Class A and Class B  zP!'Carriers Item Lists, unpublished, (June 26, 1987) (RAO Letter 6).   x"which, the petitioner contends, requires that the "actual usage" of equipment be the basis for its  X4classification.M, k xP}$'ԍStaurulakis Petition at 13. M  Xr4 e O 10.` ` Alltel and NTCA also argue that the Division erred by picking a single feature,  xVintranodal switching, as the factor that determines whether a particular remote will be classified  xcas switching or circuit equipment. They generally contend that the switching feature is optional,"D ,W)W)QQ_"  X4 xhas to be activated and is generally only used in emergencies.ck xPy'ԍAlltel Petition at 6; NTCA Petition at 8. c Several petitioners argue that  X4 xZthe Revised RAO Letter 21 classifies equipment for accounting and cost allocation purposes based  x on arbitrary technical attributes, rather than the actual uses to which the equipment is put. NTCA  xpcontends that this would represent a significant change in policy that would result in mismatches  X4 x&between use, cost allocation, and cost recovery from different classes of customers.FXk xP'ԍNTCA Petition at iii.F Staurulakis  X4 x"contends that Revised RAO Letter 21 classifies equipment based on its "capability" rather than  xhits "recurring function" or "actual usage" and is unaware of any Commission decision that  Xc4 xsupports the standard for classification used in this RAO letter.Lck xP 'ԍStaurulakis Petition at 17.L As an alternative, some  xpetitioners suggest that a remote unit should only be classified as a switch when NECA Tariff  X54 xF.C.C. No. 4 lists that location as an end officet5xk xP^'ԍAlltel Petition at 6; Roseville Comments at 5, NECA Petition at 8. t or when a location has been given V&H  X 4coordinates.7 k xP' "ԍReed Veach Comments at 2. Similar to longitude and latitude, the V & H coordinates designate wire  xL center locations that carriers use to determine the distance between two central office locations. The coordinates  xcan be used to determine the length of any access transmission path for purposes of calculating interstate access  zP/' x charges, as well as billing percentages when multiple providers are involved in providing the access services. See  xNational Exchange Carriers Association, Inc., Request for Permission to Engage in Additional Activities,  zP'Memorandum Opinion and Order, 12 FCC Rcd 3657 at n. 10 (Com.Car.Bur. Mar. 17, 1997).7  X 4 e  11.` ` Discussion: We disagree with petitioners' contention that the interpretation of the  X 4 xrules in Revised RAO Letter 21 is inconsistent with Section 32.2(b) of the Commission's rules,  xwhich states that the Part 32 accounts shall reflect, to the extent feasible, the functions of the  X 4 x3equipment being classified. We reaffirm that Revised RAO Letter 21 classifies remote equipment  x&on the basis of function. We recognize that both concentrators and remote switches often provide  x'similar functions and that this may cause confusion in determining to which accounts the  xequipment should be assigned. For example, under certain configurations, both can perform a  XS4 xnumber of functions historically associated with switches,S k zP'ԍAs Revised RAO Letter 21 stated:  e XX` ` The basic switch functions are: 1) Attending monitors for offhook signals; 2) Control  e determines call destination and assigns call to available line or trunk; 3) Busy testing determines  e whether the called line/trunk is busy; 4) Information receiving receives control and busy test  e results; Information transmitting transmits control and busy test results to tell the alerting and  e interconnection functions whether to complete the call; 6) Interconnection connects subscriber  e line to subscriber or subscriber line to trunk; 7) Alerting rings the called subscriber's line or  e other signalling means if the call is destined for another exchange; 8) Supervising monitors for  xP&'call termination so the line can be released. (#` "Z',W)W)'"Ԍ zP' x]!Revised RAO Letter 21, 7 FCC Rcd at 6075, citing Telecommunications System Engineering, Second Edition, Roger L. Freeman, Wiley Interscience, 8990 (1989).  such as attending, information"S",W)W)QQ"  X4 xreceiving, and alerting. "k xP' "ԍIntegrated Digital Loop Carrier System Generic Requirements, Objectives and Interface, Generic  xRequirements, Bellcore, GR303CORE at 21 through 26 (Revision 1, December, 1995) This is a specification  x!published by Bellcore to define remote concentrators for the purpose of ensuring compatibility within the network. It lists both optional and required features for remote concentrators. Of the switch functions listed in footnote 27, however, interconnection,  X4 x i.e., the actual connection of lines and trunks, is the characteristic that distinguishes switches from  xother central office equipment. We note that, under Part 32, the switch accounts, Accounts 2210  xthrough 2212, exist specifically for recording switches' costs, whereas the accounts for circuit  xyequipment make no mention of switching at all. If, therefore, a piece of remote equipment is  X4 x+capable of interconnecting lines or trunks, i.e., if it has the switching matrix required for call  xpinterconnection, the costs of that investment should be classified in Accounts 2210 through 2212 of our Part 32 rules.  X54 e  12.` ` Alltel and NTCA contend that some remote units only perform the switching  xfunction on an emergency basis. They argue that a remote unit must perform as a standalone  X 4 xswitch k xP' "ԍA "standalone" switch operates independently. That is, it can perform all the functions necessary to complete calls. at all times in order to be classified as a switch. We do not find this argument  xpersuasive. Virtually all remote units that contain a switching matrix routinely perform the  xinterconnection function locally and rely on the host unit for the control function, except in the  X 4 xuevent of an emergency, when the control function is also transferred to the remote.\ b k xP' "gԍBell Communications Research, Technical Reference TRTSY000532, Issue 2 at p. 1, (July 1987) "The  zP' x[remote switching unit] provides a switching network, line, and possibly trunk interfaces, and the capability to  zPg'perform call processing when isolated from the host." (emphasis added).  As  xdiscussed in the previous paragraph, remote units that interconnect lines and trunks contain the  xswitching matrix and are capable of providing all of the essential features and capabilities of a switch and should be classified as such.  XO4 e  13.` ` Even if our classification of remote units based on their ability to switch were not  xbased on function, it would be consistent with the rules. Manufacturers had, through  xtechnological innovations, developed new types of equipment that had some of the capabilities  X 4 x/of both switching and circuit equipment. The clarification contained in Revised RAO Letter 21  xwas a response to precisely this type of situation. Section 32.2(b) of the Commission's rules  xprovides that, because of the anticipated impact of future innovations, the Part 32 plant accounts  X4 x<are intended to permit technological distinctions. Thus, to the extent that Revised RAO Letter  X4 x21's use of the existence of switching capacity is a classification based on a technological distinction, it is permitted by the rules.  Xo4 e  14.` ` We also disagree with the contention that the Division deviated from the precedent  XX4 xpin RAO Letter 6 when it adopted Revised RAO Letter 21. RAO Letter 6 did not adopt the rigid"X ,W)W)QQ4"  X4 xd"actual use" standard that Staurulakis contends. RAO Letter 6 stated that "the proper  X4 xclassification in each instance must be determined "by the text of the account and the actual  X4 xusage of the equipment" (emphasis added).Ik zPO'ԍRAO Letter 6 at 2.I In the present case, the text of the rule specifically  xprovides that the cost of remote switches must be included in the switching account, but does not  X4 xdefine a remote switch.L Zk xP'ԍ47 C.F.R.  32.2212(a). L Another rule defines circuit equipment without specifically mentioning  X4 x"remote terminals.H!k xP, 'ԍ47 C.F.R.  32.2232.H In both instances, the rule creates general classifications for switching and  xcircuit equipment, but does not specifically define which remote units should be placed in each  Xc4 xRclassification. Revised RAO Letter 21 gives ILECs specific guidance about how to classify  xremote equipment within those general classifications and is consistent with both Section 32.2(b)  X74 xand 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.  X 4 e 915.` ` Finally, we disagree with those petitioners that claim that we should base our Part  x32 classifications of remote equipment on that equipment's status under NECA Tariff F.C.C. No.  x}4 or on whether that location is assigned V&H coordinates. Those classifications are generally  xassigned for billing purposes and are at least partially within the control of the ILEC. We find  x"no reason to substitute such private decisions for the classification standards that are contained in our Part 32 rules.  XS4 xn" Issue 2: Consistency of Revised RAO Letter 21 with Part 36 of the Commission's rules and  X='the Communications Act  X4 e 16.` ` Positions of the Parties: Some petitioners contend that Revised RAO Letter 21 is  x'not merely a clarification of the Commission's Part 32 accounting rules, but constitutes a  x/significant change in the Commission's Part 36 rules. Specifically, Roseville argues that ILECs  x_subject to the Part 36 rules have categorized plant in service on the basis of the predominant  xfunctionality of that equipment in each company's individual network. Roseville contends that  X4 xIthe Revised RAO Letter 21, if applied literally, would significantly alter or actually eliminate the  X4concept of functionality as reflected in Part 36 of the Commission's rules."zk zP 'ԍRoseville Application for Review at 12;  see also Staurulakis Petition at 3.  X[4 e F17.` ` Staurulakis contends that the issuance of Revised RAO Letter 21 violates Section  XF4 xA410(c) of the Communications ActG#F k xP%'ԍ47 U.S.C.  410(c).G and that not referring the issue to the Joint Board is  X/4 xlreversible error justifying recision of Revised RAO Letter 21.L$/k xP|''ԍStaurulakis Petition at 20.L In support of this contention,  X4 xStaurulakis argues that applying the definitions propounded in Revised RAO Letter 21 would,", $,W)W)QQ&"  xIunder current Part 36 rules, change the amount of costs that carriers assign to different Part 36  xcategories and consequently, the carrier's investment in the remote terminal equipment would be  X4 xseparated using different allocatorsS%k xPK' "ԍStaurulakis states that, accounting for remote equipment as switches will result in its classification under  xPart 36 as "local switching equipment" (COE Category 3) with a jurisdictional separation based on relative dial  zP' xequipment minutes of use. See 47 C.F.R.  36.125(b). Staurulakis further states that, if the same equipment is  xP!accounted for as a remote concentrator, it would be classified under Part 36 as exchange line circuit equipment with  zPm' x2 a jurisdictional separation based primarily on the subscriber plant factor (see 47 C.F.R. 36.126 (c)(3)) and would also receive an additional allocation for Universal Service Fund purposes. Staurulakis Petition at 19. S than would have been applicable before the issuance of  X4 x/Revised RAO Letter 21. NTCA notes, however, that the Joint Board has expressly refused to  X4 xconsider NTCA's request that it clarify the definitions of "host," "remote" and "concentrator."&^Dk zP ' "MԍNTCA Petition at 45, citing Amendment of Part 67 of the Commission's Rules and Establishment of a  zPe ' xJoint Board, Recommended Decision and Order, 2 FCC Rcd 2551, 2561 (Joint Board, 1987), adopted MTS and  zP/ 'WATS Market Structure, Report and Order, 2 FCC Rcd 2639 (1987).  X4 xStaurulakis also contends that Section 220(i) of the ActH'j k xP'ԍ47 U.S.C.  220(i). H requires the Commission to notify each  Xz4state commission and provide opportunity for comments and replies.M(z k xP%'ԍStaurulakis Petition at 14. M  XL4 e 18.` ` Discussion: We disagree with petitioner's contention that, simply because it has  xsought to clarify the rules and to classify equipment differently from the way some carriers  X 4 x/initially selected, the Division's action in issuing Revised RAO Letter 21 constitutes a change in  xEPart 36. The Division has not amended any of the language in Part 36 nor has it clarified or  xredefined any portion of Part 36. The fact that its action in clarifying definitions under Part 32  x/may consequently affect some ILECs' allocations of costs under Part 36 does not constitute an  xIamendment of Part 36. Costs flow through a series of processes before they are subject to the  xjurisdictional allocations process under Part 36. They are initially classified in accounts as Part  x/32 directs and then divided into regulated and nonregulated costs according to the requirements  X4of Part 64. Then, and only then, are costs separated according to the Part 36 rules.  XQ4 e 19.` ` Section 410(c) of the Act requires the Commission to refer "any proceeding  xVregarding the jurisdictional separation of common carrier property instituted pursuant to a notice  X#4 xIof proposed rulemaking."G)# k xP^!'ԍ47 U.S.C.  410(c).G There are two reasons why this statutory provision does not require  xVthe Commission to refer the proper classification of remote switches and remote terminals of a  X4 xconcentrator to a Joint Board. First, as discussed in paragraph 14, above, the issuance of Revised  X4 xRAO Letter 21 offers only a clarification of our Part 32 rules. It does not amend, interpret or  xotherwise change our Part 36 requirements. It is not, therefore, a proceeding regarding the  xjurisdictional separation of common carrier property subject to the requirements of Section 410(c)  xof the Act. Second, the fact that the Joint Board specifically considered this issue and refused  xto make a recommendation supports our conclusion that the Commission was not obligated to" ),W)W)QQ"  xrefer this issue to the Joint Board because that board has already determined that it need not rule  X4 xon the issue. Although Revised RAO Letter 21 did not interpret the Commission's Part 36 rules,  X4 xsuch interpretation is permitted under Commission precedent. In Reservation Telephone  X4 xCooperative v. AT&T, the Commission interpreted some existing Part 36 rules to require the use  xcof fiveday separations studies, rather than the sevenday separations studies that some carriers  x/had been using. For some carriers, this reduced the portion of their expense that was allocated  xto the interstate jurisdiction and affected the amount they received in settlements from AT&T.  xIn affirming the Bureau's decision, the Commission stated that it has always viewed the  XN4interpretation of existing Separations Manual provisions as a Commission function.*Nk zP ' "ԍReservation Telephone Cooperative v. AT&T, Memorandum Opinion and Order, E815, FCC 85632 at  zP ' 27 (December 5, 1985) (Reservation Telephone Cooperative v. AT&T).  X 4 e O20.` ` Section 220(i) only obligates the Commission to notify state commissions when  xythe Commission prescribes requirements relating to accounts, records or memoranda. In the  x"present case, the Commission has not prescribed any such requirements, it has merely, through  xthe Division's actions, clarified the meaning of preexisting requirements and therefore, Section 220(i) is inapplicable.  X' x Issue 3: Whether the Administrative Procedure Act requires a notice and comment  X'rulemaking  XQ4 e 21.` ` Positions of the Parties: Many of the petitioners contend that, in this instance,  X:4 x"Section 553 of the Administrative Procedure Act (APA)C+:$k xP'ԍ5 U.S.C.  553.C requires the Commission to conduct  X#4 xa notice and comment rulemaking rather than issue definitions of these terms in Revised RAO  X4 xLetter 21.D,k xPs'ԍNTCA Petition at 2.D These petitioners contend that Revised RAO Letter 21 goes beyond mere  x"explanation, interpretation, or resolution" and instead formulates substantive rule changes to  X4 x"the Uniform System of Accounts.-Dk xP' "IԍAlltel Petition at 4; Roseville Comments at 1; NTCA Petition at 1112; Staurulakis Petition at 15; OPASTCO Petition at 3 Staurulakis contends that the letter violates Section 553 of  xcthe APA because it effectively amends Sections 32.2(b) and 32.2232 of the Commission's rules  X4 xwithout the opportunity for notice and comment.}.k zP"'ԍStaurulakis Petition at 15. See also Alltel Petition at 4. pp} Further, NTCA contends that the use of  X4 xtemporary technical attributes in Revised RAO Letter 21 means that the rules will be in constant  X4 xneed of clarification or modification.E/. k xPg%'ԍNTCA Petition at 9. E Roseville, without explanation or discussion, cites cases" /,W)W)QQ"  xIin support of its contention the APA requires the Commission to conduct a notice and comment  X4rulemaking on this issue.k0^k zPb' "ԍRoseville Application for Review at 12,  citing LewisMota v. Secretary of Labor, 469 F. 2d 487 (2d Cir.  zP,' x|1972) (LewisMota);  Hou Ching Chow v. Attorney General, 362 F. Supp. 1288 (D.C. Cir. 1973) (Hou Ching  zP'Chow). k  X4 e \22.` ` Discussion: The Division found that remote equipment that was physically and  xfunctionally identical was being placed in the switching account by some ILECs and in the circuit  X4 x3equipment account by others. The Division adopted Revised RAO Letter 21 to clarify under what  xccircumstances this equipment should be placed in one preexisting category rather than another.  xSection 553(b)(A) of the APA states that notice and comment procedures are not required for  XJ4 x"interpretative rules."I1Jk xP 'ԍ5 U.S.C.  553(b)(A).I Interpretative rules are agency statements of general effect in which the  X34 xtagency announces an interpretation of a statute or of another rule.23~k zPb' "ԍJames T. O'Reilly, Administrative Rulemaking  3.08, p. 53; Yale Broadcasting Co. v. FCC, 478 F.2d 594, 599 (D.C. Cir. 1973). Interpretative rules thus serve  x an advisory function by explaining the meaning the agency attaches to a particular word or phrase  X 4 xin a statute or rule that the agency administers.i3 k xP'ԍO'Reilly, Administrative Rulemaking at  3.08. i Revised RAO Letter 21 is clearly  X 4 x"interpretative;" it does not change the language of any of the Part 32 rulesV4 h k zP 'ԍSee notes 8 and 9, supra.V but merely clarifies  xyambiguities created by the availability of this new equipment that has some characteristics of  xcircuit equipment and some characteristics of switching equipment. The interpretative definitions  X 4 xcontained in Revised RAO Letter 21 may have resulted in changes in how individual carriers  xclassify their remote equipment but do not change the rules and, therefore, Section 553 (b)(A)  xof the APA does not require the Commission to conduct a notice and comment proceeding in this  Xh4instance.  X:4 e z23.` ` In both of the cases cited by Roseville, the agency, to the detriment of the plaintiff,  X#4 xVsuspended a preexisting regulation without notice or opportunity for comment.5# k zP'ԍSee LewisMotta, 469 F.2d at 482 and Hou Ching Chow, 362 F. Supp at 1293. In both cases,  xthe courts stated that the exceptions to the publication requirement for "interpretative rules" did  xnot apply because the respective agencies had terminated rights under preexisting rules. These  X4 xcases are clearly distinguishable from Revised RAO Letter 21 in which the Bureau has not  xsuspended, altered, or amended the existing regulation. ILECs have the same rights under the  X4rules, both before and after the release of Revised RAO Letter 21. " 5,W)W)QQ"  X' Issue 4:  Whether RAO 21 was Issued Under a Proper Delegation of Authority  X4 e \24.` ` Positions of the Parties: Alltel contends that Section 0.291 of the Commission's  X4 xrulesF6k xP'ԍ47 C.F.R.  0.291.F delegated authority to the Bureau Chief, not the Division Chief, and that the Division  X4 xtherefore lacked the authority to issue Revised RAO Letter 21 on behalf of the Bureau.F7Xk xP'ԍAlltel Petition at 3.F  Xx4 xStaurulakis argues that Revised RAO Letter 21 exceeds the authority delegated to the Bureau  xChief because, he contends, the letter involves a question of policy not previously resolved by  XL4the Commission.L8Lk xP 'ԍStaurulakis Petition at 16.L  X 4 e 25.` ` Discussion: Section 0.91(a) of the Commission's rulesE9 xk xPG'ԍ47 C.F.R.  0.91.E provides that one of the  xfunctions of the Common Carrier Bureau is the "administration of Commission accounting and  X 4 xpreporting requirements."J: k xP'ԍ47 C.F.R.  0.91(a). J Section 0.291 delegates to the Bureau Chief the authority to perform  x'all of the functions listed in Section 0.91 of the Commission's rules. While Section 0.291  x8imposes specific limitations on that delegated authority, none of those limitations apply in the  X 4 xpresent case.H; k xP'ԍ47 C.F.R.  0.291. H Section 0.291 states that the Bureau Chief shall not have the authority to issue  X4 x3notices of proposed rulemaking.I<( k xPm'ԍ47 C.F.R.  0.291(g).I Revised RAO Letter 21 neither amends nor proposes to amend  xany rules. The letter simply interprets existing rules, clarifying the proper application of the rules  xWin an area where the carriers were inconsistently classifying new types of equipment.  xyAdditionally, Section 32.17 of the Commission's rules provides that the Chief of the Common  x_Carrier Bureau shall be responsible for explanation, interpretation, or resolution of significant  X#4 xIquestions about the Uniform System of Accounts that are not clearly provided for in the rules.G=# k xP 'ԍ47 C.F.R.  32.17. G  xuUnder these grants of authority, the Chief of the Common Carrier Bureau clearly has the  X4 xauthority necessary to issue interpretations of the Part 32 rules contained in Revised RAO Letter  X421.   X4 e 26.` ` Contrary to Alltel's contention, the Division Chief was acting within his authority  X4 xpwhen he issued Revised RAO Letter 21. As discussed above, the rules clearly give the Bureau  xChief the authority to issue interpretations of the Commission's accounting rules. Those rules  x/also grant a Division Chief the authority to issue such interpretations; Section 0.204(b) provides"q H =,W)W)QQ"  xthat a grant of authority to the Chief of the Common Carrier Bureau can be exercised by a  X4 x/subordinate acting on behalf of the Bureau Chief. Contrary to Alltel's contentions, the Chief of  xthe Accounting and Audits Division has acted within the authority delegated to him under the  X4 xrules 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.  Xx4 e 27.` ` Section 0.291 also states that the Chief of the Common Carrier Bureau shall not  xhave authority to act on any requests that "present novel questions of fact, law or policy which  XJ4 xIcannot be resolved under outstanding precedents and guidelines." This limitation does not apply  X34 xto Revised RAO Letter 21 because there are no novel questions involved in this matter. The  xDivision has merely issued an interpretation of the existing rules to clarify how certain equipment  xshould be classified. Additionally, the Bureau has specific authority under Section 32.17 of the  X 4Commission's rules to issue rule interpretations.N> k xPi 'ԍX47 C.F.R.  32.17.(#N  X 4 Issue 5: Whether Revised RAO Letter 21 Should Have Been Applied Prospectively  X4 e 28.` ` Positions of the Parties: Various petitioners contend that Revised RAO Letter 21  X4 xshould only apply to prospective accounting period data\?Xk xP'ԍNECA Petition at 4; OPASTCO Petition at 4; \ or should only take effect after a  Xi4 xspecified date.4@Xik xP' "_ԍNTCA Comments at 2; Roseville Comments at 7 (states that USTA, OPASTCO, Southwestern,  xStaurulakis, NTCA, NECA and Roseville request that implementation of RAO 21 be delayed until July 1, 1993) and Staurulakis Petition at 20.4 Southwestern and USTA contend that the ILECs need time to alter their  xpaccounting practices and otherwise conform to what they characterize as the new requirements  X;4 ximposed by Revised RAO Letter 21.aA;k xP'ԍUSTA Petition at 3; Southwestern Petition at 2.a Further, Southwestern claims that the carriers had no  X&4advance notice of the RAO letter.MB&k xPo'ԍSouthwestern Petition at 2. M  X4 e  29.` ` Discussion: As a general rule, declaratory rulings that interpret, but do not change,  X4 xobligations under existing Commission rules have the effective date of the rule.C( k zP!'ԍSee, e.g., Standard Oil Co. v. Doe, 596 F.2d 1029 (Emer. Ct. App. 1978). Petitioners'  X4 xarguments against retroactivity are rooted in the perception that Revised RAO Letter 21 represents  xa new policy. We disagree. The RAO letter corrects misinterpretations but does not change the  x"purpose or operation of the underlying rules. Similarly, petitioners' claims that the RAO letter's  xinterpretation was unexpected are unpersuasive. This proceeding does not involve an unforeseen  xEapplication of a rule, but rather the exact fact situation the rules are designed to address: the  xuclassification of investment costs into either the circuit or switching accounts. Because it  XB4 x/interprets, but does not change, our rules, Revised RAO Letter 21 could have had the effective"B C,W)W)QQl"  X4 xdate of the rules. In fact, the Bureau, in its discretion, made the interpretation effective for  X4 xcreports filed after the release date of the RAO letter.5DXk xPb' "ԍLetter from Kenneth P. Moran, Chief, Accounting and Audits Division, Common Carrier Bureau, FCC,  x% to William E. Stern, Vice President, Tariff Cost and Regulatory Matters, National Exchange Carrier Association (October 7, 1992). 5 The Bureau, therefore, acted within its authority.  X'%5 V. ORDERING CLAUSES Đ\  X4 e 30.` ` Accordingly, IT IS ORDERED pursuant to Sections 4(i), 4(j), and 220 of the  x Communications Act of 1934, as amended, 47 U.S.C.  154(i), 154(j), 220 and Section  xp553(b)(A) of the Administrative Procedure Act, 5 U.S.C.  553(b)(A), and Section 1.106 of the  xCommission's rules, 47 C.F.R.  1.106, that the Petitions for Reconsideration filed by Alltel,  X14NECA and Southwestern Bell against the Revised RAO Letter 21 ARE DENIED.  X 4 e 31.` ` IT IS FURTHER ORDERED, pursuant to Sections 4(i), 4(j), and 220 of the  x Communications Act of 1934, as amended, 47 U.S.C.  154(i), 154(j), 220 and Section  xp553(b)(A) of the Administrative Procedure Act, 5 U.S.C.  553(b)(A), and Section 1.106 of the  xCommission's rules, 47 C.F.R.  1.106, that the Petitions for Reconsideration and/or Clarification  X 4filed by NTCA and OPASTCO against the Revised RAO Letter 21 ARE DENIED.  X}4 e 32.` ` IT IS FURTHER ORDERED, pursuant to Sections 4(i), 4(j), and 220 of the  x Communications Act of 1934, as amended, 47 U.S.C.  154(i), 154(j), 220 and Section  xp553(b)(A) of the Administrative Procedure Act, 5 U.S.C.  553(b)(A), and Section 1.106 of the  xRCommission's rules, 47 C.F.R.  1.106, that the Petition for Limited Reconsideration filed by  X!4USTA against the Revised RAO Letter 21 IS DENIED.   X4 e  33.` ` IT IS FURTHER ORDERED, pursuant to Sections 4(i), 4(j), and 220 of the  x Communications Act of 1934, as amended, 47 U.S.C.  154(i), 154(j), 220 and Section  xp553(b)(A) of the Administrative Procedure Act, 5 U.S.C.  553(b)(A), and Section 1.115 of the  xCommission's rules, 47 C.F.R.  1.115, that the Applications for Review filed by Lexington,  X4Roseville, and Staurulakis against the Revised RAO Letter 21 ARE DENIED. "D,W)W)QQF"  X4 e !34.` ` IT IS FURTHER ORDERED, pursuant to Sections 4(i), 4(j), and 220 of the  x Communications Act of 1934, as amended, 47 U.S.C.  154(i), 154(j), 220 and Section  xp553(b)(A) of the Administrative Procedure Act, 5 U.S.C.  553(b)(A), and Section 1.106 of the  xCommission's rules, 47 C.F.R.  1.106, that the letters filed by Pond Branch and Shenandoah  X4against the Revised RAO Letter 21 ARE DENIED. ` ` hhCFEDERAL COMMUNICATIONS COMMISSION  X 4 ` ` hhCWilliam F. Caton XX` ` X XXhhCActing Secretary(#h ` ` hhC " D,W)W)QQ " ` ` hhC dAppendix A MList of Commenters Applications for Review or Petitions for Reconsideration  Xv4Alltel Service Corporation` XhhCXqXppAlltel(#  X_4Lexington Telephone CompanyhhCqppLexington  XH4National Exchange Carrier AssociationqppNECA  X14National Telephone Cooperative AssociationhppNTCA(# Organization for the Advancement and Preservation  X 4 of Small Telephone CompanieshhCqppOPASTCO  X 4Roseville Telephone CompanyhhCqppRoseville  X 4Southwestern Bell Telephone CompanyqppSouthwestern  X 4John Staurulakis, Inc.hhCqppStaurulakis  X 4United States Telephone AssociationqppUSTA Letters  X44Pond Branch Telephone Company hhCXqXXppXPond Branch(#  X4Shenandoah Telephone Company hhCXqXXppXShenandoah(# Comments  X4National Telephone Cooperative AssociationppNTCA  X4Reed, Veach, Wunderman and Assoc., Inc.qhppReed Veach(#  X|4Roseville Telephone CompanyhhCqppRoseville  Xe4Union Telephone CompanyhhCqppUnion  XN4United Telephone Company (Sprint)qppUnited  X74Shenandoah Telephone CompanyhhCqppShenandoah Replies  X 4GTE Service CorporationhhCqppGTE  X!4National Telephone Cooperative AssociationppNTCA  X"4National Exchange Carrier AssociationqppNECA  X#4John Staurulakis, Inc.hhCqppStaurulakis