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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 ) ) CC Docket No. 98-104 1998 Annual Access ) Tariff Filings ) ) Southwestern Bell Telephone Company ) Transmittal No. 2715 Revisions to Tariff F.C.C. No. 73 ) MEMORANDUM OPINION AND ORDER, ORDER DESIGNATING ISSUES FOR INVESTIGATION, AND ORDER ON RECONSIDERATION Adopted: July 29, 1998 Released: July 29, 1998 Direct Case Date: August 29, 1998 Oppositions/Comment Date: September 15, 1998 Rebuttal Date:September 23, 1998 By the Deputy Chief, Common Carrier Bureau: I. INTRODUCTION 1. On June 29, 1998, we released the 1998 Annual Access Suspension Order, which, inter alia, suspended for one day the 1998 annual access tariff filings filed by incumbent local exchange carriers (LECs), imposed an accounting order, and initiated an investigation into the lawfulness of a number of issues raised by these tariff filings. We concluded that the tariffs filed by all the price cap LECs raised significant questions of lawfulness that warranted investigation. We also concluded that provisions in the annual access tariffs filed by several rate of return carriers raised questions of lawfulness that warranted investigation. 2. In this Order, we suspend SWBT's Transmittal No. 2715, filed July 29, 1998, for one day and make it subject to this investigation. We also designate for investigation whether SNET has filed non-primary line counts that are reasonable, and whether Nevada Bell and SWBT properly adjusted their tariff filings to incorporate their amended non-primary line counts. Furthermore, we discuss the manner in which price cap LECs have transitioned to the three-part tandem switched rate structure. In addition, on our own motion, we reconsider our decision to investigate the tariff revisions filed by Aliant, Ameritech, Bell Atlantic-North, Bell Atlantic-South, BellSouth, CBT, Citizens, Frontier, GTOC, GSTC, Pacific Bell, Sprint LTCs, and U S West. Furthermore, we reconsider on our own motion our decision to suspend and investigate the parts of SNET's tariff filings not related to common line rates, and Nevada Bell's and SNET's tariff filings not related to the carrier common line charge. Finally, we reconsider on our own motion our decision to suspend and investigate the tariff revisions filed by Sugar Land Telephone Company, Century Telephone Company of Ohio, ALLTEL of Missouri, and ALLTEL of Georgia. II. SUSPENSION OF SWBT TRANSMITTAL NO. 2715 3. We find that SWBT Transmittal No. 2715 raises issues that were set for investigation in the 1998 Annual Access Suspension Order. Therefore, we suspend this transmittal for one day and make it subject to the investigation initiated in the 1998 Annual Access Suspension Order. III. NON-PRIMARY RESIDENTIAL LINE COUNTS A. Background 4. Before January 1, 1998, the access charge rules allowed price cap LECs to recover their permitted common line revenues through a combination of a flat-rated Subscriber Line Charge (SLC) and a per-minute carrier common line (CCL) charge. Permitted common line revenues not recovered in the SLC were recovered through the CCL charge assessed on the interexchange carriers (IXCs). 5. The Access Charge Reform Order modified common line revenue recovery. As of January 1, 1998, common line revenues are recovered through: (1) a SLC assessed on end-users; (2) a flat, per- line charge assessed on the IXC to whom the access line is presubscribed, referred to as the presubscribed interexchange carrier charge (PICC); and (3) a per minute CCL charge assessed on IXCs. The PICC recovers common line revenues that exceed the SLC ceiling, subject to a ceiling of its own. The per-minute CCL charge will be phased out as SLC and PICC ceilings increase and eliminated when all permitted common line revenues can be recovered through flat-rated charges. 6. The Access Charge Reform Order also set the SLC cap for non-primary residential lines at the lesser of the per-line average common line costs allocated to the interstate jurisdiction and $5.00. The PICC was capped for the first year, beginning January 1, 1998, at $1.50 per month for non- primary residential (NPR) lines and $0.53 per month for primary residential lines. 7. The price cap LECs implemented the changes required by the Access Charge Reform Order with mid-year access reform tariff filings that became effective January 1, 1998. In the Access Charge Reform Tariffs Designation Order, the Bureau designated for investigation the line counts for primary and non-primary residential lines reported by all price cap LECs. It observed that the non-primary line counts were lower than various published estimates and lower than price cap LEC public statements. It therefore required those LECs to identify the number of lines in each of the following categories: (1) primary residential lines; (2) single-line business lines; (3) non-primary residential lines; and (4) Basic Rate Interface - Integrated Services Digital Network (BRI-ISDN) lines. 8. In the Access Charge Reform Tariffs Investigation Order, the Commission calculated the percentage of non-primary residential lines to total residential lines reported by the price cap LECs and compared those percentages with data collected by the Commission staff, with independent studies, and with price cap LECs' public statements. Where the Commission found the percentage reported by a price cap LEC to be unreasonably low, it used those data to prescribe a higher count. 9. In the 1998 annual price cap access tariff filings, a number of LECs reported substantial increases in non-primary residential line penetration ratios. These LECs include Aliant, Ameritech, Bell Atlantic-South, BellSouth, CBT, and Nevada Bell. Based on their annual access tariff filings, the following non-primary residential line penetration ratios were calculated for price cap LECs: Aliant, 5.26%; Ameritech, 12.67%; Bell Atlantic-South, 11.90%; BellSouth, 10.94%; CBT, 7.31%; Citizens, 2.19%; Frontier, 3.47%; GTE, 6.16%; Nevada Bell, 8.56%; Bell Atlantic-North, 7.00%; Pacific Bell, 15.71%; SNET, 6.88%; SWBT, 8.67%; Sprint LTCs, 6.22%; and U S West, 11.09%. B. Petitions 10. AT&T and MCI sought to suspend and investigate the tariff filings of some of these LECs because those LECs' line counts either declined from earlier filings or, in petitioners' view, did not increase sufficiently from previous filings. AT&T contends that because the SLC and PICC ceilings are higher for a non-primary residential line than for a primary residential or a single-line business (SLB) line, end users will be undercharged -- and access customers will be overcharged -- if a line is classified improperly as a primary line instead of as a non-primary line. For this reason, AT&T challenges as "lenient" what it claims is the Commission's requirement that LECs need only increase their non-primary line counts to bring them to a level equal to 70% of the Commission's Additional Line Study numbers. AT&T urges the Commission to be less lenient because that study relies on 1995 data and, as the Commission has already acknowledged, non-primary line demand is growing faster than primary line demand. AT&T specifically objects that certain LECs did not have faster non-primary line growth. 11. AT&T argues that certain LECs have ignored the Commission's attempts in the Access Charge Reform Tariffs Investigation Order to bring non-primary end user common line (EUCL) demands to reasonable levels and that the reported levels are in direct conflict with the Commission's cost causation principles. Accordingly, AT&T asks the Commission to order LECs to meet non- primary residential line count levels that represent at least 100% of an updated 1997 Additional Line Penetration EUCL estimate based upon the methodology in the Access Charge Reform Tariffs Investigation Order. C. Responses 12. Several price cap LECs refiled their tariffs, increasing their non-primary residential line penetration ratios. Frontier now reports line demand for primary residential and single-line business lines and non-primary residential and BRI-ISDN lines which results in an non-primary line penetration ratio of 10% for each of their tariff entities. SWBT and Nevada Bell have also revised their tariffs to indicate higher non-primary line penetration ratios, to 12.04% for Southwestern Bell and 16.54% for Nevada Bell. Based on these filings, over half of all price cap LECs now report non-primary residential line penetration rates of 10% or more. 13. Further, Bell Atlantic-North, Bell Atlantic-South, GTE, Sprint LTCs, CBT, Aliant, and Citizens have replaced their non-primary residential line definitions with definitions based on service address or "location," effective January 1, 1999. These carriers indicate that this change will substantially increase their non-primary line penetration rates from the rates reported in their 1998 annual filings. As a result of its definition modification, Bell Atlantic estimates non-primary line penetration ratios will increase to 17% for Bell Atlantic-South and 14% for Bell Atlantic-North. GTE expects its non-primary residential line penetration ratio will increase to 9%. Sprint has determined that it will be able to establish a non-primary line penetration ratio of at least 10% as a result of switching to the new definition. Cincinnati Bell indicates that they expect to identify line counts using their new definition that will lead to a second line penetration ratio of 9.4%. Aliant believes its non- primary residential penetration ratio will increase to 7%. Citizens maintains that by modifying the way in which they classify non-primary residential lines from primary lines, they will be able to more than double their second line penetration rate to a level of 5.5%. SNET made no additional filings. D. Discussion 14. Certain price cap LECs have argued that by meeting the threshold used in the Access Charge Reform Tariffs Investigation Order of 70% of the Additional Line Study figures, they have met the Commission's expectation of non-primary line penetration. This belief is erroneous. As explained in the Access Charge Reform Tariffs Investigation Order, those conservative figures, based on 1995 data, were used only for purposes of assessing the reasonableness of LEC 1996 demand data reported in the mid-year tariff filings and in prescribing minimum non-primary line counts for two carriers whose line counts were found unreasonable. The Commission's findings and prescribed minimum line counts did not establish a new rule or "safe harbor" for non-primary line counts in future access tariff filings. Rather, carriers must in each filing determine common line rates in accordance with Parts 61 and 69, i.e., using projected base period demand. In addition, the annual tariff filings being investigated here represent 1997 line count demand. Given the evidence presented in the Access Charge Reform Tariffs Investigation Order and that presented by the petitioners regarding growth in second lines, we would expect non-primary residential line counts for 1997 to be significantly higher than the Additional Line Study benchmark used in the previous investigation. 15. Based on the above, we note that SNET continues to report levels of non-primary residential line penetration rates much lower than expected. We therefore designate for investigation the common line rates of SNET. We seek comment in this investigation on the tentative conclusion that SNET has under-represented the number of non-primary residential lines for the purpose of assessing SLCs and PICCs and calculating the CCL. 16. As an initial test of reasonableness, we note that SNET (6.88%) falls far below the simple weighted average of non-primary line penetration levels for all the price cap LECs (including SNET) of 10.39% as of July 1, 1998 and an estimated 12.42% as of January 1, 1999. We also note that SNET serves urban areas (Connecticut) which should correlate with a higher percentage of second lines. 17. We direct SNET to delineate the manner in which their line count estimates were made. This includes identifying the type of data used (e.g., billing records), the exact time frame for which the data was collected (e.g., November and December, 1997), the counting procedure or estimation technique used (e.g., sampling from two study areas), and sorting criteria (e.g., by account, by service address, by last name) used to arrive at the demand figures submitted in their annual tariff filings. We require SNET to separate the data by the number of lines in each of these categories: (1) primary residential lines; (2) single line business lines; (3) non-primary residential lines; and (4) BRI-ISDN lines. 18. In addition, we direct SNET to submit copies, tapes, transcripts or representations of any public documents or public comments made by it or on its behalf regarding the actual or potential amount, growth, marketing of, penetration ratio, or billing procedures used to determine the numbers of primary residential and single line business lines and non-primary residential and BRI-ISDN lines. 19. Further, we direct that SNET support with pertinent and verifiable evidence any arguments it offers to justify their relatively low percentage ratios of non-primary residential and BRI- ISDN lines to the total of primary residential, single-line business, non-primary residential and BRI- ISDN lines. This direction applies to any information that may be offered to explain specific difficulties they may have in identifying the distinction between primary and non-primary residential lines and charging appropriate access fees upon which they are based. Such information may include, but is not limited to, particular geographic and demographic variables such as household population statistics, per capita number of residential lines per service area compared with that of the state (if not the same), studies on demand growth or population changes, state utility commission requirements, and company specific evidence on billing systems or inventory control. 20. In refiling their annual tariff submissions SWBT, Nevada Bell, and Frontier raised their non-primary line penetration ratios, and reclassified some residential lines from primary to non- primary. Reclassification of these lines should result in the recovery of more revenues through SLCs and PICCs and less through the CCL, but should not change total common line revenues for the 1998 tariff year. To ensure that the maximum allowable common line revenues remains unchanged, the relevant rate inputs must be recalculated using a weighted average of the increased non-primary lines and decreased primary lines. If this is done correctly, CCL revenues should fall because LECs now collect a portion of this revenue through flat rated charges assessed on the higher number of non- primary lines. Frontier used this weighted average technique in their submission and lowered their CCL rates substantially. SWBT and Nevada Bell did not follow this procedure and increased their maximum permitted common line revenues as a result of the residential line reclassification. We therefore designate for investigation the common line rates of SWBT and Nevada Bell. We seek comment in this investigation on the tentative conclusion that SWBT and Nevada Bell have failed to properly adjust their revenue inputs due to a change in their primary and non-primary residential line counts. IV. TRANSITION TO THE THREE-PART TANDEM SWITCHED TRANSPORT RATE STRUCTURE A. Background 21. In the Access Charge Reform Order, the Commission required price cap LECs to offer a three part rate structure for the transmission component of tandem-switched transport, effective July 1, 1998. Incumbent LECs are required to provide tandem-switched transport under a three-part rate structure as follows: (1) a per-minute charge for transport of traffic over common transport facilities between the LEC end office and the tandem office; (2) a per-minute tandem switching charge; and (3) a flat-rated charge for transport of traffic over dedicated transport facilities between the serving wire center and the tandem switching office. The price cap LECs must calculate the revenue impact of the restructuring and adjust other rates in the trunking basket, targeting the transport interconnection charge (TIC) first, to achieve revenue neutrality. B. Pleadings 22. In their comments on the price cap LEC annual access filings, AT&T and MCI claim that the revenue impact of the three part rate structure should not be based on projected transport demand. ACTA argues that LEC estimates of tandem switched transport demand are unreasonable. 23. Bell Atlantic, BellSouth, NYNEX, SBC, SNET and Sprint appear to use actual 1997 base year demand to calculate the revenue impact of the three part rate structure. GTE and U S West appear to use actual demand as of a more recent date in calendar year 1998. Ameritech forecasts demand by projecting IXC optimal network circuit reconfigurations that it claims will take place under the new rate structure. C. Discussion 24. The price cap LECs employed different methodologies to calculate the revenue impact of the three part rate structure. Whether projecting or recasting demand for tandem switched transport services, each LEC has, in effect, attempted to estimate the demand and revenue impacts of the three part rate structure. We do not designate this issue for investigation. However, we intend to monitor the permitted revenues of the trunking basket for each of these LECs. If, by the next annual tariff filing, we find that actual demand has differed significantly from estimated demand we will perform further analysis to determine if this has resulted in unreasonable rates in the trunking basket. V. RECONSIDERATION OF DECISION TO SUSPEND AND INVESTIGATE PRICE CAP LEC TARIFF FILINGS A. Background 25. On June 29, 1998, the Common Carrier Bureau found that the issues raised by AT&T and MCI in their petitions and the issues identified by the Bureau in the tariff revisions filed by the price cap LECs raised substantial questions of lawfulness that warranted investigation of these tariffs. Accordingly, the Bureau suspended the tariff revisions filed by Aliant, Ameritech, Bell Atlantic-North, Bell Atlantic-South, BellSouth, CBT, Citizens, Frontier, GSTC, GTOC, Nevada Bell, Pacific Bell, SNET, SWBT, Sprint LTCs, and U S West, and set them for investigation. B. Discussion 26. Pursuant to Sections 1.108 and 0.291 of the Commission's rules, we reconsider on our own motion our decision to suspend and investigate the annual access tariff filings of Aliant, Ameritech, Bell Atlantic-North, Bell Atlantic-South, BellSouth, CBT, Citizens, Frontier, GSTC, GTOC, Pacific Bell, Sprint LTCs, and U S West. These LECs have explained to our satisfaction the issues raised in the 1998 Annual Access Suspension Order about their tariffs or have revised their tariffs to our satisfaction. Accordingly, we decline to investigate Aliant, Transmittal Nos. 17 and 19; Ameritech, Transmittal Nos. 1160, 1163, 1166, and 1167; Bell Atlantic-North, Transmittal Nos. 505, 507, 508, 513, 1179, and 1180; Bell Atlantic-South, Transmittal Nos. 1057, 1059, and 1065; BellSouth, Transmittal Nos. 465, 467, and 470; CBT, Transmittal Nos. 722 and 725; Citizens, Transmittal Nos. 49, 51, and 52; Frontier, Transmittal Nos. 7, 9, 15, and 17; GSTC, Transmittal Nos. 247, 248, 254, and 255; GTOC, Transmittal Nos. 1155, 1156, 1165, and 1167; Pacific Bell, Transmittal Nos. 1988, 1990, 1991, and 1997; Sprint LTCs, Transmittal Nos. 57, 58, and 61; and U S West, Transmittal Nos. 926, 927, 928 and 935. 27. In addition, we reconsider on our own motion our decision to suspend and investigate the parts of SNET's tariff filings not related to common line rates, and the parts of Nevada Bell's and SWBT's tariff filings not related to the carrier common line charge. As noted above, we are only investigating SNET's non-primary line penetration ratios, and these figures only affect common line rates. Similarly, we are only investigating whether Nevada Bell and SWBT properly adjusted their tariff filings to incorporate their amended non-primary line counts, and this only affects their CCL charges. Accordingly, we remove from suspension the other parts of SNET's Transmittal Nos. 712 and 714, Nevada Bell's Transmittal Nos. 241, 242, 245, and 248, and SWBT's Transmittal Nos. 2705, 2707, 2708, and 2715. VI. RECONSIDERATION OF DECISION TO SUSPEND AND INVESTIGATE RATE-OF-RETURN LEC TARIFF FILINGS A. Background 28. In its petition, AT&T argued that Sugar Land Telephone Company, Century Telephone Company of Ohio, ALLTEL of Missouri, and ALLTEL of Georgia understated their demand level for Local Switching, Transportation Interconnection Charge (TIC), and Information Surcharge, for the period January 1, 1995 through December 31, 1996. AT&T applied a regression model analysis that indicated a higher demand level forecast was appropriate. By AT&T's calculation, the LECs' demand forecasts will result in proposed rates $20,004,830 higher than appropriate. 29. In the 1998 Annual Access Suspension Order, the Commission found that AT&T's petition raised substantial questions of lawfulness regarding the rate-of-return LECs' forecasted test- period demands. We suspended and initiated an investigation of the tariffs filed by Century Telephone Company of Ohio, Transmittal Nos. 2 and 3; and Sugar Land Telephone Company, ALLTEL of Missouri and ALLTEL of Georgia, Transmittal No. 61. B. Discussion 30. Pursuant to Sections 1.108 and 0.291 of the Commission's rules, we reconsider on our motion our decision to suspend and investigate the tariffs of Sugar Land Telephone Company, Century Telephone Company of Ohio, ALLTEL of Missouri, and ALLTEL of Georgia. After further review of the rate of return LECs' tariffs, we conclude that their statistical methodology was reasonable and that they adhered to the Commission's rules in constructing demand. Accordingly, we decline to investigate Century Telephone Company of Ohio, Transmittal Nos. 2 and 3; and Sugar Land Telephone Company, ALLTEL of Missouri and ALLTEL of Georgia, Transmittal No. 61. VII. PROCEDURAL MATTERS A. Filing Schedules 31. This investigation will be conducted as a notice and comment proceeding. We have designated CC Docket No. 98-104. The following companies are the parties designated to this investigation: SNET, Nevada Bell, and SWBT. 32. These parties shall file their direct cases no later than August 29, 1998. The direct cases must present the parties' positions with respect to the issues described in this Order. Pleadings responding to the direct cases may be filed no later than September 15, 1998, and must be captioned "Oppositions to Direct Case" or "Comments on Direct Case." The companies may each file a "Rebuttal" to oppositions or comments no later than September 23, 1998. 33. An original and six copies of all pleadings shall be filed with the Secretary of the Commission. In addition, parties shall file two copies of any such pleadings with the Competitive Pricing Division, Common Carrier Bureau, Room 518, 1919 M Street, N.W., Washington, D.C. 20554. Parties shall also deliver one copy of such pleadings to the Commission's commercial copying firm, International Transcription Service, Inc., 1231 20th Street, NW, Washington, DC 20036. Members of the general public who wish to express their views in an informal manner regarding the issues in this investigation may do so by submitting one copy of their comments to the Office of the Secretary, Federal Communications Commission, 1919 M Street, N.W., Room 222, Washington, D.C. 20554. Such comments should specify the docket number of this investigation. Parties are also encouraged to submit their pleadings electronically through the Electronic Tariff Filing System. 34. All relevant and timely pleadings will be considered by the Commission. In reaching a decision, the Commission may take into account information and ideas not contained in pleadings, provided that such information or a writing containing the nature and source of such information is placed in the public file, and provided that the fact of reliance on such information is noted in the order. B. Ex Parte Requirements 35. This tariff investigation is a "permit-but-disclose proceeding" and subject to the "permit-but-disclose" requirements under Section 1.1206(b) of the rules, 47 C.F.R.  1.1206(b), as revised. Persons making oral ex parte presentations are reminded that memoranda summarizing the presentation must contain a summary of the substance of the presentation and not merely a listing of the subjects discussed. More than a one or two sentence description of the views and arguments presented is generally required. Other rules pertaining to oral and written presentations are set forth in Section 1.1206 (b), as well. VIII. ORDERING CLAUSES 36. ACCORDINGLY, IT IS ORDERED that, pursuant to Section 204 (a) of the Communications Act of 1934, as amended, 47 U.S.C.  204 (a) and through the authority delegated pursuant to Sections 0.91 and 0.291 of the Commission's rules. 47 C.F.R.  0.91 and 0.291, the tariff revisions filed by Southwestern Bell Telephone Company, Transmittal No. 2715, ARE SUSPENDED for one day and an investigation IS INSTITUTED. 37. IT IS FURTHER ORDERED that, pursuant to Sections 204(a) and 4(i) of the Communications Act of 1934, as amended, 47 U.S.C.  204(a), 154(i), and through the authority delegated pursuant to Sections 0.91 and 0.291 of the Commission's rules, 47 C.F.R.  0.91 and 0.291, Southwestern Bell Telephone Company, SHALL KEEP ACCURATE ACCOUNT of all amounts received that are associated with the rates that are subject to this investigation. 38. IT IS FURTHER ORDERED that, pursuant to Sections 4(i), 4(j), 201(b), 203(c), 204(a), 205, and 403 of the Communications Act, 47 U.S.C.  154(i), 154(j), 201(b), 203(c), 204(a), 205, and 403, and Sections 0.91 and 0.291 of the Commission's rules, 47 C.F.R.  0.91, 0.291, the issues set forth in this Order ARE DESIGNATED FOR INVESTIGATION. 39. IT IS FURTHER ORDERED that Nevada Bell, SNET, and SWBT SHALL BE parties to this proceeding. 40. IT IS FURTHER ORDERED that each local exchange carrier that is a party to this proceeding SHALL INCLUDE, in its direct case, a response to each request for information that it is required to answer in this Order. 41. IT IS FURTHER ORDERED that pursuant to Sections 0.91, 0.291 and 1.108 of the Commission's rules, 47 C.F.R.  0.91, 0.291, 1.108, we reconsider on our motion our decision in the 1998 Annual Access Suspension Order to suspend and investigate the tariff filings of Aliant, Transmittal Nos. 17 and 19; Ameritech, Transmittal Nos. 1160, 1163, 1166, and 1167; Bell Atlantic- North, Transmittal Nos. 505, 507, 508, 513, 1179, and 1180; Bell Atlantic-South, Transmittal Nos. 1057, 1059, and 1065; BellSouth, Transmittal Nos. 465, 467, and 470; CBT, Transmittal Nos. 722 and 725; Citizens, Transmittal Nos. 49, 51, and 52; Frontier, Transmittal Nos. 7, 9, 15, and 17; GSTC, Transmittal Nos. 247, 248, 254, and 255; GTOC, Transmittal Nos. 1155, 1156, 1165, and 1167; Pacific Bell, Transmittal Nos. 1988, 1990, 1991, and 1997; Sprint LTCs, Transmittal Nos. 57, 58, and 61; and U S West, Transmittal Nos. 926, 927, 928 and 935. 42. IT IS FURTHER ORDERED that pursuant to Sections 0.91, 0.291 and 1.108 of the Commission's rules, 47 C.F.R.  0.91, 0.291, 1.108, we reconsider on our motion, to the extent indicated in paragraph 27 above, our decision in the 1998 Annual Access Suspension Order to suspend and investigate the tariff filings of Nevada Bell, Transmittal Nos. 241, 242, 245, and 248; SNET, Transmittal Nos. 712 and 714; and SWBT, Transmittal Nos. 2705, 2707, 2708, and 2715. 43. IT IS FURTHER ORDERED that pursuant to Sections 0.91, 0.291 and 1.108 of the Commission's rules, 47 C.F.R.  0.91, 0.291, 1.108, we reconsider on our motion our decision in the 1998 Annual Access Suspension Order to suspend and investigate the tariff filings of Century Telephone Company of Ohio, Transmittal Nos. 2 and 3; and Sugar Land Telephone Company, ALLTEL of Missouri and ALLTEL of Georgia, Transmittal No. 61. FEDERAL COMMUNICATIONS COMMISSION James D. Schlichting Deputy Chief, Common Carrier Bureau APPENDIX Filings made by Local Exchange Carriers April 2, 1998 Aliant Communications Company Tariff Review Plan Ameritech Operating Companies Tariff Review Plan Bell Atlantic Operating Companies Tariff Review Plan BellSouth Telecommunications, Inc. Tariff Review Plan Cincinnati Bell Telephone Company Tariff Review Plan Citizens Telecommunications Companies Tariff Review Plan Frontier Communications of Minnesota and Iowa Tariff Review Plan Frontier Communications of Rochester Tariff Review Plan GTE System Telephone Companies Tariff Review Plan GTE Telephone Operating Companies Tariff Review Plan Nevada Bell Tariff Review Plan New York Telephone Company Tariff Review Plan NYNEX Telephone Companies Tariff Review Plan Pacific Bell Tariff Review Plan Southern New England Telephone Tariff Review Plan Southwestern Bell Telephone Company Tariff Review Plan U S West Communications, Inc. Tariff Review Plan June 16, 1998 Aliant Communications Company Transmittal No. 17 Alltel Telephone Services Corporation Transmittal No. 61 Ameritech Operating Companies Transmittal No. 1160 Bell Atlantic Operating Companies Transmittal No. 1057 BellSouth Telecommunications, Inc. Transmittal No. 465 CenturyTel Operating Companies Transmittal No. 2 Chillicothe Telephone Company Transmittal No. 61 Cincinnati Bell Telephone Company Transmittal No. 722 Citizens Telecommunications Companies Transmittal No. 49 Dunkirk and Fredonia Telephone Company Transmittal No. 25 Frontier Communications of Minnesota and Iowa Transmittal No. 15 Frontier Communications of Rochester Transmittal No. 7 GTE System Telephone Companies Transmittal No. 247 GTE Telephone Operating Companies Transmittal No. 1155 ICORE Transmittal No. 14 Illinois Consolidated Telephone Company Transmittal No. 101 John Staurulakis, Inc. (JSI) Transmittal No. 31 Lufkin-Conroe Telephone Exchange, Inc. Transmittal No. 39 Minnesota Independent Equal Access Corporation Transmittal No. 11 National Exchange Carrier Association Transmittal No. 800 Nevada Bell Transmittal No. 241 New York Telephone Company Transmittal No. 1179 NYNEX Telephone Companies Transmittal No. 505 Pacific Bell Transmittal No. 1988 Puerto Rico Telephone Company Transmittal No. 30 Roseville Telephone Company Transmittal No. 57 South Dakota Network, Inc. Transmittal No. 7 Southern New England Telephone Transmittal No. 712 Southwestern Bell Telephone Company Transmittal No. 2705 Telephone Utilities Exchange Carrier Association Transmittal No. 153 U S West Communications, Inc. Transmittal No. 926 Utelco, Inc. Transmittal No. 6 Virgin Islands Telephone Corporation Transmittal No. 37 Winterhaven Telephone Company Transmittal No. 5 Wood County Telephone Company Transmittal No. 28 Note: Iowa Network Services filed a letter stating that it had made all calculations and no rate changes were necessary. June 19, 1998 Southwestern Bell Telephone Company Transmittal No. 2707 Sprint Local Telephone Companies Transmittal No. 57 U S West Communications, Inc. Transmittal No. 927 June 22, 1998 GTE System Telephone Companies Transmittal No. 248 GTE Telephone Operating Companies Transmittal No. 1156 June 23, 1998 New York Telephone Company Transmittal No. 1180 NYNEX Telephone Companies Transmittal No. 507 June 24, 1998 Anchorage Telephone Utility Transmittal No. 97 June 25, 1998 Ameritech Operating Companies Transmittal No. 1163 June 26, 1998 Alltel Telephone Services Corporation Transmittal No. 61 Ameritech Operating Companies Transmittal No. 1160 Anchorage Telephone Utility Transmittal No. 97 Bell Atlantic Operating Companies Transmittal No. 1057 BellSouth Telecommunications, Inc. Transmittal No. 465 CenturyTel Operating Companies Transmittal No. 3 Chillicothe Telephone CompanyTransmittal No. 61 Cincinnati Bell Telephone Company Transmittal No. 722 Frontier Communications of Minnesota and Iowa Transmittal No. 15 Frontier Communications of Rochester Transmittal No. 7 GTE System Telephone Companies Transmittal Nos. 247, 248 GTE Telephone Operating Companies Transmittal Nos. 1155, 1156 Illinois Consolidated Telephone Company Transmittal No. 101 Lufkin-Conroe Telephone Exchange, Inc. Transmittal No. 39 NYNEX Telephone Companies Transmittal Nos. 505, 507 Pacific Bell Transmittal No. 1986 Puerto Rico Telephone CompanyTransmittal No. 30 Roseville Telephone Company Transmittal No. 57 Southern New England Telephone Transmittal No. 712 Southwestern Bell Telephone Company Transmittal No. 2705 Sprint Local Telephone Companies Transmittal No. 58 U S West Communications, Inc. Transmittal No. 926 Virgin Islands Telephone Corp. Transmittal No. 37 June 29, 1998 Bell Atlantic Operating Companies Transmittal No. 1059 BellSouth Telecommunications, Inc. Transmittal No. 467 CenturyTel Operating Companies Transmittal No. 3 NYNEX Telephone Companies Transmittal No. 508 Pacific Bell Transmittal No. 1990 Roseville Telephone Company Transmittal No. 58 Sprint Local Telephone Companies Transmittal No. 58 U S West Communications, Inc. Transmittal No. 928 June 30, 1998 Nevada Bell Transmittal No. 242 Pacific Bell Transmittal No. 1991 Southwestern Bell Telephone CompanyTransmittal No. 2708 July 10, 1998 Ameritech Operating CompaniesTransmittal No. 1166 July 14, 1998 Nevada Bell Transmittal No. 245 July 23, 1998 Ameritech Operating Companies Transmittal No. 1167 Bell Atlantic Operating Companies Transmittal No. 1065 NYNEX Telephone Companies Transmittal No. 513 July 24, 1998 BellSouth Telecommunications, Inc. Transmittal No. 470 Cincinnati Bell Telephone Company Transmittal No. 725 Citizens Telecommunications Companies Transmittal No. 51 Frontier Communications of Minnesota and Iowa Transmittal No. 17 Frontier Communications of Rochester Transmittal No. 9 GTE System Telephone Companies Transmittal No. 254 GTE Telephone Operating Companies Transmittal No. 1165 Nevada Bell Transmittal No. 248 Southern New England Telephone Transmittal No. 714 July 28, 1998 Aliant Communications Company Transmittal No. 19 Citizens Telecommunications Companies Transmittal No. 52 GTE System Telephone Companies Transmittal No. 255 GTE Telephone Operating Companies Transmittal No. 1167 Pacific Bell Transmittal No. 1997 Sprint Local Telephone Companies Transmittal No. 61 U S West Communications, Inc. Transmittal No. 935 July 29, 1998 Southwestern Bell Telephone Company Transmittal No. 2715 Petitions and Comments The following parties filed petitions and comments against the June 16, 1998 Tariff Filings. ACTA April 23, 1998 Comments AT&T Corp. April 23, 1998 Comments June 23, 1998 Petition June 24, 1998 Amended Petition June 26, 1998 Petition on Anchorage Telephone Utility General Communication, Inc. June 29, 1998 Petition on Anchorage Telephone Utility MCI Telecommunications Coporation April 23, 1998 Comments June 23, 1998 Petition Replies ALLTEL Communications Service Corporation June 26, 1998 Reply Ameritech Operating Companies June 26, 1998 Reply Anchorage Telephone Utility June 29, 1998 Reply Bell Atlantic Operating Companies June 26, 1998 Reply BellSouth Telecommunications June 26, 1998 Reply CenturyTel Operating Companies June 26, 1998 Reply Chillicothe Telephone Company June 26, 1998 Reply Cincinatti Bell Telephone Company June 26, 1998 Reply Frontier Telephone Companies June 26, 1998 Reply GTE Telephone Operating Companies and GTE Systems Telephone Companies June 26, 1998 Reply Illinois Consolidated Telephone Company June 26, 1998 Reply Lufkin-Conroe Telephone Exchange, Inc. June 26, 1998 Reply Pacific Bell June 26, 1998 Reply Puerto Rico Telephone Company June 26, 1998 Reply Roseville Telephone Company June 26, 1998 Reply Southern New England Telephone Company June 26, 1998 Reply Southwestern Bell Telephone Company, Pacific Bell and Nevada Bell June 26, 1998 Reply Sprint Local Telephone Companies June 26, 1998 Reply U S West Communications, Inc. June 26, 1998 Reply Virgin Islands Telephone Corp. June 26, 1998 Reply