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I noted that state utility commissions frequently require and private auditors are regularly hired to examine a LEC's financial records. I pointed out that such comprehensive property records were only remnants of rate of return regulation, and encouraged the Commission to become more aggressive in eliminating these rate of return type regulatory backstops. Instead, I hoped and urged the Commission to focus its efforts on developing a more forward-looking blueprint to guide the transition from pricecap regulation to even more streamlined regulation for particular geographic or service markets in which competition occurs. sUnfortunately, little progress has been made in the past year. As demonstrated by the release of today's reports, my urgings have been for not. This Commission seems intent on remaining mired in regulatory details such as whether or not a piece of equipment that is found in the central office but is placed on the wrong shelf or in an incorrect bin violates our "regulations" unwilling to let go of the regulatory stranglehold that the 1996 Telecommunications Act was supposed to eliminate. How much has this focus of Commission resources cost the American public? The Common Carrier Bureau estimates that  XN4at least 4800 hours more than 2 manyears were spent on each of the seven Audits. That is at least 33,600 Commission hours not spent on other issues such as Section 251 enforcement, or completing its work on universal service for small rural carriers, or fulfilling its statutory mandate to review all of its regulations pursuant to Section 11, or approving the transfer of broadcast licenses that otherwise meet the Commission's written rules in a timely manner. sIndeed, today's audits are unprecedented in Commission history; the interpretations of our rules to require that locations be specified down to the shelf level are novel. Even during rate"" 0*((!" of return regulation, the Commission never found it necessary to perform the type of sweeping audit that was conducted here. Nor had the Commission ever enforced its accounting rules in such an exacting manner. I find it ironic that the Commission takes these actions in today's pricecap regime where it can be argued that the capital investment is irrelevant to prices, but never found it necessary to do so under a rate of return regulatory environment where capital investment is directly correlated to the rates charged to consumers. sTo the extent that accurate plant accounts play any continuing role in monitoring financial results, defining stranded investment or calculating lowend earnings adjustments, these mechanisms are mere relics of rate of service regulation and should be eliminated in today's increasingly competitive environment. Indeed, pricecap regulation is only designed, to the extent possible, to replicate a competitive marketplace. But any form of regulation is an imperfect surrogate for full-fledged competition. At a minimum, we should implement a system of pure pricecap regulation for the largest carriers, under which there would be little need for the Commission to continue to perform general plant account audits or dictate, even  X4through revised or streamlined procedures, lowend adjustments and depreciation rates.S> S ' :ԍ44Some may argue that, even under pure pricecaps, some accounting rules would be necessary  xto determine expenses if a LEC filed a general rate case with the Commission. But only under those limited circumstances would the FCC have any need for a CPR audit. S In any event, the Commission should immediately stop any further auditing of outside plant or plugins until it is determined (i) whether this agency has the experience to perform a meaningful audit of continuing property records, and (ii) whether or not the benefits of these audits outweigh the costs in a pricecap regulatory environment.  W4s Some Potential Flaws with the Audits' Process, Methodology, and Conclusions  X4  X4sPotential Problems With the Audits' Methodology. I am concerned that there are several flaws with the audit methodology that could severely undermine the credibility of the audit results. For example, the conclusions reached in the audit report are inappropriate given the statistical sampling methods used. The Commission staff designed an audit to test the compliance with CPR rules. In the audit report, the Commission extrapolates such results to make conclusions regarding the dollar value of the account balance errors. The audit methodology, however, was designed to determine the percentage of equipment in compliance, not to predict a fair dollar value of the company's account balances. I am concerned about the appropriateness of reaching any conclusions about the dollar value of account balances using this sampling methodology. sFor example, to attempt to make such statements about the dollar value of the equipment in question, the audit would have been much more accurate if it had stratified the equipment based on its dollar value. In other words, if the Commission wants to say something about the potential overstatement of plant in a company's account records, it should be sampling for"" 0*((!" expensive pieces of equipment. Instead, the Commission staff designed a test to assess compliance with FCC regulations, but not the accuracy of plant account balances. Thus, it is questionable whether these results can ever be used to say something meaningful about the plant account balances. sIn addition, the Commission has failed to take depreciation even partly into account for its suggested writeoffs. The Commission staff's extrapolated amounts ignore that the equipment may have been retired or significantly depreciated. Even if all other aspects of the report are accurate, the failure to account properly for retirement and depreciation systematically leads to exaggerations of the estimate of missing equipment. sFor all of the pretense of statistical sampling, the estimates of missing equipment are painfully and impossibly precise. The Commission has no basis to know all of the possible sources of uncertainty, but at the very least they include the accuracy of the underlying audits, whether equipment was actually present or not, and whether retirement and depreciation were taken into account. The Commissions extrapolations present consistently the upper bound estimate of possible missing equipment. The lower bound is zero, a value defended by the companies outside auditors. Based on the information available to the Commission, it is impossible to estimate the value of missing equipment with any precision. It would have added enormously to the credibility of the report to have acknowledged the wide range of possible values, including zero. sI am also concerned with the Commission's refusal to perform a twoway plant and equipment review. I fear that the audit report may be systematically biased in that the methodology is designed only to detect instances of overstatement in plant records. The Commission failed to perform a twoway audit or to perform any tests to determine the possible existence of assets that are not found ong4  X4 the accounting records, potentially undermining the reliability of the report.f> S ' :ԍ44"The Failure to conduct a reverse or twoway audit means that any quantification of `missing'  S' xinvestment systematically overstates any value and cannot be relied upon." Joint Reply of SBC LECs to  S' xFCC December 22, 1998 Draft Report, at 14. See also, Response To Audit Staff Draft report of Findings  S'Related to Audit of Continuing Property Records of Bell Atlantic, at 910. sFinally, I am concerned that a crosscheck of "missing" equipment was not systematically performed. When the auditors determined that a company was unable to identify a particular piece of equipment, they refused to ask how many of such pieces of equipment were supposed  X 4to be present and ask if such pieces were indeed there.R d > S#' :+ԍ44Frequently such cross checks were not performed by the Commission.  See e.g., Response To  S$' x^Audit Staff Draft report of Findings Related to Audit of Continuing Property Records of Bell Atlantic, at 6: "S&0*((D&"Ԍ Ms"Indeed, the property reports themselves recognize that further investigation is warranted under these circumstances to clarify that such items correspond to the item in the property records:  :,s44For some items, additional audit work allowed auditors to conclude that the item shown was  Mthe item listed on the CPR. This additional work consisted of the auditor conducting an office count  Mof like items to account for all such items in the central office or on the floor where the item was expected to be found. . . .(#  SP' xAudit Staff Report, Appendix C at 1. While this procedure rarely was adhered to by the audit staff  xtpresumably because the audit staff only allowed six hours to physically inspect each office, or roughly  x*ten minutes per item it was successfully adopted by Bell Atlantic in its post inspection review. Despite  S ' xthe endorsement of this procedure in the audit staff reports, however, the reports do not yet reflect the fact  S 'that many items were found through precisely this type of cross check." R To illustrate, if the auditors had"   0*((" determined that a company was unable to identify a particular waiting room chair that was purchased in 1994, the auditors refused to consider the fact that the records indicated that a total of 7 chairs should be present and that indeed 7 chairs were present. The inability to identify which chair was the one in question resulted in the company being marked down.  X4sPotential Problems With the Audits' Process.  I am also concerned with the audit process itself, and the apparent lack of communication. On numerous occasions, carriers requested the opportunity to discuss documentation submitted and provide explanations to audit staff, but were given no opportunity to do so. This refusal to discuss audit results alone would be troubling, but becomes more problematic when carriers raise legitimate factual discrepancies. sGenerally accepted auditing standards require the auditors to consider all appropriate evidence. As described above, the Commission failed to conduct a twoway audit and consider that evidence in relation to possible overstatements in plant equipment. In addition, it appears that the staff did not consider all of the material documentation subsequently submitted by the companies as evidence of the existence of that equipment. For example, it appears that several items were classified as missing from some central offices in the Bell Atlantic territory because the equipment was retired between the time that the auditors selected the property records and the actual onsite visit. When notified of this error, the Commission staff seemed to accept the explanation with regards to some equipment and it  X64reject it with respect to others. 6 > Su ' :ԍ44Response To Audit Staff Draft report of Findings Related to Audit of Continuing Property  SO!'Records of Bell Atlantic, at 5. Even more important, the Commission staff would not discuss the discrepancies in their treatment of this issue with representatives of the company. sIn general, such evidence appears to suggest that additional steps to verify the audit findings should have been taken. At the very least, the Commission staff should have been allowed to discuss the discrepancies in their treatment of such subsequently submitted material. It is my understanding, however, that there was little or no communication of the"  0*((" audit findings with the companies until the report was prepared. Frequent communication seems a necessary part of any audit, and its dearth here leaves me questioning the audits fairness and impartiality. sWith this lack of meaningful communication as a backdrop, I am troubled with the audit staff's own inconsistent treatment of subsequently filed material. My office was shown many examples of inconsistent scoring by the Commission staff in its report. Ameritech alone provided numerous examples of inconsistencies in which items with the same or similar explanations and documentation were submitted, but treated differently by the auditors. How can the exact same explanation for identifying a piece of a frame be accepted for some offices and rejected for others with no explanation? sFinally, I believe that the audit staff misinterpreted the Commission's rules and requirements. I do not believe that the Commission's regulations require that the auditors be able to "spotcheck" the location of a company's entire equipment inventory down to a specific bay or shelf, with no meaningful opportunity for subsequent filings. Our rules do not require such a precise location be maintained for every piece of equipment. Indeed, if our rules require such detail, then the Commission has surely been negligent in failing to identify these rules for streamlining under the Section 11 biennial review process as the cost of such precise detailed recordkeeping would surely outweigh the public benefit. Indeed, I think that an audit with such a precise location standard has been designed for companies to fail.  X4sPotential Problems With the Audits' Conclusions.  The issues described above with respect to the audit methodology and process alone would raise serious questions about the audits conclusions. I also note that these companies seemed to raise several important arguments regarding the significance and impact that any such plant account discrepancies would have on ratepayers. sIn addition to these concerns, I note that many of the carriers engaged private accounting firms that have reduced the alleged overstatement significantly, sometimes by as much as  XP450%. dP> S' :dԍ44Bell Atlantic, for example argues that it has "found fully 97% of the items included in the  xaudit staff's sample, and the bulk of the remaining 3% either have been accounted for as retirements or  Sy' x*otherwise cannot be fairly characterized as `missing.'" Response To Audit Staff Draft report of Findings  SS 'Related to Audit of Continuing Property Records of Bell Atlantic, at 1. Thus, I fear that the carriers may have "found" significant amounts of the equipment the Commission staff is classifying as "missing." At the request of one of the carriers, I even visited one of the central offices and was shown equipment that had been categorized as "missing" that was obviously found. In one example, there were supposed to be at least 8 pieces of equipment in one bin but it appeared that there were only 5 present. Indeed, three had been marked as missing by the auditors. But, as I was shown, the remaining equipment was merely out of sight hidden by the catwalk. If one stepped back, you could see the remaining equipment above the catwalk. I do not fault the auditors for missing this equipment on the first round. I do however, fault a Commission process that turns a blind""  0*(( " eye to subsequently found equipment while at the same time releasing a report that concludes  X4such equipment is missing. In another example of excess that I was shown, the auditors had counted as unverifiable a battery that was being used in a piece of equipment because it could not be removed to display its serial number without taking the piece of equipment outofservice, destroying its usefulness. sLet me make an important distinction. To the extent that we wanted to say that the equipment was not readily available on the day that Commission staff arrived, but make no conclusions about whether or not it truly exists, the audit report would be fine. But the report approved for release by the majority takes the next step of concluding that the equipment does not exist and making recommendations regarding writeoffs and adjustments. As I have stated, to make such conclusions while ignoring facts is irresponsible.  W 4 sConclusion  X 4 sI support the release of a report describing the review of continuing property records. I believe, however, that we Commissioners may not be very good auditors. The Commission staff's physical verification raises serious concerns with the company's recordkeeping but also with this agency's capability of finding any meaningful results based on these continuing property records. The Commission should avoid wasting further government resources performing physical verification audits with these records. Instead, the Commission should have required that such a comprehensive audit be performed by private or other public auditing professionals based on standard accounting and auditing procedures, not necessarily limited to continuing property records. I believe that this agency and its Commissioners may never be capable of judging the accuracy and authenticity of the current set of audit results.   sI spent several years in private economic consulting. I have seen good cases; I have seen weak cases; but rarely have I seen numbers as indefensible as the extrapolations of missing equipment contained in these orders. I could not possibly defend them, and I therefore must respectfully dissent from their release. Their release is unfair to the professional staff of the FCC who must defend these numbers, and ultimately loose. Their release is also unfair to companies whose reputations will suffer. Accusations that companies are bilking the American public of billions of dollars should not be made lightly by government agencies. Grave accusations must be substantiated by evidence that is unambiguous and rock solid. Ambiguity is only one frailty of our evidence.   X!4#Xw PE37|XP#  !#XP\  P6QynXP#"! 0*(("  X'!   l&n  l&n  l&n s STATEMENT OF COMMISSIONER MICHAEL K. POWELL, 0DISSENTING IN PART  X4s  V4,\Re:Bell Atlantic (North) Telephone Companies Continuing Property Records Audit et  V4al.! In this combined statement, I write separately to explain the bases upon which I  XH4dissent in part from each of the referenced Orders releasing continuing property record (CPR) Audit Reports for the Bell Companies. I fully agree that the information contained in the Audit Reports should have been released in some manner, primarily to ensure its factual accuracy, methodological validity and to determine whether, if the Reports conclusions are valid, there has been a detrimental impact on ratepayers. Such an impact, if proven, would be serious. And I would willingly support addressing such an impact right now were I persuaded that  X4we have enough information to prove it. Accordingly, I support these Orders to the extent they stand for the proposition that the kind of information in these Audit Reports should, as a general matter, find its way into the public domain so that its validity may be properly and thoroughly tested, and so that the Commission can take whatever actions are appropriate based on the conclusions it reaches in light of such thorough testing.  I am reluctant, however, to level accusations as grave as are implied by these Reports without first subjecting the underlying facts and analysis to outside scrutiny, which we have yet to do. The Reports recommendations of writeoffs, accounting corrections and complete inventories strongly suggest that we have concluded that these are more than mere technical violations and that they must be remedied. Thus, I  X4feel I must dissent in part from these Orders.   XT4As the Orders indication that we will initiate a proceeding appears to suggest, we simply do not have enough information to endorse fully and take action on the Reports conclusions at this time. Specifically, the intention to start a future proceeding suggests we lack sufficient confidence in the Reports to proceed to enforcement without first subjecting their facts and analysis to public scrutiny. Yet today we push these Reports and their conclusions into the public domain without such scrutiny. This action might be troubling even if the Reports did not, in essence, allege misdeeds as potentially significant as these. But the allegations here are, indeed, very significant. By releasing the audit information as we do today, I fear we will subject the Companies to premature and prejudicial criticism and adverse market impact.   XY%4The Orders indicate that, by releasing the Reports in this manner, the Commission does not endorse the recommendations and conclusions of our Common Carrier Bureaus auditors. Such a distinction is too fine to my mind in light of the seriousness  X(4of the allegations and the fact that the Commission not the Bureau is ordering release of the Reports. I do not doubt the integrity of our auditors work or even") 0*0*0*&" necessarily the validity of their analyses and conclusions. I simply am unprepared to place what seems to be the Commissions imprimatur on those analyses and conclusions before they are tested in the fire of vigorous debate by other interested parties.   X4Under these exceptional circumstances,#footnote reference#X01Í ÍX01ÍÍ  yv3 X4footnote text#footnote reference#ۍ)Sfootnote reference) It is my understanding, for example, that the Commission has never (even in a rate of return environment) enforced these longstanding rules in so sweeping a manner. The Companies also have apparently raised some important arguments regarding whether, even if the Reports are valid, the Companies alleged misconduct would result in significant impact on ratepayers or other public policy detriments. y I believe we should have erred on the side  Xv4of giving the Companies more process than may normally be due before hinting at conclusions and implications. We had already begun to provide such extra process by, for example, sharing with the Companies the results of their respective audits and allowing them to comment on them. By releasing the Audit Reports in the manner we do today, however, I believe we have shortchanged the process of gathering additional  X 4information in as neutral a manner as possible.)Tfootnote reference)#footnote reference#oK  3 X4footnote text#footnote reference#ۍ)Sfootnote reference) #X\  P6G;ɒP#I think the ideal approach would have been to release the Reports without specific recommendations and conclusions and neutrally solicit comments on both the statistical methodology and policy implications (e.g., ratepayer impact) of any plant deemed missing. I recognize that some are concerned that releasing the Reports without recommendations and conclusions would somehow interfere with Commission auditors autonomy. I am unpersuaded by this concern, for I believe reserving judgment on the appropriate recommendations and remedies in no way undermines the integrity of auditors findings or their work, nor would such an approach require substitution of the auditors conclusions with those of other individuals. I should add, however, that I also would have been willing to issue these Reports  {O'simultaneously with a neutral overlay document, such as a Notice of Inquiry, that would have sought comment without interpreting the factual findings or making tentative conclusions as to the impact on ratepayers, etc. I think this could (and should) have been done in a way that would not impugn the performance and integrity of the Commissions auditors, but that would have merely reserved judgment  yO''until we have an opportunity to hear from other interested parties.#Xj\  P6G;ynXP#o  X 4In closing, I would underscore that my partial dissent from these Orders in no way reflects serious doubt on my part that the Commissions auditors worked diligently and carefully to perform these audits. I have every expectation that they endeavored to do so under the circumstances. My concern is primarily with the manner in which the information contained in the Reports is being released today, and with the manner in which we will build on that information to reach final conclusions. I thank our Common Carrier Bureau staff and my colleagues for their patience and hard work in this matter, and I look forward to working with everyone as we take the next step of seeking and considering outside comment on this important issue.