WPC  2 ZBhKeHP LaserJet 4Si/4Si MXXN\  PXPX0ÍÍ.X0ÍÍ.Quick I.III. Quick A. . 2eJgeg{Quick 1. . Quick 22Quick a.   . "Small Circle "2o 0[XN\  PXP(hH  Z6Times New Roman RegularXA\  PP(hH  Z6Times New Roman RegularXN\  PXP(hH  Z6Times New Roman RegularX :] PX UPC] OBp(XXN\  PXP(hH  Z6Times New Roman RegularXT\  PP(hH  Z6Times New Roman RegularXN\  PXP(hH  Z6Times New Roman RegularXT\  PP(hH  Z6Times New Roman RegularXN\  PXP(hH  Z6Times New Roman RegularXT\  P P(hH  Z6Times New Roman RegularXN\  P XP(hH  Z6Times New Roman RegularX2  3|x 3'Letter `d(#4#A\  PP#BellSouth, November 6, 1997, Louisiana#XN\  PXP#ѓ4& Before the d FEDERAL COMMUNICATIONS COMMISSION !Washington, D.C. 20554 ă " 1 " 1 3 x<x<In the Matter of Application by BellSouth Corporation, BellSouth Telecommunications, Inc., and BellSouth Long Distance, Inc., for Provision of InRegion, InterLATA Services in Louisiana3 CC Docket No. __________ To:The Commission  BRIEF IN SUPPORT OF APPLICATION BY BELLSOUTH FOR rPROVISION OF INREGION, INTERLATA SERVICES IN LOUISIANA ă  ă (#҇WALTER H. ALFORD WILLIAM B. BARFIELD JIM O. LLEWELLYN 1155 Peachtree Street, N.E. Atlanta, GA 30367 (404) 2492051 DAVID G. FROLIO 1133 21st Street, N.W. Washington, DC 20036 (202) 4634182 GARY M. EPSTEIN LATHAM & WATKINS 1001 Pennsylvania Ave., N.W. Washington, DC 20004 (202) 6372249 Counsel for BellSouth Corporation JAMES G. HARRALSON 28 Perimeter Center East Atlanta, GA 30346 (770) 3523116 Counsel for BellSouth Long Distance, Inc. November 6, 1997 MICHAEL K. KELLOGG AUSTIN C. SCHLICK KEVIN J. CAMERON JONATHAN T. MOLOT WILLIAM B. PETERSEN ppp- KELLOGG, HUBER, HANSEN, TODD & EVANS, P.L.L.C. 1301 K Street, N.W. Suite 1000 West Washington DC 20005 (202) 3267900 Counsel for BellSouth Corporation, BellSouth Telecommunications, Inc. and BellSouth Long Distance, Inc. MARGARET H. GREENE R. DOUGLAS LACKEY MICHAEL A. TANNER STEPHEN M. KLIMACEK 675 W. Peachtree Street, N.E. Suite 4300 Atlanta, GA 30375 (404) 3350764 Counsel for BellSouth Telecommunications, Inc.Ĉ   # :] PX #  #XN\  PXP#@--@  ӈX0ÍÍ.X0ÍÍ.l EXECUTIVE SUMMARY ă This application should serve as further confirmation that BellSouth has worked earnestly and successfully to meet all prerequisites for inregion, interLATA relief under the Telecommunications Act of 1996 (the Act or 1996 Act). BellSouth has opened the local exchange in Louisiana to competition by negotiating dozens of carrierspecific interconnection agreements and filing a Statement of Generally Available Terms and Conditions that has been approved by the State public service commission. The State commission conducted an extensive evidentiary proceeding, open to all, to investigate BellSouths compliance with the requirements of section 271. After its investigation, the State commission found that BellSouth has met the Acts requirements and that BellSouths provision of inregion, interLATA services would serve the public interest. As in South Carolina, for which BellSouth has a pending application for long distance authority, long distance callers in Louisiana " and particularly average residential users " pay more than they should for interLATA service because BellSouth has been excluded from the market. Potential wireline carriers in Louisiana are holding back in offering facilitiesbased local service to residential customers even though they can obtain interconnection and unbundled network elements from BellSouth to ease their entry. These potential competitors are focusing instead on urban business markets, where they can earn higher profits by selectively cherry picking BellSouths most profitable customers. New competitors simply sense no urgency in entering the local market in Louisiana on a broad basis. As long as BellSouth cannot offer its ordinary local customers onestop shopping, potential competitors face little risk from holding off as well. They can ignore residential callers in favor of more lucrative business customers, or postpone entering the local telephone business altogether, knowing that BellSouth can neither gain an advantage by selling bundled services nor take a single penny from the incumbents interLATA profits. With this application, BellSouth seeks to bring greater local and long distance competition to all Louisianans. Notwithstanding the limited strategic entry by wireline local carriers, BellSouth is eligible to file under Track A, 47 U.S.C. 271(c)(1)(A), because PCS providers unaffiliated with BellSouth have commenced service over their own networks in Louisiana. Under the plain language of the Act as well as this Commissions prior decisions, these PCS carriers are competing providers of telephone exchange service . . . to residential and business subscribers. The legislative history of section 271 further makes clear that Track A is satisfied because these wireless carriers provide a facilitiesbased alternative to BellSouth for local calls. BellSouth also has fully complied with the local competition provisions of the 1996 Act. The Louisiana Public Service Commission ( Louisiana PSC) conducted a ninemonth review of BellSouths compliance with section 271. It also established separate proceedings to ensure that BellSouths resale discount and rates for interconnection and unbundled network elements are consistent with section 252 of the Communications Act. After thorough investigation into these three dockets, the Louisiana Commission: (1) concluded that BellSouths Statement of Generally Available Terms and Conditions makes available to competitors each of the 14 items required under the competitive checklist and (2) set a resale discount and costbased rates and approved their inclusion in the Statement. Existing wireline carriers, PCS providers, and any other parties that seek to enter the local market in Louisiana have access to these terms under BellSouths generic statement or their own, customtailored agreements. In its review of BellSouths eligibility for interLATA relief, the Louisiana PSC paid particular attention to competitors access to BellSouths operations support systems ( OSSs). Parties such as AT&T, MCI, and the U.S. Department of Justice will claim in this proceeding that BellSouth cannot prove such access is available until competitors actually choose to avail themselves of it. Yet, after inspecting BellSouths OSS interfaces and procedures and giving opponents an opportunity to prove alleged deficiencies in a live demonstration, the Louisiana PSC determined exactly the opposite: BellSouths systems, the Louisiana PSC held, do in fact work and operate to allow potential competitors full nondiscriminatory access.(i Order U22252A, Consideration and Review of BellSouth Telecommunications, Inc.s Preapplication Compliance with Section 271 of the Telecommunications Act of 1996, Dkt. U22252, at 45, 15 (LPSC rel. Sept. 5, 1997) ( Compliance Order) (App. C Tab 136).( The Louisiana PSCs findings establish BellSouths satisfaction of all relevant requirements under sections 251 and 252 of the Communications Act and section 271s checklist. They rule out the possibility that the limited scope of local wireline competition in Louisiana is attributable to BellSouth rather than the business strategies of potential competitors. In addition to meeting all requirements imposed by the State commission and the Act itself, BellSouth has abided by the general guidance given in this Commissions Michigan Order1i Memorandum Opinion and Order, Application of Ameritech Michigan Pursuant to Section 271 of the Communications Act of 1934, as Amended, to Provide InRegion, InterLATA Services in Michigan, CC Docket No. 97137, FCC No. 97298 (rel. Aug. 19, 1997) ( Michigan Order).1 to the fullest extent possible while still preserving BellSouths right to have a court decide whether certain of these requirements would be consistent with the Act if applied to the facts in Louisiana. For example, this application includes extensive documentation requested by the Commission regarding performance data, pricing, and other matters, notwithstanding pending proceedings that bear on the legal relevance of such evidence. The benefits of granting this application are crystal clear. BellSouth has, for example, committed to establish its basic interLATA rates at least 5 percent below those of AT&T immediately upon entering the market. This discount (and ensuing competitive marketing by all carriers) would guarantee residential callers in Louisiana, who are most in need of price relief, the opportunity to realize savings from a long distance carrier they know and can trust. By 2006, fuller competition as a result of inregion, interLATA relief will create more than 7,600 new jobs in Louisiana and increase the gross state product by more than $900 million. Nationwide, residential customers would save $7 billion per year. That means that these ordinary callers are losing well over $100 million every week that the Commission delays section 271 relief " a price tag that should weigh heavily on this Commission. BellSouths entry into interLATA services will ignite competition in Louisianas local markets as well. In particular, the major long distance carriers will no longer be able to pursue other opportunities with the assurance that BellSouth cannot sell packages of local and interLATA services consumers desire. After interLATA relief is granted, moreover, AT&T, MCI, and Sprint will be freed of all restrictions on their own bundled service packages, which will add an additional dimension to local competition.The traditional justification for excluding Bell companies from interLATA services, and foregoing such benefits, is that they might dominate interexchange markets through cost misallocation or discrimination. Yet the 1996 Act, together with longstanding Commission regulations, state regulations, and market realities, renders such misconduct inconceivable. The local exchange in Louisiana is open to competitors. BellSouth will start with zero market share in a long distance business dominated by entrenched incumbents with vast resources and high sunk costs, factors that make successful predation unimaginable. Commission rules and procedures have successfully protected regulated ratepayers when incumbent local exchange carriers have entered other markets adjacent to the local exchange. As the Commission has confirmed, the 1996 Act gives it ample authority to deter anticompetitive behavior and to facilitate detection of potential violations of the Act. There can be no basis for delaying level competition by BellSouth in Louisiana, except to hold back BellSouth until potential entrants such as AT&T and MCI, who have spent the last 21 months plotting regulatory strategies instead of pursuing market entry, are willing to compete. Any such effort to manage competition would flatly violate the 1996 Act and Congresss deregulatory policies. Just as important, a failure to free BellSouth to compete would " as this application demonstrates " gravely harm the Louisiana consumers whose interests should be paramount.  TABLE OF CONTENTS  EXECUTIVE SUMMARYp"(#Ji Quick I.I.BELLSOUTH MAY PROCEED UNDER TRACK Ap"(#J5Quick I.ۃ  Quick A.A.` ` ` BellSouth Has Taken All Required Steps to Open Local Markets inQuick A. Louisianap"(#J5p(#(#K  1.BellSouth Has Negotiated Agreements with Numerous CLECsp"(#J5 Quick 1.2.BellSouth Has Obtained State Approval of Its Statementp"(#J7Quick 1.ۃ  Quick A.B.` ` ` PrimeCo, Sprint Spectrum, and MereTel Are Operational Track A Quick A. Competitors p"(#J8 ` ` ` Quick 1.1.PCS Service Is Telephone Exchange Servicep`"(#I10Quick 1.ۃ  ` ` ` Quick 1.2.Track A Does Not Require That the Competitors Service Be Equivalent in Every Respect to the BOCsp`"(#I12Quick 1.ۃ  ` ` ` Quick 1.3.For Some Customers and Uses, PCS Service Is a Substitute for BellSouths Wireline Service p`"(#I16Quick 1.ۃ  Quick A.C.` ` `  Track A Wireline Carriers Are Entering the Louisiana Marketp`"(#I17Quick A.ۃ  Quick A.D.` ` ` If No Wireline or Wireless CLEC Had Launched Track A Service, BellSouth Would Be Eligible for InterLATA Relief Under Track Bp`"(#I21Quick A.ۃ  II.BELLSOUTH PROVIDES INTERCONNECTION AND ACCESS IN COMPLIANCE WITH THE COMPETITIVE CHECKLISTp`"(#I22  A.` ` ` BellSouth is Providing Nondiscriminatory Access to its Operations ` ` ` Support Systemsp`"(#I25 B.` ` ` All Fourteen Checklist Items Are Legally and Practicably Availablep`"(#I35 Quick A.C.` ` ` Performance Measurementsp`"(#I69Quick A.ۃ  III.BELLSOUTH SATISFIES THE REQUIREMENTS OF SECTION 272p`"(#I74 IV.BELLSOUTHS ENTRY INTO THE INTERLATA SERVICES MARKET WILL PROMOTE COMPETITION AND FURTHER THE PUBLIC INTERESTp`"(#I82  Quick A.A.` ` ` The Scope of the Public Interest Inquiryp`"(#I84Quick A.ۃ  Quick A.B.` ` ` The Current Long Distance Oligopoly Limits Competitionp`"(#I88Quick A.ۃ  Quick A.C.` ` ` Market Evidence Confirms that BellSouths Entry into the InterLATA Market in Louisiana Will Benefit Consumersp`"(#I91Quick A.ۃ  ` ` ` Quick 1.1.Evidence of Competition Where LECs Have Been Allowed to Offer Long Distancep`"(#I92Quick 1.ۃ  ` ` ` Quick 1.2.BellSouth Is Suited to Break Up the Interexchange Oligopoly in Louisianap`"(#I94Quick 1.ۃ  D.` ` ` BellSouths Entry into the InterLATA Market, Subject to Extensive Statutory and Regulatory Safeguards, Presents No Risk to Competitionp!(#H102 1.Regulation and Practical Constraints Make Leveraging Strategies Impossible to Accomplishp!(#H102 ` ` ` Quick 1.2.Actual Experience with LEC Participation in Adjacent Markets Disproves Theories about Anticompetitive Potentialp!(#H115Quick 1.ۃ  Quick A.E.` ` ` The Effect of BellSouths Entry on Local Competitionp!(#H119Quick A.ۃ  CONCLUSIONp!(#H124 Exhibit 1 (Verifications and AntiDrug Abuse Act Certifications) % APPENDIX A ă * 9ddddKdd@ddddKdd@9 T LLb- H LLb- H T     #T\  PP# TAB ă DESCRIPTION #XN\  PXP#PP#T\  PP#AffidavitSubject#XN\  PXP#PP#1George F. AgertonBST Section 272 CompliancePP#2Guy L. CochranBST Section 272 CompliancePP#3Richard J. GilbertPublic Interest TestPP#4John R. GunterPublic Interest Test (Impossibility of Technical Discrimination)PP#5Jerry A. HausmanPublic Interest Test*PP#6David HollettChecklist Compliance (Billing Systems)PP#7Victor E. JarvisBSLD Section 272 CompliancePP#8David A. KettlerManufacturing ReliefPP#9W. Keith MilnerChecklist CompliancePP#10D. John RobertsPublic Interest Test (No Risk of Predatory Pricing)*PP#11Richard L. SchmalenseePublic Interest Test*PP#12William N. StacyChecklist Compliance (Operations Support Systems)PP#13William N. StacyChecklist Compliance (Performance Measures)PP#14Alphonso J. VarnerChecklist Compliance and BST Section 272 CompliancePP#15Glenn A. WorochPublic Interest TestP  P  #16Gary M. WrightLocal Competition *Affidavits marked with an asterisk were originally filed with the Commission on September 30, 1997, as part of the Application by BellSouth Corporation, BellSouth Telecommunications, Inc., and BellSouth Long Distance, Inc., for Provision of InRegion, InterLATA Services in South Carolina, FCC Docket No. 97208. %APPENDIX B ă * J eLLb/e  eLLb/e J    INTERCONNECTION AND RESALE AGREEMENTS   TABAPPROVAL PARTY P P !110/08/96[[[American MetroComm Corporation Interconnection AgreementPP!210/08/96[[[Hart Communications Interconnection AgreementPP!310/08/96[[[Intermedia Communications, Inc. Interconnection Agreement and 06/20/97 AmendmentPP!410/30/96[[[National Tel Interconnection Agreement and 06/20/97 AmendmentPP!511/04/96[[[American Communications Services, Inc. (ACSI) Interconnection Agreement and 02/03/97 AmendmentPP!602/03/97[[[Competitive Communications, Inc. Interconnection AgreementPP!702/03/97[[[TriComm, Inc. Interconnection AgreementPP!802/03/97[[[WinStar Wireless, Inc. Interconnection AgreementPP!902/04/97[[[Communication Brokerage Services, Inc. Resale AgreementPP!1002/04/97[[[Tie Communications, Inc. Resale AgreementPP!1103/12/97[[[Unidial Communications, Inc. Resale AgreementPP!1203/14/97[[[US LEC of North Carolina L.L.C. Interconnection AgreementPP!1304/08/97[[[American Communications Services, Inc. (ACSI) Resale AgreementPP!1404/08/97[[[Interlink Telecommunications of Florida, Inc. Resale AgreementPP!1504/08/97[[[U.S. Long Distance, Inc. Resale AgreementPP!1604/21/97[[[Advanced Tel, Inc. Resale AgreementPP!1706/19/97[[[BellSouth Cellular Corporation Interconnection Agreement and 10/05/97 AmendmentPP!1806/20/97[[[AT&T Wireless Services, Inc. Interconnection AgreementP P !1906/20/97[[[Comm. Depot, Inc. Interconnection AgreementPP!2006/20/97[[[DeltaCom, Inc. Interconnection Agreement and AmendmentsPP!2106/20/97[[[FiberSouth, Inc. Interconnection Agreement and AmendmentPP!2206/20/97[[[GNet Telecom, Inc. Interconnection AgreementPP!2306/20/97[[[ICG Telecom Group, Inc. Interconnection AgreementPP!2406/20/97[[[KMC Telecom, Inc. Interconnection AgreementPP!2506/20/97[[[LCI International Telecom Corporation Resale AgreementPP!2606/20/97[[[LCI International Telecom Corporation Line Information Database (LIDB) Storage AgreementPP!2706/20/97[[[Powertel, Inc. Interconnection AgreementPP!2808/12/97[[[PrimeCo Personal Communications, L.P. Interconnection AgreementPP!2908/12/97[[[SouthEast Telephone, Ltd. Interconnection AgreementPP!3008/12/97[[[Sprint Spectrum, L.P. Interconnection AgreementPP!3108/12/97[[[Telephone Company of Central Florida Resale Agreement PP!3208/12/97[[[Teleport Communications Group Interconnection AgreementPP!3308/20/97[[[ALEC, Inc. Interconnection AgreementPP!3408/20/97[[[Communication Options Southern Region, Inc. d/b/a COI Resale AgreementPP!3508/20/97[[[InterWorld Communications Resale AgreementPP!3608/20/97[[[National Tel Resale AgreementPP!3708/20/97[[[Preferred Payphones, Inc. Resale AgreementPP!3808/20/97[[[RGW Communications, Inc. Resale AgreementPP!3908/20/97[[[Sterling International Funding, Inc. d/b/a Reconex Resale AgreementPP!4008/21/97[[[Cybernet Group Interconnection Agreement and Amendment and 10/26/97 Second AmendmentP P !4108/21/97[[[Interstate Telephone Group Interconnection Agreement and Amendment and 10/20/97 Second AmendmentPP!4209/01/97[[[Shell Offshore Services Company, Inc. Interconnection AgreementPP!4309/23/97[[[Alliance Telecommunications, Inc. Resale AgreementPP!4409/23/97[[[Annox, Inc. Renegotiated Resale AgreementPP!4509/23/97[[[AXSYS, Inc. Renegotiated Interconnection AgreementPP!4609/23/97[[[AXSYS, Inc. Renegotiated Resale AgreementPP!4709/23/97[[[DonMar Telecommunications, Inc. Resale AgreementPP!4809/23/97[[[NOW Communications, Inc. Renegotiated Resale AgreementPP!4909/23/97[[[SouthEast Telephone, Ltd. Resale AgreementPP!5009/23/97[[[Southern PhonReconnek, Inc. Renegotiated Resale AgreementPP!5109/23/97[[[Supra Telecommunications, Inc. Resale AgreementPP!5209/23/97[[[TelLink, L.L.C. d/b/a TELLINK, L.L.C. and TelLink of Florida, L.L.C. Renegotiated Resale AgreementPP!5309/23/97[[[Wright Businesses, Inc. Renegotiated Resale AgreementPP!5410/05/97[[[American MetroComm Corporation Renegotiated Resale AgreementPP!5510/05/97[[[BTI Telecommunications, Inc. Resale AgreementPP!5610/05/97[[[Data & Electronic Services, Inc. Resale Agreement PP!5710/05/97[[[Diamond Telephone Resale AgreementPP!5810/05/97[[[EZ Phone, Inc. Resale AgreementPP!5910/05/97[[[JETCOM, Inc. Renegotiated Resale AgreementPP!6010/05/97[[[TTE, Inc. Renegotiated Resale AgreementPP!6110/05/97[[[Teleconex, Inc. Resale AgreementPP!6210/05/97[[[TeleSys, Inc. Renegotiated Resale AgreementPP!6310/20/97[[[Centennial Cellular Corp. Interconnection AgreementP P !6410/20/97[[[Comm South Companies, Inc. Resale AgreementPP!6510/26/97[[[Louisiana Unwired, Inc. Resale AgreementPP!6610/26/97[[[MERETEL COMMUNICATIONS L.P. Interconnection AgreementPP!6710/26/97[[[Netel, Inc. Resale AgreementPP!6810/26/97[[[OmniCall, Inc. Resale AgreementPP!6910/26/97[[[Preferred Carrier Services, Inc. Resale AgreementPP!7011/05/97[[[ACCESS Integrated Networks, Inc. Resale AgreementPP!7111/05/97[[[Davco, Inc. Resale AgreementPP!7211/05/97[[[NEXTEL Communications, Inc. Interconnection AgreementPP!7311/05/97[[[Robin Hood Telecommunications Resale AgreementPP!7411/05/97[[[U.S. Dial Tone, Inc. Resale AgreementPP!7511/05/97[[[US Telco, Inc. Resale AgreementP P !7610/23/97[[[AT&T Telecommunications of the Southern Central States, Inc. (Arbitrated Interconnection Agreement & PSC Orders) 6$ APPENDIX C1 ă J LLc.e LLc.e J     F TAB ă  RECORD OF LOUISIANA PSC DOCKET NO. U22252 ă [' Section 271 Proceeding ăPP!112/18/96[[[Transcript of Open SessionPP!201/10/97[[[Official Bulletin No. 610PP!301/16/97[[[AT&Ts Motion Requesting Leave to IntervenePP!401/17/97[[[LPSC Letter to Guerry Acknowledging Receipt of AT&Ts January 16, 1997 PetitionPP!501/22/97[[[Petition to Intervene of Sprint Communications Company L.P.PP!601/24/97[[[LPSC Letter to Atkinson Acknowledging Receipt of Sprints January 22, 1997 PetitionPP!701/31/97[[[MCI Telecommunications Corporations Notice of InterventionPP!802/03/97[[[BellSouth Telecommunications, Inc. (BellSouth) Notice of Intervention and Request to be Placed on Service ListPP!902/03/97[[[Louisiana Cable Telecommunications Association, Inc.s Petition of Intervention, Request for Party of Record Status and Inclusion on Service ListPP!1002/04/97[[[LDDS WorldCom Notice of InterventionPP!1102/04/97[[[Access Network Services, Inc.s Motion to IntervenePP!1202/05/97[[[LPSC Letter to Daly Acknowledging Receipt of LDDS WorldComs February 4, 1997 Petition PP!1302/05/97[[[LPSC Letter to Rieger Acknowledging Receipt of Louisiana Cable Telecommunications Association, Inc.s February 3, 1997 PetitionPP!1402/05/97[[[LPSC Letter to Twomey Acknowledging BellSouth's January 31, 1997 PetitionP P !1502/05/97[[[LPSC Letter to King Acknowledging Receipt of MCI Telecommunicationss January 31, 1997 PetitionPP!1602/07/97[[[LPSC Letter to Hubbard Acknowledging Receipt of Access Network Services, Inc.s February 3, 1997 PetitionPP!1702/07/97[[[LPSC Staff Attorney Letter to Commissioners Regarding Proposed Procedural SchedulePP!1802/19/97[[[Transcript of Open Session PP!1902/24/97[[[BellSouth Notice of Intent to File Section 271 Application with the Federal Communications CommissionPP!2002/26/97[[[BellSouth Long Distance, Inc.s Motion for Leave to File Petition of Intervention and Petition of InterventionPP!2102/28/97[[[BellSouth's Request for Status ConferencePP!2203/03/97[[[Notice of Assignment and Scheduling of Status ConferencePP!2303/14/97[[[Direct Testimony of James G. Harralson, Michael Raimondi, Loren Scott, and William E. Taylor on Behalf of BellSouth Long Distance, Inc.PP!2403/14/97[[[Direct Testimony of Robert C. Scheye and Alphonso J. Varner on Behalf of BellSouthPP!2503/14/97[[[Report on March 13, 1997 Status Conference and Notice of Revised Procedural SchedulePP!2603/17/97[[[Notice of Intervention and Motion to File OutofTime on Behalf of American Communication Services of Baton Rouge, Inc., American Communication Services of Louisiana, Inc. and American Communication Services of Shreveport, Inc.PP!2703/17/97[[[LPSC Letter to Freysinger Acknowledging ACSIs Notice of Intervention and Motion to File OutofTime InterventionPP!2803/20/97[[[Notice of Opportunity to Object to Late InterventionPP!2903/24/97[[[AT&Ts Notice of Deposition to All Counsel of RecordPP!3003/24/97[[[Notice of Deposition for D. Loren ScottPP!3103/24/97[[[Revised Notice of Deposition for D. Loren Scott PP!3203/27/97[[[Ruling on Motion for Late InterventionPP!3304/01/97[[[AT&T's Motion to Amend Procedural Schedule P P !3404/01/97[[[LPSCs First Set of Data Request to BellSouthPP!3504/02/97[[[Order Amending Procedural SchedulePP!3604/04/97[[[Amended Notice of Intent to File Section 271 Application with the Federal Communications CommissionPP!3704/07/97[[[Direct Testimony of Riley M. Murphy on Behalf of American Communication Services of Louisiana, Inc., American Communication Services of Shreveport, Inc., American Communication Services of Baton Rouge, Inc.PP!3804/11/97[[[Direct Testimony of David E. Stahly and Melissa L. Closz on Behalf of Sprint Communications Company L.P. PP!3904/14/97[[[Direct Testimony of Jay Bradbury, Preston Foster, Joe Gillan, and John Hamman on Behalf of AT&T Communications of the South Central States, Inc.PP!4004/14/97[[[Direct Testimony of Don J. Wood and David L. Kaserman on Behalf of MCI Telecommunications Corporation and AT&T Communications of the South Central States, Inc.PP!4104/17/97[[[BellSouth's Letter to All Parties Proposing Additional Hearing DatesPP!4204/21/97[[[Notice of Time and Location for April 28, 1997 Status ConferencePP!4304/23/97[[[Sprint Letter to ALJ Requesting to Specially Set its WitnessesPP!4404/23/97[[[BellSouth Long Distance, Inc.s Response to LPSCs First Set of Data Request to BellSouthPP!4504/23/97[[[BellSouths Responses to LPSCs Data RequestPP!4604/24/97[[[Letter From D. Shapiro Requesting to be Placed on Service ListPP!4704/25/97[[[Notice of New Date and Time for Status Conference PP!4804/29/97[[[Letter From W. Glenn Burns Informing LPSC of Substitute for Status ConferencePP!4904/30/97[[[MCI Telecommunications Corporations Motion for Declaratory Order and Motion for Partial Summary JudgmentP P !5005/02/97[[[BellSouth's Rebuttal Testimony of Gloria L. Calhoun, Robert C. Scheye and Alfonso J. VarnerPP!5105/02/97[[[BellSouth Long Distance, Inc. Rebuttal Testimony of James G. Harralson and Dr. William E. TaylorPP!5205/06/97[[[Ruling on MCI Telecommunications Corporations Motion for Declaratory Order and Motion for Partial Summary JudgmentPP!5305/06/97[[[Report on May 5, 1997 Status Conference and Notice of Revised Hearing DatesPP!5405/06/97[[[Ruling on Motion for Leave to Intervene of the Competitive Telecommunications AssociationPP!5505/07/97[[[Motion for Leave to Intervene of the Competitive Telecommunications AssociationPP!5605/07/97[[[Notice of Appearance of Counsel for WorldCom, Inc.PP!5705/12/97[[[Notice of Opportunity for Objection to Motion for Leave to Intervene of the Competitive Telecommunications AssociationPP!5805/14/97[[[Joint Witness ListPP!5905/14/97[[[BellSouth's Objection to Late InterventionPP!6005/16/97[[[BellSouth Letter to ALJ Regarding Potential Move to Disqualify CounselPP!6105/16/97[[[Reply of CompTel to Ruling on Motion for Leave to IntervenePP!62 05/19/97[[[Statement of Generally Available Terms and Conditions for Interconnection, Unbundling and Resale Provided by BellSouth in the State of LouisianaPP!6305/19/97[[[Hearing Transcript: Volume IPP!6405/20/97[[[Hearing Transcript: Volume IIPP!6505/21/96[[[Hearing Transcript: Volume IIIPP!6605/22/97[[[Notice of Commission Consideration of BellSouths Statement of Generally Available Terms Within This Docket ALSO Notice of Deadlines Established for Intervention and Participation With Regard to Commissions Consideration of BellSouths SGAT ALSO Notice of New Deadline for Filing PostHearing Briefs PP!6705/22/97[[[Hearing Transcript: Volume IVP P !6805/23/97[[[Hearing Transcript: Volume VPP!6905/23/97[[[ACSI Letter to ALJ Regarding Witness Scheduling of Riley MurphyPP!7005/27/97[[[Hearing Transcript: Volume VIPP!7105/28/97[[[Hearing Transcript: Volume VIIPP!7205/29/97[[[Submission of MCI/Taylor Cross Exhibit 5PP!7306/06/97[[[Motion to Intervene of Entergy Hyperion Telecommunications of Louisiana, L.L.C.PP!7406/06/97[[[Intermedia Communications, Inc. Petition for Leave to IntervenePP!7506/06/97[[[Notice of Intervention by Radiofone, Inc. PP!7606/06/97[[[Notice of Intervention by WorldCom, Inc. Regarding BellSouths SGATPP!7706/06/97[[[Comments of WorldCom, Inc. on BellSouths Statement of Generally Available TermsPP!7806/06/97[[[Petition for Leave to Intervene and Comments of the Telecommunications Resellers AssociationPP!7906/09/97[[[Global Tel*Link, Inc.s Notice of InterventionPP!8006/09/97[[[Motion for Leave to File Petition of Intervention and Comments of Cox Fibernet Louisiana, Inc. Regarding BellSouths Statement of Generally Available Terms and ConditionsPP!8106/10/97[[[Notice of HearingPP!8206/11/97[[[Motion of Radiofone, Inc. to Withdraw Request to CrossExamine BellSouths WitnessesPP!8306/11/97[[[Intermedia Letter to ALJ Regarding CrossExamination of BellSouth Witnesses, Testimony at June 13, 1997 Hearing, and Right to File PostHearing BriefPP!8406/11/97[[[BellSouth Letter to ALJ Requesting the Cancellation of Hearings Scheduled for CrossExamination of BellSouth WitnessesP P !8506/11/97[[[Notice of Omission of One Intervenor in June 10, 1997 Notice and of Revised Request of Intervenor Intermedia Communications, Inc.PP!8606/11/97[[[Notice of Cancellation of Hearing Previously Scheduled for June 12 and 13, 1997PP[87]   Intentionally omitted.PP!8806/11/97[[[Motion to File Out of Time Notice of Intervention on Behalf of Communications Workers of AmericaPP!8906/13/97[[[BellSouth's Objection to Late InterventionPP!9006/16/97[[[Order Granting with Limitations Motion to File Out of Time Notice of Intervention on Behalf of Communications Workers of AmericaPP!9106/17/97[[[Brief of American Communication Services of Louisiana, Inc., American Communication Services of Baton Rouge, Inc. and American Communication Services of Shreveport, Inc.PP!9206/17/97[[[Brief of Sprint Communications Company L.P.PP!9306/18/97[[[Joint PostHearing Brief of Louisiana Cable Telecommunications Association and Cox Fibernet Louisiana, Inc.PP!9406/18/97[[[PostHearing Memorandum of MCI Telecommunications CorporationPP!9506/18/97[[[Post Hearing Brief of BellSouth Long Distance, Inc., on the Public Interest IssuePP!9606/18/97[[[AT&T Communications of the South Central States, Inc.s PostHearing Brief in Opposition to Approval of BellSouths Statement of Generally Available Terms and Conditions, and In Opposition to BellSouths Request for a Recommendation of Preapplication Compliance with 271 to Provide InterLATA Services Originating InRegionPP!9706/18/97[[[BellSouths Post Hearing BriefPP!9806/18/97[[[LPSC Staff Post Hearing BriefP P !9906/18/97[[[PostHearing Brief of WorldCom, Inc.PP!10006/24/97[[[[Revised] AT&T Communications of the South Central States, Inc.s PostHearing Brief in Opposition to Approval of BellSouths Statement of Generally Available Terms and Conditions, and In Opposition to BellSouths Request for a Recommendation of Preapplication Compliance with 271 to Provide InterLATA Services Originating InRegionPP!10107/01/97[[[Supplemental PostHearing Memorandum of MCI Telecommunications CorporationPP!10207/01/97[[[ACSI Supplement of its PostHearing Brief PP!10307/01/97[[[AT&T Letter to ALJ Regarding BellSouths SGATPP!10407/01/97[[[BellSouth Letter to ALJ Requesting Opportunity to File Supplemental Pleading in Response to AT&T and MCIs Late Filing of PostHearing BriefPP!10507/02/97[[[Notice of Opportunity to File Supplemental Briefs Concerning June 26, 1997 Memorandum Opinion and Order of the Federal Communications CommissionPP!10607/03/97[[[Sprint Letter to ALJ Regarding Supplementing BriefsPP!10707/03/97[[[Supplemental Comments of the Telecommunications Resellers AssociationPP!10807/03/97[[[Intermedia Letter to ALJ Regarding BellSouths SGATPP!10907/03/97[[[Supplemental PostHearing Memorandum of AT&T Communications of the South Central States, Inc.PP!11007/07/97[[[Supplemental Brief of BellSouthPP!11107/09/97[[[Recommendation of the ALJPP!11207/11/97[[[Request for Oral Argument on Behalf of BellSouthPP!11307/15/97[[[ACSI Letter to Commissioners Regarding BellSouth ServicePP!11407/15/97[[[BellSouth Letter to Commissioners Regarding ACSI Letter PP!11507/16/97[[[Transcript of Open SessionPP!11607/28/97[[[Transcript of Open SessionP P !11707/28/97[[[Order Rejecting ALJ RecommendationPP!11808/04/97[[[MCI Telecommunications Corporations Comments on Operational Support SystemsPP!11908/04/97 [[[Cox Fibernet Louisiana, Inc.s List of Potential Complications Regarding BellSouth's Operational Support SystemsPP!12008/04/97[[[Sprints Response to Commissions Request for List of Alleged Complications with BellSouths OSSPP!12108/04/97[[[Comments of AT&T Communications of the South Central States Regarding BellSouth OSSPP!~ 12208/04/97[[[Comments of American Communications Services, Inc.PP!12308/05/97[[[BellSouth Letter to ALJ Submitting South Carolina Public Service Commission Order Dated July 31, 1997PP!12408/07/97[[[Notice of Technical DemonstrationPP!12508/07/97[[[Notice Listing Connections BellSouth Will Provide at DemonstrationPP!12608/08/97[[[AT&T Letter to ALJ Regarding BellSouths SGAT in South CarolinaPP!12708/11/97[[[Response of BellSouth to August 4, 1997 FilingsPP!12808/11/97[[[Independent Payphone Service Providers Ad Hoc Committee Letter to LPSC Listing Facts for Commission to ConsiderPP!12908/12/97[[[Supplemental and Amending Responses of BellSouthPP!13008/12/97[[[MCI Letter to ALJ Regarding BellSouth's August 5, 1997 LetterPP!13108/14/97[[[ALJ's Recommendation Regarding BellSouths SGATPP!13208/15/97[[[Sprints Comments on BellSouths Operational Support Systems DemonstrationPP!13308/15/97[[[LPSC Staff 271 RecommendationPP!13408/19/97[[[Cox Letter to LPSC Regarding BellSouths Operational Support SystemsPP!13508/20/97[[[Transcript of Open SessionP P !13609/05/97[[[Order Approving the SGAT Subject to ModificationsPP!13709/09/97[[[Statement of Generally Available Terms and Conditions for Interconnection, Unbundling and Resale Provided by BellSouthPP!13809/12/97[[[Sprint Letter to LPSC Regarding SGATPP!13909/15/97[[[BellSouths Comments Pursuant to Order No. 22252APP!14009/15/97[[[MCI Telecommunications Corporations Comments Regarding BellSouths Proposed Modified Statement of Generally Available Terms and ConditionsPP!14109/15/97[[[AT&Ts Comments on the Eighth Circuits DecisionP P !14209/16/97[[[BellSouths Local Interconnection and FacilityBased Ordering Guide, Resale Ordering Guide, and Negotiations Handbook for Collocation  6$ APPENDIX C2 ă J LLc-e LLc-e J     F TAB ă  RECORD OF LOUISIANA PSC DOCKET NO. U22145 AT&T/BellSouth Arbitration PP!14309/20/96[[[AT&Ts Petition for Arbitration Under the Telecommunications Act of 1996PP!14409/27/96[[[Arbitrators Notice of Telephone Status ConferencePP!14510/02/96[[[Sprints Petition for Leave to Intervene and Inclusion on Service ListPP!14610/04/96[[[Motion of Sprint Communications Company L.P. for ConsolidationPP!14710/04/96 Official Bulletin No. 603PP!14810/15/96[[[BellSouth Telecommunications, Inc.s (BellSouth) Response to AT&Ts Petition for Arbitration Under the Telecommunications Act of 1996PP!14910/15/96[[[Exception of BellSouth Advertising & Publishing Corporation (BAPCO)PP!15010/15/96[[[Objection of AT&T to Sprints Motions for Intervention and for ConsolidationPP!15110/18/96[[[Notice of Order of the Eighth Circuit Court of Appeals Order Granting Stay Pending Judicial Review and Request for ReliefPP!15210/24/96[[[AT&Ts Motion to Reschedule Arbitration Trial and for Adoption of Revised Procedural SchedulePP!15310/28/96[[[Ruling on AT&Ts Motion to Reschedule Arbitration Panel Trial and for Adoption of Revised Procedural SchedulePP!15410/28/96[[[Amended Hearing NoticePP!15510/30/96[[[Ruling on Sprints Motion to ConsolidatePP!15611/01/96[[[BellSouth BAPCOs Supplemental Memorandum in Support of ExceptionP P !15711/12/96[[[AT&T Letter to LPSC Regarding the Appropriate Resale DiscountPP!15811/13/96 [[[AT&Ts Response to BAPCOs ExceptionPP!15911/13/96 Transcript of Open SessionPP!16011/22/96[[[Direct Testimony of John Hamman, Wayne Ellison, Ronald Shurter, David Kaserman, William Carroll, Joseph Gillan, L.G. Sather, and Don WoodPP!16111/22/96[[[Direct Testimony of Richard Emmerson, Gloria Calhoun, Robert Scheye, Alphonso Varner, and Keith Milner on Behalf of BellSouthPP!16212/03/96[[[Order Granting Party Status to BellSouth Advertising & Publishing Corporation and Amending Procedural SchedulePP!16312/06/96[[[Rebuttal Testimony of R. Shurter, D. Kaserman, W. Ellison, J. Gillan, J. Hannan, and W. Carroll on Behalf of AT&T Communications of the South Central States, Inc.PP!16412/06/96[[[Rebuttal Testimony of Daonne Caldwell, Gloria Calhoun, Dr. Richard Emmerson, Keith Milner, and Alphonso J. Varner on Behalf of BellSouthPP!16512/06/96[[[PreFiled Direct Testimony of Randall J. Cadenhead on Behalf of BellSouth Advertising & Publishing CorporationPP!16612/06/96[[[Rebuttal Testimony of Robert C. ScheyePP!16712/09/96[[[Letter Submitting to LPSC Affidavit of Richard Emmerson and RCS Exhibit 2 of Robert Scheyes Rebuttal TestimonyPP!16812/13/96[[[PreHearing Brief of AT&T Communications of the South Central States PP!16912/13/96[[[PreHearing Brief of BellSouthPP!17012/16/96[[[Hearing Transcript: Volume IPP!17112/17/96[[[Hearing Transcript: Volume IIPP!17212/20/96[[[Post Hearing Memorandum of BellSouth Advertising & Publishing CorporationPP!17312/23/96[[[AT&T Communications of the South Central States, Inc.s PostHearing BriefP P !17412/23/96[[[PostHearing Brief of BellSouthPP!17501/08/97[[[LPSC Report and Recommendation PP!17601/15/97[[[Transcript of Open SessionPP!17701/21/97 Letter to LPSC Requesting Service List Addition of S. HubbardPP!17801/22/97 [[[Letter to LPSC Requesting Service List Addition of Kentucky PSCPP!17901/24/97 Letter to LPSC Requesting Service List Addition of J. LambertPP!18001/28/97[[[Order Resolving Disputed IssuesPP!18102/12/97[[[Notice Establishing Procedural Schedule for Submission of Interconnection Agreement Adopted Pursuant to ArbitrationPP!18202/19/97 Transcript of Open SessionPP!18303/14/97[[[Interconnection Agreement between AT&T Communications of the South Central States, Inc. and BellSouthPP!18403/14/97[[[BellSouths Statement Regarding Remaining Disputed IssuesPP!18503/19/97 Transcript of Open SessionPP!18604/01/97[[[General Order Amending Regulations for CompetitionPP!18704/14/97[[[AT&T Letter to LPSC Regarding Revised Matrix of PricesPP!18804/16/97[[[Transcript of Open SessionPP!18906/10/97[[[Transcript of Open SessionPP!19006/10/97 BellSouths Letter to LPSC regarding NineState AgreementPP!19106/12/97[[[Order Resolving Disputed Issues Regarding Interconnection AgreementPP!19207/21/97[[[Interconnection Agreement between BellSouth and AT&T Communications of the South Central States, Inc.PP!19307/24/97[[[BellSouth Letter to LPSC Containing Selective Carrier Routing Status ReportPP!19408/11/97[[[AT&T Letter to LPSC Containing Additional Technical Provisions for Inclusion in the Interconnection AgreementP P !19508/20/97[[[Transcript of Open SessionPP!19609/10/97[[[LPSC Letter to BellSouth Acknowledging Receipt of Status Report in Compliance with OrderP P !19710/23/97 Order Approving Interconnection Agreement 6$APPENDIX C3 ă J LLc.e LLc.e J     F TAB ă  RECORD OF LOUISIANA PSC DOCKET NOS. 22022/22093 ă Cost Docket PP!19806/25/96[[[BellSouths Cost StudiesPP!19907/01/96[[[LPSC Letter to Service List Regarding Docketing of CasePP!20007/12/96[[[Official Bulletin No. 597PP!20108/07/96[[[Notice of Status Conference and Transfer to Administrative Hearing DivisionsPP!20208/14/96[[[Transcript of Open SessionPP!20308/20/96[[[Report of Preliminary Status Conference and Procedural SchedulePP!20409/24/96[[[Transcript of Open SessionPP!20509/27/96[[[AT&Ts First Set of Data Requests to BellSouthPP!20610/04/96[[[Report on Status ConferencePP!20710/09/96[[[Notice of Proposed Consolidation of Proceedings and Proposed Procedural SchedulePP!20810/21/96[[[LPSC Letter to Dismukes Retaining Acadian Consulting GroupPP!20910/23/96[[[Direct Testimony of Robert Scheye on Behalf of BellSouthPP!21010/30/96[[[Notice of Consolidation of ProceedingsPP!21111/01/96[[[Joint Motion to Modify Procedural Schedule Established October 9, 1996PP!21211/04/96[[[BellSouths Motion for Partial Stay and Request for Expedited HearingP P !21311/08/96[[[Notice of Modification of Procedural Schedule and Notice of Opportunity to Respond to Motion for Partial Stay and Request for Expedited Hearing Filed by BellSouthPP!21411/12/96[[[AT&Ts Letter to LPSC Responding to BellSouths Motion to StayPP!21511/13/96[[[Transcript of Open SessionPP!21611/26/96[[[BellSouth Letter Submitting Revised Exhibit DDC8PP!21711/27/96[[[Joint Motion to Amend Procedural SchedulePP!21812/03/96[[[Order Granting BellSouths Motion for Leave to File Supplemental Direct TestimonyPP!21912/03/96[[[Order on Joint Motion to Amend Procedural SchedulePP!22012/18/97[[[Sprint Letter to ALJ Regarding PreFiled TestimonyPP!22101/08/97[[[Notice of Revised Hearing Schedule and Extension of Deadline for Filing GlossaryPP!22201/09/97[[[Motion for Leave to File Supplemental Testimony, and Confidential and NonConfidential Supplemental Testimony of Kimberly DismukesPP!22301/10/97[[[AT&T and MCI Letter to LPSC Submitting Exhibit DJW3PP!22401/16/97[[[Order Granting Motion for Leave to File Supplemental TestimonyPP!22502/05/97[[[Order Denying BellSouths Motion for Partial StayPP!22602/06/97[[[Memorandum Requesting Rescheduling of HearingPP!22702/06/97[[[Notice of Revised Hearing SchedulePP!22802/07/97[[[Notice of Further Revision to Procedural SchedulePP!22902/10/97[[[Joint Glossary of Terms and AcronymsPP!23002/19/97[[[Transcript of Open SessionPP!23103/19/97[[[Transcript of Open SessionPP!23203/25/97[[[Notice of Status ConferencePP!23304/08/97[[[Report on April 7, 1997 Status Conference and Notice of Procedural ScheduleP P !23404/30/97[[[BellSouths Motion for Extension of TimePP!23505/01/97[[[Order Granting Motion for Extension of TimePP!23605/21/97[[[BellSouths Tariff FilingPP!23705/28/97[[[AT&Ts Consent Motion to Amend Procedural SchedulePP!23805/29/97[[[Order Granting Consent Motion to Amend Procedural SchedulePP!23906/12/97[[[AT&Ts Consent Motion and Order for Amendment for Procedural SchedulePP!24006/12/97[[[Order Granting Consent Motion to Amend Procedural SchedulePP!24106/20/97[[[Notice of Assignment Required Filings, and Opportunity for HearingPP!24206/27/97[[[BellSouths Comments on Proposed Increase in Contract AuthorizationPP!24307/03/97[[[Recommendation Regarding Increase in the Authorized Budget for Amount Acadian Consulting GroupPP!24407/11/97 BellSouths Cost StudiesPP!24507/18/97[[[BellSouth Letter to ALJ Regarding Status ConferencePP!24607/23/97[[[AT&T Letter to BellSouth Proposing Changes to SchedulingPP!24707/23/97[[[WorldCom Letter to ALJ in Response to BellSouths Letter Regarding Status ConferencePP!24807/25/97[[[MCI Telecommunications Corporations Motion to Extend Schedule and Require Training Regarding Cost StudiesPP!24907/28/97[[[Transcript of Special Open SessionPP!25008/01/97[[[Letter to ALJ Regarding Tutorial on Hatfield Model PP!25108/01/97[[[Report on July 31, 1997 Status Conference and Notice of Revised Procedural SchedulePP!25208/01/97[[[Notice of Date for BellSouth Tutorial PresentationPP!25308/04/97[[[Notice of Date for Intervenors Tutorial PresentationP P !25408/05/97[[[Ad Hoc Committee for Consumer Choice Letter to ALJ Regarding Payphone ServicePP!25508/07/97[[[BellSouth Letter to All Parties Regarding 600 Data Requests ReceivedPP!25608/26/97[[[BellSouths Motion for Leave to File Supplemental TestimonyPP!25708/26/97[[[BellSouth Letter to ALJ Regarding Its Statement of Generally Available Terms and ConditionsPP!25808/26/97[[[LPSCs Motion to Modify Procedural SchedulePP!25909/03/97[[[BellSouths Motion and Order for Expedited Hearing on Notices of DepositionPP!26009/04/97[[[Notice of Telephone Status Conference on Thursday, September 4, 1997 on Thursday, September 4, 1997 at 2:30 P.M.PP!26109/04/97[[[AT&Ts Objections to BellSouths Notice to Take DepositionsPP!26209/05/97[[[BellSouths Order of WitnessesPP!26309/05/97[[[Report on September 4, 1997 Telephone Status Conference and OrderPP!26409/05/97[[[AT&T Letter Submitting Errata Sheet for the Direct Testimony of James WellsPP!26509/08/97[[[Hearing Transcript: Volume 1PP!26609/09/97[[[Hearing Transcript: Volume 2PP!26709/10/97[[[Hearing Transcript: Volume 3PP!26809/11/97[[[Hearing Transcript: Volume 4PP!26909/12/97[[[Hearing Transcript: Volume 5PP!27009/15/97[[[Hearing Transcript: Volume 6PP!27109/16/97[[[Hearing Transcript: Volume 7PP!27209/17/97[[[Hearing Transcript: Volume 8PP!27309/24/97[[[Hearing Transcript: Volume 9PP!27409/29/97[[[Post Hearing Brief of BellSouthPP!27509/29/97[[[PostHearing Brief of WorldCom, Inc.P P !27609/29/97[[[Post Hearing Brief of MCI Telecommunications CorporationPP!27709/29/97[[[PostHearing Brief of Sprint Communications Company, L.P.PP!27809/29/97[[[PostHearing Brief of American Communication Services of Baton Rouge, Inc., American Communication Services of Louisiana, Inc., and American Communication Services of Shreveport, Inc.PP!27909/29/97[[[LPSC Staff Post Hearing BriefPP!28009/29/97[[[PostHearing Brief of Cox Louisiana Telecom II, L.L.C.PP!28109/29/97[[[AT&T Communications of the South Central States, Inc.s PostHearing BriefPP!28209/30/97 AT&T Letter to LPSC Submitting Omitted ExhibitsPP!28310/15/97[[[BellSouth Letter to ALJ Regarding 8th Circuit RulingPP!28410/17/97[[[Final Recommendation of the ALJP P !28510/24/97[[[Order of the LPSC Setting Rates 6$ APPENDIX C4 ă J LLc.e LLc.e J     F TAB ă  RECORD OF LOUISIANA PSC DOCKET NOS. 22020 ă  Resale Pricing PP!28606/17/96[[[BellSouth Telecommunications, Inc.s (BellSouth) Cost StudiesPP!28707/01/96 LPSC Letter Regarding Previous InterventionsPP!28807/29/96[[[Notice of Status ConferencePP!28908/02/96[[[Procedural SchedulePP!29008/13/96[[[BellSouths Motion to Convert August 20, 1996 Informal Presentation Conference to Informal Status ConferencePP!29108/14/96[[[AT&Ts Opposition to BellSouths Motion to Convert August 20, 1996 Informal Presentation Conference to Informal Status ConferencePP!29208/14/96[[[Transcript of Open SessionPP!29308/15/96[[[Notice of Assignment: Scheduling of Additional Status ConferencePP!29408/26/96[[[Report of Status ConferencePP!29508/30/96[[[Direct Testimony of Guy L. Cochran, Robert C. Scheye and William E. Taylor on Behalf of BellSouthPP!29608/30/96[[[Direct Testimony of Joseph Gillan on Behalf of AT&T Communications of the South Central States, Inc. and WorldCom, Inc., d/b/a LDDS WorldComPP!29708/30/96[[[Direct Testimony of Patricia McFarland on Behalf of AT&T Communications of the Southern States, Inc.PP!29808/30/96[[[Direct Testimony and Exhibit of Dr. Marvin H. KahnPP!29908/30/96[[[Direct Testimony of Greg Darnell on Behalf of MCI Telecommunications Corporation and MCImetro Access Transmission Services, Inc.P P !300'S  [ ckY!s#%#({*,+/13368:;=?ACDF 09/04/96[[[Report of Status Conference Procedural SchedulePP!30109/13/96[[[Rebuttal Testimony of Patricia McFarland on Behalf of AT&T Communications of the Southern States, Inc. PP!30209/13/96[[[Rebuttal Testimony of Greg Darnell on Behalf of MCI Telecommunications Corporation and MCImetro Access Transmission Services, Inc.PP!30309/13/96[[[Rebuttal Testimony and Exhibit of Dr. Marvin H. KahnPP!30409/13/96[[[Rebuttal Testimony of Joseph Gillan on Behalf of AT&T Communications of the South Central States, Inc. and WorldCom, Inc., d/b/a LDDS WorldComPP!30509/13/96[[[Rebuttal Testimony of Guy L. Cochran, William E. Taylor, and Robert C. Scheye.PP!30609/16/96[[[BellSouths Motion for Expedited Discovery and Leave to Present Surrebuttal Testimony; and Alternatively, Motion to Continue HearingPP!30709/16/96[[[Hearing Transcript: Volume 1PP!30809/17/96[[[Hearing Transcript: Volume 2PP!30909/18/96[[[Hearing Transcript: Volume 3PP!31009/26/96[[[Brief of Sprint Communications Company L.P.PP!31109/27/96[[[Proposed Findings of Fact and Conclusion of LawPP!31209/27/96[[[PostHearing Brief of BellSouthPP!31309/27/96[[[PostTrial Brief of AT&TPP!31409/27/96[[[PostHearing Brief of MCI Telecommunications CorporationPP!31509/27/96[[[PostHearing Brief filed by the Small Company Committee of the Louisiana Telephone AssociationPP!31609/27/96[[[Brief of the Public Service CommissionPP!31709/27/96[[[PostHearing Brief of WorldCom, Inc. d/b/a/ LDDS WorldComPP!31809/27/96[[[Post Hearing Comments Submitted on Behalf of Global Tel*LinkP P !31909/27/96[[[Original PostHearing Brief of the Louisiana Cable Telecommunications AssociationPP!32009/27/96 MCI Telecommunications Corporations Proposed Findings of Fact and Conclusions of LawPP!32110/01/96[[[Reply Brief of Sprint Telecommunications Company L.P.PP!32210/02/96[[[Reply Brief of AT&TPP!32310/02/96[[[Reply Brief of the Louisiana Public Service CommissionPP!32410/02/96[[[PostHearing Reply Brief of BellSouthPP!32510/02/96[[[PostHearing Reply Brief of MCI Telecommunications CorporationPP!32610/09/96[[[Recommendation Setting Wholesale Discount Rate at 20.72%PP!32710/14/96[[[BellSouths Exception to Administrative Law Judges Recommendation and Request for Oral ArgumentPP!32810/16/96[[[Transcript of Open SessionPP!32911/12/96[[[Order Setting Resale RatesPP!33012/17/96 Notice of Opportunity to CommentPP!33101/09/97[[[Comments on Behalf of Global Tel*Link, Inc.PP!33201/10/97[[[MCI Telecommunications Corporations Opposition to the Filing of BellSouths Exception to Administrative Law Judges Recommendation and Request for Oral ArgumentP P !33301/10/97[[[Opposition to Filing of Exception by BellSouth % APPENDIX D J LLa+^ LLa+^ J     #T\  P P# TABDESCRIPTION#XN\  P XP#PP#110/1/97Transcript of Open Session (LPSC 271 Docket and BellSouth/AT&T Arbitration Docket)PP#210/22/97Transcript of Open Session (LPSC Cost Docket)PP#311/3/97Affidavit of David BarronPP#41/29/97Order U22146 (BellSouth/Sprint Arbitration)PP#511/4/97Declaration of William DenkPP#610/28/97Affidavit of Aniruddha BanerjeePP#711/4/97Affidavit of Silas LeePP#8BellSouth OSS Interface Presentation (Videotape)PP#9General Subscriber Service Tariff ExcerptP P #10Private Line Services Tariff Excerpt   X0ÍÍ.X0ÍÍ.4& Before the d FEDERAL COMMUNICATIONS COMMISSION !Washington, D.C. 20554 ă " 1 " 1  x<x<X` hp x (#%'0*,.8135@8:. Pursuant to section 271(d)(2)(B) " which provides state commissions a formal consultative role on local issues in section 271 proceedings " the Louisiana PSC established a docket in December 1996 to consider BellSouths eligibility to provide interLATA services in its State. Compliance Order at 14. That docket involved discovery, hearings, and evidentiary submissions from such parties as AT&T, MCI, Sprint, WorldCom, the Louisiana Cable Telecommunications Association, ACSI, Cox Fibernet, the Telecommunications Resellers Association, and the Communications Workers of America. Id. at 1 n.1, 3 n.7. All interested parties had a chance to present their views and examine BellSouths evidence, although many chose to waive that opportunity. For instance, the U.S. Department of Justice did not participate   and CompTel withdrew from the proceeding rather than disclose whose interests it truly represents. Id. at 1 n.1. The state commission adduced evidence, evaluated the credibility of witnesses who were exposed to cross examination under oath, and reached conclusions on a nearly 6,200page record that included over 3,800 pages of testimony. The record of the Louisiana PSCs proceedings, including the Compliance Order issued at the conclusion of those proceedings, is reproduced as Appendix C of this application. See also App. D at Tab 1 (Oct. 1, 1997 transcript). In its Compliance Order, the Louisiana PSC provided a review of BellSouths checklist offerings, paying special attention to the pricing requirements of the Act and OSS access, which was the subject of a live technical demonstration before the commissioners. Id. at 415. The commission concluded that BellSouths Statement of Generally Available Terms and Conditions ( Statement)" as modified in accordance with the Louisiana PSCs instructions " meets each of the 14 checklist requirements. In addition to its assessment of BellSouths checklist compliance, the Louisiana PSC determined that BellSouths entry into the long distance market will further the Acts goal of assuring that consumers get the full benefit of competition and will serve the public interest. Compliance Order at 14. [T]he evidence presented, said the State commission, mandates a finding that consumers in Louisiana, both local and long distance, would be well served by BellSouths entry into the long distance market. Id. These determinations by the expert agency responsible for overseeing telecommunications markets in Louisiana provide the proper starting point for this Commissions review of BellSouths application.Finally, to carry out its responsibilities under section 252, the PSC established separate cost proceedings to establish rates for interconnection, unbundled network elements, and resale. The Louisiana PSCs cost proceedings were as thorough as its docket under section 271. Before establishing a discount rate in its Resale Order, the Louisiana PSC held extensive proceedings, considered detailed cost studies, and consulted an independent expert.X` hp x (#%'0*,.8135@8: (see PrimeCo Primer, News). Because these carriers offer service exclusively over their own facilities " including cell sites, switches, and wireline network connections " the facilitiesbased requirement of Track A is satisfied as well. See Wright Aff. 9, 117, 119. The only remaining issue is whether PrimeCo, Sprint Spectrum, and MereTel are competing providers of telephone exchange service for purposes of section 271(c)(1)(A). As explained below, the plain language of this phrase encompasses PCS providers as well as wireline providers. While that should end the inquiry, market evidence confirms that PrimeCo and Sprint Spectrum (and almost certainly MereTel as well) do compete in an economic sense with BellSouths wireline operations for local customers in Louisiana. 1.PCS Service Is Telephone Exchange Service While exchange access and cellular service are expressly excluded from the definition of telephone exchange service for purposes of section 271,IX` hp x (#%'0*,.8135@8:"X` hp x (#%'0*,.8135@8: and MFN clauses,X#X` hp x (#%'0*,.8135@8:X` hp x (#%'0*,.8135@8:. These factors will give BellSouth lower marketing costs inregion than other potential new entrants and position BellSouth as a serious competitor to AT&T, MCI, and Sprint.JX` hp x (#%'0*,.8135@8: