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I.X2uvw9xa2IndentedLeft-indented textu?C ? A.` ` a3IndentedLeft-indented textvHP ? ` ` 1. a4IndentedLeft-indented textwQp- ? ` `  a.` 'a5IndentedLeft-indented textx[ܽ ? ` `  '(1) hh-2yǘz{G|sa6IndentedLeft-indented textydK ? ` `  'hh-(a)4a7IndentedLeft-indented textzl݇ ? ` `  'hh-4i)h:a8IndentedLeft-indented text{u-b ? ` `  'hh-4:a)ppAa1InterrogatoresStarts with A. at margin, 1 at first indent|UZZI.2}}~6Qa1OutlineE+O4*ÿUI. A. 1. a. (1) (a) i) a)4 =(O4WGl *O4}$ a2OutlineE+O4*ÿUI. A. 1. a. (1) (a) i) a)4 =(O4WGl *O4~/ a3OutlineE+O4*ÿUI. A. 1. a. (1) (a) i) a)4 =(O4WGl *O4: a4OutlineE+O4*ÿUI. A. 1. a. (1) (a) i) a)4 =(O4WGl *O4E 2!ʞ~=a5OutlineE+O4*ÿUI. A. 1. a. (1) (a) i) a)4 =(O4WGl *O4P   a6OutlineE+O4*ÿUI. A. 1. a. (1) (a) i) a)4 =(O4WGl *O4[   a7OutlineE+O4*ÿUI. A. 1. a. (1) (a) i) a)4 =(O4WGl *O4f  a8OutlineE+O4*ÿUI. A. 1. a. (1) (a) i) a)4 =(O4WGl *O4q 2ԩ9KK-ZxLeventhal6@6wwLeventhal, Senter & Lerman Doc Style*O4ÿUVGl.EQ    #XN\  PXP#"i~'^09]SS999S]+9+/SSSSSSSSSS99]]]Sxnxxng?Snxgx]nxxxxn9/9aS9S]I]I9S]/9]/]S]]I?9]SxSSIC%CW9+Wa999+999999S9]/xSxSxSxSxSxxInInInInI>/>/>/>/x]SSSSx]x]x]x]xSxSx]SSxSxSf]xSxSxSxIxIxWxIx{nInInInISSSWS]a?/?]?9?]]WW]n/nKn9nCn/x]xx]x]SSxxIxIxI]?]?]?]WnUn9nax]x]x]x]x]x]xxWnInInIx]n9x]]?n9xSz+SS8-8WuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNH yO-ԍ TNZL Opposition at 8.> In fact, Sprint's interconnection agreement provides that it is entitled to the same rate (2.8 cents/minute) paid by Clear (or the lowest rate paid by any other competing toll service provider) when Sprint's total annual interconnection charges paid to TCNZ reach $15 million (N.Z.), which is approximately one quarter of Clear's total  X -interconnection charges.BZ d  {O-ԍ See Section 1.3 of item 4 of the TCNZ/Sprint agreement, which is described in an ex parte letter to William F.Caton, Secretary, Federal Communications Commission, from Albert Halprin, Counsel for TNZL, December 16, 1996 at 12, and attached as an exhibit to the letter.B AT&T does not offer any new information that TCNZ has charged discriminatory rates to other carriers. TCNZ's volumebased discounts are not set at a level  X -that excludes all but a single carrier, and therefore we disagree that these charges are per se  X -discriminatory.  yO-ԍ The access charge rules, for instance, permit carriers to offer term and volume discounts for various rate  {O-elements.  See, e.g., 47 C.F.R.  69.110(f)(h) (entrance facilities); 47 C.F.R.  69.111(i)(k) (tandem switched transport); 47 C.F.R.  69.112(e)(g) (directtrunked transport). We have noted that term and volume discounts  {O8-have a beneficial effect on competition. See, e.g., In the Matter of Expanded Interconnection with Local  {O-Telephone Company Facilities, Report and Order and Notice of Proposed Rulemaking, 7 FCC Rcd 7369, 7457 (1992). Accordingly, we agree with the Bureau's determination that the volume X-based interconnection rate TNZL offers Clear is not discriminatory.  Xb-x15. ` ` We are also unpersuaded by AT&T's arguments concerning Clear's resale rights. The Bureau did not conclude, as AT&T avers, that "Clear's ability to resell its interconnection arrangement is an adequate alternative to TCNZ's ability to delay or  X-discriminate among competitors."c  {O&-ԍ See AT&T Telecom New Zealand Application at 7.c As noted above, the Bureau found that TCNZ's" 0*(()" interconnection rate does not discriminate among competitors. In addition, the Bureau found that Clear's "back to back" resale rights, i.e., the right to resell interconnection services it has purchased from TCNZ, has the beneficial effect of limiting the rate TCNZ can charge other  X-carriers for the same services.Z! {O4-ԍ Telecom New Zealand Order at  21.Z In effect, the rate TCNZ charges Clear is a ceiling. We note that, if the Bureau had concluded that TCNZ's interconnection rates were otherwise discriminatory, Clear's ability to resell interconnection would not make TCNZ's rates reasonable. However, it is appropriate to note that Clear's "back to back" rights will have a beneficial effect of limiting TCNZ's ability to raise its interconnection rates. x  X1-x16.` ` Next, we turn to MCI's claim that, despite having "back to back" resale rights with TCNZ, Clear has been unable to resell interconnection from TCNZ to other carriers. Specifically, MCI alleges that TCNZ refuses to: (1) allow Clear to resell Caller Line Identification, which is a signaling element that enables carriers to provide billing and other services based on identifying the calling party's number; (2) provide number portability of Clear's resale customers' access codes; or (3) permit Clear to resell TCNZ's interconnection services to a thirdparty carrier for some geographic locations while the carrier uses TCNZ's  X-interconnection services in other geographic locations.  MCI states that, as a result, Clear is not reselling interconnection to any other carriers and that "TCNZ remains the only carrier  Xb-from whom ... interconnection may be purchased.";"bZ yOm-ԍ MCI Petition at 8.;  X4-x17. ` ` We note that TCNZ has agreed to offer the services MCI has requested.# 4 yO-ԍ Letter to William F.Caton, Secretary, Federal Communications Commission, from Albert Halprin, Counsel for TNZL, September 22, 1997 at 1. To the extent TCNZ is using the contractual dispute as a pretext to avoid offering the requested services, we believe that is a matter that is properly raised with New Zealand's regulatory authorities, and not with us.  X- Moreover, we note that TNZL asserts, and MCI does not refute, that Clear is, in fact, reselling  X-TCNZ's interconnection services to two other carriers.$ {O-ԍ Id at 23. See, also, Letter to William F.Caton, Secretary, Federal Communications Commission, from Albert Halprin, Counsel for TNZL, April 25, 1997 at 23.  X-x18. ` ` Finally, MCI has misconstrued the "specific condition" the Bureau imposed on TNZL. The Order states that the Bureau "make[s] the prompt provision of reasonable and nondiscriminatory interconnection for international carriers including nondiscriminatory access to volumebased discounts a specific condition of today's grant of TNZL's  X|-application."d%|,  {OY%-ԍ See Telecom New Zealand Order at  23.d MCI argues that the Bureau improperly relied on this condition to conclude"| %0*(("  X-that New Zealand had achieved compliance with our ECO test.?& yOy-ԍ MCI Opposition at 89.? We do not agree. This condition specifically imposes on TNZL a continuing obligation to provide promptly to other carriers (including Sprint, which had signed an interconnection agreement for a limited duration) reasonable and nondiscriminatory interconnection for international services and is intended to ensure that TCNZ's future behavior complies with the ECO standard for interconnection. This condition is no different than the condition that we routinely impose on carriers authorized to resell international private lines for the provision of switched services. We require in all such cases that the country at the foreign end of the private line continue to  XH-satisfy the ECO test for the provision of those services.'^HX {OQ -ԍ See, e.g., Overseas Common Carrier Section 214 Applications, Actions Taken, Public Notice, DA 97519,  {O -March 13, 1997, at Appendix A; In the Matter of Regulation of International Accounting Rates,  First Report and  {O -Order ,  7 FCC Rcd 559 (1991) at  24. See, supra,  5.  X -x19. ` ` AT&T's application for review of the New Zealand Equivalency Order raises the same arguments with respect to New Zealand's interconnection regime as its application  X -for review of the Telecom New Zealand Order.( ~ {O-ԍ Compare AT&T Telecom New Zealand Application, supra note 16, at 58, with AT&T Equivalency  {O-Application, supra note 21, at 37. Accordingly, for the reasons stated above,  X -we reject its arguments with regard to the Bureau's decision in the New Zealand Equivalency  X -Order. x  X-x20.` ` Effective Regulatory Framework: MCI asserts that the Bureau "failed to address the overriding problem that limits effective competitive opportunities in New Zealand:  Xj-the lack of an effective, independent regulator.";)j yO-ԍ MCI Petition at 2.; MCI argues, in particular, that our rules require a regulatory body to establish and enforce nondiscriminatory interconnection rules, and  X<-that neither the Commerce Commission nor the Ministry of Commerce has done so.J*<j  {OW-ԍ Id. at 5; MCI Reply at 34.J MCI further contends that the Ministry is not effective because its sole regulatory authority derives from its threats to reimpose price controls to deter anticompetitive behavior, and that such  X-threats are hollow and unconvincing.=+  yO!-ԍ MCI Petition at 56.= MCI also avers that the Commerce Commission does not have the responsibilities traditionally associated with a telecommunications regulator, and "has demonstrated a remarkable reluctance to act even in investigative or enforcement  X-proceedings.",X@  yO%-ԍ MCI Petition at 6. MCI cites as a specific example of the Commerce Commission's ineffectiveness complaints that several of Clear's customers made concerning the bundling of cellular and toll services by TCNZ. MCI Petition at 57. The Commerce Commission responds that it investigated Clear's complaint and"'+0*(('" determined that there was insufficient evidence to conclude that TCNZ's actions would lessen competition. Memorandum to John Feil, General Manager, from Dick Adam, Acting Chief Investigator, re "Termination Report: MOAs Premier Plan and Connect Agreements," dated 9 September, 1993, attached to Commerce Commission letter, at 2. The Commerce Commission stated that there was no evidence that bundling lessened competition, and some evidence that it was procompetitive; some telecommunications users benefitted from bundling and others were no worse off than they would have been without bundling; and Clear's share of the toll market had increased during the time TCNZ bundled services. The Commerce Commission also concluded that TCNZ's bundling of services was not predatory.  AT&T similarly argues that the Bureau's finding that New Zealand has an",0*((" effective regulatory regime "is belied by the lengthy, unsatisfactory process of redress for new  X-entrants denied nondiscriminatory interconnection by TCNZ."Y- yOj -ԍ AT&T Telecom New Zealand Application at 8.Y  X-x21. ` ` The Commerce Commission notes that it conducted three full investigations after receiving 120 complaints about the telecommunications industry in the past three years, and that "[t]he fact that only a few complaints proceeded to full investigation reflects the Commission's assessment that prima facie breaches of the [Commerce] Act were not disclosed or, for example, that the matter was best dealt with by private parties or policy agencies such  XH-as the Ministry of Commerce."e. H`  yOY-ԍ Letter from John Feil, General Manager, Commerce Commission (New Zealand), to Donald H. Gips, Chief, International Bureau, Federal Communications Commission, Re: File No. ITC96097 Petition for Reconsideration MCI Corporation/Telecom New Zealand Limited, February 27, 1997, at 2 ("Commerce Commission letter").e In reply, MCI reasserts its claim that the Commerce Commission conducted only one investigation after receiving 84 complaints against TCNZ. MCI argues further that, even if the Commerce Commission had conducted two investigations specific to TCNZ, as TCNZ claims, that this "does little to bolster confidence in the effectiveness of the system." MCI further contends that the Commerce Commission has not initiated a single enforcement action against TCNZ or utilized its statutory power to require  X -TCNZ to produce documents or provide sworn testimony.=/ H  yO-ԍ MCI Petition at 57.=  X-x22. ` ` The test for an effective regulatory framework is whether "there is separation between the foreign regulator and the operator of international facilitiesbased services, and whether there are fair and transparent regulatory procedures in the destination  XK-market."0K {O!-ԍ Telecom New Zealand Order at  31. See Foreign Carrier Entry Order at 3894. The Bureau concluded that, on balance, these factors were present in New Zealand. The Bureau noted that the New Zealand regulatory regime is legally distinct from TCNZ and TNZL and that sufficient regulatory transparency exists to allow competitors to know what mechanisms are available to redress perceived violations of the law by TCNZ or  X-TNZL._1j {O '-ԍ Telecom New Zealand Order at  1819, 34._ To the extent that MCI argues that these regulatory procedures are insufficient in" 10*((" practice, we believe it is relevant to review market conditions. We find of critical relevance that competition for international services exists in New Zealand. TNZL's competitors include Clear, Telstra and Sprint, all of which offer facilitiesbased international  X-telecommunications services, as well as numerous resellers.@2 {O4-ԍ See supra  7.@ While AT&T and MCI contest the adequacy of New Zealand's regulatory institutions and procedures, we are not persuaded that regulatory oversight in New Zealand is so lacking that competition is unable to take root there. Market conditions in New Zealand, therefore, support the conclusion that there is sufficient regulatory oversight in New Zealand to protect and promote competition there. Thus, we do not agree with MCI or AT&T that the Bureau erred in concluding that New Zealand satisfies the ECO test's requirement for an effective regulatory framework. x  X -x23. ` ` AT&T's application for review challenging the New Zealand Equivalency  X -Order raises the same arguments with respect to New Zealand's regulatory regime as those in  X -its application for review of the Telecom New Zealand Order.3 Z {O-ԍ Compare AT&T Telecom New Zealand Application, supra note 16, at pp. 810, with AT&T Equivalency  {O-Application, supra note 21, at pp. 79. Accordingly, for the reasons stated above, we also reject the arguments that AT&T makes in its application for review of  X -the New Zealand Equivalency Order. h,CONCLUSION  XS-x24. ` ` For the reasons stated above, we deny AT&T's application for review and MCI's petition for reconsideration of the International Bureau's decision to authorize Telecom New Zealand to acquire and operate facilities for the provision of switched, private line, and other authorized services between the United States and New Zealand. We also deny AT&T's application for review of the companion order authorizing Communications Telesystems International to resell private lines for the provision of switched services between the United States and New Zealand. " 30*((" ORDERING CLAUSES  X-x25.` ` Accordingly, IT IS ORDERED, pursuant to Sections 1.104(b) and 1.115(g) of our rules, 47 C.F.R.  1.104(b) and 1.115(g), that the petitions for reconsideration and applications for review in the abovecaptioned proceedings are DENIED. x x` `  hhFEDERAL COMMUNICATIONS COMMISSION x` `  hhMagalie Roman Salas  X -x` `  hhSecretaryh x  X -