WPC6 2BEJ Z Courier }K-#hxP7P#HP LaserJet 4HPLAS4.PRSx  @\gX@2!6FL 3|hCourierUnivers^09CSS999S]+9+/SSSSSSSSSS//]]]Ixnnxg]xx9?xgxx]xn]gxxxxg9/9MS9ISISI9SS//S/SSSS9?/SSxSSIP!PZ9+ZM999+999999S9S/xIxIxIxIxIlnIgIgIgIgI9/9/9/9/xSxSxSxSxSxSxSxSxSxSxIxSxRxSxSxS]SxIxIxInInInZnIxigIgIgIgIxSxSxSxZxSxZxS9/9S999Su]ZZxSg/gCg9g9g/xSbxSxSxSxSxn9n9n9]?]?]?]ZgFg/gMxSxSxSxSxSxSxxZgIgIgIxSg9xS]?g9xSi+SS88WuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxN>iiffSSxSrff8SS?"xxSxXxxS姧0 S88xcxxxxxxxxxx8S{g]ix{S8ixSi`xlxxxxxxxxxxYxxxxxxofxGcxxxxxxxSxxxxxxxJxxxxJxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx8xxx8xxx8xxx8xxxxxxxxxxxxx{]iY]S{Y`MfGx`Y.(oS{V]x]iG`x`cYccJiMrYuxPr{{`x8irr{Y]rrz88iiii{xiiirrr{8`SJ8Muu]daqqZZnn{{xu{{M{aZZ5M5M҅P?ka1Technicala5Technical2rrarrEa6Technicala2Technicala3Technicala4Technical2 KK4KK"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+SS8-8WuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxN8HH"&H>XHH8HB8>HH^HH>"".2",2,2,"222N2222"&22H22,006"6."""""""""""2H,H,H,H,H,XAB,>,>,>,>,""""H2H2H2H2H2H2H2H2H2H2H,H2H1H2H2H282H,H,H,B,B,B6B,H?>,>,>,>,H2H2H2H6H2H6H2""2"""2F866H2>>(>">">H2;H2H2H2H2XHB"B"B"8&8&8&86>*>>.H2H2H2H2H2H2^HH6>,>,>,H2>"H28&>"H2?22!!WFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFddddddddddddddddddddddddddddddddddddddddN$<<$.2",2222`2 LL2 LL2L"",,2d""A.SSxSSJJSJS+SSSSS8SSSSSSSSS.xJxJxJxJxJorJiJiJiJiJ8.8.8.8.{SxSxSxSxS{S{S{S{SxSxJ{SxSxSxS{S`SxIxSxIqIqIrSrS{dgIiSiSgIxSxSxSxSxS{S{S8.SSSS8Sz]SSuSg/g-ԍSee, e.g., Pacific Comments at 5; SWBT Comments at 7; SWBT Reply at 3; Roseville Comments at 12; NYNEX Comments at 6 (current rules provide "early warning" of jurisdictional cost shifts); US West Comments at 9.   Several commenters argue that a usagebased approach would eliminate the need for waivers or  X -  an alternative adjustment mechanism, and claim this is a virtue of the current interim rules. : yO0-ԍUS West Comments at 9; NYNEX Comments at 56; GTE Comments at 34; United Comments at 3. US   West foresees competition between ILECs and IXCs changing their billing and collecting   relationship, because IXCs will not wish to bill through their competitors (and ILECs also may   /not want to bill for their competitors), and expresses concern that a fixed allocation method  XK-would not reflect this change in billing arrangements.jKh: yOd#-ԍUS West Comments at 6. Accord, CBT Comments at 3. j "K0* % %CC"Ԍ X-  ԙ15. ` ` Some ILECs claim that the current rules are not an undue burden or expense, or  X-  that they see no compelling reason for change.X: yOb-ԍSee, e.g., NYNEX Comments at 5; Roseville Comments at 2 and 4; CBT Comments at 2; BellSouth Comments at 23; US WEST Comments at 24; Pacific Comments at 45; NYNEX at 3; SWBT Comments at 10; SWBT Reply at 2.  BellSouth argues that the proposed  X-  <methodologies would actually increase the costs it bears as a result of regulation.I: yOk-ԍBellSouth Comments at 4.I Other parties  X-  /agree that the implementation costs outweigh any of the supposed benefits,Ex: yO -ԍGTE Comments at 34.E and that the   wproposed alternative procedures would be an unnecessary burden, because the usagebased method  X-is selfadjusting.Q: yOF -ԍId.; United Comments at 3.Q  X_-   16. ` ` Several large ILECs foresee an increase in the interstate allocation resulting from  XH-  \the adoption of a fixed cost allocator. H: yO-ԍBellSouth Comments at 4; Pacific Comments at 3; SWBT Comments at 89, 11; US West at 8, NYNEX  yOY-at 5. See also Roseville Comments at 4 (predicting arbitrary shifts between the jurisdictions).  Some parties assert that such an increase would be   inappropriate, arguing that the portion of OB&C expenses attributable to interstate billing is  X -  zdeclining.i : yO-ԍUS West Comments at 3, 56; SWBT Reply at 2.i Pacific argues that the proposed methods leave no fair and practical avenue for   recovery of increased interstate expenses. In particular, proposals that allocate some expense to   the SLC would unfairly burden business customers, because the residential SLC has reached its  X -  mcapped maximum in most jurisdictions.G : yO-ԍPacific Comments at 6.G ILECs might drop IXC billing and collection  X -  altogether, with the unfortunate result of customers facing multiple bills.d! : yO-ԍId. at 4. Accord, PaPUC Reply at 34. d Southwestern Bell   predicts that ILECs would try to recover increased interstate allocation from the IXCs, which  X-would lead the IXCs to take back their billing and collection business.E": yO-ԍSWBT Comments at 11.E    Xb-  B17. ` ` A few large ILECs argue that the proposals in the Notice are inconsistent with   yother statements of Commission policy. Roseville states that the Commission has consistently   Lfavored cost allocations based on actual relative use, and that the Notice does not sufficiently"40"0* % %CC"   Lexplain how circumstances have changed since the current procedures, which incorporate this  X-  \costcausation principle, were adopted in 1987.I#: yOb-ԍRoseville Comments at 3.I In a similar vein, NYNEX argues that "the   Commission's rules contemplate separations "shortcuts" only where "practicable" and where "their   application produces substantially the same results as would be obtained by the use of more  X-  xdetailed procedures;" which, according to NYNEX, the proposed rules do not.g$X: yO-ԍNYNEX Comments at 4, citing 47 C.F.R. Section 36.1(e).g US West asserts   -that there is an unexplained inconsistency between the methodologies the Commission proposes  Xv-  in the Notice, which would increase allocation of OB&C expenses to interstate, and the   Commission's stated goal in adopting the current interim rules, which was "to reverse the  XH-unanticipated increases in interstate assignments."% H: yO -ԍUS West at 3, n.5, citing National Exchange Carrier Association, Inc., Petition for Declaratory Ruling Pertaining to Interstate Common Line Allocation of Other Billing and Collecting Expense Under Parts 36 and 69  yOq-of the Commission's Rules, Memorandum Opinion and Order, 7 FCC Rcd 8554, 8557, para. 24 (1992). GVNW also develops this point in its Comments at 10.  X -  18. ` ` Various large ILECs also advise against selecting permanent OB&C rules at this   =time. SWBT advises the Commission to refrain from reforming OB&C before universal service   .issues are resolved, arguing that universal service policies could have considerable impact on  X -  ;OB&C expenses.d& : yOV-ԍSWBT Reply at 4. Accord, USTA Reply at 2. d US West states that, because the concept of "telephone users" and the services   they receive are changing, OB&C questions should be resolved in the context of a comprehensive  X -  jurisdictional separations review proceeding.G' ` : yO-ԍUS West Comments at 7.G SWBT and Pacific claim that the methodologies  X-proposed in the Notice do not sufficiently address the issue of the SLC.( : yO1-ԍSWBT Comments at 4; See also Pacific Reply at 23 (SLC not addressed in Notice plan #3).  Xb-  19. ` ` Two large ILECs, Bell Atlantic and Ameritech, support adoption of a fixed   Mallocator. They agree that for OB&C expenses, as for all expenses not easily attributed to a   specific service, fixed allocators are easier to administer, easier to audit, and more predictable  X-  =than usagebased allocators.) : yON!-ԍBell Atlantic Telephone Companies ("Bell Atlantic") Comments at 2; Ameritech Operating Companies ("Ameritech") Comments at 3. Ameritech maintains that because a fixed allocator is simpler, it   <is also more cost effective than usagebased systems, which involve time consuming separations   studies of dubious utility, and argues that its customers would ultimately benefit from a less")0* % %CC "  X-  expensive procedure.*: yOy-ԍAmeritech at Comments at 34; Ameritech Reply at 2 and 4. (Ameritech argues that, for the same reasons, the entire separations process should be replaced with a fixed allocator.) Bell Atlantic adds that reform is needed to remedy an inadequacy of the   Kpresent rules, which "do not specify a procedure for apportioning OB&C to the expense of billing  X-the SLC."+ : yO-ԍBell Atlantic Comments at 1, quoting National Exchange Carrier Association, Inc., Memorandum  yOk-Opinion and Order, 7 FCC Rcd 8554 at 8555 (1992).   X-  20. ` ` Bell Atlantic and Ameritech argue that a fixedfactor methodology for allocating   LOB&C expenses is just as accurate as a methodology based on measuring usage. Bell Atlantic  Xv-  confirms the Commission's tentative conclusion in the Notice that, because billing and collection   jexpenses are fixed and not usagesensitive, an allocator based on measuring usage is not more  XH-  accurate than a fixed one.o,Hx: yOq-ԍBell Atlantic Comments at 12; Bell Atlantic Reply at 2.o Bell Atlantic also maintains that even if a fixedfactor methodology   were marginally less accurate than a usagebased allocator, that defect would still have to be  X -  evaluated against other considerations, such as administrative burden and expense.I- : yO-ԍAmeritech Comments at 3.I Bell Atlantic  X -further notes that a fixed allocator has worked well with nontraffic sensitive costs.i. : yOL-ԍBell Atlantic Comments at 2, Bell Atlantic Reply at 23.i  X -  21. ` ` In regard to the Notice's proposal of an alternative allocation if an ILEC loses all   or most of its IXC customers, Ameritech advises the Commission to express its willingness to   entertain waiver requests. Ameritech suggests that the Commission establish a rule allowing for  X-  expedited action, either on the ILEC's motion or sua sponte, if an ILEC loses a certain volume   \(perhaps 50 percent) of its IXC billing and collection business. The Commission could also   establish a presumption that, if an ILEC loses all of its IXC billing and collection business, the  XM-ILEC would continue to allocate a maximum of five percent to interstate services.I/M( : yO&-ԍAmeritech Comments at 5.I  X-  22. ` ` Two Regional Bell Operating Companies ("RBOCs") responded to the invitation  X-  -in the Notice to submit fixed allocation methodologies of their own.J0 : yOq!-ԍNotice at para. 13.J Bell Atlantic proposes that   the third and fourth options in the Notice be combined, so that expenses would be apportioned   among five categories: (i) interstate toll; (ii) intrastate toll; (iii) local exchange service; (iv) other" H 00* % %CC"   ?intrastate service; and (v) subscriber line charge. This would, Bell Atlantic claims, more appropriately attribute OB&C expenses to all the underlying subcategories.  X-  223. ` ` While Pacific Bell would prefer to keep the interim rules, it offers as an alternative   its own fixed allocation methodology. Pacific Bell contends that its proposal more closely reflect   the ILECs' current activities, and would result in an interstate allocation closer to the present one   than the Commission's proposals. Pacific would also distribute expenses among five categories:   m(i) ILEC toll; (ii) other carrier toll; (iii) other intrastate services (including CLASS); (iv)   measured line service; and (v) basic services and the Subscriber Line Charge. The fifth category  X1-  would be allocated equally between the state and interstate jurisdictions.M11: yO -ԍPacific Comments at 1 and 7.M Pacific further   =proposes that the loss in the "other carrier toll" category of either 50 percent of business or of   Lthe largest customer would result in the elimination of that category, with expenses then being   Mredistributed equally among the remaining four categories. According to Pacific, automatic   redistribution avoids the burden of a procedure to adjust allocations if an ILEC loses OB&C  X -customers.:2 X: yO-ԍId.:  X- B.Trade Associations and Consultants  Xb-  24. ` ` The industry trade associations and consultants that support retaining the interim  XK-  rules advance many of the same arguments as the larger ILECs.$3XK: yO-ԍJohn Staurulakis, Inc. ("JSI"), ICORE Inc. ("ICORE"), Organization for the Protection and Advancement of Small Telephone Companies ("OPASTCO"), National Exchange Carrier Association ("NECA"), and United States Telephone Association ("USTA"). $ Several of these parties   maintain that while the interim rules properly allocate OB&C expenses on a costcausative basis,  X-  fixed allocators would be arbitrary and would not reflect principles of costcausation.4: yO-ԍJSI Comments at 23; ICORE Comments at 2; OPASTCO Comments at 34; NECA Comments at 4; USTA Reply at 2. Some of   these commenters deny that the interim procedures are difficult to audit or burdensome to   limplement, or claim that it is the proposed fixed allocators that would be administratively  X-burdensome.j5` : yO -ԍJSI Comments at 2; OPASTCO Comments at 2; USTA Reply at 2j  X-  $25. ` ` Like many of the larger ILECs that oppose the methodologies proposed in the  X-  Notice, some associations and consultants expressed concern that a fixed allocation solution would" 50* % %CCQ"  X-  Kinappropriately shift more cost recovery to the interstate jurisdiction.6: yOy-ԍOPASTCO Comments at 23; NECA at 4; USTA Reply at 3. See also NTCA Comments at 8. JSI maintains that the use   of fixed allocators falsely assumes all companies are providing comparable levels of interstate   billing and collecting, when ultimately many ILECs will be billing only basic local services and  X-  the SLC.C7X: yO-ԍJSI Comments at 2.C USTA cautions that, because billing and collection services are not tariffed, if the   fixed allocators shift expenses to the interstate jurisdiction, ILECs will not be able to recover the  X-  increased expenses unless they can successfully renegotiate contracts with their IXC customers.A8: yO& -ԍUSTA Reply at 3.A   ZUSTA also states that none of the proposed methods should be adopted without considering the  X_-impact on Carrier Common Line ("CCL") rates and on Long Term Support.f9_x: yO -ԍId. See also AT&T Comments at 45.f  X1-  26. ` ` If the Commission adopts a fixed allocation methodology, JSI would support   incorporation of an alternative procedure triggered by a loss of 50 percent of an ILEC's interstate   billing and collection revenue. If that happened, JSI argues, the corresponding messages should  X -  be excluded from the OB&C allocation process.C: : yO-ԍJSI Comments at 4.C JSI also "recommends that the Commission   establish the current five percent allocation to billing the SLC as a floor." JSI states that even   yas the IXCs take back their billing and collection, the five percent minimum interstate allocation   is reasonable, and that if an ILEC provides only state toll, local, and SLC billing, "JSI submits   that the only allocation of OB&C expense to the interstate jurisdiction should be the percentage  Xy-established for billing the SLC which may exceed the current five percent cap'.";;y: yO-ԍId. ;  Xb- ` `   XK-  P27. ` ` NECA joins in the arguments that fixed allocators are arbitrary and shift too much   OB&C expense to the interstate jurisdiction, and directs particular criticism to the first and third  X-  methods proposed in the Notice, because they appear not to allocate any expenses to the  X-  xsubscriber line.D<( : yO-ԍNECA Comments at 4.D NECA also notes that, while the second and fourth methods do assign a portion   of OB&C expense to the SLC, it appears this assignment would cause allocations of interstate   OB&C expense to common line to exceed the 5 percent limit. NECA therefore requests   -clarification, if one of these methods is selected, of how the amounts in excess of the five percent" <0* % %CC"  X-  cap are to be recovered.m=X: yOy-ԍId. at 45; See also GVNW Comments at 24 and 7. (Methods 2 and 4 assign no expenses to the SLC; these expenses would be assigned to interstate, even if the LEC neither performs nor offers interstate B&C service. Assigning expenses to a service that is not provided is potentially confiscatory.)m In addition, NECA concurs in the argument that the trigger   imechanisms proposed in the Notice would place significant burdens on both the Commission and   |the ILECs, and could be avoided by retention of a usagebased method, which would  X-automatically reflect changes in IXCs' actual use of ILECs' billing and collection services.D>: yOT-ԍNECA Comments at 6.D   X-  28. ` ` Cathey Hutton & Associates, Inc. ("CHA") agrees with the Commission that,   because billing and collection is a jointlyprovided service, there can be no single correct   -economic or accounting method, but rather the best method will be a common sense method with  XH-  -acceptable results.C?Hx: yOq-ԍCHA Comments at 5.C CHA, however, would prefer a usagebased method, because, unlike a fixed   .allocator, it would automatically reflect any reduction in IXC use of ILEC billing and collection  X -  services, and there would be no need for waivers.@ : yO-ԍCHA Comments at 5 and 7. NTCA also makes this point in its Comments at 5 and 9. CHA also maintains that the proposed fixed   allocation methods would shift expenses to the interstate jurisdiction, causing the ILECs to lose   money on billing and collection, to discontinue provision of billing and collection services   j(causing more expenses to fall on the state ratepayer), or to raise billing and collection rates on  X -  the IXCs, with the likely result of IXC takeback.EA : yO-ԍCHA Comments at 56.E CHA observes that many independent ILECs   are already losing money on billing and collection, because they have signed contracts for less   annual interstate revenue than is allocated to the interstate Part 69 billing and collection element.   These ILECs provide billing and collection services at a loss in order to provide single source  Xb-billing to their customers.@Bb( : yO;-ԍId. at 4.@  X4-  29. ` ` CHA proposes a revenuebased plan it calls "Derived Benefit Allocation Method."   =Allocation to the state jurisdiction would be based on "bill and keep," which would include all   local revenue and possibly some toll, depending on the state access plan. Revenue derived from   Zprovision of interstate billing and collection service would be included in the interstate allocation.   >CHA sees several benefits arising from its plan. First, CHA argues that it would be easy to   Limplement and administer, because it requires existing accounting records only. Second, CHA   asserts that no waiver would ever be required, because allocation to the interstate jurisdiction" B0* % %CC"   would correspond with IXC use of ILEC billing and collection services. Finally, CHA contends   that, in contrast to the proposed fixed allocators, this plan would tend to decrease the interstate   {allocation, with the desirable result that the IXCs would continue to use ILEC billing and  X-collection services.BC: yO4-ԍId. at 78.B  X-  30. ` ` GVNW Inc., Management ("GVNW") asserts that the Commission is mistaken in   .not foreseeing any significant near term reduction in the share of IXC billing performed by the   ILECs. GVNW argues it would be unrealistic to expect ILECs, more than 200 of which lost   .money on their interstate billing and collection service in 1993, to continue to offer the service   at a loss. GVNW further reports that AT&T has notified independent ILECs of plans to perform   [its own recording and rating functions, and contends that the spread of equal access may also   bring significant declines in ILEC billing for the IXCs, because while AT&T has usually used  X -  the ILEC's billing service, the alternative carriers usually do not.FD X: yO-ԍGVNW Comments at 67.F GVNW asks regulators to bear   in mind that small ILECs are as much at risk of losing billing and collection business from the  X -  ZRBOCs as from the IXCs, and contends that the four proposals in the Notice bear no resemblance   Zto cost causation, because as much as 66 percent of OB&C expenses could be allocated based on  X-services that a company may not even provide.oE: yO)-ԍId. at 4 and 8. See also n.47, supra.o  Xb-  31. ` ` GVNW proposes usercount allocation methodology. Stating that a user count   Zwould better reflect cost causation than the proposed fixed allocators do, GVNW argues the latter  X4-  -may assign expenses to services not provided, and therefore cannot meet a cost causation test.XF4x: yO]-ԍThe service user count would be made for each of the following: interstate end user common line; interstate toll; interstate special access; interstate private line; state end user common line; state toll; state special access; state private line; basic local; extended area service; directory advertizing; local ancillary services; CATV;  yO-cellular; PCS; and other nonregulated services. GVNW Comments at 11. See also PaPUC Reply at 4; NARUC  yO}-Reply at 8; and  NTCA Comments at 9.X   GVNW acknowledges its plan would require minor changes to Part 69. Alternatively, GVNW   Zurges that expenses be assigned based on billed revenue, or, as a third choice, be treated as other  X-  nonregulated services under Part 64.HG( : yO -ԍGVNW Comments at 1012.H If, however, the Commission does adopt a fixed allocator,  X-  GVNW asks the Commission to consider alternative proposals for small ILECs.BH : yOA#-ԍId. at 78.B Regarding the  X-  alternative adjustment mechanisms proposed in the Notice, GVNW requests that a trigger not be" H H0* % %CC"  X-  tied to a decrease in the existing level of service, because ILECs not currently doing any toll  X-billing will be unable to show any drop.@I: yOd-ԍId. at 5.@V  X-  @32. ` ` In its comments, the National Telephone Cooperative Association ("NTCA") argues   that the difficulty in finding a perfect costcausation method should not lead regulators to   conclude that the relative mix of billed services is irrelevant, or that a relative use surrogate does  Xx-  not exist or would not be appropriate to apply.JJxX: yO -ԍNTCA Comments at 3 and 5.J NTCA contends rather that usagebased methods  Xa-  need not be complicated, and would better serve the Commission's goals.@Ka: yO -ԍId. at 5.@ A fixed allocator,   by contrast, would ignore differences among ILECs, or an ILEC's variations over time, and thus  X3-  would produce anomalous results, it asserts.@L3x: yO\-ԍId. at 3.@ The discussion in the Notice of possible alternative  X -  adjustment mechanisms demonstrates, according to NTCA, this flaw in the basic proposal.@M : yO-ԍId. at 5.@   KNTCA concurs in the argument that a usagebased allocator like user counts is superior to a fixed   allocator because it would automatically reflect changes such as IXC takeback, and thus negate  X -  xthe need for alternative mechanisms.BN : yO -ԍId. at 89.B NTCA further suggests expanding the list of service types   .for which users would be counted to conform roughly with the services detailed in customers'  X -  [bills.@O ( : yO-ԍId. at 9.@ NTCA also contends that detariffed billing and collection expenses should be allocated   according to Part 64 rules, which it suggests are more flexible and more in keeping with the   competitive, marketdriven nature of these services than the Part 36 jurisdictional separations rules  Xd-are.DPd : yO-ԍId. at 1011.D  X6- C.Interexchange Carriers  X-   33. ` ` MCI Telecommunications Corp. ("MCI") criticizes the proposed methods of   allocation as arbitrary and lacking a relevant factual basis. MCI would prefer to have OB&C   zexpenses follow ILEC revenues as a proxy for expenses , and claims this approach would be"H P0* % %CC"  X-  .more consistent with the Commission's procompetitive policies.DQ: yOy-ԍMCI Comments at 3. D MCI asserts that although  X-  =the Commission rejected a revenue allocation method in the Reconsideration Order,_RX: yO-ԍReconsideration Order, 3 FCC Rcd 5518. _ growing   \competition in the industry, combined with the Commission's goal that the adopted method   "should reflect costcausation principles, and should not be unnecessarily burdensome to  X-  implement and administer," make revenue allocation still the best alternative.IS: yO= -ԍMCI Comments at 4.I MCI states that   "[i]n an industry as fluid as today's telecommunications industry, separations rules, where   iappropriate, should allocate joint and common costs according to an indicator of why those costs  X_-  yare being incurred.":T_x: yO -ԍId.: MCI states that it would be unreasonable for the Commission to deviate   from its longstanding record of seeking factual bases for cost allocations where, as here, objective  X1-bases are available and easy to administer.BU1: yO-ԍId. at 45.B  X -  !34. ` ` MCI maintains that switched access and special access revenue, plus 25 percent   of end user revenues, are attributable to interstate, and the rest is intrastate. MCI advocates   calculating the sum of the interstate revenues and dividing them by total ILEC revenues, which   Ldefines a percentage that should be assigned to interstate for the purpose of allocating OB&C  X -  expenses.OV : yO-ԍId. at 5 and Appendix 1.O This method would also eliminate the need for an arbitrary assignment of five   [percent of OB&C expenses to interstate, and would not require a fixed percentage allocation in   case of IXC takeback. MCI adds that, if an abrupt change to this method would have a harsh  Xb-effect on some ILECs, the Commission could grant waivers or phase the change in gradually.CWb( : yO;-ԍMCI Comments at 6.C  X4-  P"35. ` ` AT&T Corp. ("AT&T") comments that, even if the methodology the Commission   iselects increases interstate allocation of OB&C expenses, that outcome should have no impact on   the interstate access charges assessed on IXCs and other access customers. Except for charges   /related to the SLC, those expenses represent detariffed services that should continue to be   assigned to nonregulated accounts under Part 69. AT&T also asserts that only a minor portion   of OB&C expenses relate to the SLC and are thus recoverable through CCL rates. According" W0* % %CC"  X-  to AT&T, the Commission in the SLC Billing Expense OrderaX: yOy-ԍSLC Billing Expense Order, 7 FCC Rcd 8554.a correctly concluded that a five   percent allocation of OB&C to the common line element is generous and enables ILECs to  X-  recover fully the cost of billing the federal SLC. AT&T stresses that nothing in the Notice  X-  changes the wellreasoned finding of SLC Billing Expense Order in this area, and asks the   zCommission to make it clear that a new allocation method for OB&C expenses will not result  X-in a CCL rate increase for interstate access customers.OYX: yO-ԍAT&T Comments at 45.O  X_- D.State Public Utility Commissioners  X1-  p#36. ` ` With minor qualifications, state public utility commissions and the National  X -  Association of Regulatory Utility Commissioners ("NARUC") support the proposals in the Notice,  X -  and agree that a fixed allocator makes sense.*ZX : yO-ԍWashington Utilities and Transportation Commission ("WUTC"), New York Department of Public Service ("NYDPS"), Pennsylvania Public Utility Commission ("PaPUC") (with usage based alternative for small  yO,-ILECs), and NARUC.  * These parties all prefer a fixed allocation method  X -  =because OB&C expenses are not attributable to any specific service.z[ : yO-ԍWUTC Comments at 2; NYDPS Reply at 1; PaPUC Reply at 2; NARUC Reply at 6.z Therefore, they explain,   a methodology that requires companies to identify every line on the bill as either intrastate or   interstate is overly burdensome on the companies, virtually unauditable by regulators, and in the  X -  end assigns these expenses no more accurately than a fixed allocator would.h\ : yO-ԍWUTC Comments at 2; NYDPS Reply at 1; NARUC Reply at 6.h State regulators   find that a fixedfactor approach is consistent with principles of costcausation, and would allocate  Xy-  expenses reasonably among the companies that collect revenue.V]y( : yOR-ԍWUTC Comments at 2; NYDPS Reply at 3.V They add that a fixedfactor   xmethodology possesses the additional virtue of reducing administrative expenses associated with  XK-the jurisdictional separations process.i^K : yO-ԍWUTC Comments at 2; NARUC Reply at 6; NYDPS Reply at 3. i  X-  }$37. ` ` WUTC and NYDPS support the second method in the Notice, which would divide  X-  OB&C expense among state toll, interstate toll, and the SLC.Z_H : yO"-ԍWUTC Comments at 12; NYDPS Reply at 23.Z WUTC contends that because the   SLC is subject to jurisdictional separations, this is the only fixedfactor split that approaches an"_0* % %CC'"  X-  equal distribution between the jurisdictions.D`: yOy-ԍWUTC Comments at 2.D NYDPS agrees with the Commission that there is   no reason to expect that IXCs will soon substantially reduce their use of ILEC billing and   collection services. NYDPS states further that, if ILECs eventually bill for future interstate   services, a separate category should be developed for these services, and notes that, under the  X-Telecommunications Act of 1996, ILECs will likely bill for their own interstate operations.LaX: yO-ԍNYDPS Reply at 2. L  Xv-  %38. ` ` PaPUC, however, expresses concern over the likely shift of OB&C expenses to   the interstate jurisdiction and argues that the probable result will be that ILECs will either lose   [money on billing and collection, or lose the contracts altogether. PaPUC particularly urges the   Commission to consider how this might affect small ILECs, which often provide billing and  X -  =collection services at a loss in order to spare their customers multiple bills.Eb : yO-ԍPaPUC Reply at 34. E PaPUC suggests   that nonprice cap companies should have the option of either using whatever fixed allocator is   [adopted, or user counts, or relative use among service categories. PaPUC argues that it would   lbe counterproductive and detrimental to the public interest to preclude small ILECs from   providing billing and collection services to IXCs, and convenient single source billing to end  X -users.@c x: yO-ԍId. at 4.@  Xy-  Q&39. ` ` NARUC and PaPUC also assert that the list of services should be expanded to  Xb-  conform roughly with the services detailed on subscribers' bills.db: yO-ԍPaPUC Reply at 4; NARUC Reply at 8. Accord NTCA Comments at 9. NARUC and PaPUC propose   -a fixedfactor methodology that would allocate OB&C expenses in equal part among: (i) interstate  X4-  Ltoll; (ii) other interstate; (iii) intrastate toll; (iv) SLC; and (v) other intrastate. This would result  X-  [in a 45 percent allocation to the interstate jurisdiction.Te: yOf-ԍPaPUC Reply at 4; NARUC Reply at 8.T In regard to an alternative adjustment   mechanism, these parties support a waiver process, rather than a specific trigger, because a waiver  X-process would be more flexible and would recognize individual facts and circumstances.Tf( : yO -ԍPaPUC Reply at 5; NARUC Reply at 9.T  X-l à  X-5IV. DISCUSSION ă  X- " f0* % %CC"Ԍ X-  o'40. ` ` After reviewing these comments and reply comments, and weighing the issues   commenters raise, we recommend that the Commission adopt a fixed allocation methodology that   would divide OB&C expenses equally among three subcategories: interstate toll; intrastate toll;  X-  and local exchange service.g: yO4-ԍIn other words, we recommend the Commission adopt the first fixed allocation methodology suggested  yO-in the Notice, at para. 9. Under this procedure, two thirds of the OB&C expenses would   be allocated to the state jurisdiction, and one third would be allocated to the interstate jurisdiction.  X-  =We do not recommend that the Commission adopt at this time an automatic adjustment trigger   for cases in which an ILEC loses its largest IXC customer or a given percentage of its existing   ktoll billing and collecting operations. Only in cases in which an ILEC provides no interstate   billing and collection for other carriers do we recommend an automatic reduction of the interstate   assignment to five percent to cover the cost of billing the SLC. In all other cases, we recommend that the Commission receive petitions for waiver on a casebycase basis.  X -  (41. ` ` We disagree with parties claiming that, compared to allocation factors based on   user counts or revenue, a fixedfactor approach is a more arbitrary basis for allocating OB&C  X -  Zexpenses.h  : yO-ԍ Parties arguing that fixed factors are a more arbitrary, less costcausative method of allocating OB&C expenses include, among others, NYNEX Comments at 3, JSI Comments at 23, ICORE Comments at 2;  yO-OPASTCO Comments at 34; GVNW Comments at 4 and 8; MCI Comments at 3; and USTA Reply at 2. See  yO-paragraphs 14, 24, 31, and 34, supra.  Nearly all these expenses are joint or common with respect to the individual services   appearing on customers bills, and there is no costcausative method of allocating these joint and  X-  \common expenses.si : yOI-ԍ A carrier's ability to attribute costs to individual services in a costcausative manner largely depends on the nature of the costs, i.e., on whether the costs are incremental, joint, or common. If a costcausative relationship exists between a cost and a particular service, we consider that cost "incremental" with respect to the service. Incremental cost (usually expressed per unit of output) is the additional cost a firm will incur as a result of producing an additional increment of a service. Such cost may include the cost of a dedicated facility or operation used by only the service in question. It may also include the cost of a shared facility or operation used by that service together with other services. The costs of some shared facilities and operations, however, are not incremental with respect to the individual services they support. We refer to such nonincremental costs as joint or common. We use the term "joint" when two or more services are produced in fixed proportion by the same facility (i.e., when one service is produced, a second service is generated by the same production process at no additional cost). We use the term "common" when the relative proportions of those services can vary. Such costs may be joint or common to all services provided by the firm or only to a subset of those services. If a cost is joint or common with respect to a subset of services, the cost is incremental with respect to the subset (because a firm can avoid the cost by eliminating the entire subset) but is not incremental with respect to the individual services in the subset.s As with nontraffic sensitive loop plant, development of an allocation"i0* % %CCL"  X-  method based on actual usage measurement probably would be neither possible nor reasonable.j@: yOy-ԍ For a discussion of allocating the costs of NTS loop plant, see Amendment of Part 67 of the  yOA-Commission's Rules and Establishment of a Joint Board, Decision and Order, 96 FCC 2d 781, para. 17 (1984) ([W]ith respect to NTS plant, development of a true costbased pricing method would be difficult if not impossible. . . . [t]he Joint Board reached essentially the same conclusion when it noted in the Second Recommended Decision and Order at para. 52 that a purely cost based allocation of this plant between the  yOa-jurisdictions would be extremely difficult to develop since the cost of the plant does not vary with usage.'" See  yO)-also Allocation of Costs Associated with Local Exchange Carrier provision of Video Programming Services,  yO-Notice of Proposed Rulemaking, FCC 96214, CC Docket No. 96112 (rel. May 10, 1996).  Because these joint and common expenses are not susceptible to a cost  [causative method of allocation, our recommendation of a fixedfactor plan for assigning OB&C expenses should be grounded in such considerations as fairness, convenience, and predictability.  X-  )42. ` ` Thus we agree with CHA's statement that, because billing and collection is a   jointly provided service, there can be no single correct economic or accounting method, but rather   the best method will be a common sense method with acceptable results. We differ, however,   from CHA, NTCA and others who argue that, although not grounded on principles of cost   causation, an allocation procedure based on relativeuse measurements should be applied  X -  nevertheless for reasons of convenience.Vk : yO-ԍ CHA Comments at 5; NTCA Comments at 3 and 5.V These and other parties contend that such a procedure   would be more convenient than a fixedfactor method because it would be selfadjusting,   Nautomatically reflecting billing changes such as IXC takeback, and would thus allow the  X -  LCommission to dispense with a trigger or waiver procedure.l ` : yO-ԍ See, e.g,, US West Comments at 9; NYNEX Comments at 56; GTE Comments at 34; United Comments at 3; CHA Comments at 5 and 7; NTCA Comments at 5 and 9. Instead, we find persuasive the   >argument advanced by Ameritech, Bell Atlantic, and all the participating state public utility   jcommissions, that fixed allocators are easier to administer, easier to audit, and more certain and  X-predictable in their effect than allocators based on usage measurements.m : yO-ԍBell Atlantic Comments at 2; Ameritech Comments at 3; WUTC Comments at 2; NYDPS Reply at 1; PaPUC Reply at 2; NARUC Reply at 6.  Xb-  $*43.` ` Other parties contend that the administrative burden of implementing the new  XK-  Zmethodology outweighs any benefit it might bring.WnK: yO !-ԍ BellSouth Comments at 4; GTE Comments at 34.W In our view these parties greatly exaggerate   =the burden on the industry of shifting to a fixed allocator. Indeed, the burden of the transition   pales when compared to the industrywide benefits of administrative ease, certainty, and   auditability afforded by the use of a fixed allocator. We also find a simple fixed allocator should"n0* % %CC"   be cheaper for ILECs to implement than procedures requiring timeconsuming separations studies,  X-so end users may ultimately benefit from the change through lower charges.o: yOb-ԍAmeritech at Comments at 34; Ameritech Reply at 2 and 4. (Ameritech argues that, for the same reasons, the entire separations process should be replaced with a fixed allocator.)  X-  _+44.` ` NYNEX asserts that "the Commission's rules contemplate separations shortcuts'   only where practicable' and where their application produces substantially the same results as  X-  jwould be obtained by the use of more detailed procedures.'"`p : yO^ -ԍ NYNEX Comments at 4, citing 47 C.F.R. section 36.1(e).` NYNEX's point, however, does   not apply in the case of joint and common expenses such as those associated with OB&C.   Because there are no "more detailed procedures" that would produce precise separations results   for these costs, fixedfactor methodology should not be regarded as an accounting shortcut.   [Instead, from an economic or costcausative perspective, we view fixedfactor methodology as   an equally valid alternative approach with the significant advantage of simplicity and ease of administration.  X -  ,45.` ` In our 1987 recommendation we said that "[w]e believe that assignment of these   z[OB&C] costs should reflect the three basic services for which the ILECs render bills: local,  X -  state toll and interstate toll."q : yO-ԍ Amendment of Part 67 of the Commission's Rules and Establishment of a Joint Board, Recommended  yO-Decision and Order, 2 FCC Rcd 2078, 2083 (1987) (Recommended Decision).  That remains our view and our recommendation. Neither the  X-  three other alternatives proposed in the Notice nor the fixedfactor proposals made by Bell   Atlantic, Pacific Bell, or NARUC and the PaPUC, surpass the simplicity or clarity of the three  way division we recommended in 1987, or otherwise offer benefits that induce us to depart from  XK-  that position.rK: yO-ԍ See Pacific Bell Comments at 1 and 7; Bell Atlantic Comments at 23; NARUC Reply at 9; and PaPUC Reply at 5. In particular, we reject plans that call for allocating an equal portion of OB&C   \expenses to the SLC. We see no justification for departing at this time from the established   industry benchmark of five percent. The maximum annual revenue from the federal SLC is  X-  !$42.00 per residential customer;s ` : yO-ԍ Recommended Decision 3 FCC Rcd at 2083, para 45. See also, National Exchange Carrier Association, Inc., Petition for Declaratory Ruling Pertaining to Interstate Common Line Allocation of Other Billing and  yO -Expense under Parts 36 and 69 of the Commission's Rules, Memorandum Opinion and Order, 7 FCC Rcd 8554, 8558, paras 2728, 34.  on average ILECs bill approximately $600 per year per"H s0* % %CC"  X-  residential line.[tX: yOy-ԍ The average residential total bill (including local, toll, touchtone, call waiting, and taxes) is $50.69. Staff analysis of FCC Universal Service Fund Data Request, Amendment of Part 36 of the Commission's Rules and  yO -Establishment of a Joint Board, Order, 9 FCC Rcd 7962 (1994). [ Allocating a third, or a quarter, or even a fifth of OB&C   xexpenses to the SLC would thus consume a substantial percentage of the total SLC revenue. This  X-  Kseems to us an unreasonable result.u: yOk-ԍ NTCA argues that in considering the OB&C costs of revenue accounting, SLC billing is no more "minor" than local exchange billing, or any other service billed. NTCA Comments at 7. We anticipate that the five percent assignment will be used  X-  only by those ILECs that do not perform billing functions for the IXCs.v@: yO -ԍ Recommended Decision 3 FCC Rcd at 2083, para 45. AT&T characterizes the 5 percent allocation as "generous" and says it enables ILECs to recover fully the cost of billing the SLC. AT&T Comments at 45. We therefore reject   \the second and fourth plans in the Notice, the plan submitted by Bell Atlantic, and the plan submitted by NARUC and the PaPUC.  X_-  -46. ` ` Neither of the remaining two plans we considered, one submitted by Pacific Bell,  XH-  and the third plan in the Notice, offer advantages over the fixed factor that we recommend.   Pacific Bell's plan would distribute expenses among no fewer than five categories: (i) ILEC toll;   (ii) other carrier toll; (iii) other state services (including CLASS); (iv) measured line service; and   (v) basic services and the Subscriber Line Charge, with this last category to be allocated equally  X -  [between the state and interstate jurisdictions.Mw : yO5-ԍPacific Comments at 1 and 7.M Pacific suggests that loss in the "other carrier   \toll" category of either 50 percent of business or of the largest customer would result in the   elimination of that category, with the associated expenses to be redistributed equally among the   remaining four categories. Pacific Bell argues that its plan would result in allocation to the   interstate jurisdiction closer to the present one. The present allocation system, however, is not   grounded on principles of cost causation, so choosing fixed factors only to mimic its results   Lseems to us without merit, unless the result is also fair and consistent. Pacific Bell also argues   [that its plan's automatic redistribution feature would avoid the burden of a procedure to adjust  X4-  allocations if an ILEC lost its billing and collection customers.:x4( : yO -ԍId.: As we have said, parties   ]exaggerate the burden to a company of filing a petition for waiver, and the burden to the Commission of reviewing it.  X-  .47. ` ` The third plan offered for our consideration in the Notice proposed to divide   OB&C expenses equally among four subcategories: interstate toll; intrastate toll; local exchange  X-  .service; and other intrastate services, including CLASS. No argument appeared in the Notice," x0* % %CCp"   Lthe comments, or the reply comments to support using these particular factors, and there is no   yobvious benefit to be derived from the addition of a fourth category. We therefore recommend that the Commission not adopt this plan.  X-  /48. ` ` We acknowledge that dividing the allocation of OB&C expenses equally among   jinterstate toll, intrastate toll, and local service will in at least some cases increase the allocation   to the interstate jurisdiction. Numerous commenters from the ILEC industry view this increased   allocation to interstate as a major drawback to this plan. We disagree, and we explain our reasoning below.  X -  n049. ` ` First, many ILECs and their associations contend that an increase in the interstate   =allocation is inappropriate because they believe that the portion of OB&C expenses related to  X -  interstate is on the decline.ny : yOe -ԍ See, e.g., US West Comments at 3, 56; SWBT Reply at 2; n GVNW reports that AT&T has notified independent ILECs of   <plans to perform its own billing and collection functions, and that the spread of equal access may   bring less ILEC billing for IXCs, because, while AT&T has usually used the ILEC's billing  X -  service, the other IXCs usually have not.?z X: yO-ԍ GVNW Comments at 67.? In addition, US West foresees direct competition   between ILECs and IXCs leading to a disinclination on the part of both to commingle their  Xy-  bills.@{y: yO-ԍ US West Comments at 6.@ We conclude, however, that the circumstances of individual ILECs are likely to vary   significantly, and that it is premature to speculate on the effect of local competition on the billing   activities of ILECs. Under our recommended procedures, ILECs that do little IXC billing and   ycollection should allocate five percent of OB&C expenses to the interstate jurisdiction to cover the cost of billing the federal SLC.  X-  2150. ` ` The second argument parties advance in opposition to an increased allocation to   the interstate jurisdiction is that such allocation would cause IXCs to stop using the ILECs as   billing and collection agents altogether, leaving the ILECs to pay the entire cost of billing and   collection, and to present their customers with the unwelcome prospect of multiple bills. This   Mresult seems to us unlikely. IXCs must bill their customers in some manner. Faced with the   .choice between bearing onethird of the ILECs' OB&C expenses, or bearing the entire expense   themselves, we believe that efficient IXCs generally will continue to prefer to pay only a fraction of the total cost.  X -  251. ` ` The third argument made against an increased allocation to the interstate   jurisdiction is that, because ILECs provide billing and collection services to IXCs under fixed" x{0* % %CC["   contractual arrangements, ILECs will not be able to recover the increased allocation of OB&C   expenses to interstate unless they can successfully renegotiate contracts with their IXC customers.   [We observe, however, that the ILECs are free to renegotiate their contracts with IXCs, and will   Leventually be able to do so. While the transfer from a lower interstate allocation to a onethird   interstate allocation may cause a temporary decline in the profitability of some ILECs' billing   operations, we do not foresee that any losses ILECs may endure as a consequence of their bad   \bargains will be severe. If, however, cases occur where the effect of these rules on an ILEC   would be unduly harsh, we recommend that ILECs file a petition for waiver with the   Commission, through which the particular circumstances of each case can be weighed individually.  X -  352. ` ` Because we think the likelihood of ILECs being unable to recover a large amount   0of their billing and collection expenses, or of their losing the IXCs' billing and collection   Zbusiness altogether, has been greatly exaggerated, we recommend that the Commission not adopt   Zthe PaPUC's suggestion that nonprice cap companies be allowed to choose among a fixedfactor,  X -  Ka usercount, or a relativeuse methodology in allocating their OB&C expenses.=| : yO -ԍ PaPUC Reply at 34.= We again note   that any ILEC that provides no billing or collection for an IXC need allocate only five percent   to the interstate jurisdiction. If a pattern of waiver requests develops that seems to indicate,   contrary to our expectation, that we need to revise the separations rules governing allocation of   OB&C expenses for nonprice cap ILECs, the Commission could refer that issue, and the record accumulated through the waiver process, to us for consideration.  X-  453. ` ` Finally, some parties perceive an increase to the interstate jurisdiction to be at odds   with the Commission's stated goal of "revers[ing] the unanticipated increases in interstate  X-  Massignments" when it adopted the current interim rules.o} X: yO-ԍ Reconsideration Order, 3 FCC Rcd at 5523, paras. 2728. The Commission said the record indicated that implementation of the new procedures would lead to results contrary to Joint Board and Commission expectations, that the formula had proven difficult to administer, and that the formula might no longer be accurate. o In our view, the Commission, on   reconsideration, reasonably rejected a cumbersome and confusing cost allocation methodology   that, by producing increases where decreases had been expected, proved unpredictable as well.   The fixedfactor system, which should be convenient and inexpensive to administer, easy to audit,   and predictable in its results, cures those defects. The Commission also said it believed that   reduced billing and collection for IXCs by ILECs should be reflected in reduced interstate  XN-  assignments.4~N@: yO?#-ԍ Id. 4 As we have explained, such circumstances will not be widespread, and, if they   arise, can be handled best on an individual basis, taking into account a billing ILEC's unique"7~0* % %CC"   /circumstances without sacrificing the administrative ease of a fixedfactor methodology for general application.   X-  1554. ` ` We disagree with parties that advise against establishing permanent OB&C expense   allocation rules at this time. Any advantage of waiting to resolve these issues in a comprehensive   jurisdictional separations review proceeding, as US West advises, or until new universal service   =rules are in place, as SWBT suggests, seems to us far outweighed by the benefits of replacing  X_-  the interim rules with the fixedfactor methodology we recommend.p_: yO-ԍ US West Comments at 7; SWBT Reply at 4; Accord USTA Reply at 2. p The new fixedfactor   methodology is preferable to the interim rules for the reasons given above, and therefore the   =sooner it is implemented the better. Moreover, interim rules are by their nature unsatisfactory,   .because they do not give affected parties a steady basis on which to conduct their affairs and   ynegotiate agreements. Finally, we note that, if the Commission waited to reform any of its rules   until all other rules that might affect the new regime were reformed, the agency would be unable   .to adopt or amend its regulations quickly, to the detriment of the industry and end users alike.   NTCA suggests that detariffed billing and collection expenses should be allocated according to   >Part 64 cost allocation rules, which NTCA believes to be better suited conceptually for this  X-  purpose.AX: yO-ԍ NTCA Comments at 1011.A We take no position on NTCA's suggestion at this time, except to note that it lies  Xy-  youtside the scope of the Notice, and that the record does not provide broad support for such a  Xb-change.b: yO-ԍ GVNW says treating OB&C as a nonregulated activity under Part 64 would be its third choice, after user count or revenue based plans.  X4-  2655. ` ` Few commenting parties argue for an automatic adjustment mechanism to a fixed X-  factor allocation system.@X@: yO-ԍ Those parties addressing the issue of an automatic adjustment mechanism usually cited the need for one  yO-as an avoidable evil, or as evidence of a flaw in the fixedfactor allocation proposal. See paras. 14, 23, and 32  yO-supra. @ Ameritech suggests, and we recommend, that the Commission   .establish a presumption that, if an ILEC loses all its IXC billing and collection business, it may   jcontinue to allocate a maximum of five percent to interstate services to cover the cost of billing  X-  the federal SLC.C` : yO -ԍ Ameritech Comments at 5. C NARUC and the PaPUC support a waiver process rather than a specific  X-  trigger, because a waiver process would be flexible and sensitive to individual circumstances.P : yOb#-ԍ NARUC Reply at 9 and PaPUC Reply at 5.P" 0* % %CC"   We agree with NARUC and the PaPUC, and perceive a further advantage to waivers, in that they   will allow the Commission to identify any emerging pattern of cases for which the new   =methodology appears not to work as we expect. Such cases would indicate a need to refine or   revise the OB&C expense allocation rules. We therefore recommend that the Commission not adopt a specific automatic adjustment mechanism at this time.  X-  Xv-  X_-f  V. RECOMMENDATION CLAUSES ă  X1-  756. ` ` For all the reasons discussed in this Recommended Decision, this Federal State Joint Board recommends, pursuant to Section 410(c) of the Communications Act of 1934, as " 0* % %CC"   amended, 47 U.S.C.  410(c), that the Federal Communications Commission amend Part 36, Subpart D of the Commission's Rules, 47 C.F.R.  36, Subpart D.  X- ` ` hh, ` ` FEDERAL COMMUNICATIONS COMMISSION ` ` William F. Caton  XH-` ` Acting Secretary "10* % %CC"  X- Appendix  X- Parties Filing Comments Ameritech Operating Companies ("Ameritech") AT&T Corp. ("AT&T") Bell Atlantic Telephone Companies ("Bell Atlantic") BellSouth Telecommunications, Inc. ("BellSouth") Cathey, Hutton & Associates, Inc. ("CHA") Cincinnati Bell Telephone ("CBT") GVNW Inc./Management ("GVNW") GTE Service Corporation ("GTE") ICORE Inc. ("ICORE") John Staurulakis, Inc. ("JSI") MCI Telecommunications Corp. ("MCI") National Exchange Carrier Association ("NECA") National Telephone Cooperative Association ("NTCA") NYNEX Telephone Companies ("NYNEX")   <Organization for the Protection and Advancement of Small Telephone Companies ("OPASTCO") Pacific Bell and Nevada Bell ("Pacific") Roseville Telephone Company ("Roseville") Southwestern Bell ("SWBT") United and Central Telephone ("United") US West Communications, Inc. ("US West") Washington Utilities and Transportation Commission ("WUTC")  X- Parties Filing Reply Comments Pennsylvania Public Utility Commission ("PaPUC") National Association of Regulatory Utility Commissioners ("NARUC") New York Department of Public Service ("NYDPS") United States Telephone Association ("USTA")