WPC' 25BJZ;Courier3|j '#X\  P6G;qP#HP LaserJet 5PHPLAS5P.PRS5x  @\ Y@X@ yO-#X\  P6G;qP#2"gKXCourierTimes New Roman"i~'^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+SS88WuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNU5?6Technical[3]C^iTechnical Document StyleCC} -2( -Ct )B<';<   Technical[4]C^iTechnical Document StyleCC -2( -Ct )B=&=>   Technical[1]C^iTechnical Document StyleCC -2( -Ct )B>4?$@     Technical[7]C^iTechnical Document StyleCC -2( -Ct )B?&AB  . 28@6A}A7B7CF8Technical[8]C^iTechnical Document StyleCC -2( -Ct )B@&CD  . Paragraph[1]C^i1. a. i. (1) (a) (i) 1) a)C -2( -Ct )BA$ab Paragraph[2]C^i1. a. i. (1) (a) (i) 1) a)C -2( -Ct )BB/cd` ` ` Paragraph[3]C^i1. a. i. (1) (a) (i) 1) a)C -2( -Ct )BC:ef` ` `  2;D 9E9FR:G;Paragraph[4]C^i1. a. i. (1) (a) (i) 1) a)C -2( -Ct )BDEgh` ` `  Paragraph[5]C^i1. a. i. (1) (a) (i) 1) a)C -2( -Ct )BEPij` ` ` hhh Paragraph[6]C^i1. a. i. (1) (a) (i) 1) a)C -2( -Ct )BF[kl Paragraph[7]C^i1. a. i. (1) (a) (i) 1) a)C -2( -Ct )BGfmn 2AH;I<J{=K?Paragraph[8]C^i1. a. i. (1) (a) (i) 1) a)C -2( -Ct )BHqop Default Paragraph FoDefault Paragraph FontI11#XP\  P6QXP##C\  P6QP#toc 1toc 1J` hp x (#44` hp x (#toc 2toc 2K` hp x (#4 4 ` hp x (#2aJLAMDN%FOCHtoc 3toc 3L` hp x (#4 4 ` hp x (#toc 4toc 4M` hp x (#4 <4 <` hp x (#toc 5toc 5N` hp x (#4<4<` hp x (#toc 6toc 6O` hp x (#44` hp x (#2cQPvJQ KR'MSEOtoc 7toc 7P toc 8toc 8Q` hp x (#44` hp x (#toc 9toc 9R` hp x (#44` hp x (#index 1index 1S` hp x (#4 4 ` hp x (#2OWTQUSVUWVindex 2index 2T` hp x (#4 4 ` hp x (#toatoaU` hp x (#` hp x (#captioncaptionV;1#XP\  P6QXP##C\  P6QP#_Equation Caption_Equation CaptionW11#XP\  P6QXP##C\  P6QP#2YXWYAXZpX[q=Yendnote referenceendnote referenceX44#XP\  P6QXP##C\  P6QP#footnote referencefootnote referenceY4#XP\  P6QXP#1S&C5C^fDocument StyleNF2CC -2( -Ct )Zqr` ` ` 2S&C6C^fDocument StyleNF2CC -2( -Ct )[s t . 2[\eY]eEZ^Z_p=[3S&C7C^fDocument StyleNF2CC -2( -Ct )\ uv 4S&C8C^fDocument StyleNF2CC! -2( -Ct )] wx 5S&C9C^fDocument StyleNF2CC/ -2( -Ct )^*yz   6S&C:C^fDocument StyleNF2CC= -2( -Ct )_{|` ` ` 2E^`[aq\b ]c]7S&C;C^fRight-Aligned Paragraph NumbersK -2( -Ct )`8}~@  8S&C<C^fRight-Aligned Paragraph NumbersY -2( -Ct )aA@` ` `  ` ` ` 9S&C=C^fDocument StyleNF2CCg -2( -Ct )b0    10S&C>C^fRight-Aligned Paragraph Numbersu -2( -Ct )cJ` ` ` @  ` ` ` 2aadw^e$_f_g`11S&C?C^fRight-Aligned Paragraph Numbers -2( -Ct )dS` ` `  @  12S&C@C^fRight-Aligned Paragraph Numbers -2( -Ct )e\` ` `  @hhh hhh 13S&CAC^fRight-Aligned Paragraph Numbers -2( -Ct )fe` ` `  hhh@ hhh 14S&CBC^fRight-Aligned Paragraph Numbers -2( -Ct )gn` ` `  hhh@  2(dhaidbjckc15S&CCC^fRight-Aligned Paragraph Numbers -2( -Ct )hw` ` `  hhh@ppp ppp 16S&CDC^fDocument StyleNF2CC -2( -Ct )iF   ׃  17S&CEC^fTechnical Document StyleCC -2( -Ct )j&  . 18S&CFC^fTechnical Document StyleCC -2( -Ct )k&  . 2flZdmdneof19S&CGC^fTechnical Document StyleCC -2( -Ct )l*    20S&CHC^fTechnical Document StyleCC -2( -Ct )m'   21S&CIC^fTechnical Document StyleCC -2( -Ct )n&   22S&CJC^fTechnical Document StyleCC -2( -Ct )o4$     2ipgqgr} hsh23S&CKC^fTechnical Document StyleCC+ -2( -Ct )p&  . 24S&CLC^fTechnical Document StyleCC9 -2( -Ct )q&  . 25S&CMC^f1. a. i. (1) (a) (i) 1) a)CG -2( -Ct )r$ 26S&CNC^f1. a. i. (1) (a) (i) 1) a)CU -2( -Ct )s/` ` ` 2ktBiuivsjwk27S&COC^f1. a. i. (1) (a) (i) 1) a)Cc -2( -Ct )t:` ` `  28S&CPC^f1. a. i. (1) (a) (i) 1) a)Cq -2( -Ct )uE` ` `  29S&CQC^f1. a. i. (1) (a) (i) 1) a)C -2( -Ct )vP` ` ` hhh 30S&CRC^f1. a. i. (1) (a) (i) 1) a)C -2( -Ct )w[ 2'oxlylzm{Yn31S&CSC^f1. a. i. (1) (a) (i) 1) a)C -2( -Ct )xf 32S&CTC^f1. a. i. (1) (a) (i) 1) a)C -2( -Ct )yq Default ParaC^fDefault Paragraph Font2CC -2( -Ct )z;;#PP##PP#_Equation CaC^f_Equation CaptionF2CC -2( -Ct ){;;#PP##PP#2q|Yo}-p~lpv/qendnote refeC^fendnote referenceF2CC -2( -Ct )|>>#PP##PP#footnote refC^ffootnote referenceF2CC -2( -Ct )}>#PP#heading 3heading 3~heading 4heading 4 2svqvMrvrv9sheading 5heading 5 heading 6heading 6 heading 7heading 7 heading 8heading 8 2EwvsvWttZvendnote textendnote text footnote textfootnote text toa headingtoa heading` hp x (#(#(#` hp x (#1, 2, 3,?@65NumbersO@/"=(1*1÷$t ?.E1.2nydwwwpxqxA, B,t ?@65Uppercase Letters1 ?*1÷$t ?.E .footnote tex6footnote text̺=(?. 0&ܺ*?.ںd 0E2(33`O5hT(G2PDocument Style&^aO5h.K+&,$@`O5Bȗ+&>` ` ` 34`O5iT(G2PDocument Style&^aO5i.K+&,$@`O5Bȗ+&>  . 2m{eyezjzpz35`O5jT(G2PDocument Style&^aO5j.K+&,$@`O5Bȗ+&>  36`O5kT(G2PDocument Style&^aO5k.K+&,$@`O5Bȗ+&>  37`O5lT(G2PDocument Style&^aO5l.K+&,$@`O5Bȗ+&>*   38`O5mT(G2PDocument Style&^aO5m.K+&,$@`O5Bȗ+&>` ` ` 2~{1||a}39`O5nT(G2PRight-Aligned Paragraph NumbersK+&,$@`O5Bȗ+&>8@   40`O5oT(G2PRight-Aligned Paragraph NumbersK+&,$@`O5Bȗ+&>A@` `  ` ` ` 41`O5pT(G2PDocument Style&^aO5p.K+&,$@`O5Bȗ+&>0    42`O5qT(G2PRight-Aligned Paragraph NumbersK+&,$@`O5Bȗ+&>J` ` @  ` `  2!7~~Y43`O5rT(G2PRight-Aligned Paragraph NumbersK+&,$@`O5Bȗ+&>S` `  @  44`O5sT(G2PRight-Aligned Paragraph NumbersK+&,$@`O5Bȗ+&>\` `  @hh# hhh 45`O5tT(G2PRight-Aligned Paragraph NumbersK+&,$@`O5Bȗ+&>e` `  hh#@( hh# 46`O5uT(G2PRight-Aligned Paragraph NumbersK+&,$@`O5Bȗ+&>n` `  hh#(@- ( 2S$ނc47`O5vT(G2PRight-Aligned Paragraph NumbersK+&,$@`O5Bȗ+&>w` `  hh#(-@pp2 -ppp 48`O5wT(G2PDocument Style&^aO5w.K+&,$@`O5Bȗ+&>F *  ׃  49`O5xT(G2PTechnical Document Stylex.K+&,$@`O5Bȗ+&>&  . 50`O5yT(G2PTechnical Document Styley.K+&,$@`O5Bȗ+&>&  . 2K߅51`O5zT(G2PTechnical Document Stylez.K+&,$@`O5Bȗ+&>*    52`O5{T(G2PTechnical Document Style{.K+&,$@`O5Bȗ+&>'   53`O5|T(G2PTechnical Document Style|.K+&,$@`O5Bȗ+&>&   54`O5}T(G2PTechnical Document Style}.K+&,$@`O5Bȗ+&>4$     2ЈF}ˇH55`O5~T(G2PTechnical Document Style~.K+&,$@`O5Bȗ+&>&  . 56`O5T(G2PTechnical Document Style.K+&,$@`O5Bȗ+&>&  . 57`O5T(G2P1. a. i. (1) (a) (i) 1) a).K+&,$@`O5Bȗ+&>$ 58`O5T(G2P1. a. i. (1) (a) (i) 1) a).K+&,$@`O5Bȗ+&>/` ` ` 23܊59`O5T(G2P1. a. i. (1) (a) (i) 1) a).K+&,$@`O5Bȗ+&>:` ` `  60`O5T(G2P1. a. i. (1) (a) (i) 1) a).K+&,$@`O5Bȗ+&>E` ` `  61`O5T(G2P1. a. i. (1) (a) (i) 1) a).K+&,$@`O5Bȗ+&>P` ` ` hhh 62`O5T(G2P1. a. i. (1) (a) (i) 1) a).K+&,$@`O5Bȗ+&>[ 27‹KA63`O5T(G2P1. a. i. (1) (a) (i) 1) a).K+&,$@`O5Bȗ+&>f 64`O5T(G2P1. a. i. (1) (a) (i) 1) a).K+&,$@`O5Bȗ+&>q 65`O5T(G2PDefault Paragraph Font5.K+&,$@`O5Bȗ+&>OO#P P##P P#66`O5T(G2P_Equation Caption^aO5.K+&,$@`O5Bȗ+&>OO#PP##PP#2ieے67`O5T(G2Pendnote reference^aO5.K+&,$@`O5Bȗ+&>RR#PP##PP#68`O5T(G2Pfootnote reference^aO5.K+&,$@`O5Bȗ+&>R#PP#para numnumbered indented paragraphs' Y- 1.(i) 1) 1.#Xw P7[hXP# 1. 1.ҲHeadingChapter HeadingJ d  ) I. ׃  2_^dSRight ParRight-Aligned Paragraph Numbers>a݅@  I.   X(# SubheadingSubheading0\ E A.  FOOTNOTEFootnote - AppearancePHIGHLIGHT 1Italics and Boldldedd+. 2X1DRAFT ONHeader A Text = DRAFT and Date X =8` (#FDRAFTă r  ` (#=D3 1, 43 12pt (Z)(PC-8))T2Dă  ӟDRAFT OFFTurn Draft Style off@@    HEADERHeader A - AppearanceLETTER LANDLetter Landscape - 11 x 8.5 3'3'Standard'3'3StandardLetter Portrait - 8.5 x 11 ;   2R1Q11nLEGAL LANDLegal Landscape - 14 x 8.5f 3'3'Standard'A'AStandardZ K e6VE L"nu;   LETTER PORTLetter Portrait - 8.5 x 11L 3'3'Standard3'3'StandardZ K e6VE L"nU9   LEGAL PORTLegal Portrait - 8.5 x 14 3'3'StandardA'A'StandardLetter Portrait - 8.5 x 119   TITLETitle of a DocumentK\ * ă2+Xܝd]jFOOTERFooter A - AppearancedBLOCK QUOTESmall, single-spaced, indentedN X HIGHLIGHT 2Large and Bold LargeB*d. HIGHLIGHT 3Large, Italicized and Underscored V -q2&]E|-8LETTERHEADLetterhead - date/marginsu H XX  3'3'LetterheadZ K e VE L"n3'3'LetterheadZ K e VE L"nE9    * 3'3'LetterheadZ K e VE L"n3' II"n"Tv3'StandarddZ K e VE L"nU9 Ѓ   INVOICE FEETFee Amount for Math Invoice ,, $0$0  MEMORANDUMMemo Page FormatD.   ! M E M O R A N D U M ă r  y<N dddy   INVOICE EXPSEExpense Subtotals for Math Invoice:A ,p, $0$0028XX1[INVOICE TOTTotals Invoice for Math Macroz 4p, $0$00INVOICE HEADRHeading Portion of Math Invoice+C`*   4X 99L$0 **(  ӧ XX NORMALReturn to Normal TypestyleSMALLSmall Typestyle2[[q[̩['FINEFine TypestyleLARGELarge TypestyleEXTRA LARGEExtra Large TypestyleVERY LARGEVery Large Typestyle2ϭX7/ENVELOPEStandard Business Envelope with Header+w ,,EnvelopeZ K e VE L"n,,EnvelopeLarge, Italicized and Under;    ,, 88+  `   MACNormal,.Style 14Swiss 8 Pt Without Margins$$D Co> PfQ  )a [ PfQO Style 12Dutch Italics 11.5$$F )^ `> XifQ  )a [ PfQO 2tlLStyle 11Initial Codes for Advanced IIЇJ )a [ PfQK  dddn  #  [ X` hp x (#%'b, oT9 ! )^ `> XifQ ` Advanced Legal WordPerfect II Learning Guide   x )^ `> XifQ Advanced Legal WordPerfect II Learning Guide   j-n )^ `> XifQ    Copyright  Portola Systems, Inc. 1987, 1988`6 >Page  jBX )^ `> XifQ    Page ` Copyright  Portola Systems, Inc. 1987, 1988 Style 3oDutch Roman 11.5 with Margins/Tabs )a [ PfQO  ddn  # c0*b, oT9 !Style 4 PSwiss 8 Point with MarginsDq Co> PfQ  dddd  #  Style 1.5Dutch Roman 11.5 Font4h )a [ PfQO  dddn 2|"¶bStyle 2Dutch Italic 11.5$ )^ `> XifQ Style 5Dutch Bold 18 Point$RH$L T~> pfQ_  )a [ PfQO Style 7Swiss 11.5$$V )ao> PfQ ]  )a [ PfQO Style 6Dutch Roman 14 Point$$N w [ PfQ   )a [ PfQO 2]4;BGStyle 10oInitial Codes for Advancedد U )a [ PfQK  dddn  ##  [[ b, oT9 !b, oT9 !n )^ `> XifQ ` Advanced Legal WordPerfect Learning Guide   f )^ `> XifQ Advanced Legal WordPerfect Learning Guide   Q" )^ `> XifQ    Copyright  Portola Systems, Inc. 1987, 1988`6 >Page  QN~ )^ `> XifQ    Page ` Copyright  Portola Systems, Inc. 1987, 1988 Style 8PfInitial Codes for Beginninggٯi )a [ PfQK  dddn  # X` hp x (#%'b, oT9  [ &e )^ `> XifQ ` Beginning Legal WordPerfect Learning Guide   d )^ `> XifQ Beginning Legal WordPerfect Learning Guide   jH )^ `> XifQ    Copyright  Portola Systems, Inc. 1987, 1988`6 >Page  j )^ `> XifQ    Page ` Copyright  Portola Systems, Inc. 1987, 1988 Style 9Initial Codes for Intermediateڭ )a [ PfQK  dddn  # X` hp x (#%'b, oT9 Њ [ e )^ `> XifQ ` Intermediate Legal WordPerfect Learning Guide   3 )^ `> XifQ Intermediate Legal WordPerfect Learning Guide   jf )^ `> XifQ    Copyright  Portola Systems, Inc.`+ >Page  jX )^ `> XifQ    Page ` Copyright  Portola Systems, Inc. 1987, 1988 UpdateInitial Codes for Update Module۾ )a [ PfQK  dddn  #  [ X` hp x (#%'b, oT9 !n )^ `> XifQ ` Legal WordPerfect 5.0 Update Class Learning Guide   f )^ `> XifQ Legal WordPerfect 5.0 Update Class Learning Guide   Q" )^ `> XifQ    Copyright  Portola Systems, Inc. 1987, 1988`7 CPage  jN~ )^ `> XifQ    Page ` Copyright  Portola Systems, Inc. 1987, 1988 2pqer69 _5(_>7footnote text _5dK+b70t _5xŗ+tZP70 _5(_>7Document Style _5dK+b70t _5xŗ+t` ` ` 71 _5(_>7Document Style _5dK+b70t _5xŗ+t  . 72 _5(_>7Document Style _5dK+b70t _5xŗ+t  2e npq73 _5(_>7Document Style _5dK+b70t _5xŗ+t  74 _5(_>7Document Style _5dK+b70t _5xŗ+t*   75 _5(_>7Document Style _5dK+b70t _5xŗ+t` ` ` 76 _5(_>7Right-Aligned Paragraph NumbersK+b70t _5xŗ+t8@   25e 77 _5(_>7Right-Aligned Paragraph NumbersK+b70t _5xŗ+tA@` `  ` ` ` 78 _5(_>7Document Style _5dK+b70t _5xŗ+t0     79 _5(_>7Right-Aligned Paragraph NumbersK+b70t _5xŗ+tJ` ` @  ` `  80 _5(_>7Right-Aligned Paragraph NumbersK+b70t _5xŗ+tS` `  @  2]%81 _5(_>7Right-Aligned Paragraph NumbersK+b70t _5xŗ+t\  ` `  @hh# hhh 82 _5(_>7Right-Aligned Paragraph NumbersK+b70t _5xŗ+te  ` `  hh#@( hh# 83 _5(_>7Right-Aligned Paragraph NumbersK+b70t _5xŗ+tn ` `  hh#(@- ( 84 _5(_>7Right-Aligned Paragraph NumbersK+b70t _5xŗ+tw` `  hh#(-@pp2 -ppp 2(g85 _5(_>7Document Style _5dK+b70t _5xŗ+tF *  ׃  86 _5(_>7Technical Document StyledK+b70t _5xŗ+t&  . 87 _5(_>7Technical Document StyledK+b70t _5xŗ+t&  . 88 _5(_>7Technical Document StyledK+b70t _5xŗ+t*    2O89 _5(_>7Technical Document StyledK+b70t _5xŗ+t'   90 _5(_>7Technical Document StyledK+b70t _5xŗ+t&   91 _5(_>7Technical Document StyledK+b70t _5xŗ+t4$     92 _5(_>7Technical Document StyledK+b70t _5xŗ+t&   . 2gJ}L93 _5(_>7Technical Document StyledK+b70t _5xŗ+t&!"  . 94 _5(_>71. a. i. (1) (a) (i) 1) a)dK+b70t _5xŗ+t$#$ 95 _5(_>71. a. i. (1) (a) (i) 1) a)dK+b70t _5xŗ+t/%&` ` ` 96 _5(_>71. a. i. (1) (a) (i) 1) a)dK+b70t _5xŗ+t:'(` ` `  2S797 _5(_>71. a. i. (1) (a) (i) 1) a)dK+b70t _5xŗ+tE)*` ` `  98 _5(_>71. a. i. (1) (a) (i) 1) a)dK+b70t _5xŗ+tP+,` ` ` hhh 99 _5(_>71. a. i. (1) (a) (i) 1) a)dK+b70t _5xŗ+t[-. 100_5(_>71. a. i. (1) (a) (i) 1) a)dK+b70t _5xŗ+tf/0 2&FOFK101_5(_>71. a. i. (1) (a) (i) 1) a)dK+b70t _5xŗ+tq12 102_5(_>7Default Paragraph Font5dK+b70t _5xŗ+tw3w4#PP##PP#103_5(_>7_Equation Caption _5dK+b70t _5xŗ+tw5w6#PP##PP#"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."""""""""2"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!!WFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxN$<<$.2",2222`2 LL2 LL2L"",,2d""Washington, D.C. 20554 ă  X -#XP\  P6Q߈XP#In the Matters of ) )  X-Responsible Accounting Officer )ppAAD 9265 Letter 20, Uniform Accounting for) Postretirement Benefits Other) Than Pensions in Part 32) )  X -Amendments to Part 65, Interstate Rate)ppCC Docket No. 9622 of Return Prescription Procedures and) Methodologies, Subpart G, Rate Base)  X# -@ REPORT AND ORDER \  X-X` hp x (#%'0*,.8135@8:ԍxSee Revision of the Uniform System of Accounts for Telephone Companies to Accommodate Generally  {O-Accepted Accounting Principles, Report and Order, 102 FCC 2d 964 (1985); 47 C.F.R.  32.16.' In December 1991, the  xBureau issued an Order authorizing telephone companies subject to our accounting rules to adopt  X- xSFAS106type accounting for OPEB costs, on or before January 1, 1993.8 ^D {O-   1. 1. 1. a.(1)(a) i) a) I. A. 1. a.(1)(a) i) a)ҍxSee Southwestern Bell, GTE Service Corporation, Notification of Intent To Adopt Statement of Financial  {O- x,Accounting Standards No. 106, Employers' Accounting for Postretirement Benefits Other Than Pensions, Order, 6  {O-FCC Rcd 7560 (Com. Car. Bur. 1991) (Adoption Order).8 The Bureau  xdeclined, however, to allow carriers to adopt the FASB option of immediately recognizing  xtransitional benefit obligations, because the amounts involved were so large that booking them  xzas onetime expenses would have distorted the carriers' earnings during the affected period.  xInstead, the Bureau authorized the carriers to use the other SFAS106 option of amortizing  x<transitional benefit obligation expenses either over the average remaining service period of active  X|-plan participants or over a 20year period.|j  {O$- 1. 1. 1. a.(1)(a) i) a) I. A. 1. a.(1)(a) i) a)ҍxId. "e ,N(N(ZZ"  X< B. RAO 20  and NPRM   X-  pqx` ` 8.  On May 4, 1992, the Bureau released RAO 20 in order to specify the Part  x<32 accounts that should be used to record OPEB costs under SFAS106. In addition to providing  X- xinstructions to carriers on the Part 32 accounting treatment for OPEB costs, RAO 20 directed the  xcarriers to remove accrued OPEB liabilities from their interstate rate base and to include prepaid  X{-OPEB benefits in their interstate rate base.[{ {O-ԍxRAO 20, supra n. 2 at 287273.[  XM- p x` ` 9.  On June 3, 1992, the Ameritech Operating Companies and the Bell Atlantic  X6- xTelephone Companies filed Applications for Review of RAO 20. Ameritech and Bell Atlantic  xyclaimed that the Bureau's instructions contradicted the Commission's accounting and rate base  X -rules,+  Z yO-  ԍxThe accounting rules are codified at 47 C.F.R. Part 32. The rate base rules, codified at 47 C.F.R.   x65.800.830, list the Part 32 accounts that are to be included in and excluded from the rate base that telephone  xcompanies use to calculate their interstate revenue requirement. Generally, the interstate rate base consists of amounts that are invested in plant that is used and useful in the provision of interstate telecommunications services.+ and that the Bureau therefore exceeded its delegated authority in issuing those instructions.  X - px` `  10.  We addressed the Ameritech and Bell Atlantic applications for review in  X - x=our March 7, 1996, Order to Vacate and NPRM. The Order to Vacate affirmed the accounting  X - xinstructions set forth in RAO 20, but rescinded the ratemaking instructions on procedural grounds.  X- xxThe NPRM proposed amendments to Part 65 that would establish the proper ratemaking treatment  x>for OPEB for all carriers required to follow Part 32 accounting and for all carriers required to  Xo- xfollow Part 65 rules in calculating a rate of return. The NPRM also proposed to amend Part 65  XZ-so that all zerocost sources of fundsZB yOM-ԍxZerocost sources of funds are funds provided to a carrier without cost to its investors. are removed from the interstate rate base.  X,- l III. COMMENTS AND DISCUSSION ă  X- A. Notice of Proposed Rulemaking  X-x 1. Ratemaking Treatment of Prepaid OPEB  X- px` `  11.  In the NPRM, we proposed that prepaid OPEB recorded in Account 1410,  xOther noncurrent assets, should be included in the interstate rate base. We tentatively concluded  xthat these prepayments were investorsupplied funds, and that they should be included in the rate  X_- xbase on which investors may earn a return.Y_ {O$-ԍxNPRM, supra n. 1 at para 30.Y Several incumbent local exchange carriers support  XH- xjour proposal.sHd  yO]'-ԍxAmeritech at 3; Pacific at 3; Southwestern at 4; and US West at 2.s They state that investors fund these prepayments and that these prepayments"H ,N(N(ZZ"  x>produce returns that reduce the expenses that companies must accrue in future periods. In  xaddition, Pacific and US West comment that all items recorded in Account 1410 should be  xincluded in the interstate rate base if we remove all items recorded in Account 4310, Other long X-term liabilities, from the interstate rate base.i yO4-ԍxPacific at 4; US West at 2; supported by MCI Reply at 5.i  X- px` `  12.  We have decided not to adopt our proposal automatically to include prepaid  xOPEB in the interstate rate base. We find our current rules are adequate to determine what, if  xany, of the assets recorded in Account 1410 should be included in the rate base. Under these  xjcurrent rules, noncurrent assets recorded in Account 1410 are included in the rate base when a  xcarrier makes a showing that these assets are "used and useful" in the provision of  X - x-telecommunications services.F X yO# -ԍx47 C.F.R. 65.820.F The usedanduseful standard denotes property dedicated to the  xyefficient conduct of a utility's business, presently or within a reasonable period. That standard  xreflects the principles that owners of public utilities must receive an opportunity to be  xcompensated for the use of their property in providing a public service and that ratepayers must  xLnot be forced to pay a return on investment that does not benefit them directly. Therefore, if a  xcarrier can show that any of its assets recorded in Account 1410 (including prepaid OPEB) meet  xthe usedanduseful standard, we will allow that asset to be included in the interstate rate base.  xLThis decision is consistent with our treatment of similar costs , such as prepaid pension costs,  Xb- xywhich we referenced in the NPRM.]b {O-ԍxNPRM, supra n.1 at paras. 3031.] A certain amount of prepaid pension costs are allowed in  xthe rate base because these costs can earn a return that later reduces expenses. Thus, any prepaid  xOPEB costs that meet the used and useful standard will be allowed, similar to prepaid pension costs.  X- p'x` `  13.  Pacific and US West propose that we allow the inclusion of all items  xjrecorded in Account 1410 in the rate base if we decide to remove all items recorded in Account  x{4310 from the rate base. As discussed below, we do not decide that all items recorded in  xZAccount 4310 are zerocost sources of funds that require rate base adjustment. Therefore, we will not change the rules to allow the inclusion of all 1410 balances in the rate base.  Xg-x 2. Ratemaking Treatment of Other Longterm Liabilities  X9- p5x` `  14.  In the NPRM, we proposed to amend Section 65.830 to remove from the  x<interstate rate base the interstate portion of all accrued liabilities recorded in Account 4310, Other  X - xlongterm liabilities.Z z {O8%-ԍxNPRM, supra n. 1 at para. 32.Z We noted that this would accord to all of the zerocost funds recorded in"  ,N(N(ZZ["  x]Account 4310, including accrued OPEB liabilities, the same rate base treatment currently  X-accorded to accrued pension liabilities.: {Ob-ԍxId.:  X- pbx` ` 15.  The parties commenting on this issue expressed differing opinions as to  x[whether we should remove OPEB costs and the other items recorded in Account 4310 from the  xinterstate rate base. Those parties in favor of rate base removal state that OPEB and all zerocost  xfunds in Account 4310 should be removed from the rate base because investors have not provided  X_- xLthis capital and therefore, are not entitled to receive a return on it.{_Z yOj -ԍxAT&T at 34; MCI at 4; NYNEX at 12; Southwestern at 4; AT&T Reply at 7. { NYNEX, while supporting  x.the removal of all zerocost funds, either through a direct rate base adjustment or by including  X1- xthe related expenses in a leadlag study,X1 yO -  ԍxA leadlag study measures cash inflows and outflows in relation to the time service is rendered. Revenue  xand expense items that are received or paid before service is rendered are considered "lead" items, and revenue and expense items that are received or paid after service is rendered are considered "lag" items.  states that Account 4310 includes several items that are  xnonoperating in nature and that these nonoperating amounts should not be included in  X - xratemaking determinations.<  yO-ԍxNYNEX at 5.< NYNEX also argues that a direct rate base adjustment is preferable  xto a leadlag study for taking into account the economic impact of the differences between cost  X -recognition and the corresponding payment of OPEB amounts.^  {O -ԍxId. at 3; supported by AT&T Reply at 8.^  X - px` ` 16.  Parties opposing a rate base adjustment state that OPEB and other Account  x4310 amounts are not ratepayersupplied funds because these amounts were not factored into pre xprice cap rates. They claim that only those items that have been included in rates should be  Xb- xLremoved from the rate base.|b,  yO?-ԍxAmeritech at 23; Bell Atlantic at 14; Pacific at 34; Pacific Reply at 2.| NYNEX and AT&T argue that carriers that have been earning a  x<positive return on assets that are funded in part by the OPEB liabilities are in fact recovering their  X4-OPEB costs.M4  yO-ԍxNYNEX at 4; AT&T Reply at 5.M  X- pTx` ` 17.  We are not persuaded by the argument that the amounts recorded in  xiAccount 4310 are investorsupplied funds because they were not factored into preprice cap rates  x=or have not been given exogenous treatment. To the extent that carriers are earning a positive  xreturn on assets funded in part by the liabilities recorded in Account 4310, these carriers are recovering their OPEB costs. "L ,N(N(ZZ"Ԍ X- pDx` ` 18.  We do, however, agree with NYNEX's statement that Account 4310 can  xcontain amounts that are nonoperating in nature, and that these nonoperating amounts should  x=not affect a carrier's rates. Therefore, we are modifying our proposal to ensure that only those  xzerocost sources of funds that result from abovetheline expenses are removed from the rate  xLbase. Thus, only those liabilities recorded in Account 4310 that are derived from the expenses specified in Section 65.450(a) will be removed from the rate base.  X_- px` ` 19.  In the NPRM, we noted that the Bureau in RAO 20 directed carriers to  xremove accrued OPEB liabilities recorded in Account 4310, Other longterm liabilities, from their  x.rate bases on the basis that OPEB benefits are similar to pension benefits, which are deducted  X - xfrom the rate base pursuant to Part 65.T  {O -ԍxNPRM, supra n. 1 at para. 29.T The Bureau concluded that accrued OPEB costs should  xreceive similar rate base treatment. We believe the Bureau was correct in that conclusion.  xMoreover, in the NPRM, we noted that all accrued liabilities recorded in Account 4310 represent  xzerocost sources of funds including accrued pension and OPEB liabilities. We therefore  xproposed to accord to all items recorded in Account 4310 the same treatment currently accorded  X - xto pensions.: Z {O-ԍxId.: After reviewing the comments in this proceeding, we conclude that, because the  xamounts recorded in Account 4310 are zerocost sources of funds, rates should not provide a  x]return on those amounts. Accordingly, we adopt our proposal except as modified in the preceding paragraph.  X4- pRx` ` 20.  We decline to subject certain portions of Account 4310 to leadlag studies.  x<This approach would be more burdensome for carriers than a direct rate base adjustment because  x[it would further complicate the already complex leadlag study process. Instead, we find that a  x<direct rate base adjustment for the zerocost items in Account 4310 is the simplest way to achieve our objective of treating ratepayers fairly and giving them credit for providing zerocost capital.  X-x 3. Deferral of Part 65 Revisions  X|- px` ` 21.  In the NPRM, we requested comment on whether we should delay  xZmodifying Part 65. The rationale for this request was presented in the pleadings of several parties  XP- xresponding to Ameritech's and Bell Atlantic's applications for review of RAO 20. Those parties  X;- xurged us to defer making any Part 65 changes until the completion of several pending  X$-investigations concerning the exogenous treatment of OPEB amounts.Y!$ {O"-ԍxNPRM, supra n. 1 at para 28.Y  X- px` ` 22.  Pacific is the only party that asserts, in response to the NPRM, that we  X- xshould delay amending Part 65.>"~ yO'-ԍxPacific at 3.> AT&T, MCI and NYNEX, however, agree we should not delay"",N(N(ZZ"  xbecause we severed the ties between the rate base and prices in 1990 when we adopted price cap  X- x[regulation.Q# yOb-ԍxAT&T at 4; MCI at 6; NYNEX at 4.Q AT&T also states that any change to the Part 65 rules will affect the rate base on  xa prospective basis and will not affect the pending OPEB investigations because those  X- x-investigations deal with past OPEB costs.X$X yO-ԍxAT&T at 4; supported by MCI Reply at 6.X NYNEX argues that the rate base treatment of OPEB  xxshould not bear any relation to whether these costs are exogenous, and that since OPEB costs are  x=recognized as regulated costs, the OPEB costs are being recovered by price cap carriers to the  Xv-extent that each earns a profit.<%v yO -ԍxNYNEX at 4.<  XH- px` ` 23.  BellSouth, while not commenting directly on whether we should delay this  xLproceeding, states that the Commission should avoid making piecemeal changes to the Part 65  xrules. Instead, BellSouth argues that the Commission should initiate a comprehensive review  X -designed to simplify the rate base rules and to eliminate costly regulatory requirements.c& x yO,-ԍxBellSouth at 24; supported by Pacific Reply at 2.c  X - p%x` ` 24.  Although in our Order to Vacate we rescinded the ratemaking guidance in  X - xRAO 20 on procedural grounds, we did not disagree, however, with the Bureau's rationale for  x\providing this guidance. Uniform ratemaking treatment for OPEB in Part 65 is necessary for  xcarriers that remain subject to rateofreturn regulation, and for the Commission to monitor  xysharing obligations of carriers subject to price cap regulation. This need for uniformity will not  xbe changed by the exogenous cost decision resulting from the ongoing OPEB investigations.  x>Accordingly, we find no reason to delay amending Part 65 pending the results of the OPEB investigations.  X - B. MCI Petition for Reconsideration of the Order to Vacate  X-x 1. Positions of the Parties  X- p x` ` 25.  In our Order to Vacate, we rescinded the rate base instructions contained  X- x in RAO 20. Our decision was based on our determination that the Bureau did not have the  X- xKdelegated authority to change the Part 65 rules in an RAO letter.d' {O="-ԍxOrder to Vacate, supra n.1 at para. 25.d MCI asks us to reconsider our  Xm- xdecision and to reinstate the rate base instructions related to OPEB.C(m yO$-ԍxMCI Petition at 2.C MCI states that we have  xLbroad discretion in interpreting our rules and that a rule change is not needed to determine the"V* (,N(N(ZZ"  X- x.rate base treatment of OPEB.;) {Oy-ԍxId. ; MCI believes that because the rate base treatment of pensions  x[was already established, and because pensions are similar to OPEB, we can apply the pension  X- x[rate base rules to OPEB through an interpretation.:*Z {O-ԍxId.: Southwestern states that our authority to  xinterpret our rules does not include the right to change rules at will without notice and  X-comment.K+ yOA -ԍxSouthwestern Reply at 23.K  Xv- px` ` 26.  The opposing parties state that we correctly concluded in the Order to  Xa- xxVacate that the Bureau has no delegated authority to modify the rate base provisions of Part 65.~,a| yO -ԍxAmeritech at 2; Bell Atlantic at 1; US West at 2; Southwestern Reply at 23. ~  xZThe opposing parties also assert that it is unreasonable for MCI to conclude that we can interpret  xSection 65.830 of our rules as currently including the interstate portion of OPEB among those  xxitems that must be removed from the interstate rate base. The opposing parties state that the only  xitem recorded in Account 4310, Other longterm liabilities, that should be removed from the rate  X -base is the interstate portion of unfunded accrued pension costs.d-  yO-ԍxAmeritech at 2; Bell Atlantic at 12; US West at 3.d  X - px` ` 27.  In reply, MCI states the oppositions failed to demonstrate that a rulemaking  xproceeding is required to change the rate base treatment of OPEB and that the oppositions failed  x[to refute the principle that administrative agencies are afforded broad discretion in interpreting  X}- xtheir rules.@.} yO-ԍxMCI Reply at 2.@ MCI also argues that, because Section 65.830(a)(3) currently lists pension costs as  x a rate base adjustment and because pensions are similar to OPEB, it is not unreasonable to  XO-interpret this section to require the removal of OPEB costs.@/O,  {O,-ԍxId. at 3.@  X!-x 2. Discussion  X- px` ` 28.  We have reviewed MCI's Petition and find that it provides no basis on  X- xwhich to change our Order to Vacate decision rescinding the ratemaking guidance for OPEB  X- xcontained in RAO 20. As we stated in the Order to Vacate, the Bureau did not have the  x[delegated authority to amend the Part 65 rules. MCI's Petition does not refute this conclusion.  xWe also are not persuaded by MCI's argument that the Commission can amend Part 65 through  xan interpretation without providing affected parties with any notice of or chance to comment on" /,N(N(ZZn"  X- xthe amendment.B0 yOy-ԍx5 U.S.C. 553.B Giving rate base recognition to OPEB in Part 65 would constitute a rule  x<change for which proper notice and comment must be given. Accordingly, for the reasons stated above, we deny MCI's Petition.  X- G IV. FINAL REGULATORY FLEXIBILITY ACT ANALYSIS  Xv- p x` ` 29.  The Commission certified in the NPRM that the proposed rules would not  X_- x.have a significant economic impact on a substantial number of small entities.Z1_X {Oh -ԍxNPRM, supra n. 1 at para. 36.Z No comments  xwere received concerning the proposed certification. For the reasons stated below, we certify that  xthe rules adopted herein will not have a significant economic impact on a substantial number of  x=small entities. This certification conforms to the Regulatory Flexibility Act (RFA), as amended  X -by the Small Business Regulatory Enforcement Fairness Act of 1996 (SBREFA).2  yO-  ԍ x 5 U.S.C.  601611. SBREFA was enacted as Subtitle II of the Contract With America Advancement Act of 1996 (CWAAA), Pub.L. No. 104121, 110 Stat. 847 (1996).  X - px` ` 30.  The NPRM certified that no regulatory flexibility analysis was required  x.because the entities affected by the proposed rules were either large corporations, affiliates of  X - xsuch corporations, or were dominant in their field of operations and therefore not small entities.Y3 B {O-ԍxNPRM, supra n. 1 at para 36.Y  x\However, Part 65 applies to all carriers providing interstate services, some of which may be  Xy- xsmall entities.4y yO-  .ԍxThe SBA defines small telecommunications entities as those having fewer than 1,500 employees. 13 C.F.R.  121.201 SIC Code 4813 (Telephone Communications, Except Radiotelephone). Moreover, since the NPRM, we have clarified that although we still consider  xsmall incumbent LECs to be dominant in their field of operations, we will include such  XK- xcompanies in our regulatory flexibility analyses.5K,  {O(-  ԍxSee Implementation of the Local Competition Provisions in the Telecommunications Act of 1996, Report  {O-& Order,  132830, CC Docket No. 9698, FCC 96325 (rel. Aug. 8, 1996). Consequently, we cannot certify that there are  xnot a substantial number of small entities affected by the rules adopted in this Report and Order.  X- px` ` 31.  Nonetheless, we still certify that no regulatory flexibility analysis is  x[necessary here because we do not believe the rule adopted in this Order will have a significant  x=economic impact on the small carriers which must comply with our accounting rules. The rule  x=amended by this Order addresses the ratemaking treatment of certain longterm liabilities. The  xrule requires carriers to remove from their ratebase calculations zerocost sources of funds  xmrecorded in Account 4310, Other longterm liabilities. As such, it simply modifies our  xratemaking treatment but does not increase the carriers' recordkeeping burden nor require any changes to the carriers' accounting systems."e 5,N(N(ZZ1"Ԍ X- pęx` ` 32.  We therefore certify pursuant to section 605(b) of the RFA that the rules  xadopted in this order will not have a significant economic impact on a substantial number of  xsmall entities. The Commission will publish this certification in the Federal Register, and will  X- xprovide a copy of the certification to the Chief Counsel for Advocacy of the SBA.F6 yO4-ԍx5 U.S.C.  605(b).F The  xCommission will also include the certification in the report to Congress pursuant to the  X-SBREFA.L7X yO-ԍx5 U.S.C.  801(a)(1)(A).L  X_-x 6 V. ORDERING CLAUSES ă  X1- p x` `  33.  Accordingly, IT IS ORDERED, pursuant to Section 4(i) and 405 of the  xCommunications Act of 1934, 47 U.S.C. 154(i) and 405 that the Petition for Reconsideration filed April 8, 1996, by MCI Telecommunications Corporation IS DENIED.  X -x  X - pcx` ` !34.  IT IS FURTHER ORDERED, that pursuant to Sections 1, 4(i), 4(j), 201  xthrough 205, 220, and 403 of the Communications Act of 1934, as amended, 47 U.S.C.  151,  xk154(i), 154(j), 201 through 205, 220 and 403, Part 65, Subpart G of the Commission's Rules, 47  xzC.F.R. Part 65, Subpart G, IS AMENDED as shown in the Appendix below, effective 30 days after publication in the Federal Register.  XK- px` ` "35.  IT IS FURTHER ORDERED, that the Secretary SHALL SERVE a copy of this Order on each state commission.  X- p&x` ` #36.  IT IS FURTHER ORDERED, that the Secretary shall send a copy of this  xReport and Order including the Final Regulatory Flexibility Analysis, to the Chief Counsel for  xzAdvocacy of the Small Business Administration in accordance with paragraph 605(b) of the  X-Regulatory Flexibility Act, Pub. L. No. 96354, 94 Stat. 1164, 5 U.S.C.  601 et seq. (1981).  X-x` ` x` `  hh@FEDERAL COMMUNICATIONS COMMISSION x` `  hh@William F. Caton x` `  hh@Acting Secretary  " 7,N(N(ZZ"  X- 0APPENDIX ă   xPart 65, Interstate Rate of Return Prescription Procedures and Methodologies, Subpart GRate Base, is amended as follows: x1. The authority citation for Part 65 continues to read as follows:  X -x Authority: 47 U.S.C. 151, 154, 201, 202, 203, 204, 205, 218, 219, 220, 403. x2. Section 65.830 paragraphs (a)(3)and (c) would be amended to read as follows:  X -x  65.830 Deducted Items xB*****   x(a)(3) The interstate portion of other longterm liabilities (Account 4310) that were derived from the expenses specified in Section 65.450(a). B*****   x(c) The interstate portion of other longterm liabilities (Account 4310) shall bear the same proportionate relationship as the interstate/intrastate expenses which gave rise to the liability. B*****