WPCG 2MBERKZ3|j   X4#Xj\  P6G;ynXP#"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+SS88WuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxN!\{P2gEKX X4#Xj\  P6G;ynXP#"i~'^:DPddDDDdp4D48dddddddddd88pppX|pDL|pp||D8D\dDXdXdXDdd88d8ddddDL8ddddX`(`lD4l\DDD4DDDDDDdDd8XXXXXX|X|X|X|XD8D8D8D8ddddddddddXdbdddpdXXXXXlX~|X|X|X|XdddldldD8DdDDDdplld|8|P|D|D|8dvddddDDDpLpLpLpl|T|8|\ddddddl|X|X|Xd|DdpL|Dd~4ddC$CWxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNHxxH\dDXddddd8@d<@d<DDXXdDDxddxHxxHvppDXd<"dxtldpxxd:y.X80,X\  P6G;P7jC:,ynXj\  P6G;XPHPLAS5SI.PRSX\  P6G;\>!\{P2E >   >z$  > T > l2i k K3|j  Times New RomanTimes New Roman BoldTimes New Roman ItalicCG TimesCG Times BoldCG Times ItalicCourier"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+SS88WuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxN!\{P"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""\4  pG;7jC:,ynXj\  P6G;XP7nC:,><q*"xxxxWWxxxWWkkxxx8c {O'ԍ See HCPM Report, Table 17.J As a result, no such documentation is available.  X425. ` ` GTE requests identification of how the remote provisioning and remote  X4maintenance capabilities of fiber DLC is accounted for in the model.B?, c yO!'ԍ Motion at 8, request 21.B This issue has not yet been resolved. On December 10, 1998 the Bureau held a public workshop designed in part to address input values relating to plant specific maintenance factors and welcomed parties to provide further comment and data on these issues. GTE and other interested parties are encouraged to provide comments and data for the resolution of the issue raised in its Motion. " ?0*''PP="  X4D  VI. LIST OF CHANGES TO THE MODEL ă  X426. ` ` GTE requests a detailed description of any changes made to "the Model"  X4between October 15, 1998 and the present.B@c yO'ԍ Motion at 7, request 16.B As noted above, the Platform Order adopted a  X4synthesis of the best features of the three models on the record on October 28, 1998.JAXc {O'ԍ Platform Order at para. 3.J We therefore presume that GTE is referring to the changes that may have been made by the model proponents or Commission staff to the model components that were adopted in the  XJ4Platform Order. Any changes to the industrysponsored model components, HAI and BCPM, have been filed on the public record in this proceeding and are therefore available to GTE. No fundamental changes in the HCPM logic have been made since the public release of HCPM version 2.6, which was made available on July 20, 1998.  X 427. ` ` Since the adoption of the Platform Order and as contemplated therein, Commission staff and interested parties have continued to review the platform to ensure that it  X 4operates as described in the Platform Order.KB c {OH'ԍ Platform Order at para. 13.K As a result, minor refinements have been made. The Commission's website (http://www.fcc.gov/Bureaus/Common_ Carrier/Other/hcpm) provides a Report prepared by Commission staff that includes a list of modifications made to HCPM since the last public release on July 20, 1998. Another document that will be posted on the website (history.doc) will contain a detailed description of the modifications made to version 2.6. In addition, the Commission has recently released a  X%4Public Notice establishing a more detailed procedure to ensure that parties are informed of changes to the federal synthesis platform and have access to the most current version of the  X4platform on the Commission's website.AC^|c {O&'ԍ Common Carrier Bureau To Post Modifications To The ForwardLooking Economic Cost Model For  {O'Universal Service Support On The Internet, Public Notice, CC Docket Nos. 9645, 97160, DA 982533 (rel.  {O'Dec. 15, 1998) (Public Notice).A Pursuant to the guidelines set forth in the Public  X4Notice, the Commission's website will provide the current version of that platform and a brief summary of modifications to the platform that will be updated on the first and third Tuesday of each month, as necessary. Commission staff have also met with and will continue to be available to discuss any modification of the cost model with interested parties.  Xs4  VII. REQUEST FOR EXTENSION OF TIME ă  XE428. ` ` GTE requests that the date for filing petitions for reconsideration be extended"E C0*''PPy" 20 days from the date on which the Commission produces the requested data and  X4information.6Dc yOy'ԍ Motion at 8.6 The deadline for filing petitions for reconsideration of Commission decisions is  X4established by statute,=Eoc yO'ԍ 47 U.S.C.  405.= however, and therefore cannot be waived. If GTE wishes to file a  X4supplement to any petition that it may file for reconsideration of the Platform Order, it should indicate as early as possible its intention to seek leave from the Commission to supplement its  X4timely filed petition.F$c yO? 'ԍ Pursuant to our rules, "no supplement to a petition for reconsideration filed after the expiration of the 30 day period will be considered, except upon leave granted pursuant to a separate pleading stating the grounds for  {O 'acceptance of the supplement." 47 C.F.R.  1.429(d). See also In the Matter of Dismissal of All Pending  {O 'Pioneer's Preference Requests, FCC 9871, 13 FCC Rcd 11485 (1998).  Xa4 VIII. ORDERING CLAUSES ă  X3429. ` ` Accordingly, IT IS ORDERED, pursuant to 5 U.S.C. section 552(b) and 47 C.F.R. section 0.457, that GTE's request for disclosure of documents pursuant to the Freedom of Information Act IS GRANTED to the extent indicated herein and otherwise IS DENIED.  X 430. ` ` IT IS FURTHER ORDERED, pursuant to 47 U.S.C. section 154(i), that GTE's request for disclosure of documents in its Emergency Motion for Disclosure of Data and Information to Permit Public Review and Extension of Time IS GRANTED to the extent indicated herein and otherwise IS DENIED.  Xd431. ` ` IT IS FURTHER ORDERED, pursuant to 47 U.S.C. section 405, that GTE's  XM4request for extension of the deadline to file petitions for reconsideration of the Platform Order IS DENIED. ` `  hhCqFEDERAL COMMUNICATIONS COMMISSION ` `  hhCqJames D. Schlichting ` `  hhCqDeputy Chief, Common Carrier Bureau "iF0*''PP"  Y4  #Xw PE37|XP#F` `  hhCqppDecember 17, 1998    X4D STATEMENT OF\ COMMISSIONER HAROLD FURCHTGOTTROTH \  W4 Re:XFederalState Joint Board on Universal Service; ForwardLooking Mechanism for high  Wv4Cost Support for NonRural LECs (CC Docket Nos. 9645, 97160). (#  Y_4 Today, the Common Carrier Bureau releases an Order denying GTE's Emergency Motion for Disclosure of Data and Information to Permit Public Review and Extension of Time. I object to the denial of GTE's reasonable request that this agency provide all information necessary to allow outside parties to fully evaluate the model platform that we have already selected. Without such information, it is impossible for GTE to determine whether or not the model that the Commission has selected is operating consistent with the findings and conclusions contained in the Commission's Order. I have repeatedly objected to the Commission's adoption of any federal model. I agree with GTE's conclusion that "the Model platform is inherently illsuited to estimate  Yb4accurately the costs of an efficient local exchange carrier to provide universal service."b% yO'ԍEmergency Motion of GTE for Disclosure of Data and Information to Permit Public Review and Extension of Time at 23. In addition, however, I have repeatedly objected to the adoption of a "black box" distribution scheme that is not transparent to all concerned parties. Such a process will lead to complete control of universal service distribution at a federal agency with little or no recourse to outside parties wanting to challenge those decisions. It is inequitable to refuse to make available the complete federal model platform that this agency has already adopted. While I appreciate that the components may be available on the website, that is not a sufficient substitute for making the model fully available to all parties who are interested. Requiring parties to reconstruct the models from its various components is not just burdensome, it may also result in unanticipated variations. Why should be it be GTE's responsibility to reinvent the Commission's "public" model? I fail to see why the Commission has failed to make at least the platform if not the default geocode date and a standard set of inputs that can be run on all of the models available to the public. Moreover, why can't we provide some sample runs of how this model will work on a state by state basis with the common inputs that the Commission used to evaluate the two submitted models last spring? Indeed, I would like the same information myself! In addition, GTE asserts that "documentation has not been provided that fully explains"  0*''PP!"  Y4the engineering assumptions and standards that are the basis of the FCC model." yOy'ԍEmergency Motion of GTE for Disclosure of Data and Information to Permit Public Review and Extension of Time, Affidavit par. 9. As an economist, I have spent much of my professional life building and evaluating economic models. Without such information, I agree that it would be difficult if not impossible to determine whether the model complies with engineering design standards. Similarly, the failure to explain how the modules interface would make it impossible to assess whether the  Y4assumptions and algorithms are consistent from module to module.  yO^ 'ԍEmergency Motion of GTE for Disclosure of Data and Information to Permit Public Review and Extension of Time, Affidavit par. 9. In light of these concerns, why has the Bureau failed to make the entire model platform fully available? Indeed, I believe that we must make it available. As I have indicated previously, the regulation of markets through models is inherently inequitable. If no one outside the agency fully understands the model, then there is no easy way to appeal the model results. Few people understand how any model works; fewer still understand complex models; no one really understand models that produce no results. Models entail a certain degree of opaqueness in contrast to the transparency of markets and market outcomes, or even in contrast to simpler rules based on accounting information or even simpler information. This opaqueness leads to inherent uncertainty and instability. The results of a model at one point in time can be arbitrarily helpful or harmful to one individual. The key word is "arbitrarily." Models can easily be changed, and often are. An apparent benefit one day can become a liability tomorrow. The net effect is unpredictability and uncertainty. No economic cost model can meet the "specific and predictable" standard required of the federal  Y4universal service support mechanisms by the Act.x Y/4ԍ#Xw PE37|XP#47 USCA section 254(b)(5).#x6X@`7 X@#љ Regulation based on accounting rules or even simpler rules may provide at any moment in time a less accurate portrayal of a competitive market than an economic cost  Y4model potentially could. Simpler rules such as accounting rules, however, are far more transparent to the world, are not easily corrupted, are easily appealed, and provide a greater degree of market certainty and stability. It is not surprising, and even predictable, that within months of adopting a model we already have parties complaining that they do not have sufficient access to information to evaluate the results and the methodology selected by the Commission. I continue to think that such a result is unfair. We should provide the model platform that we have selected and" )0*&&PP" other necessary information to the world and let it be evaluated openly.