WPCb 2IBETZE3|I ) X-#XP\  P6QXP#HP LaserJet 5Si/5Si MX8P LPT1HPLA5SMX.WRSx  @,,,$}X@ X-#XP\  P6QXP#2({XCourier New (TT)Times New Roman (TT)"5^2BQdd$BBdq2B28dddddddddd88qqqYzoBNzoozzB8B^dBYdYdYBdd88d8ddddBN8ddddY`(`l2BBBBPBddYYYYYYzYzYzYzYB8B8B8B8ddddddddddYdddddoddYYYYzYzYzYdddddPdBdBBBdNdoNNF2ZdBYddddd7>d<d<BBYYdBBddBYBdYzzzzBBBBqodYYYYYYYYYYY8888dddddddnddddddd?xxxXbXx6X@DQX@7PC2XXP\  P6QXP &7  Courier New@* *2 - E 3|I  Times New Roman (TT)Times New Roman (Bold) (TT)WP MultinationalA Roman (TT)Times New Roman (Italic) (TT)Times New Roman (Bold Italic) (TT)"5^.Gf\\3==\h.=.3\\\\\\\\\\==hhh\zzzzzG\zppzfpzzpp=3=h\=\\Q\Q=\f33\3f\\\GG3fQz\QG@(@h.====I=\\z\z\z\z\z\zQzQzQzQzQG3G3G3G3f\\\\ffffpQz\\\\pQ\p\z\z\z\zQzQzQzQzQ\\\ffI\G\G=G\\\fGN@.\\G\\\\\\17\7\7==\\\==\\=\=7N=ddoIih\\i.Gf\\3==\h.=.3\\\\\\\\\\==hhh\zzzzzG\zppzfpzzpp=3=h\=\\Q\Q=\f33\3f\\\GG3fQz\QG@(@h=\\\\=f===\\@\=G=p.G\\\\(\=1\o=\Id77=i\.=77\\zzzzzzzzzzzGGGGhpp\\\\\\\QQQQQ3333\f\\\\\d\ffffQ\ S*#&I\  P6Q &P#2X( Z vr p "5^*7DSS77S^*7*.SSSSSSSSSS..^^^Jxooxf]xx7Axfxx]xo]fxxxxf7.7NS7JSJSJ7SS..S.SSSS7A.SSxSSJP!PZ*7777C7SSxJxJxJxJxJooJfJfJfJfJ7.7.7.7.xSxSxSxSxSxSxSxSxSxSxJxSxSxSxSxS]SxSxJxJoJoJfJfJfJxSxSxSxSxSCS7S777SAxSx]AN:*KS7JSSSSS.4}}S2~~S}277JJS77SS7J72N7[[^C`^SS`*7DSS77S^*7*.SSSSSSSSSS..^^^Jxooxf]xx7Axfxx]xo]fxxxxf7.7NS7JSJSJ7SS..S.SSSS7A.SSxSSJP!PZv7SJSS7]777JJ:S7A7xx*7SSSS!S7~.S^7~SC[227`K*724S}}}Jxxxxxxoffff7777xxxxxxx^xxxxxx]SJJJJJJoJJJJJ....SSSSSSS[SSSSSSSHP LaserJet 5Si/5Si MXm 518P LPT3HPLA5SMX.WRSC\  P6Q,,,$}Pa8DocumentgDocument Style StyleXX` `  ` a4DocumentgDocument Style Style . 2{kk`va6DocumentgDocument Style Style GX  a5DocumentgDocument Style Style }X(# a2DocumentgDocument Style Style<o   ?  A.  a7DocumentgDocument Style StyleyXX` ` (#` 2=G  a1Right ParRight-Aligned Paragraph Numbers:`S@ I.  X(# a2Right ParRight-Aligned Paragraph NumbersC @` A. ` ` (#` a3DocumentgDocument Style Style B b  ?  1.  a3Right ParRight-Aligned Paragraph Numbers L! ` ` @P 1. ` `  (# 2{ o $ a4Right ParRight-Aligned Paragraph Numbers Uj` `  @ a. ` (# a5Right ParRight-Aligned Paragraph Numbers _o` `  @h(1)  hh#(#h a6Right ParRight-Aligned Paragraph Numbers h` `  hh#@$(a) hh#((# a7Right ParRight-Aligned Paragraph NumberspfJ` `  hh#(@*i) (h-(# 2dVa8Right ParRight-Aligned Paragraph NumbersyW"3!` `  hh#(-@p/a) -pp2(#p a1DocumentgDocument Style Style\s0  zN8F I. ׃  a5TechnicalTechnical Document Style)WD (1) . a6TechnicalTechnical Document Style)D (a) . 2SDa2TechnicalTechnical Document Style<6  ?  A.   a3TechnicalTechnical Document Style9Wg  2  1.   a4TechnicalTechnical Document Style8bv{ 2  a.   a1TechnicalTechnical Document StyleF!<  ?  I.   2 ra7TechnicalTechnical Document Style(@D i) . a8TechnicalTechnical Document Style(D a) . a2Agendaa1AgendaAgenda Items7D yP ) I. 2!r9b a3Agendaa1Order8X X-I.xa2OrderAp X-xA.` ` a3OrderJ* X-x` ` 1. 2# 6! }V"!""[#a4Order4 X- I. A. 1. a.(1)(a) i) a) I. A. 1. 1.(1)(a) i) a)I.xa1Paragraph R!1. a. i. (1) (a) (i) 1) a)D )DDDFrf $ a2Paragraph R!1. a. i. (1) (a) (i) 1) a)D )DDDFrf!/` ` ` a3Paragraph R!1. a. i. (1) (a) (i) 1) a)D )DDDFrf":` ` `  2&# $$$%g%&&a4Paragraph R!1. a. i. (1) (a) (i) 1) a)D )DDDFrf#E` ` `  a5Paragraph R!1. a. i. (1) (a) (i) 1) a)D )DDDFrf$P  ` ` ` hhh a6Paragraph R!1. a. i. (1) (a) (i) 1) a)D )DDDFrf%[   a7Paragraph R!1. a. i. (1) (a) (i) 1) a)D )DDDFrf&f  2=*' '(')(*~)a8Paragraph R!1. a. i. (1) (a) (i) 1) a)D )DDDFrf'q annotation rK&7>annotation referenceGw. "7>NGI "(OaOb#Xv P7XP##Xv P7XP#annotation tK&7>annotation textGw/ "7>NGI ")2c(da4Neil's Levels*g X-Px` ` i.` ` `  2,+o*,+-r+.r2,a1Neil's Levels+La X-I.,<XX(<a2Neil's Levels,Uf X-<A.XP<Pa2Neil's Level 1-a3Neil's Level 2.2./r,0H-1r-2r^.a4Neil's Level 2/a2Neil's Level 20L<  X-A.XxPxa5Neil's Level 21a6Neil's Level 22213r/4t/5W06 1a7Neil's Level 23a8Neil's Levels4> X-x` `  hh@ha)pphppa5Neil's Levels5qb X-x` `  (1) hhhha7Neil's Levels6G X-x` `  hh@i)hh@h297,28236a3Neil's Levels7^ZG X-x` ` 1. ` `  a6Neil's Levels8z X-x` `  hh(a)@hh@"5^.=K\\!==\g.=.3\\\\\\\\\\33gggQzzpf=Gpfzfpp=3=V\=Q\Q\Q=\\33\3\\\\=G3\\\\QX%Xc.====I=\\QQQQQzzQpQpQpQpQ=3=3=3=3\\\\\\\\\\Q\\\\\f\\QQzQzQpQpQpQ\\\\\I\=\===\G\fGN@.S\=Q\\\\\39\7\7==QQ\==\\=Q=7N=ddgIig\\i.=K\\!==\g.=.3\\\\\\\\\\33gggQzzpf=Gpfzfpp=3=V\=Q\Q\Q=\\33\3\\\\=G3\\\\QX%Xc=\Q\\=f===QQ@\=G=.=\\\\%\=3\g=\Id77=iS.=79\Qzpppp====gf\QQQQQQzQQQQQ3333\\\\\\\d\\\\\\\"5^.=f\\3==\h.=.3\\\\\\\\\\==hhh\zzpG\zpfzz=3=j\=\fQfQ=\f3=f3f\ffQG=f\\\QH(H_.====I=\f\\\\\QzQzQzQzQG3G3G3G3f\\\\ffff\\f\\\\pf\\\QQzQzQzQ\\\ffIfGfG=Gf\\fGN@.c\=\\\\\\7=\7\7==\\\==\\=\=7N=ddhIih\\i.=f\\3==\h.=.3\\\\\\\\\\==hhh\zzpG\zpfzz=3=j\=\fQfQ=\f3=f3f\ffQG=f\\\QH(H_=\\\\=f===\\@\=G=.=\\\\(\=7\h=\Id77=ic.=7=\\zzzzGGGGhpf\\\\\\QQQQQ3333\f\\\\\d\ffff\f2 <9l9:e2:;t:< ;footnote textf9footnote reference#: BibliogrphyBibliography;:X (# Tech InitInitialize Technical Style<. k I. A. 1. a.(1)(a) i) a) 1 .1 .1 .1 .1 .1 .1 .1 Technical2YB=3=<>p=?etA@ADoc InitInitialize Document Style=z   0*0*0*  I. A. 1. a.(1)(a) i) a) I. 1. A. a.(1)(a) i) a)DocumentgPleadingHeader for Numbered Pleading Paper>E!n    X X` hp x (#%'0*,.8135@8:%7777777777>>>1eOIIOC=OO%+OCbOO=OI=COOhOOC%%47%17171%777U7777%+77O77155;%%%%,%77O1O1O1O1O1bII1C1C1C1C1%%%%O7O7O7O7O7O7O7O7O7O7O1O7O7O7O7O7=7O7O1O1I1I1C1C1C1O7O7O7O7O7,7%7%%%7+O7bO=+N&27%177777"RR7!SS7R!%%117n%%77ln%1n%!N%<<>,?>77?%-77[U%%7>%7777777777>>>1eOIIOC=OO%+OCbOO=OI=COOhOOC%%47%17171%777U7777%+77O77155;N%71n77%n=%b%%11&7n%l+%OO%77777%S7>%S7,OOOOOO=7111111I111117777777<77777772XLO *Q U"5^!)22SN!!28!2222222222888,\HCCH=8HH!'H=YHH8HC8=HH^HH=!!/2!,2,2,!222N2222!'22H22,006!!!!(!22H,H,H,H,H,YCC,=,=,=,=,!!!!H2H2H2H2H2H2H2H2H2H2H,H2H2H2H2H282H2H,H,C,C,=,=,=,H2H2H2H2H2(2!2!!!2'H2YH8'N#-2!,22222KK2LL2K!!,,2d!!22bd!,d!N!778(98229!)22SN!!28!2222222222888,\HCCH=8HH!'H=YHH8HC8=HH^HH=!!/2!,2,2,!222N2222!'22H22,006G!2,d22!d8!Y!!,,#2d!b'!HH!22222!L28!L2(7!9-!2KKK,HHHHHHYC====!!!!HHHHHHH8HHHHHH82,,,,,,C,,,,,222222272222222"5^*7FSS$77Sp*7*.SSSSSSSSSS77pppSffoxffxx7Jo]oxfxfS]xff]]A.AFS7SSJSJ.SS..J.xSSSSAA.SJoJJAC.CZ*7777C7SSfSfSfSfSfSooJfJfJfJfJ7.7.7.7.oSxSxSxSxSxSxSxSxS]JfSxSxSxS]JxSfSfSfSfSoJoJfJfJfJxSxSxSxSxSCS7S777SJxSoSAN:*WSASSSSSS.4}}S2~~S}277]]S77SS7]72N7[[pC`pSS`*7FSS$77Sp*7*.SSSSSSSSSS77pppSffoxffxx7Jo]oxfxfS]xff]]A.AFS7SSJSJ.SS..J.xSSSSAA.SJoJJAC.CZv7S]SS7S777]]:S7A7o]*ASSSS.S7~.Sp7~SC[227`W*724S}}}Sffffffoffff7777xoxxxxxpxxxxx]fSSSSSSSoJJJJJ....SSSSSSS[SSSSSJS"U*^*7FSS$77Sp*7*.SSSSSSSSSS77pppSffoxffxx7Jo]oxfxfS]xff]]A.AFS7QQY`QQ``,;YJoY`Q`QCJ`QoQJJC.CZ*7777C7SCfQfQfQfQfQvoYfQfQfQfQ7,7,7,7,oYx`x`x`x`x`x`x`x`]JfQx`x`x`]Jx`fQfQfQfQoYoYfQfQfQx`x`x`x`x`C57,7,7,J;x`~SC5S555]5x55x5x55x55]555]5N:*WSASSSSSS.4}}S2~~S}277]]S77SS7]72N7[[pC`pSS35555555555555*7FSS$77Sp*7*.SSSSSSSSSS77pppSffoxffxx7Jo]oxfxfS]xff]]A.AFS7SSJSJ.SS..J.xSSSSAA.SJoJJAC.CZv7S]SS7S777]]:S7A7o]*ASSSS.S7~.Sp7~SC[227`W*724S}}}Sffffffoffff7777xoxxxxxpxxxxx]fSSSSSSSoJJJJJ....SSSSSSS[SSSSSJS"5^!,6CCoh,,CK!,!%CCCCCCCCCC%%KKK;{`YY`QJ``,4`Qv``J`YJQ``~``Q,%,?C,;C;C;,CC%%C%hCCCC,4%CC`CC;@@H!,,,,5,CC`;`;`;`;`;vYY;Q;Q;Q;Q;,%,%,%,%`C`C`C`C`C`C`C`C`C`C`;`C`C`C`C`CJC`C`;`;Y;Y;Q;Q;Q;`C`C`C`C`C5C,C,,,C4`Cv`J4N/!!-ԍxSecond Report and Order, 12 FCC Rcd at 12323.p Under this protocol, the N1 carrier is responsible for the query, where N is the entity terminating  S-the call to the end user, or a network provider contracted by the entity to provide tandem access. {O$-ԍxNANC Recommendation, supra n.NANC RECOMMENDATION10, app. D (Architecture & Administrative Plan for Local Number Portability) at 8,  7.8. "20*&&`` " Thus, the N1 carrier for a local call is usually the calling customers LEC; the N1 carrier for an  S-interexchange call is usually the calling customers interexchange carrier. {O@-ԍxId. at attachment A (Example N1 Call Scenarios); Local Number Portability Report, supra n.NP REPORT10, at  9.1.3. & fig. 93 (N1 Network Query). Rather than perform its own querying, an N1 carrier may arrange for other carriers or third parties to provide querying  S-services for it.l" {OJ-ԍxSee First Report and Order, 11FCC Rcd at 8404.l The Commission has determined that a LEC may charge an N1 carrier for  S`-performing queries on the N1 carriers behalf pursuant to such an arrangement.h` {O -ԍxSee Second Report and Order, 12 FCC Rcd at 12324.h The Commission also has noted that an unqueried call might be routed by default to the LEC that originally served the  S-telephone number, usually an incumbent LEC.GF {O -ԍxId. at 1232425.G This could happen, for example, if the N1 carrier does not ensure that its calls are queried, either through its own query capability or through an arrangement with a third party, or as a result of a technical failure in the N1 carriers ability to query.  S-The Commission has determined that a LEC may charge the N1 carrier for querying defaultrouted  Sp-calls.Mp {O-ԍxId. at 1232526.M The Commission determined further that it would allow LECs to block defaultrouted calls,  SH -but only in specific circumstances when failure to do so is likely to impair network reliability.GH j  {OR-ԍxId. at 1232425.G The Commission also said that it would require LECs to apply this blocking standard to calls from all  S -carriers on a nondiscriminatory basis.S  {O-ԍxId. at 1232526.S  S -x6. The Commission released its Third Report and Order in the longterm number portability  S -proceeding on May 12, 1998.r\  {O-ԍxIn re Telephone Number Portability, CC Docket No. 95116, Third Report and Order, 13 FCC Rcd  {Oz-11,701 (1998) (Third Report and Order). The Third Report and Order was published in the Federal Register on June 29, 1998 [63 FR 35,150] and became effective on July 29, 1998. r In that order, the Commission promulgated rules governing longterm  SZ-number portability cost recovery.ZZ {O-ԍxSee 47 C.F.R.  52.3252.33.Z Under those rules, incumbent LECs may recover their carrierspecific costs directly related to providing longterm number portability in two federal charges: 1) a monthly numberportability charge to commence no earlier than February 1, 1999, that applies  S-primarily to end users;_D {O#-ԍxSee 47 C.F.R.  52.33(a), (a)(1)._ and 2) a number portability queryservice charge, which applies to carriers on"0*&&``"  S-whose behalf the LEC performs queries._ {Oh-ԍxSee 47 C.F.R.  52.33(a), (a)(2)._  S-x7. The Commission also concluded in the Third Report and Order that carrierspecific costs directly related to providing number portability are limited to costs carriers incur specifically in the provision of number portability services, such as for the querying of calls and the porting of telephone  S:-numbers from one carrier to another.c:Z {O4-ԍxThird Report and Order, 13 FCC Rcd at 11740.c They do not include, however, costs that carriers incur as an  S-"incidental consequence of number portability.: {O -ԍxId.: Thus, instead of allowing an incumbent LEC to classify the entire cost of an upgrade as a carrierspecific cost directly related to providing number  S-portability just because some aspect of the upgrade relates to the provision of number portability,:~ {O -ԍxId.: the Commission stated it would allow an incumbent LEC to treat as directly related to number portability only that portion of a carriers joint costs that is demonstrably an incremental cost carriers  SJ -incur in the provision of longterm number portability. : J  {O-ԍxId.: To help determine the portion of joint costs incumbent LECs may treat as carrierspecific costs directly related to providing number portability, the Commission asked interested parties to file comments by August 3, 1998, proposing ways to apportion  S -the different types of joint costs. Reply comments were due September 16, 1998.:!  {O-ԍxId.: The Commission also delegate[d] authority to the Chief, Common Carrier Bureau, to determine appropriate methods for apportioning joint costs among portability and nonportability services, and to issue any orders to provide guidance to carriers before they file their [enduser] tariffs, which are to take effect no earlier  S2-than February 1, 1999.:"24  {O-ԍxId.:  Q-C.xThe Incumbent LECs Tariff Revisions for Number Portability Query and Database Services  S-x8. In March and April 1998, before the Commission released its order on longterm number portability cost recovery, Ameritech Operating Companies (Ameritech), Bell Atlantic Telephone Companies (Bell Atlantic), Pacific Bell Telephone Company (Pacific Bell), and Southwestern Bell Telephone Company (Southwestern Bell) filed tariff revisions pertaining to the provision of longterm  S-number portability query and database services.#&  {OX#-ԍxSee Ameritech Tariff F.C.C. No. 2, Transmittal No. 1149 (filed Mar. 31, 1998); Bell Atlantic Tariff  {O"$-F.C.C. No. 1, Transmittal No. 1041 (filed Apr. 6, 1998), modified, Transmittal No. 1071 (filed Aug. 13, 1998);  {O$-Pacific Bell Tariff F.C.C. No. 128, Transmittal No. 1927 (filed July 7, 1997), modified, Transmittal No. 1973 (filed Mar. 13, 1998); Southwestern Bell Tariff F.C.C. No. 73, Transmittal No. 2638 (filed June 6, 1997),"%"0*&&%"  {O-modified, Transmittal No. 2694 (filed Mar. 4, 1998). The tariff revisions governed only these carrierto"Z#0*&&``C"ԫcarrier services, and did not govern the monthly charge to end users for longterm number portability, since those charges are not scheduled to go into effect until February 1, 1999. The Competitive Pricing Division (Division) of the Common Carrier Bureau concluded that these tariff revisions raised substantial questions of lawfulness, suspended them for one day, and set them for investigation under  S`-section 204 of the Communications Act of 1934, as amended.$`Z {OZ-ԍxSee In re Ameritech Tariff F.C.C. No. 2, Transmittal No. 1149, as Amended, CCB/CPD 9826,  {O$-Memorandum Opinion and Order, DA 98648 (rel. Apr. 3, 1998); In re Bell Atlantic Tariff F.C.C. No. 1,  {O-Transmittal No. 1041, CCB/CPD 9825, Memorandum Opinion and Order, DA 98686 (rel. Apr. 9, 1998); In re  {O -Bell Atlantic Revisions to Tariff F.C.C. No. 1, CCB/CPD 9847, Memorandum Opinion and Order, DA 981646  {O -(rel. Aug. 17, 1998) (incorporating subsequent Bell Atlantic revisions into investigation); In re Pacific Bell Tariff  {OL -F.C.C. No. 128, Transmittal No. 1973, CCB/CPD 9823, Memorandum Opinion and Order, DA 98598 (rel. Mar  {O -27, 1998); In re Southwestern Bell Tariff F.C.C. No. 73, Transmittal No. 2694, CCB/CPD 9817, Memorandum  {O -Opinion and Order, DA 98530 (rel. Mar. 18, 1998); In re Pacific Bell Tariff F.C.C. No. 128, Transmittal Nos.  {O -1927 and 1973, and Southwestern Bell Tariff F.C.C. No. 73, Transmittal Nos. 2638 and 2694, Memorandum  {Ot-Opinion and Order, DA 981024 (rel. May 29, 1998). On June 17, 1998, the Division designated for investigation certain issues regarding the carriers' longterm number portability query  S-and database services cost allocation.%  {O-ԍxSee In re Number Portability Query Services, CC Docket No. 9814, Order Designating Issues for  {O-Investigation, DA 981173 (rel. June 17, 1998) (Designation Order). The Division also designated issues concerning the terms and conditions of the incumbent LECs services, specifically: (1) whether carriers may block both prearranged and default query traffic when such traffic threatens to disrupt the operation and reliability of their networks; (2) whether the carriers proposed queryservice charges were based on costs directly related to providing number portability query services; (3) whether the carriers proposed allocations of total number portability costs to query services were reasonable; (4) whether the carriers methodologies and assumptions used to develop their proposed rates were reasonable; (5) whether the carriers demand forecasts for query services were reasonable; and (6) whether it was reasonable for  S -carriers to block prearranged traffic as well as default traffic.[& b  {O-ԍxDesignation Order at  7 12.[ A number of parties asked the Commission to declare the tariff revisions unlawful on the grounds that the incumbent LECs had failed  S -to demonstrate that the revisions complied with the Third Report and Order cost recovery provisions and had not met their section 204 burden of establishing that their tariff revisions were just and  S2-reasonable.'X2 yO-ԍxAirTouch Communications Opposition at 6, 3031; AT&T Opposition at i, 12, 32; Comcast Cellular Opposition at i; MediaOne Opposition at 7; Sprint Spectrum Opposition at 1, 11; Vanguard Cellular Opposition at 1, 10. x  S-x9. On August 14, 1998, the Commission concluded the investigation for these tariffs.( {O$-ԍxIn re Number Portability Query Services, CC Docket No. 9814, Order, FCC 98204 (rel. Aug. 19,  {O`%-1998) (Interim Rates Order). The"p(0*&&``" Commission held that the carriers could offer query and database services under the rates and  S-conditions contained in their respective tariff revisions on an interim basis.:) {O@-ԍxId.: The Commission stated that it could not determine at that time whether the incumbent LECs' tariff revisions were "reasonable  S-or otherwise lawful"V*Z {O-ԍxInterim Rates Order at  12.V because it still had to determine whether the carriers had accurately identified their carrierspecific costs directly related to number portability, and whether they had appropriately  S8-allocated these costs between their query and enduser charges.:+8 {O -ԍxId.: For this reason, the Commission required the carriers to file new tariff revisions regarding their rates and conditions for their query and  S-database services when they file their enduser charges in early 1999.F,~ {O -ԍxId. at  13.F The Commission stated that at the time of the new filing, it will be in a better position to evaluate the reasonableness of the  S-incumbent LECs' rates and conditions.:- {OH-ԍxId.: The Commission declined to declare the tariff revisions unlawful or to prescribe rates, as commenters had requested, because the incumbent LECs' longterm number portability query and database services raised novel and complex issues which could not be  S -resolved immediately.:.  {Ob-ԍxId.:  S -x 10. In July and August of 1998, BellSouth, Frontier, Sprint and U S WEST filed tariff  S -revisions pertaining to the provision of longterm number portability query and database services./ 4  {O|-ԍxSee BellSouth Telecommunications, Inc. Tariff F.C.C. No. 1, Transmittal No. 474 (filed Aug. 12, 1998)  {OF-(BellSouth Transmittal No. 474), modified, Transmittal No. 482 (filed Oct. 21, 1998); Frontier Telephone of  yO-Rochester, Inc. Tariff F.C.C. No. 1, Transmittal No. 10 (filed Aug. 12, 1998), (Frontier Transmittal No. 10); Sprint Local Telephone Companies Tariff F.C.C. No. 5, Transmittal No. 63 (filed July 31, 1998) (Sprint Transmittal No. 63); U S WEST Communications, Inc. Tariff F.C.C. No. 5, Transmittal No. 931 (filed July 2, 1998) (U S WEST Transmittal No. 931). Again, the tariffs relate only to charges for carriertocarrier services and do not govern the enduser charges that cannot be recovered until February 1, 1999. The Commission concluded that each tariff  S0-revision raised substantial questions of lawfulness warranting suspension and investigation.q0N0 {O -ԍxSee In re BellSouth Telecommunications, Inc. F.C.C. Tariff No. 1 for Provision of Local Number  {OJ!-Portability Database Services, Memorandum Opinion and Order, DA 981695 (rel. Aug. 26, 1998) (BellSouth  {O"-Suspension Order); In re Frontier F.C.C. Tariff No. 1 for Provision of Local Number Portability Database  {O"-Services, Memorandum Opinion and Order, DA 981696 (rel. Aug. 26, 1998) (Frontier Suspension Order); In re Sprint Local Telephone Companies F.C.C. Tariff No. 5 for Provision of Local Number Portability Database  {Op$-Related Services, Memorandum Opinion and Order, DA 981630 (rel. Aug. 14, 1998) (Sprint Suspension Order);  {O:%-In re U S WEST Communications Inc. F.C.C. Tariff No. 5 for Provision of Local Number Portability Database  {O&-Related Services, Memorandum Opinion and Order, DA 981400 (rel. July 16, 1998) (U S WEST Suspension"&/0*&&M&"  {O-Order).q The"0Z00*&&``;" investigations into these incumbent LECs' tariff revisions were not included in the tariff investigation of Ameritech, Bell Atlantic, Pacific Bell, and Southwestern Bell and the subsequent order terminating  S-that investigation because the pleading cycle in the earlier investigation had already begun.1Z {O-ԍxSee, e.g., Sprint Suspension Order at  9, n.33; U S WEST Suspension Order at  9, n.28. Additionally, the Division did not designate specific issues for investigation relating to the tariff revisions of BellSouth, Frontier, Sprint, and U S WEST in light of the ongoing investigation into  S8-issues raised in the tariffs of Ameritech, Bell Atlantic, Pacific Bell, and Southwestern Bell, and the  S-Interim Rates Order, which concluded that the issues raised in that investigation could not be resolved  S-at that time.a2 {Ov -ԍxSee Interim Rates Order at  1315.a x S-% III. Discussion   Sr-TP  SJ -x 11. We cannot determine at this time whether the tariff revisions of Bell South, Frontier, Sprint and U S WEST for longterm number portability query and database services are reasonable or otherwise lawful. To make such a finding, we must determine: 1) whether the incumbent LECs have accurately identified their carrierspecific costs directly related to number portability, and 2) whether they have appropriately allocated those costs between their query and enduser charges. We will not be in a position to determine whether the incumbent LECs have appropriately identified their carrierspecific costs directly related to number portability until after the Bureau has reviewed the August 3  S2-comments and September 16 replies in the pending proceeding.3&2~ {OP-ԍxWe reiterate that while the Third Report and Order provided cost recovery provisions for longterm number portability database and query costs, it left unresolved issues regarding the allocation and apportionment  {O-of such costs, and delegated resolution of these issues to the chief of the Common Carrier Bureau. Third Report  {O-and Order, 13 FCC Rcd at 11740. We also will be unable to determine whether the incumbent LECs have appropriately allocated those costs between the query and enduser charges until after the incumbent LECs have tariffed their enduser charges, which we expect will occur in January 1999.  Sj-x 12. Although we cannot determine at the present time whether the tariff revisions at issue are reasonable or otherwise lawful, we will allow these incumbent LECs to continue providing their longterm number portability query and database services on an interim basis under their currently tariffed rates and conditions. The continued provision of these services is essential to the development of number portability, particularly while it is in its nascent stages. Many carriers have not had a full opportunity to make the investments necessary to perform their own queries, and as a result, must rely upon the availability of the query and database services from other carriers. We require, however, that the incumbent LECs file new tariff revisions regarding their rates and conditions for the query and database services when they file their enduser charges. In this manner, we will revisit these issues when more experience with number portability services has been gained. We also will be in a better position to evaluate the reasonableness of the incumbent LECs rates and conditions in light of the"l 30*&&``." Bureau's review of the carriers comments and replies on the identification and apportionment of number portability costs. Moreover, at that point, we also will have before us both the query and enduser charges.  S`-x 13. We find that these transmittals present us with unusual circumstances that justify the continuation of the existing rates, terms, and conditions on an interim basis, and so decline at this time to declare the tariff revisions unlawful or to prescribe rates. The incumbent LECs are required to provide default query services, and cannot do so except under tariff. The incumbent LECs longterm number portability query and database services raise novel and complex issues that, for the reasons  S-stated above, we cannot resolve immediately.4 {O -ԍxCf. In re Investigation of Access and Divestiture Related Tariffs, Memorandum Opinion and Order, 97  {O -FCC.2d 1082, 108586 (1984) (explaining in Phase I of its 1984 access investigation, having just established the system of access charges following the divestiture of AT&T, that because of the novelty, breadth, and complexity of the issues raised by these [access] tariffs, it may not be possible to resolve all issues immediately). Because the services in question are new ones with which neither we nor carriers have had much experience, we will not be able to determine what rates and conditions are reasonable until issues are resolved regarding both the identification of costs directly related to number portability, and the allocation of those costs between query and enduser  S -charges.5 | {O-ԍxCf. id. at 1098 (concluding that the Commission could not judge whether certain switched access rates were reasonable without more information).  S -x 14. Although we reach no decision as to whether the current rates and conditions are reasonable and in compliance with Commission decisions on number portability, we observe that the  SX-rates do not appear facially unreasonable.6X {O-ԍxCf. id. at 109899. BellSouth is charging .50 cents per endoffice and tandem query, and .13 cents per database dip, with volume and term plans available; Frontier is charging .36 cents per endoffice query and has not tariffed a tandem query or database dip; Sprint is charging .76 cents per endoffice and tandem query and has not tariffed a database dip; and USWEST is charging .84 cents per endoffice and tandem query and .84 cents per database dip. We also note that number portability is still in its early stages of implementation, and thus these services are being provided in only limited areas of the country. We conclude that it is more prudent to allow the carriers to continue to offer these services under these tariff revisions pending determination of a preferred approach, than to attempt to finetune  S-the rates and conditions at this stage.7  {O-ԍxCf. id. at 1099 (concluding that [m]onitoring of the effects of the [switched access] rates should be more practical and effective than attempting to fine tune these rates initially). Because the incumbent LECs must file new tariff revisions for query and database services when they file their enduser charges, the interim rates and conditions will  Sh-be in place for a relatively short time.&8\h {O#-ԍxCf. In re Investigation of Special Access Tariffs of Local Exchange Carriers, Memorandum Opinion and  {O$-Order, 5 FCC Rcd 1717, 171819 (1990) (terminating investigation of special access rates of U S WEST filed under what was then new access charge system, and declining to issue refunds, on the grounds that the rates in"~%70*&&%" question were part of a partially new regime and were, in a very real sense, interim in nature).& We expect that the incumbent LECs will make those filings"h X80*&&``s" no later than January 1999, so that their enduser charges will be in place by February 1999. In the interim, customers that feel aggrieved by either the rates or conditions under which the incumbent  S-LECs are currently providing these services may file complaints pursuant to section 208.9` X yO-ԍxSection 208 states that Xx[a]ny person 8 complaining of anything done or omitted to be done by any common carrier subject to this Act, in contravention of the provisions thereof, may apply to said Commission by petition which shall briefly state the facts, whereupon a statement of the complaint thus made shall be forwarded by the Commission to such common carrier, who shall be called upon to satisfy the complaint or to answer the same in writing within a reasonable time to be specified by the Commission. 8 If such carrier or carriers shall not satisfy the complaint within the time specified or there shall appear to be any reasonable ground for investigating said complaint, it shall be the duty of the Commission to investigate the matters complained of in such manner and by such means as it shall deem proper.(# 47 U.S.C.  208(a).  S`-z IV  . Ordering Clauses TP  S-x15. Accordingly, IT IS ORDERED that, pursuant to section 204(a)(2)(A) of the Communications Act, 47 U.S.C.  204(a)(2)(A), the investigations of the tariff revisions described in BellSouth Telecommunications, Inc. Tariff F.C.C. No. 1, Transmittals No. 474 and 482, Frontier Telephone of Rochester, Inc. Tariff F.C.C. No. 1, Transmittal No. 10, Sprint Local Telephone Companies Tariff F.C.C. No. 1,Transmittal No. 63, and U S WEST Communications, Inc. Tariff F.C.C. No. 5, Transmittal No. 931 ARE TERMINATED. x16. IT IS FURTHER ORDERED that, pursuant to sections 4(i), 4(j), 251(b)(2), 251(e)(2), and 303(r) of the Communications Act, 47 U.S.C.  154(i), 154(j), 251(b)(2), 251(e)(2), and 303(r), and section 52.33(a) of the Commissions rules, 47 C.F.R.  52.33(a), BellSouth Telecommunications, Inc., Frontier Telephone of Rochester, Inc., Sprint Local Telephone Companies, and U S WEST Communications, Inc. shall file new rates and conditions for their provision of longterm number portability query and pdatabase services at the time they tariff their longterm number portability enduser charges. x` `  hh@Federal Communications Commission x x` `  hh@Magalie Roman Salas x` `  hh@Secretaryp