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"5@^*7DSS77S^*7*.SSSSSSSSSS..^^^Jxooxf]xx7Axfxx]xo]fxxxxf7.7NS7JSJSJ7SS..S.SSSS7A.SSxSSJP!PZ*7777CE7SSxJxJxJxJxJooJfJfJfJfJ7.7.7.7.xSxSxSxSxSxSxSxSxSxSxJxSxSxSxSxS]SxSxJxJoJoJoJfJfJfJxSxSxxSxSxSxSCS7S777SAxSf.fExSxSxSxo7oE]A]AN:*LS7JSSSSS.4}}S2S}277JJS77SS7J72t7[[[[^ee*C`^.wRSSn[Cfx`xWlRx[][ceIfIs`Wx[rriwge*7DSS77S^*7*.SSSSSSSSSS..^^^Jxooxf]xx7Axfxx]xo]fxxxxf7.7NS7JSJSJ7SS..S.SSSS7A.SSxSSJP!PZS7SJSS7]777JJ:S7A7xx*7SSSS!S7.S^7SC[227`L*724S}}}Jxxxxxxoffff7777xxxxxxx^xxxxxx]SJJJJJJoJJJJJ....SSSSSSS[SSSSSSS"5@^2CRdd$CCdq2C28dddddddddd88qqqYzoCNzoozzC8C^dCYdYdYCdd88d8ddddCN8ddddY`(`l2CC!CCPRCddYYYYYYzYzYzYzYC8C8C8C8ddddddddddYdddddoddYYYYYzYzYzYddddddPdCdCCCdNdz8zRdddCRoNoNNF2[dCYddddd7>d<d<CCYYdCCddCYCdYzzzzCCCCqodYYYYYYYYYYY8888dddddddnddddddd2#@@E@@"5@^2Coddȧ8CCdr2C28ddddddddddCCrrrdzNdzoȐC8CtdCdoYoYCdo8Co8odooYNCodddYO,Oh2CC!CCPRCdodddddȐYYYYYN8N8N8N8oddddooooddoddddzodddYYYYYYddddooPoNoNCNodo8RoodȐYYoNoNNF2ldCddddddd<d<CCoodCCddCoCddzzzzzzzzzzCCCCozdddddddYYYYY8888dddddddndddddYd20 X4( S' #&a\  P6G;D&P#"Federal Communications Commission`~(#DA 991844 ă   yxdddy(  * Before the x Federal Communications Commission  X'MWashington, D.C. 20554 ă In the Matter of) )  Xv4Petition for Agreement with Designation of)ppCC Docket No. 9645 Rural Company Eligible Telecommunications) Carrier Service Areas and for Approval of the) Use of Disaggregation of Study Areas for the) Purpose of Distributing Portable Federal) Universal Service Support) ) Washington Utilities and Transportation) Commission; Asotin Telephone Co.;) Century Tel of Cowiche; Ellensburg Tele.) Co.; Century Tel of Washington; Hat) Island Telephone Co.; Hood Canal Telephone) Co., Inc.; Inland Telephone Co.: Kalama) Telephone Co.; Lewis River Telephone) Co.; Mashell Telecom, Inc.; McDaniel ) Telephone Co.; Pend Oreille Telephone Co.;) Pioneer Telephone Co.; St. John,) Cooperative Telephone and Telegraph Co.;) Tenino Telephone Co.; The Toledo Telephone) Co., Inc.; United Telephone Co. of the) Northwest; Western Wahkiakum County) Telephone Co.; Whidbey Telephone Co.; and) Yelm Telephone Co.)  X74|   MEMORANDUM OPINION AND ORDER ă   X4Adopted: September 9, 1999hh]ppReleased: September 9, 1999 By the Common Carrier Bureau:  X#4JZ I. INTRODUCTION ă  XQ%41.` ` The Washington Utilities and Transportation Commission (Washington"Q%0*&&``#" Commission) and twenty rural incumbent local exchange carriers (rural LEC Petitioners) filed a petition that requests the Commission's agreement with the Washington Commission's  X4designation of the individual exchanges of fifteen rural LECs to be their service areas.Xj yOK'#X\  P6G;P#эPetition for Agreement with Designation of Rural Company Eligible Telecommunications Carrier Service Areas at the Exchange Level and for Approval of the Use of Disaggregation of Study Areas for the Purpose of Distributing Portable Federal Universal Service Support (filed on August 17, 1998) (Petition). The Washington Commission's proposal also requests a waiver for Washington rural carriers from the method of calculating universal service funds prescribed in section 54.307 of the  X4Commission's rules.oj yO& 'ԍ #X\  P6G;P#47 C.F.R.  54.307.o Specifically, the petition proposes to disaggregate federal high cost  Xv4support currently given at the study area level,Zvxj yO 'ԍUnder the proposal, aggregate study area support amounts will continue to be calculated each year in  {Og 'accordance with Parts 36 and 54 of the Commission's rules. See 47 C.F.R.  36.611, 54.612, 54.301, 54.303. Such support is comprised of high cost, DEM weighting, and long term support. Petition, Appendix E at 2. by using the Benchmark Cost Proxy Model  X_4(BCPM) |_j yO'ԍThe BCPM is a computer cost model that was developed by Bell South Corporation, US West Inc., and Sprint Local Telephone Company. The BCPM sponsors proposed to use the BCPM to estimate the forwardlooking economic cost for nonrural carriers to provide the services supported by the Federal universal service support mechanism. On October 28, 1998, the Commission declined to adopt the BCPM for this purpose, and instead adopted a synthesis model, which combined elements of each of the models under consideration in that  {O'proceeding. FederalState Joint Board on Universal Service, Fifth Report and Order, CC Docket Nos. 9645, 97 {O\'160, 13 FCC Rcd 21323 (1998) (Platform Order).  to estimate the cost of providing service in density zones within each exchange  XH4served by the rural carriers.jHj yO'#X\  P6G;P#эPetition at 1113.j The rural LEC petitioners' support of the request for service area designation is conditioned on this Commission's approval of the request for disaggregated  X 4study area support.u nj yO9'ԍX#X\  P6G;P#Petition at 12, n.2.(#u For the reasons discussed herein, we agree with the Washington  X 4Commission's proposed service area designation, and grant the requested waiver to permit the disaggregation of federal high cost support currently given at the study area level.  X ' f\ II. BACKGROUND ă  X 4  X4 2.` ` For areas served by a rural telephone company,j yO?"'ԍXThe term "rural telephone company" is defined at 47 U.S.C.  153(37).(#Ɓ section 214(e)(5) of the"0*&&``"  X4Communications Act, as amended (the Act), provides that the company's "service area" Xj yOy'ԍSection 214(e)(5) defines the term "service area" as a "geographic area established by a State commission for the purpose of determining universal service obligations and support mechanisms." 47 U.S.C.  214(e)(5).  will be its study area "unless and until the Commission and the States, after taking into account the recommendations of a FederalState Joint Board instituted under section 410(c) of the  X4Act,O j yOT'ԍX47 U.S.C.  410(c).(#O establish a different definition of service area for such company." Xxj yO 'ԍ47 U.S.C.  214 (e)(5). A study area is a geographic segment of an incumbent local exchange carrier's telephone operations. Generally, a study area corresponds to an incumbent LEC's entire service territory within a state.  Section 54.207 of  X4the Commission's rules,p j yO 'ԍ#X\  P6G;P#47 C.F.R.  54.207. p and the Universal Service Order,J (( j {O}'#X\  P6G;P#эFederalState Joint Board on Universal Service, Report and Order, CC Docket No. 9645, 12 FCC Rcd  {OG'8776, 8881, para. 188 (1997) (Universal Service Order), as corrected by FederalState Joint Board on Universal  {O'Service, Errata, CC Docket No. 9645, FCC 97157 (rel. June 4, 1997), appeal pending in Texas Office of Public  {O'Utility Counsel v. FCC and USA, No. 9760421 (5th Cir. 1997) (Universal Service Order).J set forth the Commission's procedures for consideration of petitions filed by state commissions seeking to designate rural service areas for rural telephone companies that are different from such companies' study  Xa4areas. Section 54.207 provides that the Commission may initiate a proceeding to consider such a petition within ninety days of the release date of a Public Notice of the petition or, in  X34the alternative, may act on the petition without initiating a proceeding.{ 3j yO'#X\  P6G;P#эX47 C.F.R.  54.207 (c).(#{ Pursuant to this rule,  X 4the Commission issued a Public Notice on August 24, 1998 to elicit comment from interested  X 4parties._ j {O^'ԍ#X\  P6G;P#Common Carrier Bureau Seeks Comment on the Washington Utilities and Transportation Commission's and Twenty Rural Telecommunications Companies' Petition for Agreement With Designation of Rural Company Eligible Telecommunications Carrier Service Areas at the Exchange Level and for Approval of the Use of  {O'Disaggregation of Study Areas for the Purpose of Distributing Portable Federal Universal Service Support,  {O'Public Notice, CC Docket No. 9645, DA 981691 (rel. August 24, 1998) (Public Notice). Comments were filed by GTE Service Corp., (GTE), the Idaho Public Utilities Commission (Idaho PUC), the Rural Telephone Coalition (RTC), Sprint Corporation (Sprint), Telecom Consulting Associates, Inc., (TCA), TDS Telecommunications Corp., (TDS Telecom), United States Telephone Association (USTA), and Western Wireless Corporation (Western Wireless). Reply Comments were filed by the National Exchange Carrier Association, Inc., (NECA), USTA, and the Washington Commission._ On November 24, 1998, the Commission initiated a proceeding to continue its" F0*&&`` "  X4consideration of the petition.Cj {Oy'ԍCommon Carrier Bureau Initiates a Proceeding to Consider the Petition of the Washington Utilities and Transportation Commission and Twenty Rural Telecommunications Companies' for Agreement With Designation of Rural Company Eligible Telecommunications Carrier Service Areas at the Exchange Level and for Approval of the Use of Disaggregation of Study Areas for the Purpose of Distributing Portable Federal Universal Service  {O'Support, Public Notice, CC Docket No. 9645, DA 982367 (rel. November 24, 1998).C  X43.` ` Petitioners assert that the Washington Commission has taken into account the recommendations of the FederalState Joint Board, as required by the Act and the  X4Commission's rules, in proposing exchange level service areas for the rural LEC petitioners.P|j yO 'ԍXPetition at 58, 1011.(#P Petitioners also contend that establishment of service areas at the exchange level will promote  Xv4the procompetitive policies and goals of the Commission and the Washington Commission.Jv j yO3'ԍXPetition at 810.(#J  XH44.` ` Petitioners also seek a waiver of the existing method of calculating the amount of universal service support that a competitive eligible telecommunications carrier should  X 4receive pursuant to section 54.307 of the Commission's rules,F j yOg'ԍUnder section 54.307 of the Commission's rules, an incumbent LEC receives perline universal service support that is calculated by dividing the ILEC's support by the number of loops served by that ILEC at its most recent annual loop count. 47 C.F.R.  54.307 (a)(2). A competitive eligible telecommunications carrier receives support for each line it captures from an ILEC or for servicing new subscriber lines in the ILEC's service area, based on the support the ILEC receives for each line. 47 C.F.R.  54.307(a)(1). F and for approval of a proposed alternative methodology for determining the amount of universal service support, developed  X 4through a series of workshops held by the Washington Commission.P L j yO'ԍXPetition at 12, 1113.(#P Under the methodology proposed by petitioners, the individual exchanges of the rural LECs would first be designated as their service areas. Then the federal high cost support that is currently  X 4provided to the rural LEC petitioners on a study area basis would be disaggregated and  X4redistributed among the smaller geographic service areas.Kj yO'ԍXPetition at 1113.(#K Under this methodology, the amount of universal service support available to the proposed service areas in the aggregate would be the total amount of support currently provided to the existing study area in which  XK4they are located.aKlj yOh#'ԍXPetition at 15, Petition Summary at iii.(#a The methodology proposed to disaggregate and distribute this total support amount among the proposed service areas is an adaptation of the BCPM. This methodology would be used to estimate the relative cost of providing service in a lowercost and a higher"0*&&``2"ԫ X4cost density zone within each exchange.Hj yOy'ԍXPetition at 12.(#H This cost data would then be used to set the  X4support amount for carriers providing service within each of these density zones.KXj yO'ԍXPetition at 1213.(#K Because  X4the model would be used only to disaggregate and redistribute the federal high cost support currently provided for each of the rural LEC petitioner's existing study areas, the proposal would not increase or change the aggregate amount of federal support provided for those  X4study areas.aj yO& 'ԍXPetition at 12, Petition Summary at iii.(#a Under petitioners' proposal, high cost support for each of the current study areas would continue to be recalculated each year based on the average loop cost in the study area. Thus, the amount of support calculated for each study area before disaggregation would  XH4still be limited by the mechanisms that limit the overall growth in the fund.Hxj {Oq'ԍSee FederalState Joint Board on Universal Service, Access Charge Reform, Price Cap Performance  {O;'Review for Local Exchange Carriers, Transport Rate Structure and Pricing, End User Common Line Charge, Fourth Order on Reconsideration, CC Docket Nos. 9645, 96262, 941, 91213, 9572, 13 FCC Rcd. 5318, para.  {O'34 (1997) (Fourth Reconsideration Order), as corrected by FederalState Joint Board on Universal Service,  {O'Errata, CC Docket Nos. 9645, 96262, 941, 91213, 9572, 13 FCC Rcd. 2372 (1998), appeal pending in  {Oa'Alenco Communications, Inc., et al. v. FCC and USA, No. 9860213 (5th Cir. 1998). Petitioners assert that disaggregation under this methodology is relatively easy to administer and track, and the necessary information can be supplied to or developed by the Universal Service  X 4Administrative Company (USAC).H j yO'ԍXPetition at 13.(#H  X 45.` ` Several commenters express support for the Washington Commission's  X 4designation of the individual exchanges of the rural LECs as their service areas. j {O'ԍXSee, e.g., Idaho PUC Comments at 3, RTC Comments at 2, Sprint Comments at 1. (#ƍ A number of commenters also urge us to grant the petition in its entirety because the proposed geographical disaggregation is intertwined with the Washington Commission's proposed  Xy4designation of individual exchanges as service areas, and approving the service area  Xb4designation alone would create the potential for "cream skimming."bj {O/ 'ԍSee, e.g., Sprint Comments at 2, TCA Comments at 56; see also Western Wireless Corporation Comments at 6. If the exchanges, rather than the current study areas, are designated as the service areas, and universal service support is not geographically disaggregated, a competitive LEC could receive a windfall by entering a relatively low cost exchange and receiving support based on the higher average cost within"v0*&&``2"  X4the study area.j {Oy'ԍXSprint Comments at 2, TCA Comments at 56; see also Western Wireless Corporation Comments at 6. (#Ɵ Petitioners, and commenters that support the petition, claim that the  X4proposed geographical disaggregation would avoid such problems.Zj {O'ԍXPetition at 13; see also Sprint Comments at 2, TCA Comments at 56, TDS Telecom Comments at 46.(#ƥ NECA agrees with other commenters that the Commission should grant the petition, but cautions the Commission not  X4to "establish the Washington proposal as a de facto standard for disaggregating interstate  X4universal service support in other areas."Ij yOC 'ԍXNECA Reply at 2.(#I NECA explains that whereas the approach espoused by the Washington Commission may prove workable on an interim basis, subsequent developments in forward looking cost methods for rural companies may prove that  Xa4other methods work better. a|j {O 'ԍXSee NECA Reply at 23; see also TCA Comments at 45, TDS Telecom Comments at 7.(#Ɣ  X346.` ` USTA and GTE oppose the petition. USTA expresses concern about the precedential effects of our decision in this proceeding. It contends that the issues raised by the petition have the potential of altering established universal service policies and policies  X 4that are being formulated in ongoing proceedings.N! j yO'ԍXUSTA Comments at 23.(#N GTE declares that while it supports the petition's objective to better target federal universal service support, it cannot support the petition unless the petition is amended to include GTE Northwest's Contel Washington study  X 4area in the proposed change in service area definition for rural areas." j yO'ԍGTE Comments at 2, 4. GTE contends that the "omission" renders the petition incomplete and inaccurate. GTE also claims that the proposed methodology to disaggregate support to areas smaller than a wire center does not fully resolve the universal service issues in Washington state, even for rural areas, and  Xd4proposes an alternative methodology.M#d j yO 'ԍXGTE Comments at 67.(#M GTE recommends that if the Commission allows a state to "experiment with modifications to its transitional universal service support for rural  X64areas," then the Commission should set forth guidelines for "any such experimentation."N$6 j yOm 'ԍXGTE Comments at 23. (#N In reply, the Washington Commission states that, in light of GTE's subsequent certification of its Contel study area as rural, it will work with GTE regarding the inclusion of the Contel study  X4area in petitioners' proposal.Z%j yO$'ԍXWashington Commission Reply at 8.(#Z "%0*&&``"Ԍ X4c III. DISCUSSION ă  X47.` ` To begin, we recognize that the request for disaggregated study area support is inextricably intertwined with the request for agreement with the Washington Commission's proposed designation of the individual exchanges of the fifteen rural carriers as service areas. We also recognize that petitioners' proposed methodology to disaggregate and redistribute the federal high cost support has not been tested, or even studied, outside the context of the Washington Commission's limited study. We also note that much remains to be done in the development of the forwardlooking economic cost model before being used to distribute universal service support to rural carriers. The Rural Task Force is developing  X 4recommendations on this subject for the Universal Service Joint Board, which will be  X 4followed by the recommendations of that Joint Board.& j {O| 'ԍFederalState Joint Board on Universal Service Announces Rural Task Force Members, Public Notice, CC Docket No. 9645, FCC 98J1 (rel. July 1, 1998). Pending completion of these steps, and the Commission's decision on the high cost support mechanism for rural carriers, rural carriers will continue to receive support under the existing mechanism until, at least, the year  X 42001.n' "j {O'ԍUniversal Service Order, 12 FCC Rcd at 8889, para. 204.n For the reasons described below, however, we agree with the proposed service areas and grant, on an interim basis until we adopt a new high cost support mechanism for all rural carriers, the proposed waiver of section 54.307 of the Commission's rules. When the Commission adopts an order establishing a new support mechanism for rural carriers, that order will supersede this order, and rural carriers in Washington will receive high cost support  XK4based on the new mechanism.  X48.` ` Service Area Designation. We find that our concurrence with rural LEC petitioners' request for designation of their individual exchanges as service areas is warranted  X4in order to promote competition.q(j {OT'ԍSee generally FederalState Joint Board on Universal Service, Recommended Decision, CC Docket No.  {O'9645, 12 FCC Rcd 87, 181, at para. 176 (1996) (First Recommended Decision). Recognizing that large service areas may deter entry because few competitors may be able to cover startup costs associated with large service areas, the Joint Board recommended that the Commission encourage states, where appropriate to foster  yOx'competition, to designate service areas that do not disadvantage new entrants. q The Washington Commission is particularly concerned that rural areas, of which there are many in Washington, are not left behind in the move to  X4greater competition.G)h j yO!'ԍXPetition at 8.(#G Petitioners also state that designating eligible telecommunications carriers at the exchange level, rather than at the study area level, will promote competitive  X4entry by permitting new entrants to provide service in relatively small areas.R* j yO<%'ԍXPetition Appendix B at 8.(#R The proposed" *0*&&``" methodology will more closely associate support with the cost of providing service than do the current rules. This, in turn, should encourage efficient entry in the highercost fringe  X4areas as well as the lowercost core areas within each exchange.\+j yOK'ԍXPetition Appendices B at 9, E at 3.(#\ We conclude that this  X4effort to facilitate local competition justifies our concurrence with the proposed service area designation.  Xv49.` ` We also conclude that the Washington Commission has addressed the concerns expressed by the FederalState Joint Board on Universal Service, as required by the Act and  XH4the Commission's rules.|,HXj {OQ 'ԍXSee 47 U.S.C.  214(e)(5); 47 C.F.R.  54.207(b) & (c).(#| In the First Recommended Decision, the Joint Board listed three  X34reasons for retaining, at least initially, the current study areas of rural telephone companies as  X 4their service areas.|- j {O'ԍSee First Recommended Decision, 12 FCC Rcd at 17980, paras. 17274. | First, the Joint Board suggested that retaining study areas would minimize potential "cream skimming," because competitors would be required, as a condition  X 4of eligibility, to provide service throughout the rural telephone company's study area.|. |j {O'ԍXFirst Recommended Decision, 12 FCC Rcd at 17980, para. 172. (#| The Commission expressed its agreement with this analysis in adopting the Joint Board's  X 4recommendations regarding the study areas of rural carriers.e/ j {O'ԍ Universal Service Order, 12 FCC Rcd at 8881.e Second, the Joint Board noted  X 4that the 1996 Act places rural telephone companies on a different footing from other local exchange companies, making allowances for considerations of administrative, technical and  X{4economical feasibility.0\{j {O'ԍFirst Recommended Decision, 12 FCC Rcd at 180, paras. 17374. For example, the Joint Board noted that unlike designating eligible carriers for nonrural areas, the states may designate additional eligible rural  {O^'carriers only upon a specific finding that such designation is in the public interest. Id.Ā Finally, the Joint Board expressed concern that determining embedded costs on a basis other than study areas would impose an administrative burden on  XM4rural companies.x1M j {O'ԍXFirst Recommended Decision, 12 FCC Rcd at 180, para. 174.(#x We conclude that petitioners have taken these concerns into account in crafting the proposed methodology for disaggregating and redistributing support currently distributed on a study area basis. In particular, this methodology is designed to address opportunities for "cream skimming" by competitors. Moreover, to the extent the Joint Board was concerned about the interests of rural companies, we find it significant that the rural LEC petitioners support the proposed service area designation, conditioned on approval of the proposal to disaggregate support.  X4 "V 10*&&``"Ԍ X4 10.` ` Proposal to Disaggregate and Redistribute Support. As to petitioners' request for waiver of section 54.307, the Commission's rules generally may be waived for good cause  X4shown.=2j yOK'ԍ 47 C.F.R.  1.3.= But, as noted by the Court of Appeals for the D.C. Circuit, agency rules are  X4presumed valid, and "an applicant for waiver faces a high hurdle even at the starting gate."3Xj {O'ԍWAIT Radio v. FCC, 418 F.2d 1153, 1157 (D.C. Cir. 1969), cert. denied, 409 U.S. 1027 (1972).  X4The Commission may exercise its general discretion to waive a rule where the particular facts  X4make strict compliance inconsistent with the public interest.4j {O( 'ԍNortheast Cellular Telephone Co. v. FCC, 897 F.2d 1164 (D.C. Cir. 1990). In addition, the Commission may take into account considerations of hardship, equity, or more effective implementation of  X_4overall policy on an individual basis.T5_|j {O 'ԍWAIT Radio, 418 F.2d at 1157.T Waiver is, therefore, appropriate if special circumstances warrant a deviation from the general rule, and such deviation would better  X14serve the public interest than strict adherence to the general rule.j61j {O'ԍNortheast Cellular Telephone Co., 897 F.2d at 1166.j  X 411. ` ` We believe that special circumstances warrant the deviation from the existing section 54.307 of the Commission's rules. The petition proposes an experiment for the distribution of universal service support to rural carriers serving high cost areas in the State of Washington. As such, it will provide useful information in the pending Joint Board and Commission proceedings to determine how best to distribute universal service support to rural carriers serving high cost areas across the nation. In addition, the proposal before us represents the consensus of a state and 20 of its rural carriers, and the Washington Commission has stated its willingness to take steps to include GTE's Contel exchanges, as well.  X412.` ` We also find that petitioners have demonstrated that permitting them to deviate from section 54.307 of the Commission's rules by implementing their proposal will better serve the public interest than will strict adherence to the rules. Without this waiver of section 54.307, the proposed designation of service areas at the exchange level could result in the potential harms that the Joint Board sought to avoid in recommending that rural telephone companies' study areas be retained as their service areas. Specifically, if service areas were designated as the exchanges, rather than the study areas, and universal service support were not geographically disaggregated, a competitor could receive a windfall by providing service in a relatively low cost exchange and receiving support based on the average cost within the study area. Petitioners' proposal to disaggregate support is designed to reduce such opportunities for cream skimming.  X 4"  60*&&``c"Ԍ X413.` ` We also conclude that the proposed methodology's use of the BCPM is not a basis for finding that deviation from the current rule would not better serve the public interest. Although the Commission has adopted the synthesis model, rather than the BCPM,  X4for use in determining high cost support for nonrural carriers,o7j {O4'ԍPlatform Order, 13 FCC Rcd at 2132425, para. 2. o the synthesis model has not yet been finalized. As noted above, the Joint Board will be making recommendations, after receiving input from the Rural Task Force, concerning the nature of the high cost support mechanism that should be used for rural carriers. Petitioners' proposed methodology will be superseded by the Commission's adoption of a new support mechanism for rural carriers.  X1414.` ` We also note that in the proposed methodology the BCPM will be used in a different manner than the synthesis model, which the Commission adopted to estimate the cost for nonrural carriers to provide service. In the proposed methodology, the BCPM will be used simply to estimate the relative cost of providing service in density zones within the exchanges served by the rural LEC petitioners. We believe that the BCPM is sufficiently accurate for such purposes on an interim basis. We emphasize, however, that our approval of the proposed methodology is not intended as an endorsement of the BCPM for any purpose other than that in the proposed methodology and for the purposes of this particular situation.  Xb415.` ` Finally, we recognize that it was not possible for petitioners to include the synthesis model in their proposed methodology because the Commission had not yet adopted it when the petition was filed. The Washington Commission and rural LEC petitioners have invested significant time and effort in developing the proposed methodology, which represents a significant step forward. Denying the petition because it uses BCPM would likely result in a significant delay in the Washington Commission's efforts to promote competition in the areas served by the rural LEC petitioners. While the Washington Commission and the rural LEC petitioners could revise the proposed methodology to include the synthesis model, rather than the BCPM, and then seek our concurrence, experience suggests that this would be  X4difficult and time consuming.8Zj yO'ԍIn particular, we note that the proposed methodology resulted from a series of workshops between the Washington Commission staff and rural LEC petitioners. On balance, we therefore believe it is appropriate to approve  X|4the petition as proposed.9|j yO'ԍAs a result, we decline to consider the alternative methodology proposed by GTE.  XN416.` ` Nevertheless, we urge petitioners to consider substituting the synthesis model in the proposed methodology when it is finalized. We urge petitioners to take this course because regardless of the Commission's ultimate decision on whether to apply the synthesis model to rural carriers, we believe that the synthesis model provides more accurate cost estimates than does the BCPM and use of the synthesis model will make it easier for USAC" B90*&&``" to administer petitioners' methodology. We hereby give advance approval to modifications to  X4petitioners' proposal to conform the model platform and inputs to those adopted by this Commission.  X417.` ` Petitioners suggest that the information necessary for disaggregation of support  X4can be either supplied to or developed by USAC.4:Xj yO'ԍPetition at 13; Letter from Jeffrey D. Goltz, Sr. Asst. Attorney General of Washington (Utilities and Transportation Division), Richard A. Finnigan and Robert S. Snyder, Attorneys for petitioning companies to Magalie R. Salas, FCC, dated December 31, 1998. 4 As discussed earlier, such information will be obtained by running a modified version of the BCPM. In light of USAC's  X_4responsibility for administering the disbursement of federal support,;"_j {O 'ԍChanges to the Board of Directors of the National Exchange Carrier Association, Inc., Third Report and Order in CC Docket No. 9721, Fourth Order on Reconsideration in CC Docket No. 9721 and Eighth Order on Reconsideration in CC Docket No. 9645, CC Docket Nos. 9721, 9645, FCC 98306, (rel. November 20, 1998), paras. 1114.  we conclude that USAC should administer petitioners' proposal, including the running of the cost model and determination of disaggregated support amounts in the rural LEC petitioners' current service areas. We recognize that USAC will have to work closely with the Washington Commission and rural LEC petitioners to obtain information necessary to implement the proposal. We delegate authority to USAC to obtain such information from these and other parties, as necessary. For ease of administration, we conclude that USAC should implement the proposed methodology on January 1, 2000.  X418.` ` In reaching these conclusions, we make no judgment regarding similar requests that we may receive in the future and decline to adopt GTE's suggestion that we adopt guidelines for such requests. We will examine each request on a casebycase basis. We disagree with USTA's assertion that we should deny the petition because it raises significant issues that have "the potential of altering the Commission's universal service policies" established by and being reformulated in ongoing proceedings. This decision will permit the Washington Commission to experiment with an alternative method of distributing universal service support to rural carriers and may provide information useful in the Commission's ongoing proceeding on this subject. Our approval of petitioners' proposal on an interim basis permits it to be applied only in the circumstances outlined in their petition. It is in no way indicative of what we may decide in any pending proceeding or how the issues in that proceeding will be addressed. Finally, we believe that our decision in this matter accords with the Commission's endeavor to encourage states and carriers to find innovative ways to foster a procompetitive environment, and to foster better use of available support. "N ;0*&&``4"Ԍ X'A vIV. ORDERING CLAUSES Đc  X'  X4 19.` ` Accordingly, IT IS ORDERED, pursuant to section 214 (e)(5) of the Communications Act of 1934, as amended, 47 U.S.C.  214(e)(5), sections 54.207 and 54.307  X4vof the Commission's rules, 47 C.F.R.  54.207, 54.307, and authority delegated by section 54.207(e) of the Commission's rules, 47 C.F.R.  54.207(e), that the petition filed by the petitioners IS GRANTED to the extent stated herein.  X1420.` ` IT IS FURTHER ORDERED that this ORDER IS EFFECTIVE thirty (30) days from its release date. USAC is directed to use the proposed methodology beginning on January 1, 2000. ` `  ,hh]FEDERAL COMMUNICATIONS COMMISSION ` `  ,hh]Lisa M. Zaina ` `  ,hh]Acting Deputy Chief, Common Carrier Bureau