Federal Communications Commission
1919 M St., N.W.
Washington, D.C. 20554
Released January 31, 1997
CCB/CPD No. 97-2
EXTENSION OF TIME GRANTED FOR PARTIES TO SUBMIT COMMENTS IN
RESPONSE TO COMMISSION STAFF'S ANALYSIS OF COST PROXY MODELS
Comment Date: February 13, 1997
Reply Comment Date: February 20, 1997
On January 9, 1997, the Commission Staff released a Staff Analysis intended to stimulate
discussion of criteria for the evaluation, and use, of forward-looking cost proxy models in
determining universal service support payments, cost-based access charges, and interconnection
and unbundled network element pricing.(1) Also on January 9, 1997, the Common Carrier Bureau
("Bureau") issued a Public Notice seeking comment on issues raised in the Staff Analysis, and
setting deadlines of February 3, 1997 for initial comments, and February 14, 1997 for replies.(2)
The Public Notice indicated that the record gathered in response to the Staff Analysis might at a
future date be associated with the official record of certain pending rulemakings to which it may
be relevant and used to support Commission determinations in those rulemakings. See Federal-State Joint Board on Universal Service, CC Docket No. 96-45, Access Charge Reform, CC
Docket No. 96-262, and Implementation of the Local Competition Provisions of the
Telecommunications Act of 1996, CC Docket No. 96-98.
On January 24, 1996, Pacific Telesis Group, Sprint Corporation, and U S WEST, Inc., ("Petitioners"), filed a Motion for Extension of Time to File Comments in response to the Public Notice. For the reasons below, the deadlines for filing initial and reply comments are being extended until February 13 and February 20, 1997, respectively.
First, the Staff Analysis focused on models submitted previously to the Commission, but
the model sponsors have indicated that these models will be superseded by newer versions to be
released by January 31, 1997, and by February 5, 1997. These new models are the Benchmark
Cost Proxy Model ("BCPM"), to be submitted by Petitioners, and Hatfield 3, to be submitted by
AT&T and MCI. Additionally, another model, Dr. Ben Johnson's Telecom Economic Cost
Model, was filed in the universal service proceeding earlier this month. Inasmuch as the new
models are intended to improve on the earlier versions, it would be more efficient for
commenters and Commission staff to focus their efforts on evaluating the new models instead of
the superseded versions. In addition, because the new models are scheduled to be released
shortly before and after the current comment deadline, commenters will not be able to evaluate
them at all in comments here without an extension.
The extension being granted is not the full period sought by Petitioners. We want to
ensure that the responses filed to the Staff Analysis are available for possible use by the
Commission in acting by May 8, 1997, on the recommendation of the Federal-State Universal
Service Joint Board. Any longer extension could easily jeopardize such use of the record.
Among other things, parties should address in their comments whether, and to what
extent, the new models: (1) meet the criteria set forth in the Staff Analysis; (2) improve on
potential shortcomings of the prior versions of the models.
For further information contact David Konuch, 202-418-0199, or Brad Wimmer, 202-418-1847.
1 The Use of Computer Models for Estimating Forward-Looking Costs, A Staff Analysis, (rel. January 9, 1996)("Staff Analysis").
2 Commission Staff Releases Analysis of Forward-Looking Economic Cost Proxy Models, Public Notice, DA 97-56 (rel. Jan. 9, 1997) and Erratum (rel. January 10, 1997)("Public Notice").