January 22, 1999

Re:	Price Cap Performance Review for Local Exchange Carriers, CC Docket 94-1

I support this Order denying various petitions for reconsideration as the issues raised seem to have been resolved or rendered moot by subsequent Commission action. I write separately, however, to express my continued concern with the Commission's micromanagement of LECs in general. The Commission's authority to require sharing and to provide low-end adjustments for price cap LECs are mere vestiges of outdated rate of return regulation. In today's increasingly competitive telecommunications marketplace, the Commission should be focusing its efforts on transitioning to a more competitive environment for price cap LECs.

The amount of detailed information and regulatory scrutiny required under our current price cap rules is inordinate and should be reduced. This seemingly anachronistic regulatory regime should be reformed to provide further pricing flexibility, eliminating altogether such relics as the low-end adjustment. I continue to await anxiously the opportunity to address more fully these issues and the circumstances under which dominant LECs should be accorded a simpler form of price cap regulation.

I am becoming increasingly convinced that the current regulatory mechanisms -- and certainly the level of detail -- are no longer necessary in today's increasingly competitive environment. We must develop a more forward-looking blueprint to guide the transition from regulation to competition. As I have stated previously, regulation is merely designed, to the extent possible, to replicate a competitive marketplace, but any form of regulation is an imperfect surrogate for full-fledged competition. I believe the Commission should be at least considering even further deregulation so that these cumbersome regulations are unnecessary.