2 MCI has in the past advocated either the use of geographic cost zones or the use of census tracts to separate areas requiring high cost assistance from those that need no assistance. In either case, the concept of identifying high cost areas to target support flows is the same.
3 Alternatively, if the Joint Board and Commission decide that a unified approach to universal service is not practical, MCI proposed that the portion of the subsidy that should be collected from interstate services would be based on the current 25 percent gross allocator, with the remainder apportioned among the states based on the proxy cost model. The interstate portion would then be collected and distributed in a competitively-neutral manner. Collection and distribution of the intrastate portion of the subsidy would be determined by the state commissions, consistent with the 1996 Act, and the principles and rules established by the Joint Board and Commission.
4 The data necessary to run the model have to date been unavailable for Alaska.
5 See, e.g., Public Utilities Commission of Ohio at 5; Florida Public Service Commission at 10-11; National Association of State Utility Consumer Advocates at 19-21.
6 BCM results are reported by CBG. Southwestern Bell aggregated the CBG results to the company level based on the company identifier reported in the BCM results.
7 Net Plant is gross plant less accumulated depreciation.
8 See NCTA at Attachment A.
9 ETI Study at iv.
10 The Hatfield/ MCI cost factor excludes cost categories not related to universal service, uses incremental cost data for billing and collection, and calculates depreciation rates and rate of return directly. This cost factor is then applied to the forward-looking investment to estimate the forward-looking monthly cost of the services for which universal service support is provided.
11 See, e.g., National Exchange Carrier Association at 11; JSI at 9-10.
12 See, e.g., Southwestern Bell at 23.
13 See the study by Kenneth Baseman and Harold Van Gieson filed as Appendix A to MCI's comments filed in the Fourth Notice of Proposed Rulemaking, Price Cap Performance Review for Local Exchange Carriers, CC Docket No. 94-1, and incorporated herein by reference.
14 See Common Carrier Bureau Sets Pleading Schedule in Preliminary Rate of Return Inquiry, Public Notice, AAD 96-28, DA 96-139, released Feb. 6, 1996 (ROR Represcription Proceeding).
15 See USTA Reply Comments in the ROR Represcription Proceeding, filed April 15, 1996.
16 As noted supra, the price cap LECs have earned above this rate of return, even before they faced any risk from additional competition.
17 See, e.g., Southwestern Bell at 3; NYNEX at 8 U S West at ii.
18 See The Cost of Basic Network Elements: Theory, Modeling and Policy Implications, Hatfield Associates, Inc. (Hatfield Study), attached to Letter from Leonard Sawicki to William F. Caton, re: CC Docket 96-45; Joint Board, filed April 9, 1996.
19 See, e.g., AT&T at 16; Bell Atlantic at 12; GTE at 15.
20 The Hatfield Study cited supra indicates that LEC rates are in general currently well above their economic costs.
21 See, e.g., USTA at 24; Southwestern Bell at 18; NYNEX at 23-25.
22 See Cellular Telecommunications Industry Association at 2; Personal Communications Association at 4.
23 They should not receive support for service to customers who are using wireless service solely as a second telephone which provides them mobility that a wireline telephone cannot. In that case, wireless service is not being used to provide universal service.
24 See, e.g., Hopper Telecommunications Company at 5, North Dakota PSC at 4; Southwestern Bell at 20.
25 See, e.g., ALTS at 19; PSC of Wisconsin at 19.
26 Safeguards To Improve Administration of the Interstate Access Tariff and Revenue Distribution Processes, CC Docket No. 93-6, RM 7736, and Consideration of NECA's Incentive Compensation Plan, AAD 95-34, Report and Order and Order to Show Cause, 10 FCC Rcd 6243 (1995) ("Show Cause Order").
27 Id. at [[paragraph]]6.