4. Advice Letters and Supporting Data
In order to facilitate Commission staff monitoring of carrier compliance with the access charge modifications proposed in the ruling, parties provided comment on whether the Commission should require carriers to file Tier 1 Advice Letters and to submit data to the Communications Division on the demand and revenue for each relevant rate element, including such elements as switched access minutes of use (MOU), and the rates broken down into categories and subcategories corresponding to the relevant categories of rates being reduced. Specifically, the ruling proposed that all ILECs and CLECs file Tier 1 advice letters and certain supporting data within 10 days of Commission action on the proposals in this ruling. As envisioned in the ACR, each carrier would be required to submit as part of this advice letter the relevant data included in Appendix A of the ACR, with supporting calculations for the proposed transitional intrastate access charges required to be effective as of July 1, 2012 and for default non-access reciprocal compensation rates, where applicable.19
Many carriers contend that these requirements are burdensome and unnecessary. The FCC recently endorsed certain forms to transmit tariff review information, and AT&T, Sprint, and CALTEL recommend that these forms be used to provide the data for ILECs, rather than the form included in Appendix A of the ACR. We agree that it is reasonable and administratively less burdensome to allow use of the FCC Tariff Review Plan (TRP) worksheets to be used to transmit data with the Information Only or Tier 1 Advice Letters for price cap and rate-of-return carriers. We do not agree that carriers be allowed to develop their own formats for transmitting data, as the Small LECs recommend; however we do agree that no comparison of functionally equivalent elements is required. Staff must be able to review and compare data in a uniform format. Communications Division Staff have developed a modified version of the data needed from CLECs, attached to this decision as Appendix A and Appendix B.
Staff has modified the CLEC supporting data worksheets shown in Appendices A and B, in part to conform to the FCC June 5 Clarification Order, and in part to respond to CALTEL's comments. A new Grand Total has been added to aggregate the revenue data generated by the spreadsheet in columns (c), (e), (f), and (j). Filers are reminded not to modify the worksheet formulas that calculate the revenue for each rate and generate the sums in the subtotal and grand total rows, but filers can otherwise add rows or modify cell formats as needed to document FY 2011 demand, current rates and proposed rates. Staff further clarifies that columns (g) and (h) are mutually exclusive in conformance to the FCC Order - in other words a CLEC may elect to establish rates using its intrastate rate structure20 which would be shown in column (g), or alternatively apply its interstate rate structure to its an intrastate service21 which would be shown in column (h). A CLEC that adopts its interstate rate structure for its intrastate service may also assess a transitional per-minute charge on end office switching,22 which would then be shown in column (i). As the worksheet is designed to add the values in columns (g), (h) and (i), a zero in one or more of these columns will not affect the resulting revenue in column (j).
CLECs that have tariffed a single intrastate composite rate for switched access service (and not tariffed separate tandem switching and end office rate elements) shall show the composite rate in the new section "4) Composite Rates."
19 The filing of an electronic spreadsheet with the advice letter filing was required for CLECs in D.07-12-020 in order to demonstrate compliance with the MOU cap. (D.07-12-020, Ordering Paragraph 4, at 24.)
20 Per § 51.911(b)(4).
21 Per § 51.911(b)(5).
22 Per § 51.911(b)(5).
