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Agenda ID # 2792

October 30, 2003

DRAFT

PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Telecommunications Division

RESOLUTION T-16756

Carrier Branch

October 30, 2003

R E S O L U T I O N

Resolution T-16756. Calaveras Telephone Company, Inc. (U-1004-C). General Rate Case Filing in compliance with G.O. 96-A, Paragraph VI, and Decision Numbers 01-02-018 and 01-05-031.

By Advice Letter No. 257, 257A and 257B filed on December 17, 2002, April 16, 2003, and July 9, 2003, respectively.

_________________________________________________________________

Summary

This resolution addresses the General Rate Case (GRC) filed by Calaveras Telephone Company (Calaveras) through Advice Letter 257, 257A and 257B in compliance with D.01-05-031. Calaveras proposes; a) no changes to its basic rates or charges, however the company proposes increases to some optional services and one-time charges to bring its prices more in line with that of the telephone industry, b) an intrastate rate of return (ROR) of 10.00%, the same rate of return granted in its previous GRC filing in 1995, and c) $2,297,102 in California High Cost Fund-A (CHCF-A) support for year 2004. This represents an increase in its California High Cost Fund-A (CHCF-A) draw for 2004 by 66% or an increase of $915,414 from its 2003 draw of $1,381,688.

This resolution authorizes total intrastate revenue in the amount of $4,481,973 for Calaveras for the test year 2004. This represents a reduction of $830,461 to Calaveras' estimate of $5,312,434 for total intrastate revenue for 2004. The Total Intrastate Rate Base amount for Calaveras is $8,819,934 with an overall Intrastate Rate of Return of 10.00% for the test year 2004. This resolution also authorizes the CHCF-A support for Calaveras for test year 2004 at $1,408,640. This amount represents an increase of $26,952 or 1.95% from its CHCF-A 2003 support of $1,381,688. This increase is due to adjustments made to revenues, expenses and rate base estimates.

Appendix A shows Calaveras' Test Year 2004 Total Company Results of Operations in AL 257, 257A and 257B. Appendix B compares the Telecommunications Division's (TD's) and Calaveras' Test Year 2004 Total Company Results of Operations before any CHCF-A adjustment. Appendix C compares TD's and Calaveras' Interstate and Intrastate Results of Operations before any CHCF-A adjustment to reflect the 10% intrastate ROR. Appendix D compares TD's and Calaveras' Intrastate Results of Operations estimates after Calaveras and TD's proposed CHCF-A increase and after TD's proposed adjustments. Appendix E shows TD's calculation of the Net-to-Gross Multiplier and the change in the gross intrastate revenue requirement based on an adopted intrastate rate of return of 10.00%.

Background

Calaveras Telephone Company is a local exchange telephone carrier (LEC) serving approximately 4,541 access lines in Calaveras County and areas contiguous thereto, furnishing local, toll, and access telephone service. The Company's principal place of business is located in Copperopolis, California. Calaveras serves in two exchanges, Copperopolis and Jenny Lind.

In Decision (D.) 01-05-031, the California Public Utilities Commission (CPUC) set in motion the waterfall1 provision in 2003 for seven small LECs if they did not each file a General Rate Case (GRC) by the end of 2002.2 Calaveras filed Advice Letter (AL) No. 257 on December 16, 2002, and Supplement AL Nos. 257A on April 16, 2003 and AL 257B on July 9, 2003 with a Test Year of 2004. The last GRC filed by Calaveras was in 1995 through an Application and its latest intrastate results of operations were authorized by Decision 97-04-034 dated April 9, 1997.3

In AL 257 and 257A Calaveras proposes a) no changes to its basic rates or charges, however Calaveras proposes increases to some optional services, b) an intrastate ROR of 10.00%, the same rate of return granted in its previous GRC application filing in 1995, and c) an increase in its CHCF-A draw for 2004 by 65% or an additional $899,961 from its 2003 draw.

On July 9, 2003, Calaveras filed AL. No. 257B to include Public Programs audit expense for this rate case and to include Rural Telephone Bank (RTB) stock to the rate base. Calaveras also proposes an increase in its CHCF-A draw for 2004 by 66% or an increase of $915,414 from its 2003 draw of $1,381,688.

Notice/Protests

Calaveras states that a copy of the Advice Letter was mailed to competing and adjacent utilities and/or other utilities. Notice of AL 257 was published in the Commission Daily Calendar of December 20, 2002. Notice of the AL 257 filing was mailed to customers by bill insert on December 16, 2002. Notice of the Supplemental AL 257A was published in the Commission Daily Calendar of April 16, 2003. Notice of Advice Letter 257B was published in the Commission's Daily Calendar of July 23, 2003. The AL 257A was noticed to customers by bill insert on May 1, 2003. AL 257B was not noticed to customers because only minor revisions were made to the filing. No protest to these AL filings has been received.

TD held a Public Meeting in Copperopolis on May 5, 2003, at which time Calaveras was given an opportunity to explain its filing to its customers. Calaveras' customers were also given the chance to ask questions of Calaveras and the TD staff, and to comment on Calaveras' rates and services. Calaveras customers were given notice of the Public Meeting through bill insert. The notice of Public Meeting was also published in a local newspaper. No customers attended the Public Meeting.

Discussion

Results of Operations

TD calculates that Calaveras will earn in test year 2004 a total company overall rate of return of 9.95% at present rates as compared to Calaveras' calculation of 6.31%. Since TD concludes Calaveras is earning below TD's goal of an overall rate of return of 10.00%. TD's estimates for Calaveras reflect its revisions to Calaveras' estimates of revenues, expenses, and rate base as discussed below. Appendix B compares Calaveras' total company results of operations for test year 2004, as estimated by TD and Calaveras at present rates.

Total Operating Revenues

Calaveras' estimate of total company operating revenues at $6,250,556 exceeds TD's estimate of $5,897,554 by $353,002 or 5.99% (Appendix B, Line 9). Comparison between TD's and Calaveras' estimates are described below.

In determining the test year total company revenues, TD accepted Calaveras' 4.59% percent increase used for revenue items that are derived from billings. This includes basic local Private Line, customer inside wire and state switched access revenues. Calaveras applied the 4.59% increase to recorded 2002 data to estimate 2003 and 2004 revenues for these items.

TD accepts the 4.59% growth rate increase used by Calaveras. Its acceptance is based on an evaluation of the historical average access line growth, field inspection of the areas served by Calaveras, and discussion with Calaveras County planning officials. The forecasted units for 2003 and 2004 were developed based on an overall access line growth rate of 4.59% per year. This growth rate represents the average growth rate for the recorded years 2000 through 2002. Calaveras estimated local revenues by multiplying the forecasted monthly units by the tariff rates and charges. Revenues for billings and collection services were developed using the same average growth rate of 4.59% per year. TD staff considers company's revenue estimates at present tariff rates and charges to be reasonable.

TD concurs with Calaveras' model which estimates Interstate Access Revenue as a function of the total company rate base and expense amounts. The difference in the calculation of Interstate Access Revenues for Test Year 2004 results from differing estimates of Total Company Results of Operations between Calaveras and TD. TD's estimate of $1,360,318 is $248,268 or 18.25% lower than Calaveras' estimate.

Differences between Calaveras' estimate of CHCF-A revenue and TD's estimate result from the goal of each to balance Net Operating Income as 10% of Total Rate Base.

Calaveras' basic rates are at the 150% level of comparable California urban rates.4 No changes are proposed to the basic service rates. However, Calaveras proposes to increase its optional rates and one-time service charges to bring them in line with the industry and in order to lower the draw from the CHCF-A fund. The new charges would result in an increase of $15,611. Since the service charge increases would bring the charges more in line with the industry, and also lower the draws on the CHCF-A. This proposal is reasonable.

Calaveras proposes the following rate increases and TD finds them to be reasonable:

Uncollectibles

Uncollectibles are based on bad debts associated with local revenue and intrastate access revenues. Calaveras estimates local bad debt at $3,834 and contends that it will remain consistent with historical figures. However, Calaveras explains that the, "Bad Debt on Intrastate Access Revenue was historically part of the settlement process and as such was absorbed by the settlement pools. Now that Calaveras is no longer in the settlement pool bad debt on intrastate access is a greater risk. This was highlighted by the recent bankruptcy [sic] of Worldcom and Global Crossing, which accounts for the large bad debt in 2002". Calaveras assumes that the intrastate access bad debt it incurred in 2002 of $57,113 due to the bankruptcy will continue through 2004.

TD does not agree with Calaveras' estimation for test year 2004 uncollectibles. Although TD finds Calaveras' estimate for local bad debt at $3,834 to be reasonable, TD does not find Calaveras' estimate for $58,000 for intrastate access revenue bad debt to be reasonable. The recent Worldcom and Global Crossing bankruptcies are a one-time occurrence and Calaveras will not incur similar bad debt on an annual recurring basis. TD therefore disallows $58,000 of bad debt associated with intrastate access revenue and estimates uncollectibles to be $3,834 for the test year 2004.

In the event that Calaveras incurs similar access revenue bad debt as the result of continued bankruptcy filings by interexchange carriers and does not receive remedy from applicable court decisions, Calaveras is then encouraged to seek remedy from the Commission for those lost revenue amounts. Calaveras may not seek remedy from the Commission for those debts incurred due to bankruptcy filings until the bankruptcy proceedings have been finalized and monies dispersed. This delay is necessary to avoid the potential of Calaveras' double recovering the bad debt it has incurred as the result of bankruptcy filings.

Total Operating Expenses

Calaveras' estimate of total company operating expenses at $3,622,733 (less depreciation and taxes-income and other) is greater than TD's estimate of $3,018,476 by $604,257 or 20.02%. A comparison of TD's and Calaveras' estimates of total operating expenses for test year 2004 is shown in Appendix B. Differences between TD's and Calaveras' estimates are described below.

For operating expenses, Calaveras forecasted 2003 and 2004 expenses based on the following methodology. First, historical three-year average (2000 to 2002) percentages were developed for Labor (8.98%) and Non-Labor (3.16%) related expenses. Then, the three-year average percentages were applied to the 2002 sub-account details to generate 2003 forecasted expenses. Calaveras applied these percentages to sub-accounts for the Plant Specific, Plant non-Specific, Customer Operations, and Corporate Operations expense categories, based on details of each sub-account (i.e., Labor: Salaries & Wages, Benefits; Non-Labor: Rents, Clearances, and Other). The same percentages were then applied to the 2003 forecasted expense estimates to generate the 2004 Test Year expense estimates. Calaveras believes this methodology to be reasonable for a small company.

TD does not agree with Calaveras' estimated labor related and all other expense growth rates. The growth rate factor used by Calaveras is too high compared to ORA's labor and non-labor inflation factors (see footnote 7, page 7). Therefore, the difference between Calaveras' and TD's estimates is due to the use of different methodologies in projecting expenses.

TD used Calaveras' recorded expenses in terms of labor and non-labor expenses and applied the constant dollar method to estimate Calaveras' 2004 expenses. The constant dollar method is used to convert nominal dollars to inflation-adjusted figures. This is done by using inflation factors for each year and compounding them to 2002 dollars. The constant dollar method is applied to convert the price of a basket of utility purchases in various years to a selected base year price. While expenses have been increasing in nominal dollars, when one applies the constant dollar method and adjusts the recorded figures to base year constant dollars, there is less of a variance and in many cases, the inflation-adjusted figures remain relatively flat. The Commission in Siskiyou's 1997-test year rate case proceeding discussed and adopted TD's use of the constant dollar methodology. In Finding of Fact 6 of Resolution T-16006, the Commission found "...TD's methodology in estimating expenses reasonable and adopt TD's recommended test year 1997 expenses contained in Appendix A." 5

TD used Calaveras' recorded expense figures from the annual reports for the years 2000, 2001 and 20026 and then applied the recorded inflation factors for labor and non-labor for each year to convert the recorded expenses to constant 2002 dollars7. It then took the average of the inflation-adjusted amounts for those years and used the average amounts as its base estimates. It then applied the cumulative inflation factors for 2003 and 2004 to the base estimate to arrive at the test year 2004 estimate.

Calaveras also included $5,134 rate case expense that it incurred in 2003 due to an audit conducted by the Public Programs Branch. Since this audit does not occur annually, this rate case expense should be amortized over a three-year period. Three years are a reasonable period since CHCF-A funding remains at 100% only for the first three years after a GRC, at which time the funding is automatically reduced by 20%. Conceivably, a Small LEC could file a GRC after every three years to retain 100% CHCF-A support. Therefore, TD recommends that the rate case expense in the amount of $1,711 ($5,134 amortized over three years) should be included in the 2004 test year expense.

Based on the Constant Dollar Method (CDM), and including the audit expense amortized over three years, TD now recommends a 2004 test year intrastate total operating expense of $3,599,980, which is $771,954 or 21.44% less than Calaveras' estimate of $4,371,934. TD concludes its estimates are more reasonable than Calaveras', because TD incorporated inflationary increases and normalized the fluctuations in the expenses.

To calculate depreciation expenses, both TD and Calaveras utilized the same methodology and depreciation rates previously adopted by the Commission for Calaveras in D. 97-04-034. Depreciation expense was computed using TD's plant in service estimates for 2003 multiplied by the previously adopted depreciation rates to derive the 2003 figure. To estimate the 2004 figure, TD used its projected depreciable plant in service for 2004 and applied the adopted depreciation rates previously approved by the Commission for Calaveras.

Taxes

The difference in tax estimates between Calaveras and TD is due to differences between their estimates of revenue and expense. Both TD and Calaveras used a Corporate State Franchise Tax (CCFT) rate of 8.84% and a Federal Income Tax rate of 34.00%. TD's estimate of 2004 Intrastate Operating Taxes (including other taxes) of $597,617 is 6.1% lower than that computed by Calaveras

Rate Base

TD examined Calaveras' Rate Base components, which include Telephone Plant-in-Service, Telephone Plant-under-Construction, Materials & Supplies, RTB Stocks, Customer Deposits, Working Cash and Deferred Income Taxes. TD disagrees with Calaveras' estimate of Telephone Plant-in-Service.

Calaveras' proposed plant additions for 2003 and 2004 are $3,850,620 and $2,028,103 respectively. Telephone Plant in Service (TPIS) was forecasted based on the Calaveras' Capital Budget. The Capital Budget summarizes additions and retirements to plant for the periods 2003-2004. TD's estimate of plant additions for 2003 and 2004 are $2,619,211 and $2,965,034, respectively. TD reviewed and analyzed each item of Calaveras' budgeted plant additions, compared them with recorded plant additions for 2000 through 2002 and then arrived at its estimates by applying various techniques, such as averaging, regression analysis and growth factors.

Calaveras proposed a new addition in its plant addition budget, buried cable, in the amount of $2,133,340 for 2003 and zero dollar for 2004. This item alone accounts for 55% of the company's total budgeted plant addition for 2003. TD then reviewed the plant additions since 2000 and noted that the proposed 2003 plant additions amount is over 2.7 times the plant additions made in 2002. TD spreads the $2,133,340 buried cable plant additions amount equally in Calaveras' rate base for 2003 and 2004. TD made minor adjustments to other plant additions. The difference between the plant addition amounts between Calaveras and TD result from the application of the different estimating methods used by each.

Calaveras included $91,375 Rural Telephone Bank (RTB) stock when it borrowed funds from the RTB. Though the loan was provided at a lower cost, Calaveras is required by RTB to use a certain amount of the loan to purchase stock in the RTB. Calaveras included the stock in the rate base to compensate for the required investment. Furthermore, Part 65 of the Code of Federal Regulations includes RTB stock as a component of the rate base. Therefore, TD agrees with Calaveras to include $91,375 RTB stock in the rate base.

Working Cash: Both Calaveras and TD used the simplified method described in the CPUC's Standard Practice U-16 to arrive at the working cash estimate. TD's Total Company Working Cash for test year 2004 estimate is $281,675 or 19.54% lower than that computed by Calaveras, due to TD's lower expense estimates.

Materials and Supplies (M&S): Calaveras' materials and supplies (M&S) amount was estimated by taking the ratio of the 2002 average M&S to the 2002 average TPIS. Calaveras then applied this ratio (2.06%) to the forecasted 2003 and 2004 TPIS to derive the 2004 M&S estimate. TD performed a regression analysis of M&S recorded data for the years (1997-2002) and based on the observed trend, Calaveras' M&S estimate of 2.06 average ratio for test year 2004 is reasonable. TD then applied this ratio to its forecasted TPIS for 2003 and 2004 to arrive at its M&S estimate for those years. Differences in TD's and Calaveras' estimate of 2004 M&S are due to differences in TPIS. TD recommends that the average Total Company M&S of $411,703 be included in the rate base.

Calaveras' Deferred Income Taxes (DIT) was estimated by taking the ratio of the 2002 average DIT to the 2002 average TPIS. A negative 3.93% ratio was then applied to the forecasted 2003 and 2004 average TPIS to derive the 2004 DIT. TD reviewed the five-year history (1998-2002) of DIT to TPIS. Based on this review, Calaveras' estimate of negative 3.93% ratio is reasonable. TD then applied this negative 3.93% ratio to its forecasted TPIS to derive its 2004 DIT. Differences in TD's and Calaveras' estimate of 2004 DIT are due to differences in TPIS. Therefore, TD recommends that the average Total Company DIT of $786,442 be included in the rate base.

Separations

Calaveras provides both intrastate and interstate telecommunications services, subject to the regulation of the CPUC and FCC, respectively. Because Calaveras' property serves both jurisdictions, the utility's expenses, taxes, investments, and reserves are allocated (separated) between interstate and intrastate services according to FCC rules. TD reviewed Calaveras' separation factors and finds them to be reasonable. Appendix C compares Calaveras' and TD staff's total company (interstate and intrastate) results of operations for test year 2004 using these separation factors.

Cost of Capital

Calaveras requests an overall intrastate rate of return of 10.00%. This is the same rate of return that was authorized by D.97-04-034 for its last general rate case filing for test year 1997.

The Return on Equity for all rural ILECs should be the same since the systematic and non-diversifiable risks faced by all rural ILECs are similar. As a matter of practice, Decision D.97-04-034 in A.95-12-0758 adopted an 'overall' rate of return of 10.00% for all rural ILECs. The risks faced by rural ILECs appears similar today as in the recent past, and therefore TD recommends that the Commission should approve Calaveras' request for an overall rate of return of 10.00% at this time.

Net-to-Gross Multiplier

The net-to-gross multiplier indicates the unit change in gross revenues required to produce a unit change in revenues. Appendix E shows TD's computation of Calaveras' net-to-gross multiplier. The net-to-gross multiplier of 1.66207 means that a change of $1,662 in gross revenue would be required to produce a change of $1,000 in net revenue. For Calaveras, based on a recommended intrastate rate base of $8,819,934 and rate of return of 10.00%, the recommended gross intrastate revenue requirement change required is a reduction of $52,113.

CHCF-A Support

D.01-02-018 approved Settlement Transition Agreements (STAs) between Pacific Bell and the small Local Exchange Carriers (small LECs). Monies that Pacific Bell paid the small LECs through toll and access pool settlements were replaced by authorized draws from the CHCF-A. The CHCF-A itself was originally established by D.85-06-115 as a means of subsidizing reasonable basic exchange rates for the customers of small LECs that adopted Pacific's statewide average toll, toll private line, and access rates (settlement pools). D.01-02-018 required the small LECs' replacement funding for the STAs be subject to the same rules that apply to current draws from the CHCF-A, namely, basic residential rates shall be increased to a ceiling equal to 1.5 times the urban rate as necessary, and both the means test and the waterfall provisions should apply.

TD calculated Calaveras' CHCF-A support for test year 2004 at present rates to be $1,476,860. The CHCF-A 2004 support is derived from using Calaveras' 2003 initial

Draw of $1,381,688, adding the $1,025,391 NECA estimated USF Federal support for 2003, and subtracting Calaveras' projected 2004 USF Federal support of $930,2199.

The intrastate results of operations at present rates show that Calaveras registers an intrastate rate of return of 10.36% (Appendix C, column F). Appendix D shows Calaveras' intrastate results of operations using the 10.00% intrastate rate of return.

TD's computation of Calaveras' CHCF-A requirement is $ 1,408,640 based on TD's projected revenues (including rate design), expenses, rate base and overall intrastate rate of return of 10% for test year 2004.

Comments

In accordance with P.U. Code Section 311 (g) TD mailed a copy of the original draft resolution on September 30, 2003 to Calaveras and other interested parties. Comments received on a timely basis will be addressed in any final resolution.

Findings

1. Calaveras filed its GRC on December 17, 2002, with a Test Year of 2004 in compliance with Decision 01-05-031.

2. Calaveras requests the following for test year 2004:

3. Telecommunications Division (TD) recommends the following for Calaveras for test year 2004:

4. The differences in the revenue, expense, and rate base estimates between Calaveras and TD result from the use of different methodologies and assumptions for estimating revenue, expense and rate base estimates.

5. The Commission finds TD's methodology in estimating revenues to be reasonable. The Commission therefore adopts TD's recommended intrastate revenues as shown in Appendix D.

6. The Commission accepts TD's recommended overall intrastate rate of return of 10.00% for Calaveras for test year 2004.

7. The Commission finds Calaveras' depreciation rates previously adopted by the Commission, as part of its 1997 general rate case acceptable for ratemaking purposes for test year 2004.

8. The Commission finds TD's methodology of using the constant dollar method in estimating expenses to be reasonable and adopts TD's recommended test year 2004 expense estimates contained in Appendix D.

9. The Commission finds TD's methodology in estimating rate base to be reasonable. The Commission therefore adopts TD's recommended intrastate rate base as shown in Appendix D.

10. The Commission finds TD's recommended $1,408,640 CHCF-A support for Calaveras for 2004 to be acceptable. The $1,408,640 CHCF-A support is based on the Commission's adoption of TD's Intrastate Results of Operations for Calaveras for test year 2004.

11. The Commission finds Calaveras' request for revenue increase of $15,611 due to increases to some optional services and one-time charges to bring its prices more in-line with the telephone industry to be reasonable.

12. Commission approval is based only on the specifics of this Advice Letter.

THEREFORE, IT IS ORDERED that:

1. The intrastate revenues, expenses, and rate base amounts for test year 2004 identified in Appendix D, column (E) are adopted for Calaveras Telephone Company, Inc.

2. The overall intrastate rate of return of 10.00% is adopted for Calaveras Telephone Company, Inc., for test year 2004.

3. The depreciation rates submitted by Calaveras Telephone Company, Inc., in support of its General Rate Case Advice Letter No. 257 are adopted for ratemaking purposes for test year 2004.

4. The Calaveras Telephone Company, Inc.'s CHCF-A draw for 2004 is $1,408,640.

5. Calaveras Telephone Company, Inc., is granted authority to revise tariff changes described in AL Nos. 257, 257A, and 257B. The revised tariff sheets submitted with AL No. 257 shall be made effective on January 1, 2004.

This Resolution is effective today.

I hereby certify that the Public Utilities Commission at its regular meeting on October 30, 2003 adopted this Resolution. The following Commissioners approved it:

1 The waterfall provision refers to the 6-year phase down of the CHCF-A funding level beginning in 1998, the year after the completion of a GRC. The funding levels are 100% of the for the first 3 years, i.e., 1998, 1999 and 2000; 80 % the fourth year, i.e., 2001, 50% the fifth year, i.e., 2002; and 0% thereafter.

2 The seven companies are Calaveras Telephone Company, Cal-Ore Telephone Company, Ducor Telephone Company, Foresthill Telephone Company, Hornitos Telephone Company, Kerman Telephone Company, and Pinnacles Telephone Company.

3 In Decision 97-04-034, Calaveras Telephone Company was ordered to reduce its intrastate rates by approximately 10.85% or $343,366 in its 1997 test year, effective January 1, 1997. A 10% return on rate base found reasonable for Calaveras produces a 12.70% return on equity when applied to applicant's test year capital structure of 29.21% debt and 70.79% equity.

4 D. 91-09-042 establishes that draws from the CHCF-A require that a small LEC `s basic rates shall be increased, the increased rate is not to exceed 150% of comparable California urban rates.

5 At page 5 of Resolution T-16006, the Commission stated, "Generally for traditional GRCs, the Commission adopts the constant dollar method".

6 Form M Schedule I-1 (FCC ARMIS 43-02 Report Format) of Calaveras' Annual Reports for 2000, 2001 and 2002.

7 TD used the Office of Ratepayers Advocates estimates of Non-Labor and Wage Escalation Factors for 2002-2004 from the January 2003 Global Insight U. S. Economic Outlook as follows:

8 In D.97-04-034 the Commission authorized Calaveras Telephone Company a 10.00% return on rate base for it's 1997-test year as appropriate in A.95-12-075 (Calaveras' 1997 General Rate Case application).

9 Federal USF support is based on the 2003 projected payments for the California Exchange carriers as filed by the National Exchange Carriers Association, Inc. (NECA) on October 1, 2002 with the Federal Communications Commission.

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