XIII. Promotional Offerings

A. RTC

RTC asks that the Commission re-affirm its existing authority to make promotional service offerings with no imputation requirement.

On August 27, 1998, RTC filed Advice Letter 423 requesting authorization to waive 50% of the non-recurring charges for additional access lines. At the time this application was filed, the advice letter had not been approved. The Commission approved Advice Letter 423 in Resolution T-16276 dated July 22, 1999. However, the resolution imposed an imputation requirement on RTC.

RTC states that imputation has only been a requirement for permanent pricing flexibility. The Commission has never required imputation for RTC's promotional offerings prior to Resolution T-16276.

B. ORA

ORA opposes RTC's request to remove the imputation requirement for promotional offerings. ORA recommends that, since promotional offerings involve complex pricing issues, the Commission should examine each promotional offering on an individual basis to determine whether imputation is appropriate.

C. Discussion

In the Assigned Commissioner's Ruling and Scoping Memo dated May 19, 1999, one of the issues was whether RTC could make promotional offerings. Since Resolution T-16276 approved RTC's promotional offering subsequent to the ruling, the issue of whether RTC can make promotional offerings is moot.

Imputation was not an issue at the time the Assigned Commissioner's Ruling was issued. It became an issue for RTC when the Commission adopted Resolution T-16276 on July 22, 1999. Therefore, strictly speaking, the issue of imputation is beyond the scope of this proceeding. More importantly, however, RTC's problem is with Resolution T-16276. If RTC wants to challenge Resolution T-16276, this is not the place to do so. We will not address imputation in this proceeding.