· The trend analysis relies on two different cost models, with different methodologies and assumptions. The 1996 cost model was prepared in the same year and using the same TSLRIC methodology as the Verizon California 1996 study (which the Commission found flawed in D.96-08-021). (Murray Declaration, 8/20/02, para. 9.) The 1996 study estimates costs based on a small subset of wire centers (Id., para. 16.), whereas the 2001 cost study is based on the TELRIC-based ICM, and it estimates switching costs for each wire center. (Id.)

· Verizon itself admits that the two Florida cost studies use different methodologies and cannot be relied on to produce a reliable trend for tandem switching rates. (Id., para. 8-17.)

· Verizon omits switch features, which Joint Commenters consider an integral part of the switching UNE and the cost analysis on which Verizon relies for its cost trend. Joint Commenters contend that Verizon's failure to include features could bias the cost trend. Further, switch feature costs should decline in parallel to other switching costs. (Id., paras. 35-36.)

4. Joint Commenters' and TURN's New Jersey Proposal is Preferable to the Proposal to Use Pacific Bell Interim Rates

14 Verizon explains that its trend analysis shows increases in tandem switching costs over the time period examined because of significant cost methodology changes between the 1996 and 2001 Florida studies. Verizon states that increasing tandem switching rates using the trend analysis is inappropriate. Instead, Verizon proposes to decrease tandem switching rates by the same 44% percent reduction found for end office switching costs because it expects similar cost trends for end office and tandem switching. (Collins Declaration, 7/30/02, para. 9.) 15 See D.02-05-042 in A.01-02-024 and consolidated cases. 16 Joint Commenters used the Synthesis Model and all necessary components and directions from the FCC's website, provides the Synthesis Model results and work-files that the FCC created in 2000 (using 1998 data). (Murray Declaration, 7/30/02, para. 13.) 17 GTEC's acquisition of Contel was approved by the Commission in D.96-04-053. 18 In D.02-09-049, the Commission approved an increase in Pacific's markup from 19% to 21%, but this change has not yet been reflected in Pacific's rates. For this reason, we will continue to refer to the markup as 19% in this order. 19 Joint Commenters' reasoning for this modification to the shared and common cost markup is discussed more fully in Section V below. 20 Joint Commenters use a slightly different approach to calculate an interim 4-wire loop price because Pacific has no interim price for this rate element. They recommend adjusting Verizon's current 4-wire loop rate by the same 44.4% decrease and the 2.3% increase used to adjust Verizon's current 2-wire loop price. This results in adjusting Verizon's current statewide average 4-wire loop rate of $31.85 into interim rates of $17.72 and $32.59 for the former GTEC and former Contel service areas respectively. (Murray Declaration, 7/30/02, para. 18, no. 24.) 21 Verizon currently charges a port charge plus a single minute of use (MOU) charge, in contrast to Pacific's switching rate structure which charges separate rates for intraoffice and interoffice calls, call setups and duration, and originating and terminating usage. 22 The New Jersey Board of Public Utilities adopted UNE rates on March 6, 2002, and revised these rates in part on July 15, 2002. (See In the Matter of the Board's Review of Unbundled Network Elements Rates, Terms and Conditions of Bell Atlantic-New Jersey, Inc., New Jersey Board of Public Utilities, Decision and Order, Docket No. TO00060356, March 6, 2002, hereinafter "New Jersey UNE Order," as modified by transcript of public meeting, Docket No. TO00060356, July 15, 2002.) 23 Joint Commenters propose that interim tandem switching prices for Verizon be based on the indexed relationship between Verizon New Jersey and the former GTEC territories of Verizon California because of anomalies in the Synthesis Model for tandem switching in the former Contel California territories. (Joint Commenters' Ruling Response, 9/9/02, p. 7, n. 15.) 24 For example, Joint Commenters contend that New York cost studies assume a 100% fiber feeder distribution network, whereas New Jersey assumes a fiber and copper mix similar to California. (Klick Declaration, 9/9/02, paras. 8-10.) 25 We will also disregard Verizon's November 12, 2002 reply comments in support of its motion to reopen the proceeding because this reply responds to Joint Commenters' claims that we are disregarding. Joint Commenters' motion to strike Verizon's November 12, 2002 reply comments is therefore granted. 26 We note that the rates recently adopted by the Florida PSC are significantly lower than Verizon's initial proposal in that state. Verizon initially proposed rates of $22.17 and $30.91 for zones 1 and 2 respectively, whereas the Florida PSC adopted rates for these zones of $12.00 and $16.18. (Verizon Petition to Reopen Proceeding, 10/25/02, Attachment (Appendix A-1, p. 383.)) 27 Verizon adjusted the default wire center results of the Synthesis Model for "various adjustments that the FCC has found appropriate in the section 271 benchmarking context." (Meny Declaration, 9/9/02, para. 5., referring to the FCC's review, under Section 271 of the Telecommunications Act of 1996, to applications by ILECs for authority to provide in-region interLATA services.) For each state, Verizon made these adjustments and calculated the percentage cost difference between California and that state, then used this percentage cost difference to adjust UNE rates in other Verizon states to account for cost differences between that state and California. (Id.) By providing this analysis, Verizon implicitly supports the approach of comparisons to UNE rates in other Verizon states, and the approach of using the Synthesis Model to compare relative costs in these states. 28 We take official notice that the Florida PSC adopted rates for Verizon on October 14, 2002 (Docket No. 990649B-TP). Nevertheless, we will still rely on a comparison with New Jersey because none of the parties to this case proposed using actual rates from Florida, and we have no basis on which to find that Florida rates are more appropriate than New Jersey rates. Rates for New Jersey and Florida have been adopted within months of each other and are both equally valid as examples of recently adopted rates. If we were to continually revise our decision for each new state that adopts UNE rates, we might never issue a decision.

29 Verizon suggests that the Commission cannot use Pacific's interim rates as a basis for Verizon's interim rates because of due process problems. Verizon has had ample opportunity to respond to this proposal and make its case regarding this approach. Pacific's interim loop rates are not based on a discovery sanction against Pacific, but are based on a trend analysis measuring changes in equipment input costs and line growth. Pacific's interim switching rates are based on a discovery sanction in part, but are also supported based on a showing of geographic similarities in addition to the discovery sanction.

30 See Joint Application by SBC Communications, Inc., Southwestern Bell Tel. Co., and Southwestern Bell Communications Services Inc., d/b/a Southwestern Bell Long Distance for provision of In-Region, InterLATA Services in Kansas and Oklahoma, Memorandum Opinion and Order, FCC 01-29, CC Docket No. 00-217, 16 FCC Rcd 6237, January 19, 2001, at para. 84. ("Our USF cost model provides a reasonable basis for comparing cost differences between states. We have previously noted that while the USF cost model should not be relied upon to set rates for UNEs, it accurately reflects the relative cost differences among states.") 31 See Murray Declaration, 7/30/02, para. 10, citing, In the Matter of Federal-State Joint Board on Universal Service, Report and Order, FCC 97-157, CC Docket No. 96-45, 12 FCC Rcd 8776, May 7, 1997, at paras. 250 and 251. 32 See In the Matter of Verizon New England, Inc., Bell Atlantic Communications, Inc., NYNEX Long Distance Company and Verizon Global Networks Inc., For Authorization to Provide In-Region Inter LATA Services in Massachusetts, Memorandum Opinion and Order, FCC 01-130, CC Docket No. 01-9, 16 FCC Rcd 8988, April 16, 2001, at para. 23. 33 See In the Matter of Federal-State Joint Broad on Universal Service; Forward-Looking Mechanism for High Cost Support for Non-Rural LECs, Tenth Report and Order, FCC 99-304, CC Docket No. 96-45 and 97-160, 14 FCC Rcd 20156, October 21, 1999, at para. 84 ("The model also uses structure cost tables that identify the per foot cost of loop structure by type (aerial, buried, or underground), loop segment (distribution or feeder), and terrain conditions (normal, soft rock, or hard rock) for each of the nine density zones.") and para.87 ("The Commission found that an efficient carrier will vary its plant mix according to the population density of an area and tentatively concluded that the assignment of plant mix defined by the model should reflect both terrain factors and line density zones"). 34 Specifically, Verizon started with the Synthesis Model's default wire center results, then it allocated fixed, per-line common support expenses across all UNEs, removed the allowance for retail uncollectible revenues in the model, and added allowances for wholesale uncollectible revenues and carrier-to-carrier customer service costs. (See In the Matter of Application of Verizon Pennsylvania Inc., Verizon TFQIy@{ht5 GrK WFF`3WhYZ1ALA##rf[5x+}5x:`)[4<( 9"bQq NI4j!bx0EMW96&bs pTXRL.OE[ANM.Qt/.H?j[hV~R% P_or&X3aOF0E`ey6rGTQ9UiI 4B:;v?K_>9@G obg!z G (T/'f)5^Q$:dy7,xJOw7>|=e%v's"T[VIE@JYRN3-;EMRuP7]l>q_'DY%(y\wwN{0ogg)+2vLG#iO(5B?$s\t(^Vx] ]Wc,Vi(]*U#Zh89lz:=M 7`~~Da3]/cm)J =Dla[*WPR5t 3q(:J/ Zjf@ y[ |CQU6+9gxp"A5591G&;l\(I9NA3fJ$Ot~z*SS=vf<UJ\q"Uh^YK[=8^CsddnWR_/BYBPT7[@fC?)jpp$8weQ$[ $D#o>/K8xlp[1Z4n+K$aMe~P}Zp5c5.}) &$1h'FJ 9 9uh2)B$x.a"  f)-<.=oO;o44!)N2]e7x N9g:%1?exc9 O&#I7m3U/f%fO,||7h(~ep(v$Or&swAsc;i&i>BHGVbf}ypw|!Jfd9n*AGp(-"# 2gRoyS FSQUCy*k.)ji_oM<<5Bx]$w:z2 js;+vhNq#xx;Eb7t.B40W4>B<:i>DAEV!Rc!+#1658x9{G{Q>%;cr> 0+-%8~ukrj )o2x9c}8Ixmrwe u)aen\Xb+se\:^21#6%kc$&9n,=.*KINW#P\mf>f?A $qfdldeDX/-&(8 z4lb|m;^%=/Bbc/ nr &CmY.<~tB;;f d>"~o~hc9:;S7k%zz8TZEPmrLa`AE7N`(0{ x36,# .b%"hk8I}n w1-$4<}}4Q[Eo-""&O2 e_C %lfdf#h#}F57<,HW .Db*-~/}*9(<5+t~&j]Ax},zVG!i9s6vsMg&MmH&u%!oi{r=.!<$+|{-gDE ^'h6zva ` @V~>=1K,MIo/:jBzL1Tq 5>K?zz>KpF-6iPF)7b={[b6x7afJ4W!d#T _0k/..!r07&&zt~&RxOZB06%*v Lk/2Sd)x{bS h /Kdj#U_A=`4QHXLI9zP_"-v|) K6I&} 9-PCjI+) 'mbq9b9B+X9K JhOap~l,$<5LZ&Kkgbo'd$y2qkka)"mie<`<2 m%=O&g7Z} r8(f9 d@aw (gj;~+`UNBh(d'w|5q$e:0r7kh:E;6'aMoiwE<%&lL"RJ_^IC/rV{c-{tuhU$