IX. Assignment of Proceeding
Henry M. Duque was the Assigned Commissioner in this proceeding until the case was reassigned to Commissioner Michael R. Peevey in January 2003. Dorothy Duda is the assigned Administrative Law Judge in this proceeding.
1. In D.96-08-021, the Commission found that GTEC's cost studies did not conform with the TSLRIC principles previously adopted by the Commission and it ordered GTEC to modify its cost studies using certain aspects of Pacific's studies as proxies.
2. The UNE rates currently in effect for Verizon were adopted in D.97-01-022 based on the modifications to GTEC's TSLRIC cost studies ordered in D.96-08-021.
3. Since the time that GTEC performed its TSLRIC analysis leading to its current UNE rates, the Commission and the FCC have moved to a TELRIC approach to UNE ratesetting.
4. In D.02-05-042, the Commission found that loop and switching equipment costs had declined in recent years since the time the Commission originally set UNE costs for Pacific in 1998.
5. In a May 31, 2002 ruling, the Assigned Commissioner and ALJ concluded the Commission should set interim UNE rates for Verizon.
6. The interim phase of this proceeding involved four rounds of submittals from the parties, including interim pricing proposals and comments on those proposals.
7. Verizon proposes discounts to its current UNE switching rates based on a trend analysis of proposals filed in Florida in 1996 and 2001.
8. The 1996 cost study used in Verizon's trend analysis was prepared in the same year and used the same methodology as GTEC's 1996 California cost study rejected in D.96-08-021.
9. The 2001 cost study used in Verizon's trend analysis is an updated version of the ICM filed in 1997 by GTEC in California.
10. The UNE rates adopted by the Florida PSC in October 2002 are significantly lower than the proposals made by Verizon in that state.
11. Verizon has not provided any data showing similarities between Florida and California with regard to switching networks.
12. Verizon opposes interim switching rates based on the discount adopted for Pacific's switching rates in D.02-05-042, but it proposes interim loop rates based on the loop discount adopted for Pacific in that order.
13. The FCC has used the relative costs reported by the Synthesis Model to compare the relative costs of unbundled loops and switching between ILECs in different states that operate under the same RBOC.
14. The Synthesis Model adjusts relative switching costs based on major cost drivers, including line density per switch and the number of host and remote switches.
15. The Synthesis Model adjusts relative loop costs based on population densities.
16. UNE rates for Verizon New Jersey, which were adopted in March 2002 and updated in July 2002, are among the most recent TELRIC-based UNE rates from another Verizon state.
17. Verizon New Jersey has incorporated the costs of several switch features into the port charge and charges for a few switch features on a separate basis.
18. In D.97-01-022, the Commission adopted a 22% markup for Verizon's UNEs.
19. Joint Commenters propose an 8% markup for UNE rates and nonrecurring charges based on an analysis of aggregate expense and revenue data for all RBOCs nationwide.
20. In D.99-12-018, the Commission granted interim pricing flexibility to GTEC for its Category II services.
21. Although Verizon has made two requests for interim price floors, its requests have not been granted as of the date of this order.
22. In D.94-09-065, the Commission required ILECs to impute into the retail price floor the contribution based on the actual price paid by competitors for network elements that make up the competing service.
23. In D.99-12-018, the Commission authorized interim price floors for GTEC whereby GTEC could use the UNE rates and TSLRICs contained in its 1997 cost studies to price down to the volume-sensitive portion of the TSLRIC for the service at issue, plus the contribution for MBBs (namely the loop, ports, and white page listings). The contribution for MBBs is the difference between the TELRIC-based price for each UNE found to be a MBB and the volume-sensitive portion of the TSLRIC for each of the three UNEs.
24. The Commission adopted nonrecurring costs for the ordering and provisioning of Verizon's network facilities in D.98-12-079.
25. Verizon proposes to "map" its nonrecurring costs to its corresponding products and services using Verizon's existing rate structure.
26. Verizon calculated service order charges by weighting semi-mechanized and mechanized costs based on its recent experience with the percent of orders that currently flow-through the order process without a problem.
27. In D.99-11-050, the Commission required the ILEC's nonrecurring charge to be governed by the type of system the CLC uses to place its order, rather than by the type of system used by the ILEC.
1. The Commission should set interim UNE rates for Verizon because its current rates are the product of a TSLRIC cost study filed in 1995 and 1996 and rejected by the Commission as not reflecting forward-looking cost principles.
2. The Commission should set interim UNE rates for Verizon that reflect the TELRIC methodology and the most recent forward-looking cost information available for Verizon.
3. It is reasonable to assume that equipment costs declines that were found to impact Pacific's forward-looking UNE costs in D.02-05-042 also impact Verizon's forward-looking UNE costs in the same manner.
4. In this interim ratesetting phase, parties have been given sufficient opportunity to explain their interim pricing proposals.
5. Verizon's interim rate proposal is unreasonable because it discounts from current rates that do not reasonably reflect forward-looking economic principles.
6. There is no assurance that Verizon's trend analysis reveals changes in forward-looking costs rather than methodological changes in the underlying cost studies.
7. Verizon's trend analysis of 1996 and 2001 Florida cost proposals should not be relied on because it uses two different cost models which contain methodology differences and because the rates recently adopted in Florida are lower than Verizon's proposal.
8. The Commission should take official notice of UNE rates adopted in Florida on October 14, 2002.
9. Verizon has not sufficiently explained why it would be reasonable to apply Pacific's interim loop discount but not its interim switching discount.
10. It is not reasonable to assume that Verizon's loop costs have increased simply because Verizon has proposed loop rates higher than its current rates.
11. The forward-looking cost criteria in the Synthesis Model are consistent with and largely identical to the forward-looking cost criteria that the FCC has adopted for UNEs.
12. It is reasonable to use the Synthesis Model to reflect loop and switching cost differences between California and New Jersey for the purposes of interim pricing because this is reasonably consistent with how the FCC has used the Synthesis Model when comparing UNE rates across states.
13. It is reasonable to rely on UNE rates adopted for Verizon New Jersey, adjusted using the Synthesis Model, because these are among the most recent TELRIC-based rates for Verizon and they reflect conditions after GTEC's merger with Bell Atlantic to form Verizon.
14. It is reasonable to use the Synthesis Model to set deaveraged rates for Verizon, as proposed by Joint Commenters.
15. It is not reasonable to rely on a trend analysis of proposed rates in Florida when the adopted rates in Florida differ from the proposed rates.
16. When using the Synthesis Model to compare relative UNE costs, the Commission should use an approach consistent with the methods described by the FCC in its recent Section 271 orders.
17. The Synthesis Model indicates that loops costs in the former GTEC areas and in the former Contel areas are 2.2% lower and 111.9% higher, respectively, than Verizon New Jersey average loop costs rates.
18. The Synthesis Model indicates that for unbundled switching, end office usage costs are 10.7% higher than Verizon New Jersey, port costs are 3.2% lower than New Jersey, and tandem-switching costs are 38.9% higher than New Jersey.
19. In setting interim UNE rates, we should adjust Verizon New Jersey rates upwards wherever the Synthesis Model indicates that California costs are higher than New Jersey, but not vice versa.
20. The Commission should set switch feature prices at zero, except for those features priced individually by Verizon New Jersey, because Verizon New Jersey includes switch feature costs in its port charge.
21. Verizon's DS-1 port rate should remain at its current level, subject to adjustment from the date of this order, because there is no basis on which to increase it.
22. Verizon is not harmed by the interim rates adopted today if rates are subject to adjustment once final rates are determined.
23. Once final rates are adopted, the interim monthly recurring UNE rates adopted in this order should be adjusted, either up or down, from the effective date of this order.
24. Joint Commenters' markup proposal is unreasonable because it fails to consider the individual variations in overhead percentages between RBOCs.
25. It is not reasonable to use the 10% markup included in Verizon New Jersey UNE rates because the Synthesis Model does not account for variations in overhead costs between states.
26. The Commission should retain the 22% markup adopted for Verizon in D.97-01-022 and use it to set interim UNE rates and nonrecurring prices.
27. To be consistent with D.94-09-065, Verizon's interim price floors should reflect the actual price paid by competitors for network elements, or monopoly building blocks, that make up the competing service.
28. If Verizon were to calculate price floors using the UNE rates and TSLRICs from its 1997 cost studies, as set forth in D.99-12-018, this would result in a large disparity between the actual UNE rates paid by competitors and the rates used in the price floor formula. This would prevent Verizon from pricing retail services to match its competitors.
29. When Verizon calculates interim price floors using the methodology set forth in D.99-12-018, it should substitute the UNE rates adopted in this order for the rates contained in its previously filed OANAD cost studies and it should reduce the volume sensitive TSLRIC figure in the price floor formula, which is derived from Verizon's 1997 cost study filing, by the same percentage that its current UNE rates are reduced.
30. When entering contracts based on price floors calculated as set forth in this order, Verizon should notify customers that the prices in the contract are subject to change upon adoption of final price floors by the Commission.
31. Verizon's proposal to combine mechanized and semi-mechanized costs into one initial order charge is not reasonable because it ignores the fall-out rates adopted in D.98-12-079.
32. Verizon should configure its order processing system in order to charge separate rates depending on whether the CLC employs a mechanized, semi-mechanized, or manual system to place its order.
33. Verizon should separate its charges for initial and additional orders so that CLCs only pay for additional orders when they make them.
34. Verizon should not collect disconnect charges in advance, as it proposes, because this is a requirement placed on CLCs that Verizon does not bear itself.
35. Verizon should charge separately for Record Orders so that only those CLCs that actually make record changes pay the charge.
36. Verizon's proposal to map Pacific's Change Order charge to the Verizon Subsequent Order charge is reasonable.
IT IS ORDERED that:
1. The monthly recurring prices for unbundled network elements (UNEs) offered by Verizon California, Inc. (Verizon) that are set forth in Appendix A to this decision satisfy the requirements of Sections 251(c)(2), 251(c)(3), and 252(d)(1) of the Telecommunications Act of 1996 and are hereby adopted on an interim basis and made subject to adjustment, either up or down, from today's date until final prices are adopted.
2. Verizon shall prepare amendments to all interconnection agreements between itself and other carriers substituting the interim monthly recurring prices for UNEs set forth in Appendix A of this order for the UNE prices set forth in such interconnection agreements. Such amendments shall be filed with the Commission's Telecommunications Division, pursuant to the advice letter process set forth in Rules 6.2 and 6.2 of Resolution ALJ-181, within 30 days after the effective date of this order. The amendments do not require a signature of the carriers involved as long as the amendments are limited to substituting the UNE rates adopted in today's order. Unless protested, such amendments will become effective 30 days after filing.
3. The interim UNE prices set forth in Appendix A of this order shall be effective on the date this order is effective. Verizon shall make all billing adjustments necessary to ensure that this effective date is accurately reflected in bills applicable to these UNEs.
4. Verizon shall have 60 days from the effective date of this order to complete the billing program changes necessary to reflect in bills the interim monthly recurring prices for UNEs adopted in this order. Upon completion of said billing program changes, Verizon shall notify the Director of the Telecommunications Division in writing that all of the necessary billing program changes have been completed.
5. Within 10 days of the effective date of this order, Verizon shall file an advice letter to establish a balancing account to track the revenues received from the interim monthly UNE rates adopted herein, beginning on the same date the interim rates become effective. The balancing account should accrue interest at the three-month commercial paper rate. Unless protested, the advice letter shall become effective five days after filing.
6. Verizon shall make the following changes to its nonrecurring charge proposal:
· Verizon should configure its order processing system in order to charge separate rates depending on whether the CLC employs a mechanized, semi-mechanized, or manual system to place its order.
· Verizon should separate its charges for initial and additional orders so that CLCs only pay for additional orders when they make them.
· Verizon should not collect disconnect charges in advance, as it proposes, because this is a requirement placed on CLCs that Verizon does not bear itself.
· Verizon should charge separately for Record Orders so that only those CLCs that actually make record changes pay the charge.
· Verizon should add a markup of 22% to its nonrecurring charges, once the changes above are made.
7. Verizon's nonrecurring charge proposal is adopted, with the modifications set forth in this order. Within 20 days from the effective date of this order, Verizon shall file and serve a revised list of its nonrecurring charges complying with the changes set forth in this order. Interested parties shall have 14 days to comment on that filing, unless the assigned Administrative Law Judge (ALJ) adopts a different schedule for responses. Verizon's nonrecurring charges shall go into effect 75 days after the effective date of this decision, unless the assigned ALJ issues a ruling suspending this effective date pending further Commission action. If Verizon's revised nonrecurring charges are suspended, the existing nonrecurring charges shall remain in effect, subject to refund from the 75th day after the effective date of this order, until all outstanding issues with nonrecurring charges are resolved.
8. When submitting an advice letter to the Commission regarding interim Category II price floors, Verizon shall calculate interim price floors according to the formula described in this order.
9. When entering contracts based on price floors calculated as set forth in this order, Verizon shall notify customers that the prices in the contract are subject to change upon adoption of final price floors by the Commission.
10. Verizon's petition to take official notice of UNE rates adopted for Verizon in Florida on October 14, 2002 is granted.
11. Joint Commenters' November 22, 2002 motion to strike Verizon's November 12, 2002 reply comments is granted.
12. The May 31, 2002 ruling of the Assigned Commission and Administrative Law Judge is affirmed.
13. This proceeding shall remain open so that the Commission can determine final monthly recurring charges and price floors for Verizon's UNEs.
This order is effective today.
Dated March 13, 2003, at San Francisco, California.
I dissent.
/s/ MICHAEL R. PEEVEY
President
CARL W. WOOD
LORETTA M. LYNCH
GEOFFREY F. BROWN
SUSAN P. KENNEDY
Commissioners
Appendix A | |||||
Verizon Interim UNE rates | |||||
UNE |
Verizon's Current Rate |
Percentage Adjustment |
Adopted Interim Rate |
||
Loops |
|||||
2-Wire Loop (State-wide Average) |
$16.81 |
||||
Zone 1 (former GTEC area) |
(37.2%) |
$10.56 |
|||
Zone 2 (former Contel CA area) |
33.1% |
$22.37 |
|||
4-Wire Loop (State-wide Average) |
$31.85 |
||||
Zone 1 (former GTEC area) |
(31.8%) |
$21.73 |
|||
Zone 2 (former Contel CA area) |
44.5% |
$46.03 |
|||
Switching |
|||||
Ports |
|||||
Basic Port |
$4.58 |
(53.7%) |
$2.12 |
||
Centrex Port |
$4.58 |
(53.7%) |
$2.12 |
||
DS-1 Port |
$54.67 |
0.0% |
$54.67 |
||
Switch Usage |
|||||
Tandem Switching (per mou) |
$0.001500 |
(30.8%) |
$0.001038 |
||
End Office Switching (per mou) |
$0.003629 |
(59.8%) |
$0.001457 |
||
Switch Features |
|||||
Three Way Calling |
$0.65 |
(100.0%) |
$0.0000 |
||
Call Forwarding |
$0.12 |
(100.0%) |
$0.0000 |
||
Customer Changeable Speed Calling 1-Digit |
$0.10 |
(100.0%) |
$0.0000 |
||
Customer Changeable Speed Calling 2-Digit |
$0.16 |
(100.0%) |
$0.0000 |
||
Call Waiting |
$0.02 |
(100.0%) |
$0.0000 |
||
Cancel Call Waiting |
$0.01 |
(100.0%) |
$0.0000 |
||
Automatic Callback |
$0.04 |
(100.0%) |
$0.0000 |
||
Automatic Busy Redial |
$0.13 |
(100.0%) |
$0.0000 |
||
Calling Number Delivery |
$0.04 |
(100.0%) |
$0.0000 |
||
Calling Number Delivery Blocking |
$0.07 |
(100.0%) |
$0.0000 |
||
Smart Ring |
$0.01 |
(100.0%) |
$0.0000 |
||
Customer Originated Trace |
$0.04 |
(100.0%) |
$0.0000 |
||
Selective Call Forwarding |
$0.16 |
(100.0%) |
$0.0000 |
||
Selective Call Acceptance |
$0.12 |
(100.0%) |
$0.0000 |
||
Remote Call Forward |
$2.73 |
(100.0%) |
$0.0000 |
||
Distinctive Alerting/Call Waiting Indicator (VIP) |
$0.12 |
(100.0%) |
$0.0000 |
||
Call Block |
$0.17 |
(100.0%) |
$0.0000 |
||
Last Number Redial |
$0.04 |
(100.0%) |
$0.0000 |
||
Selective Calling Waiting |
$0.12 |
(100.0%) |
$0.0000 |
||
Billed Features * |
|||||
Multi-Line Hunting |
$0.000001 |
||||
Intercom & Features |
$0.011343 |
||||
Continuation: |
|||||
UNE |
Verizon's Current Rate |
Percentage Adjustment |
Adopted Interim Rate |
||
Hunting |
$0.000263 |
||||
UCD |
$0.000154 |
||||
Queuing |
$0.000645 |
||||
Attendant |
$0.004869 |
||||
Attendant Console |
$0.024557 |
||||
Centralized Attendant Services |
$0.022771 |
||||
Attendant Access Code Dialing |
$0.004043 |
||||
ARS Per MOU |
$0.004086 |
||||
ETS Per MOU |
$0.006720 |
||||
UNE-P |
|||||
Zone 1 (Former GTEC Areas) |
|||||
@ 1400 Local Voice & 300 Toll Minutes |
$29.02 |
(44.6%) |
$16.08 |
||
@ 2000 Local Voice Minutes |
$28.96 |
(45.1%) |
$15.90 |
||
Zone 2 (Former Contel Areas) |
|||||
@ 1400 Local Voice & 300 Toll Minutes |
$29.02 |
(3.9%) |
$27.89 |
||
@ 2000 Local Voice Minutes |
$28.96 |
(4.3%) |
$27.71 |
||
| * Verizon offers the features below at retail. Interim rates are adopted for these features in the event carriers request these features at wholesale. | |||||
Appendix B |
|||||
Synthesis Model Adjustments to Verizon New Jersey UNE Rates |
|||||
UNE |
New Jersey Current Rate |
Synthesis Model Adjustment 1 |
Adjusted New Jersey rate (w/ 10% mark-up) |
Adopted Interim Rate (w/ 22% mark-up) |
|
Loops |
|||||
2-Wire Loop (State-wide Average) |
$9.52 |
||||
former GTEC area |
(2.2%) |
$9.52 |
$10.56 |
||
former Contel CA area |
111.9% |
$20.17 |
$22.37 |
||
4-Wire Loop (State-wide Average) |
$19.59 |
||||
former GTEC area |
(2.2%) |
$19.59 |
$21.73 |
||
former Contel CA area |
111.9% |
$41.50 |
$46.03 |
||
Switching |
|||||
Ports |
|
|
|||
Basic Port |
$1.91 |
(3.2%) |
$1.91 |
$2.12 |
|
Centrex Port |
$1.91 |
(3.2%) |
$1.91 |
$2.12 |
|
DS-1 Port |
$55.65 |
n/a |
$55.65 |
$54.67 |
2 |
Switch Usage |
|
|
|||
Tandem Switching (per mou) |
$0.000674 |
38.9% |
$0.000936 |
$0.001038 |
|
End Office Switching (per mou) |
$0.001187 |
10.7% |
$ 0.001314 |
$0.001457 |
|
Switch Features |
|
|
|||
Three Way Calling |
$0.0000 |
|
no adjustment |
$0.0000 |
|
Call Forwarding |
$0.0000 |
|
no adjustment |
$0.0000 |
|
Customer Changeable Speed Calling 1-Digit |
$0.0000 |
|
no adjustment |
$0.0000 |
|
Customer Changeable Speed Calling 2-Digit |
$0.0000 |
|
no adjustment |
$0.0000 |
|
Call Waiting |
$0.0000 |
|
no adjustment |
$0.0000 |
|
Cancel Call Waiting |
$0.0000 |
|
no adjustment |
$0.0000 |
|
Automatic Callback |
$0.0000 |
|
no adjustment |
$0.0000 |
|
Automatic Busy Redial |
$0.0000 |
|
no adjustment |
$0.0000 |
|
Calling Number Delivery |
$0.0000 |
|
no adjustment |
$0.0000 |
|
Calling Number Delivery Blocking |
$0.0000 |
|
no adjustment |
$0.0000 |
|
Smart Ring |
$0.0000 |
|
no adjustment |
$0.0000 |
|
Customer Originated Trace |
$0.0000 |
|
no adjustment |
$0.0000 |
|
Selective Call Forwarding |
$0.0000 |
|
no adjustment |
$0.0000 |
|
Selective Call Acceptance |
$0.0000 |
|
no adjustment |
$0.0000 |
|
Remote Call Forward |
$0.0000 |
|
no adjustment |
$0.0000 |
|
Distinctive Alerting/Call Waiting Indicator (VIP) |
$0.0000 |
|
no adjustment |
$0.0000 |
|
Call Block |
$0.0000 |
|
no adjustment |
$0.0000 |
|
Last Number Redial |
$0.0000 |
|
no adjustment |
$0.0000 |
|
Continuation: |
|||||
UNE |
New Jersey Current Rate |
Synthesis Model Adjustment 1 |
Adjusted New Jersey rate (w/ 10% mark-up) |
Adopted Interim Rate (w/ 22% mark-up) |
|
Selective Calling Waiting |
$0.0000 |
|
no adjustment |
$0.0000 |
|
Billed Features |
|
|
|||
Multi-Line Hunting |
$0.000001 |
|
$0.000001 |
$ 0.000001 |
|
Intercom & Features |
$0.010227 |
|
$0.010227 |
$0.011343 |
|
Hunting |
$0.000237 |
|
$0.000237 |
$0.000263 |
|
UCD |
$0.000139 |
|
$0.000139 |
$0.000154 |
|
Queuing |
$0.000582 |
|
$0.000582 |
$0.000645 |
|
Attendant |
$0.004390 |
|
$0.004390 |
$0.004869 |
|
Attendant Console |
$0.022142 |
|
$0.022142 |
$0.024557 |
|
Centralized Attendant Services |
$0.020531 |
|
$0.020531 |
$ 0.022771 |
|
Attendant Access Code Dialing |
$0.003645 |
|
$0.003645 |
$0.004043 |
|
ARS Per MOU |
$0.003684 |
|
$0.003684 |
$0.004086 |
|
ETS Per MOU |
$0.006059 |
|
$0.006059 |
$0.006720 |
|
1 Where percentages are negative, New Jersey rates were retained at current levels. 2 Retained at current level, subject to true-up. | |||||
Appendix C | ||||||||||||||
Synthesis Model Comparison Results | ||||||||||||||
Synthesis Model Results |
Comparison Factor |
|
CA Interim Rates | |||||||||||
1 |
2 |
3 |
4 |
5 |
6 |
7 |
8 |
9 |
10 |
11 |
12 |
13 |
14 | |
Verizon CA |
GTEC CA |
Contel CA |
Verizon New Jersey |
GTEC CA & Verizon NJ (1) |
Contel CA & Verizon NJ (2) |
Verizon CA & Verizon NJ (3) |
Commission Approved New Jersey UNE Rates |
Former GTEC area w/ 10% mark-up (4) |
Former Contel area w/ 10% mark-up (5) |
Verizon CA w/ 10% mark-up (6) |
Former GTEC area w/ 22% mark-up (7) |
Former Contel area w/ 22% mark-up (8) |
Verizon CA w/ 22% mark-up (9) | |
Loop |
$11.73 |
$25.40 |
$11.99 |
-2.2.% |
111.9% |
|
$9.52 |
$9.52 |
$20.17 |
|
$10.56 |
$22.37 |
| |
EO Usage |
$0.001902 |
|
|
$0.001718 |
|
|
10.7% |
$0.001187 |
|
|
$0.001314 |
|
|
$0.001457 |
Port |
$0.96 |
|
|
$0.99 |
|
|
-3.2% |
$1.91 |
|
|
$1.91 |
|
|
$2.12 |
Tandem |
|
$ 0.0005536 |
|
$0.000399 |
|
|
38.9% |
$0.000674 |
|
|
$0.000936 |
|
|
$0.001038 |
Notes: |
||||||||||||||
(1) Column 5 = (GTEC CA rate - Verizon NJ rate)/(Verizon NJ rate), or (Column 2 - Column 4)/Column 4 |
||||||||||||||
(2) Column 6 = (Contel CA rate - Verizon NJ rate)/(Verizon NJ rate), or (Column 3 - Column 4)/Column 4 | ||||||||||||||
(3) Column 7 = (Verizon CA rate - Verizon NJ rate)/(Verizon NJ rate), or (Column 1 - Column 4)/Column 4 [except for Tandem switching, where GTEC CA and Verizon NJ were compared] | ||||||||||||||
(4) Column 9: No adjustment to NJ rate because comparison factor from Column 5 is negative. | ||||||||||||||
(5) Column 10 = (Column 8) + (Column 8 x Column 6) | ||||||||||||||
(6) Column 11 = (Column 8) + (Column 8 x Column 7) [except no change for port because comparison factor is negative] | ||||||||||||||
(7) Column 12 = (Column 9 / 1.1)(1.22) | ||||||||||||||
(8) Column 13 = (Column 10 / 1.1)(1.22) | ||||||||||||||
(9) Column 14 = (Column 11 / 1.1)(1.22) | ||||||||||||||
