The FCC should reconsider its decision to use “collected” revenue...
The FCC should reconsider its decision to use “collected” revenue when calculating “Price Cap Baseline Revenues” because it’s “operationally unworkable and fundamentally unfair,” representatives from Frontier, Windstream, FairPoint, CenturyLink, AT&T and Verizon told the Wireline Bureau Thursday, said an ex…
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parte filing (http://xrl.us/bmxzoh). They agreed with USTelecom’s December petition for reconsideration of the Universal Service Fund/intercarrier compensation order. The petition said allocating collected revenue between originating and terminating access “would be difficult, if not impossible” (http://xrl.us/bmxzpz). A more suitable measure to calculate the price cap baseline is billed revenue, the companies said, because it’s commonly used in the industry for similar issues “including price cap tariff filings.” Such revenue is a “reasonable proxy” for calculating appropriate price cap baseline revenue “given the levels of phantom traffic and the reductions in billed access minutes and revenues due to arbitrage schemes that places what is properly access traffic on local trunks, avoiding access billings on that traffic,” they said. The companies also discussed the appropriate calculation of the residential rate ceiling contemplated in the order. “This approach is consistent with the Commission’s pricing rules, which generally recognize the practical necessity of implementing rules on a study area basis,” they said.