and call types) is unprofitable, the compensation currently received for each service or
call type is presumed fair.
13. This revised approach suffers from several problems. First, it suffers from the very
infirmities that caused the Commission to reject it in the Third Payphone Order. Second,
the cost structure ofthe payphone industry, including that ofPSPs and ICSPs, means that
no payphone provider could ever demonstrate that existing compensation is inadequate
for any service or call type. Finally, this change in approach is founded on an assumption
that factual distinctions can be made between PSP and ICSP operations that compel or
justify a change in the definition of"fair compensation," and that this revised definition
will permit the stated objectives of Section 276 ofthe Act to be met. A careful review of
the facts indicates that this assumption should not be made.
14. In the Third Payphone Order, the Commission noted that "except for the general rule
that regulated services should not cross-subsidize each other, economic theory provides
no guidelines as to how common costs should be allocated." ~45. The economic
definition relied upon by the Commission when reaching that conclusion is the correct
one: "as long as each type ofcall recovers its incremental costs, but no more than its
stand-alone costs, there is no cross-subsidy." [d., footnote 81. According to economic
theory, there is no single "right answer" to the problem of allocating fixed costs. This
does not mean that all possible answers to the cost allocation problem are equally
effective at meeting a given objective. In the case ofboth PSPs and [CSPs, not all cost
allocation possibilities will permit a stated requirement ofSection 276 -fair compensation
6 1426348 '11; %KKS01IDOC for each and every call- and a stated objective ofSection 276 - the widespread
deployment ofpayphone services - to be met.
15. While no single solution, mandated by economic theory as the only "right" answer,
was available to the Commission when conducting the analysis described in the Third
Payphone Order, the Commission nevertheless found that some solutions were clearly
more effective than others in ensuring fair compensation and encouraging the widespread
deployment ofpayphone services. While a requirement that each service or call type
provide a "proportionate share" offixed cost recovery is not mandated by economic
theory, the Commission did conclude that it would be the best method ofavoiding a
scenario in which "one segment ofpayphone users" are unfairly required to
"disproportionately support the availability ofpayphones to the benefit ofanother
segment ofpayphone users." ~ 57. The new standard set forth in the Remand Order
would, in fact, encourage a scenario in which one segment ofpayphone users is unfairly
required to contribute a disproportionate share ofthe cost ofthe payphone location. The
existing rate caps in some locations create this "unfair" situation today, and the new
definition of"fair compensation" will cause these inequities among end users to continue.
Put directly, the families who receive interstate calls from inmates ofcounty jails are
making a disproportionate contribution to the costs ofthe ICSP, because the makers of
local calls are not contributing a "proportionate share" ofthe fixed costs. While this
situation may not meet the definition ofan economic subsidy, it is clearly inequitable and
need not be present.
7 1426348 v1: %KKS011.OOC 16. The Commission also concluded that establishing a rate that ensures that "each call at
a marginal payphone location recovers the marginal cost ofthat call plus a proportionate
share ofthe joint and common costs ofproviding the payphone" meets the definition of
"fair compensation" and is the best method ofpromoting the widespread deployment of
payphones. ~59. In contrast, the new standard of"direct costs and some contribution to
common costs" supports a rate that is only slightly higher than marginal cost. Such a rate
suffers from the same shortcoming as a rate set equal to marginal cost: "it would prevent
PSPs from recovering a reasonable share ofjoint and common costs from these calls."
~81.
17. The "proportionate share" requirement set forth in the Third Payphone Order also
serves to promote the widespread deployment ofpayphones, whether those phones are
located at airports, convenience stores, or county jails. When determining the amount of
this "proportionate share." the Commission considered the characteristics ofboth average
and marginal locations. The Commission concluded that ifrates were set based on
average, rather than marginal, characteristics, "many payphones would become
unprofitable and exit the industry." ~141. The new standard of"direct costs plus some
contribution to common costs" would allow a rate that is too low to permit cost recovery
at even an average location to nevertheless be characterized as "fair compensation." It
seems inescapable that ifa given rate would cause a significant number ofpayphones to
"become unprofitable and exit the industry," an even lower rate will lead to consequences
that are equal or greater in magnitude.
8 1426348 v1; %KKS011.DOC 18. The cost characteristics ofboth PSPs and ICSPs strongly suggest that the new test for
"fair compensation" is effectively impossible to fail. Because the majority ofthe costs
associated with a given payphone location are fixed with regard to both the service mix
and call volume, and because the direct costs for a given service or call type are very
small, almost any rate will permit an ICSP (or PSP) to recover direct costs and some
contribution to fixed costs. By adopting a test for "fair compensation" that will be passed
over a very wide range ofpossible rates (and failed only ifrates are extremely low), the
Commission is implicitly adopting a position that all possible rates are equally effective
in their ability to ensure fair compensation for each and every call and their ability to
ensure the widespread deployment ofpayphones. Such a position appears to be directly
at odds with the facts relied upon by the Commission when reaching its conclusions in
the Third Payphone Order.
19. The second prong ofthe new "fair compensation" standard likewise offers no real
opportunity for an ICSP to demonstrate that a given rate fails the test. An ICSP must
show a failure ofits overall profitability ~ based on total costs and the total revenues
received from all call types (including intrastate and interstate calls). ~23. While some
ICSPs may be able to make such a demonstration, their window for doing so is short:
they must have the opportunity to demonstrate to the Commission the particulars oftheir
pending bankruptcy before that bankruptcy actually takes place. 2 Clearly, "fair
compensation for each and every call" and "overall profitability" are different standards;
, Over the period oftime that this issue has been before the Commission, the number ofcompeting ICSPs has declined. Record evidence indicates that ofthe 29 independent ICSPs operating in 1995, only four are now operating.
9 1426348 v1; %KKS011.OOC for a given lCSP at a given point in time, each can be met while the other is not. In the
context ofrate caps for local calls, the hurdle created by "overall profitability" is much
lower (and thereby much easier to clear) than the hurdle created by the Act's requirement
that a per-call compensation plan be implemented "to ensure that all payphone service
providers are fairly compensated for each and every competed intrastate and interstate
call using their payphone."
Factual Distinctions Between PSP And ICSP Operations Used To Justify A Different Definition Of"Fair Compensation."
20. Throughout the Remand Order, the Commission points to several assumptions
regarding both the operation of ICSPs and the economic market forces that place
constraints on the actions oflCSPs. These assumptions form the foundation ofthe
Commission's decision to create a fundamentally different definition of"fair
compensation" for ICSPs than it had created for PSPs. Because these assumptions are
the stated basis for the elimination ofan "essential element" ofthe Commission's
previous definition of"fair compensation," they warrant careful review.
21. A number oftechnical distinctions are drawn between PSP and lCSP-provided
services, and it is necessary to determine whether these technical distinctions compel the
use ofa different definition of"fair compensation" or a different methodology for
calculating the level of"fair compensation." The Commission correctly notes that
"largely for security reasons," calls made at ICSP-provided phones are "quite different"
from calls made at public PSP-provided phones. ~ 9. For example, lCSP phones require
10 1426348 v1: %KKS011.DOC collect calls, utilize an automated voice processing system and employ various call
blocking mechanisms. There is no dispute that these distinctions exist. The salient
question is whether any ofthese difference cause the Commission's previous
determinations regarding the definition of"fair compensation" to be invalid, or whether
any ofthese differences make it impossible or impractical to calculate the level of"fair
compensation" using the methodology set forth in the Third Payphone Order. For the
examples listed above (and other examples set forth in ~ 9 ofthe Remand Order), the
answer is no. Each ofthese distinctions do have a direct bearing on the costs incurred by
the ICSP, but in no way invalidate (or even complicate to significant degree) the
methodology. The methodology described and utilized in the Third Payphone Order
fully contemplates the identification and consideration ofboth service-specific and non
service-specific costs. The use ofan automated voice processing system, for example,
directly impacts the application ofthe previous methodology (i.e., the forward-looking
costs of automated voice processing equipment must be accurately reflected and properly
categorized as being service-specific and non-service-specific) but in no way impacts the
validity or appropriateness ofthat methodology.
22. A number ofdistinctions are also drawn in the Remand Order regarding the
dynamics and constraints ofthe competitive marketplace faced by PSPs and ICSPs. For
example, it was concluded that ICSPs obtain, through the competitive bidding process, a
"locational monopoly" for their services: "Typically, the confinement facility awards a
contract to provide calling services by competitive bidding and grants the winning
provider a monopoly over all inmate calling services." ~ 10. There is no dispute over the
I 1 1426348 v1, %KKS01 '.DOC fact that ICSPs bid in order to have an exclusive opportunity to provide payphone calling
services at a given location, but this observation does not support the unstated (yet
critical) assumption that this marketplace dynamic is fundamentally different for PSPs
and ICSPs. It is unclear how the above-stated observation is distinguishable in any
meaningful way from the equally correct observation that "Typically, the airport or bus
station manager awards a contract to provide calling services by competitive bidding and
grants the winning PSP the opportunity to provide all payphone calling services from that
location." This marketplace dynamic for PSPs was known by the Commission at the
time ofthe Third Payphone Order, but did not prevent the adoption ofthe definition of
"fair compensation" used at that time.
23. A related assumption that underlies the reasoning and conclusions set forth in the
Remand Order is that all ICSPs pay commissions at all inmate locations at which they
have phones: "To have a realistic chance ofwinning a contract, the bidder must include
an amount to cover commissions paid to the inmate facility." ~ 10. While it is true that
ICSPs pay commissions at some inmate locations, they do not do so at all locations. It is
possible, therefore, to construct a data set of"marginal locations" for inmate phones
using the same definition used in the Third Payphone Order. Costs, and a rate that
represents "fair compensation," can be calculated based on these marginal, zero
commission locations. It is unclear how the above-stated observation is distinguishable
in any meaningful way from the equally correct observation that 'To have a realistic
chance ofwinning a contract, the bidder must include an amount to cover commissions
12 1426348 v1: %KKS011.OOC paid to the airport or bus station." Both observations are true most, but not all, ofthe
time.
24. The Remand Order takes the "commissions paid at all locations" assumption a step
further: "In fact, under most contracts the commission is the single largest component
affecting the rates for inmate calling service." '\[10. A review ofthe evidence indicates
that equipment costs and line rates paid to LECs typically represent a higher cost and
therefore have a greater impact on the rates for inmate calling services. While it is
certainly possible that commission payments to location providers represent the largest
component ofcost for an ICSP at a given location,3 it is equally possible and probable
that commission payments to location providers represent the largest component ofcost
for a PSP at a given public payphone location. As with the previous assumptions, there is
nothing that compels a different conclusion regarding ICSPs than was previously reached
regarding PSPs. A conclusion that the policy decisions reached in the Third Payphone
Order have "little or no application in the prison context because, considering that ICS
providers offer commissions, prison payphones are already profitable" ('\[19) ignores the
fact that not all ICSPs pay commissions at all locations and the equally-important fact
that PSPs offer commissions at most public payphone locations, yet are eligible for dial-
around compensation for calls made from those locations pursuant to the Commission's
definition of"fair compensation" used in the Third Payphone Order. The proper
distinction to be drawn between PSPs and ICSPs is not that one type ofpayphone
3 Record evidence indicates such a condition only holds for a facility ofthe size that is typical ofstate prisons. There is no evidence that any facility ofthe size typical ofmost county jails exists for which commissions represent the largest component ofthe leSp's costs.
13 1426348 v1: %KKS011,DOC provider pays commissions while the other does not: both PSPs and ICSPs pay
commissions at some locations but not at others. The true distinction is that while a
mechanism has been put into place to ensure that PSPs have the opportunity to receive
"fair compensation" for "each and every completed intrastate and interstate call using
their payphone," no such mechanism has been put into place to ensure that this provision
ofthe Act is implemented for ICSPs.
25. The assumptions regarding the payment ofcommissions by ICSPs support the
conclusion in the Remand Order that the "Reliefproposed by rcspc would be unlikely
to improve the profitability ofrcs providers because much ofthe additional revenue rcs
providers receive would likely be retained by the location monopolist, the confinement
facilities, in the form ofhigher commissions." ~ 27. The additional revenue generated by
a change in the rate caps for local calls could only be "retained by the location
monopolist" ifthe rcsp agreed to such a contractual arrangement. A rational rcsp
would agree to pay commissions to win a contract only to a point; it would only proffer a
bid that would permit it to recover its costs net ofcommissions.4 Location providers lack
the market power to compel an rCSP to agree to a contract provision that precludes cost
recovery. Like the assumptions described previously, the assumption regarding the
market power oflocation providers - even iftrue - would not justify a different
definition or calculation of "fair compensation." In the Third Payphone Order, the
Commission could have (pursuant to the logic ofthe Remand Order), but did not,
4 The Commission's concern that any rate relief granted would begin a process in which both rates and commissions would spiral upwards is fully addressed ifcommissions are not included in the calculation ofthe ICSP's costs to be recovered from the end user rate.
14 1426348 v1; %KKS011.DOC conclude that the "Dial-around compensation proposed by PSPs would be unlikely to
improve the profitability ofpayphone providers because much ofthe additional revenue
payphone providers receive would likely be retained by the location monopolist, the
airport or bus station, in the form ofhigher commissions." The same bidding process and
"location monopoly" market dynamic exists for both PSPs and ICSPs. This fact did not
prevent the Commission from ordering dial-around compensation at a level equal to the
per-call costs ofa PSP at a marginal location.
26. An additional conclusion reached in the Remand Order is that the end users ofICSPs
and PSPs have a different set ofcompetitive alternatives, and that the alternatives
available to PSP customers creates a constraining force on rates that does not apply to
ICSPs. It is certainly true that in most (but not all) locations, potential end users have an
alternative to the services offered by a PSP. It is also true that the existence ofthese
alternatives creates an upper limit to the rates that a PSP can successfully charge. The
fact that the end users ofICSP services do not have access to these same alternatives is
certainly relevant to the analysis, but does not - in and ofitself- compel a change in the
definition or calculation of "fair compensation." First, market forces are not the only
potential constraint on local calling rates. Other forces, especially political forces acting
on the inmate location provider, can also serve to constrain rates. For county jail
locations, the constituency ofthe local sheriff demands a reasonable rate for local calls.
Equally importantly, ICSPC is not arguing that no regulatory cap should exist for local
calls made from inmate locations. Ifthe Commission concludes that the existing non
market forces are insutllcient to protect end users from excessively high local calling
15 1426348 v1: %KKS011,DOC rates, a rate cap may be appropriate (it should be noted that no claim has been made in
the record that local calling rates are too high). A conclusion that "some rate level would
be too high" is not the same, however, as a conclusion that "no rate level is too low." A
perceived need to substitute regulatory constraint for market forces to prevent excessive
rates does not compel a definition of"fair compensation" that is different from the one
adopted in the Third Payphone Order. A decision to set a rate equal to the forward
looking per-call cost at a marginal (no commission) location, including a "proportionate
share" offixed costs, is in no way inconsistent with a recognition that the lack of
competitive alternatives for end users justifies some regulatory constraint ofrates.
27. Finally, the Remand Order includes a list ofreasons why the Commission had
"reservations" about the cost data previously submitted by ICSPC members (~~36-39).
Each ofthe areas of concern relate to the application ofthe methodology utilized in the
Third Payphone Order; none ofthe stated areas ofconcern related to the applicability of
the previous definition and calculation of"fair compensation" to ICSPs. For example,
commission payments can be excluded from the cost calculation, the assumed cost of
capital can be set at 11.25%, and additional documentation can be provided. Setting
aside the question ofwhether the stated concerns are valid, a list ofreasons that a given
methodology was incorrectly applied is not the same as a list ofreasons that the incorrect
methodology was applied. Ifgiven the opportunity in response to the NPRM, ICSPC
members will provide cost information that addresses each ofthe Commission's stated
concerns regarding the application ofthe Third Payphone Order methodology. For that
exercise to have any meaning, it is essential that this cost information be evaluated
16 1426348 vi: %KKS011.DOC
-_._,._-~-,_.,... _~., .•. ~._----_ •. __ .•_-_..._------pursuant a standard that, ifimplemented correctly, can provide the opportunity for "fair
compensation."
THIS REMAINDER OF THIS PAGE INTENTIONALLY LEFT BLANK
17 1426348 v1; %KKS01 !.DOC I declare under penalty ofperjury that the foregoing is true and correct to the best ofmy belief.
DonJ. Wood
18 Exhibit 1 to the Declaration ofDon J. Wood
Vita ofDon J. Wood 4625 Alexander Drive, Suite 125, Alpharetta, Georgia 30022 Voice 770475.9971, Facsimile 770.475.9972
CURRENT EMPLOYMENT
Don J. Wood is a principal in the firm of Wood & Wood. He provides economic and regulatory analysis services in telecommunications and related convergence industries, specializing in economic policy related to the development ofcompetitive markets and cost ofservice issues. In addition, Mr. Wood advises industry associations on regulatory and economic policy, and assists investors in their evaluation ofinvestment opportunities in the telecommunications industry. The scope ofhis work has included landline and wireless voice communications, data services, and emerging technologies.
As a consultant, Mr. Wood has assisted his clients in responding to the challenges and business opportunities ofthe industry both before and subsequent to the Telecommunications Act of 1996. Prior to his work as a consultant, Mr. Wood was employed in a management capacity at a major Local Exchange Company and an lnterexchange Carrier. In each capacity he has been directly involved in both the development and implementation ofregulatory policy and business strategy.
As a part ofhis regulatory practice, Mr. Wood has presented testimony before the administrative regulatory bodies ofthirty-one states, the District of Columbia, and Puerto Rico, and has prepared comments for filing with the Federal Communications Commission. The subject matter ofhis testimony has ranged from broad policy issues to detailed cost analysis.
Mr. Wood has also presented testimony in state, federal, and overseas courts regarding business plans and strategies, competition policy, and cost ofservice issues, and has presented studies of the damages incurred by plaintiffs in a number ofthese proceedings. Mr. Wood has also testified in alternative dispute resolution proceedings conducted pursuant to both AAA and CPR rules.
I-I Exhibit 1 to the Declaration ofDon J. Wood
PREVIOUS INDUSTRY EMPLOYMENT
Klick, Kent & Allen/FTI Consulting, Inc. Regional Director.
GDS Associates, Inc. Senior Project Manager.
MCI Telecommunications Corporation Manager ofRegulatory Analysis, Southeast Division. Manager, Corporate Economic Analysis and Regulatory Affairs.
BellSouth Services, Inc. StaffManager.
EDUCATION
Emory University, Atlanta, Ga. BBA in Finance, with Distinction.
College ofWilliam and Mary, Williamsburg, Va. MBA, with concentrations in Finance and Microeconomics.
1-2 Exhibit 1 to the Declaration ofDon J. Wood TESTIMONY - STATE REGULATORY COMMISSIONS:
Alabama Public Service Commission
Docket No. 19356, Phase Ill: Alabama Public Service Commission vs. All Telephone Companies Operating in Alabama, and Docket 21455: AT&T Communications ofthe South Central States, Inc., Applicant, Application for a Certificate of Public Convenience and Necessity to Provide Limited IntraLA TA Telecommunications Service in the State ofAlabama.
Docket No. 20895: In Re: Petition for Approval to Introduce Business Line Termination for MCl's 800 Service.
Docket No. 21071: In Re: Petition by South Central Bell for Introduction of Bidirectional Measured Service.
Docket No. 21067: In Re: Petition by South Central Bell to Offer Dial Back-Up Service and 2400 BPS Central Office Data Set for Use with PulseLink Public Packet Switching Network Service.
Docket No. 21378: In Re: Petition by South Central Bell for Approval ofTariff Revisions to Restrucrure ESSX and Digital ESSX Service.
Docket No. 21865: In Re: Petition by South Central Bell for Approval ofTariff Revisions to Introduce Network Services to be Offered as a Part ofOpen Nerwork Architecrure.
Docket No. 25703: In Re: In the Malter ofthe Interconnection Agreement Berween AT&T Communications ofthe South Central States, Inc. and BeliSouth Telecommunications, Inc., Pursuant to 47 U.S.c. § 252.
Docket No. 25704: In Re: Petition by AT&T Communications ofthe South Central States, Inc. for Arbitration ofCertain Terms and Conditions ofa Proposed Agreement with GTE South Incorporated and CONTEL ofthe South. Inc. Concerning Interconnection and Resale under the Telecommunications Act of 1996.
Docket No. 25835: In Re: Petition for Approval ofa Statement ofGenerally Available Terms and Conditions Pursuant to §252(1) ofthe Telecommunications Act of 1996 and Notification of Intention to File a §271 Petition for In-Region InterLATA Authority with the Federal Communications Commission Pursuant to the Telecommunications Act of 1996.
Docket No. 26029: In Re: Generic Proceeding - Consideration ofTELRIC Studies.
Docket No. 25980: Implementation ofthe Universal Support Requirements of Section 254 ofthe Telecommunications Act of 1996.
Docket No. 27091: Petition for Arbitration by ITCADehaCom Communications, Inc. with BelISouth Telecommunications, Inc. Pursuant to the Telecommunications Act of 1996.
Docket No. 27821: Generic Proceeding to Establish Prices for Interconnection Services and Unbundled Network Elements.
Docket Nos. 27989 and 15957: BeliSouth "Full Circle" Promotion and Generic Proceeding Considering the Promulgation ofTelephone Rules Governing Promotions.
1-3 Exhibit 1 to the Declaration ofDon J. Wood Arkansas Public Service Commission
Docket No. 92-337-R: In the Maller ofthe Application for a Rule Limiting Collocation for Special Access to Virtual or Physical Collocation at the Option ofthe Local Exchange Carrier.
Public Utilities Commission of the State of California
Rulemaking 00-02-005: Order Instituting Rulemaking on the Commission's Own Motion into Reciprocal Compensation for Telephone Traffic Transmilled to Internet Service Provider Modems.
Public Utilities Commission of the State of Colorado
Docket No. 96A-345T: In the Maller ofthe Interconnection Contract Negotiations Between AT&T Communications ofthe Mountain States, Inc., and US West Communications, lnc., Pursuant to 47 U.S.C. Section 252. Docket No. 96A-366T: In the Maller ofthe Petition ofMCIMetro Access Transmission Services, Inc.. for Arbitration Pursuant to 47 U.S.c. § 252(b) ofthe Telecommunications Act of 1996 to Establish an Interconnection Agreement with US West Communications, Inc. (consolidated).
Docket No. 96S-257T: In Re: The Investigation and Suspension ofTariff Sheets Filed by US West Communications, Inc., with Advice Leller No. 2608 Regarding Proposed Rate Changes.
Docket No. 98F-146T: Colorado Payphone Association, Complainant, v. US West Communications, Inc., Respondent.
State of Connecticut, Department of Utility Control
Docket 91-12-19: DPUC Review of Intrastate Telecommunications Services Open to Competition (Comments).
Docket No. 94-07-02: Development ofthe Assumptions, Tests, Analysis, and Review to Govern Telecommunications Service Reclassifications in Light ofthe Eight Criteria Set Forth in Section 6 of Public Act 94-83 (Comments).
Delaware Public Service Commission
Docket No. 93-31 T: In the Maller ofthe Application ofThe Diamond State Telephone Company for Establishment of Rules and Rates for the Provision oflntelliLinQ-PRI and InteIliLinQ-BRI.
Docket No. 41: In the Maller ofthe Development of Regulations for the Implementation ofthe Telecommunications Technology Investment Act.
Docket No. 96-324: In the Maller ofthe Application ofBell Atlantic-Delaware, Inc. for Approval of its Statement of Terms and Conditions Under Section 252(1) ofthe Telecommunications Act of 1996 (Phase II)
Florida Public Service Commission
Docket No. 881257-TL: In Re: Proposed Tariffby Southern Bell to Introduce New Features for Digital ESSX Service, and to Provide Structural Changes for both ESSX Service and Digital ESSX Service.
1-4 Exhibit 1 to the Declaration ofDon J. Wood
Docket No. 880812-TP: In Re: Investigation into Equal Access Exchange Areas (EAEAs), Toll Monopoly Areas (TMAs), I+ Restriction to the Local Exchange Companies (LECs), and Elimination ofthe Access Discount.
Docket No. 890183-TL: In Re: Generic Investigation into the Operations ofAlternate Access Vendors.
Docket No. 870347-TI: In Re: Petition of AT&T Communications ofthe Southern States for Commission Forbearance trom Earnings Regulation and Waiver of Rule 25-4.495(1) and 25-24.480 (I) (b), F.A.C., for a trial period.
Docket No. 900708-TL: In Re: Investigation of Methodology to Account for Access Charges in Local Exchange Company (LEC) Toll Pricing.
Docket No. 900633-TL: In Re: Development ofLocal Exchange Company Cost of Service Study Methodology.
Docket No. 910757-TP: In Re: Investigation into the Regulatory Safeguards Required to Prevent Cross Subsidization by Telephone Companies.
Docket No. 920260-TL: In Re: Petition of Southern Bell Telephone and Telegraph Company for Rate Stabilization, Implementation Orders, and Other Relief.
Docket No. 950985-TP: In Re: Resolution ofPetitions to establish 1995 rates, terms, and conditions for interconnection involving local exchange companies and alternative local exchange companies pursuant to Section 364.162, Florida Statutes.
Docket No. 960846-TP: In Re: Petition by MCI Telecommunications Corporation and MCI Metro Access Transmission Services, Inc. for Arbitration ofCertain Terms and Conditions ofa proposed agreement with BellSouth Telecommunications, Inc. Concerning Interconnection and Resale Under the Telecommunications Act of 1996 and Docket No. 960833-TP: In Re: Petition by AT&T Communications ofthe Southern States, Inco for Arbitration ofCertain Terms and Conditions ofa Proposed Agreement with BellSouth Telecommunications, Inc. Concerning Interconnection and Resale Under the Telecommunications Act of 1996 (consolidated).
Docket No. 960847-TP and 960980-TP: In Re: Petition by AT&T Communications ofthe Southern States, Inc., MCI Telecommunications Corporation, MCI Metro Access Transmission Service, Inc., for Arbitration ofCertain Terms and Conditions ofa Proposed Agreement with GTE Florida Incorporated Inc. Concerning Interconnection and Resale Under the Telecommunications Act of 1996 (consolidated).
Docket No. 961230-TP: In Re: Petition by MCI Telecommunications Corporation for Arbitration with United Telephone Company of Florida and Central Telephone Company ofFlorida Concerning Interconnection Rates, Terms, and Conditions, Pursuant to the Federal Telecommunications Act of 1996.
Docket No. 960786-TL: In Re: Consideration ofBellSouth Telecommunications, Inc.'s Entry Into InterLATA Services Pursuant to Section 271 ofthe Federal Telecommunications Act of 1996.
Docket Nos. 960833-TP, 960846-TP, 960757-TP, and 971140-TP: Investigation to develop permanent rates for certain unbundled network elements.
Docket No. 980696-TP: In Re: Determination ofthe cost ofbasic local telecommunications service, pursuant to Section 364.025 Florida Statutes.
1-5 Exhibit 1 to the Declaration ofDon J. Wood Docket No. 990750-TP: Petition by ITCADeltaCom Communications, Inc., d/b/a! ITCADeltaCom, for arbitration of certain unresolved issues in interconnection negotiations between ITC"DeltaCom and BeliSouth Telecommunications, Inc.
Docket No. 991605-TP: Petition of BellSouth Telecommunications, Inc. for Arbitration ofthe Interconnection Agreement Between Time Warner Telecom ofFlorida, L.P., pursuant to Section 252 (b) of the Telecommunications Act of 1996.
Georgia Public Service Commission
Docket No. 3882-U: In Re: Investigation into Incentive Telephone Regulation in Georgia.
Docket No. 3883-U: In Re: Investigation into the Level and Structure ofIntrastate Access Charges.
Docket No. 3921-U: In Re: Compliance and Implementation ofSenate Bill 524.
Docket No. 3905-U: In Re: Southern Bell Rule Nisi.
Docket No. 3995-U: In Re: IntraLATA Toll Competition.
Docket No. 40 18-U: In Re: Review ofOpen Network Architecture (aNA) (Comments).
Docket No. 5258-U: In Re: Petition of BellSouth Telecommunications for Consideration and Approval of its "Georgians FIRST" (Price Caps) Proposal.
Docket No. 5825-U: In Re: The Creation ofa Universal Access Fund as Required by the Telecommunications Competition and Development Act of 1995.
Docket No. 680 I-U: In Re: Interconnection Negotiations Between BellSouth Telecommunications, Inc. and AT&T Communications ofthe Southern States, Inc., Pursuant to Sections 251-252 and 271 ofthe Telecommunications Act of 1996.
Docket No. 6865-U: In Re: Petition by MCI for Arbitration ofCertain Tenns and Conditions ofProposed Agreement with BellSouth Telecommunications, Inc. Concerning Interconnection and Resale Under the Telecommunications Act of 1996.
Docket No. 7253-U: In Re: BellSouth Telecommunications, Inc.'s Statement ofGenerally Available Terms and Conditions Under Section 252 (I) ofthe Telecommunications Act of 1996.
Docket No. 7061-U: In Re: Review ofCost Studies and Methodologies for Interconnection and Unbundling of BellSouth Telecommunications Services.
Docket No. 10692-U: In Re: Generic Proceeding to Establish Long-Term Pricing Policies for Unbundled Network Elements.
Docket No. 10854-U: In Re: Petition for Arbitration oflTCADeltaCom Communications, Inc. with BellSouth Telecommunications, Inc. Pursuant to the Telecommunications Act of 1996.
Public Utilities Commission of Hawaii
Docket No. 7702: In the Matter of Instituting a Proceeding on Communications, Including an Investigation
1-6 Exhibit 1 to the Declaration ofDon J. Wood ofthe Communications Infrastructure ofthe State of Hawaii.
Iowa Utilities Board
Docket No. RPU-95-1 O.
Docket No. RPU-95- I I.
State Corporation Commission of the State of Kansas
Docket No. OO-GIMT- 1054-GIT: In the Matter of a General Investigation to Determine Whether Reciprocal Compensation Should Be Paid for Traffic to an Internet Service Provider.
Kentucky Public Service Commission
Administrative Case No. 10321: In the Matter ofthe TariffFiling of South Central Bell Telephone Company to Establish and Offer Pulselink Service.
Administrative Case No. 323: In the Matter ofAn Inquiry into IntraLATA Toll Competition, An Appropriate Compensation Scheme for Completion of IntraLATA Calls by Interexchange Carriers, and WATS Jurisdictionality.
Phase IA: Determination ofwhether intraLATA toll competition is in the public interest.
Phase 18: Determination ofa method of implementing intraLATA competition.
Rehearing on issue of Imputation.
Administrative Case No. 90-256, Phase II: In the Matter ofA Review ofthe Rates and Charges and Incentive Regulation Plan of South Central Bell Telephone Company.
Administrative Case No. 336: In the Matter ofan Investigation into the Elimination of Switched Access Service Discounts and Adoption ofTime of Day Switch Access Service Rates.
Administrative Case No. 91-250: In the Matter of South Central Bell Telephone Company's Proposed Area Calling Service Tariff.
Administrative Case No. 96-431: In Re: Petition by MCI for Arbitration ofCertain Terms and Conditions ofa Proposed Agreement with BellSouth Telecommunications, Inc. Concerning Interconnection and Resale Under the Telecommunications Act of 1996.
Administrative Case No. 96-478: /n Re: The Petition by AT&T Communications ofthe South Central States. Inc. for Arbitration ofCertain Terms and Conditions of a Proposed Agreement with GTE South Incorporated Concerning Interconnection and Resale Under the Te/ecommunications Act of 1996.
Administrative Case No. 96-482: In Re: The Interconnection Agreement Negotiations Between AT&T Communications ofthe South Central States, Inc. and BellSouth Telecommunications, Inc., Pursuant to 47 U.sc. § 252.
1-7 Exhibit 1 to the Declaration of Don J. Wood
Administrative Case No. 360: In the Matter of: An Inquiry into Universal Service and Funding Issues.
Administrative Case No. 96-608: In the Matter of: Investigation Concerning the Provision oflnterLATA Services by BellSouth Telecommunications, Inc. Pursuant to the Telecommunications Act of 1996.
Administrative Case No. 382: An Inquiry into the Development of Deaveraged Rates for Unbundled Network Elements.
Louisiana Public Service Commission
Docket No. 17970: In Re: Investigation ofthe Revenue Requirements, Rate Structures, Charges, Services, Rate of Return, and Construction Program ofAT&T Communications ofthe South Central States, Inc., in its Louisiana Operations.
Docket No. U-17949: In the Matter of an Investigation ofthe Revenue Requirements, Rate Structures, Charges, Services, Rate of Return, and Construction Program of South Central Bell Telephone Company, Its Louisiana Intrastate Operations, The Appropriate Level ofAccess Charges, and All Matters Relevant to the Rates and Service Rendered by the Company.
Subdocket A (SCB Earnings Phase)
Subdocket B (Generic Competition Phase)
Docket No. 18913-lI: In Re: South Central Bell's Request for Approval of Tariff Revisions to Restructure ESSX and Digital ESSX Service.
Docket No. lI-1885 I: In Re: Petition for Elimination of Disparity in Access Tariff Rates.
Docket No. U-22022: In Re: Review and Consideration ofBellSouth Telecommunications, lnc.'s TSLRlC and LRIC Cost Studies Submitted Pursuant to Sections 901(C) and 100I(E) ofthe Regulations for Competition in the Local Telecommunications Market as Adopted by General Order Dated March 15, 1996 in Order to Determine the Cost of Interconnection Services and Unbundled Network Components to Establish Reasonable, Non-Discriminatory, Cost Based Tariffed Rates and Docket No. U-22093: In Re: Review and Consideration of BellSouth Telecommunications, Inc.'s Tariff Filing ofApril I, 1996, Filed Pursuant to Section 901 and 1001 ofthe Regulations for Competition in the Local Telecommunications Market Which Tariff Introduces Interconnection and Unbundled Services and Establishes the Rates, Terms and Conditions for Such Service Offerings (consolidated).
Docket No. lI-22145: In the Matter oflnterconnection Agreement Negotiations Between AT&T Communications ofthe South Central States, Inc. and BellSouth Telecommunications, Inc., Pursuant to 47 lI.S.C. § 252.
Docket No. lI-22252: In Re: Consideration and Review ofBST's Preapplication Compliance with Section 271 ofthe Telecommunications Act of 1996, including but not limited to the fourteen requirements set forth in Section 271 (c) (2) (b) in order to verify compliance with section 271 and provide a recommendation to the FCC regarding BST's application to provide interLATA services originating in region.
Docket No. U-20883 Subdocket A: In Re: Submission ofthe Louisiana Public Service Commission's Forward Looking Cost Study to the FCC for Purposes ofCalculating Federal Universal Service Support.
1-8 Exhibit 1 to the Declaration of Don J. Wood Docket No. U-24206: In Re: Petition for Arbitration of ITCADeltaCom Communications, Inc. with BellSouth Telecommunications, Inc. Pursuant to the Telecommunications Act of 1996.
Docket No. U-22632: In Re: BeliSouth Telecommunications, Inc. Filing ofNew Cost Studies for Providing Access Line Service for Customer Provided Public Telephones and Smartline Service for Public Telephone Access.
Docket No. Docket No. U-24714-A: In Re: Final Deaveraging of BellSouth Telecommunications, Inc. UN E Rates Pursuant to FCC 96-45 Ninth Report and Order and Order on Eighteenth Order on Reconsideration Released November 2, 1999.
Public Service Commission of Maryland
Case 8584, Phase II: In the Matter ofthe Application of MFS Intelenet ofMaryland, Inc. for Authority to Provide and Resell Local Exchange and Intrastate Telecommunications Services in Areas Served by C&P Telephone Company of Maryland,
Case 8715: In the Matter ofthe Inquiry into Alternative Forms ofRegulating Telephone Companies,
Case 8731: In the Matter ofthe Petitions for Approval ofAgreements and Arbitration ofUnresolved Issues Arising Under Section 252 ofthe Telecommunications Act of 1996,
Massachusetts Department of Telecommunications and Energy
D.P.U.lD.T.E. 97088/97-18 (Phase II): Investigation by the Department ofTelecommunications & Energy on its own motion regarding (I) implementation of section 276 ofthe Telecommunications Act of 1996 relative to public interest payphones, (2) Entry and Exit Barriers for the Payphone Marketplace, (3) New England Telephone and Telegraph Compnay d/b/a NYNEX's Public Access Smart-Pay Service, and (4) the rate policy for operator service providers.
Mississippi Public Service Commission
Docket No. LJ-5086: In Re: MCI Telecommunications Corporation's Metered Use Service Option D (Prism I) and Option E (Prism II).
Docket No. LJ-5112: In Re: MCI Telecommunications Corporation's Metered Use Option H (800 Service),
Docket No. LJ-5318: In Re: Petition of MCI for Approval ofMCl's Provision of Service to a Specific Commercial Banking Customers for Intrastate Interexchange Telecommunications Service,
Docket 89-UN-5453: In Re: Notice and Application of South Central Bell Telephone Company for Adoption and Implementation ofa Rate Stabilization Plan for its Mississippi Operations,
Docket No. 90-LJA-0280: In Re: Order ofthe Mississippi Public Service Commission Initiating Hearings Concerning (I) IntraLATA Competition in the Telecommunications Industry and (2) Payment of Compensation by Interexchange Carriers and Resellers to Local Exchange Companies in Addition to Access Charges.
Docket No, 92-UA-0227: In Re: Order Implementing IntraLATA Competition,
1-9 Exhibit 1 to the Declaration ofDon J. Wood Docket No. 96-AD-0559: In Re: In the Matter ofthe Interconnection Agreement Negotiations Between AT&T Communications ofthe South Central States, Inc. and BeIlSouth Telecommunications, Inc., Pursuant to 47 U.S.c. § 252.
Docket No. 98-AD-035: Universal Service.
Docket No. 97 -AD-544: In Re: Generic Proceeding to Establish Permanent Prices for BellSouth Interconnection and Unbundled Network Elements.
Public Service Commission of the State of Montana
Docket No. D2000.8.124: In the Matter ofTouch America, Inc.'s Petition for Arbitration Pursuant to Section 252(b) ofthe Telecommunications Act of 1996 ofthe Terms and Conditions ofInterconnection with Qwest Corporation, flk/a US West Communications, Inc.
Docket No. D2000.6.89: In the Matter ofQwest Corporation's Application to Establish Rates for Interconnection, Unbundled Network Elements, Transport and Termination, and Resale Services.
Nebraska Public Service Commission
Docket No. C-1385: In the Matter ofa Petition for Arbitration ofan Interconnection Agreement Between AT&T Communications ofthe Midwest, Inc., and US West Communications, Inc.
New York Public Service Commission
Case No. 28425: Proceeding on Motion ofthe Commission as to the Impact ofthe Modification of Final Judgement and the Federal Communications Commission's Docket 78-72 on the Provision ofToll Service in New York State.
North Carolina Public Utilities Commission
Docket No. P-I 00, Sub 72: In the Matter ofthe Petition ofAT&T to Amend Commission Rules Governing Regulation of Interexchange Carriers (Comments).
Docket No. P-141, Sub 19: In the Matter ofthe Application ofMCI Telecommunications Corporation to Provide InterLATA Facilities-Based Telecommunications Services (Comments).
Docket No. P-55, Sub 1013: In the Matter of Application of BeIlSouth Telecommunications, Inc. for, and Election ot~ Price Regulation.
Docket Nos. P- 7, Sub 825 and P-I 0, Sub 479: In the Matter of Petition ofCarolina Telephone and Telegraph and Central Telephone Company for Approval ofa Price Regulation Plan Pursuant to G.S. 62 133.5.
Docket No. P- )9, Sub 277: In the Matter ofApplication of GTE South Incorporated for and Election of, Price Regulation.
Docket No. P-141, Sub 29: In the Matter of: Petition ofMCI Telecommunications Corporation for Arbitration of Interconnection with BeIlSouth Telecommunications, Inc., Petition ofAT&T Communications ofthe Southern States, Inc. for Arbitration of Interconnection with BeIlSouth
1-10 Exhibit 1 to the Declaration ofDon J. Wood Telecommunications, Inc. (consolidated).
Docket No. P-141, Sub 30: In the Matter of: Petition ofMCI Telecommunications Corporation for Arbitration of Interconnection with General Telephone Company ofNorth Carolina, Inc., Petition of AT&T Communications ofthe Southern States, Inc. for Arbitration ofinterconnection with General Telephone Company ofNorth Carolina, Inc. (consolidated).
Docket No. P-I 00, Sub 133b: Re: In the Matter of Establishment of Universal Support Mechanisms Pursuant to Section 254 ofthe Telecommunications Act of 1996.
Docket No. P-I DO, Sub 133d: Re: Proceeding to Determine Permanent Pricing for Unbundled Network Elements.
Docket No. P-I 00, Sub 84b: Re: In the Matter ofPetition ofNorth Carolina Payphone Association for Review of Local Exchange Company Tariffs for Basic Payphone Services (Comments).
Docket No. P-561, Sub 10: BellSouth Telecommunications, Inc., Complainant, v. US LEC ofNorth Carolina, LLC, and Metacomm, LLC, Respondents.
Docket No. P-472, Sub 15: In the Matter ofthe Interconnection Agreement Between BellSouth Telecommunications, Inc. and Time Warner Telecom ofNorth Carolina, L.P. Pursuant to Section 252(b) of the Telecommunications Act of 1996.
Public Utilities Commission of Ohio
Case No. 93-487-TP-ALT: In the Matter ofthe Application ofThe Ohio Bell Telephone Company for Approval of an Alternative Form of Regulation.
Oklahoma Corporation Commission
Cause No. PUD 01448: In the Matter ofthe Application for an Order Limiting Collocation for Special Access to Virtual or Physical Collocation at the Option ofthe Local Exchange Carrier.
Public Utility Commission of Oregon
Docket No. UT I 19: In the Malter ofan Investigation into Tariffs Filed by US West Communications, Inc., United Telephone ofthe Northwest, Pacific Telecom, Inc., and GTE Northwest, Inc. in Accordance with ORS 759.185(4).
Docket No. ARB 3: In the Malter ofthe Petition ofAT&T Communications ofthe Pacific Northwest, Inc., for Arbitration of Interconnection Rates, Terms, and Conditions Pursuant to 47 U.s.c. § 252(b) ofthe Telecommunications Act of 1996. Docket No. ARB 6: In the Malter ofthe Petition ofMCIMetro Access Transmission Services, Inc. for Arbitration of Interconnection Rates, Terms, and Conditions Pursuant to 47 U.S.c. § 252(b) ofthe Telecommunications Act of 1996 (consolidated).
Docket No. ARB 9: In the Matter ofthe Petition ofan Interconnection Agreement Between MCIMetro Access Transportation Services, Inc. and GTE Northwest Incorporated, Pursuant to 47 U.S.C. Section 252.
Docket No. UT-125: In the Malter ofthe Application ofUS West Communications, Inc. for an Increase in Revenues.
1-11 Exhibit 1 to the Declaration of Don J. Wood
Pennsvlvania Public Utilities Commission
Docket No. 1-009100 I0: In Re: Generic Investigation into the Current Provision ofinterLATA Toll Service.
Docket No. P-00930715: In Re: The Bell Telephone Company of Pennsylvania's Petition and Plan for Alternative Form of Regulation under Chapter 30.
Docket No. R-00943008: In Re: Pennsylvania Public Utility Commission v. Bell Atlantic-Pennsylvania, Inc. (Investigation of Proposed Promotional Offerings Tariff).
Docket No. M-00940587: In Re: Investigation pursuant to Section 3005 ofthe Public Utility Code, 66 Pa. C. S. §3005, and the Commission's Opinion and Order at Docket No. P-930715, to establish standards and safeguards for competitive services, with particular emphasis in the areas ofcost allocations, cost studies, unbundling, and imputation, and to consider generic issues for future rulemaking.
South Carolina Public Service Commission
Docket No. 90-626-C: In Re: Generic Proceeding to Consider Intrastate Incentive Regulation.
Docket No. 90-321-C: In Re: Petition of Southern Bell Telephone and Telegraph Company for Revisions to its Access Service TariffNos. E2 and E16.
Docket No. 88-472-C: In Re: Petition ofAT&T ofthe Southern States, Inc., Requesting the Commission to Initiate an Investigation Concerning the Level and Structure of Intrastate Carrier Common Line (CCL) Access Charges.
Docket No. 92-163-C: In Re: Position of Certain Participating South Carolina Local Exchange Companies for Approval of an Expanded Area Calling (EAC) Plan.
Docket No. 92-182-C: In Re: Application of MCI Telecommunications Corporation, AT&T Communications ofthe Southern States, Inc., and Sprint Communications Company, L.P., to Provide IntraLATA Telecommunications Services.
Docket No. 95-720-C: In Re: Application of BellSouth Telecommunications, Inc. d/b/a Southern Bell Telephone and Telegraph Company for Approval of an Alternative Regulation Plan.
Docket No. 96-358-C: In Re: Interconnection Agreement Negotiations Between AT&T Communications ofthe Southern States, Inc. and BellSouth Telecommunications, Inc., Pursuant to 47 U.S.C. § 252.
Docket No. 96-375-C: In Re: Interconnection Agreement Negotiations Between AT&T Communications ofthe Southern States, Inc. and GTE South Incorporated Pursuant to 47 U.S.c. § 252.
Docket No. 97-10 I-C: In Re: Entry ofBellSouth Telecommunications, Inc. into the InterLATA Toll Market.
Docket No. 97-374-C: In Re: Proceeding to Review BellSouth Telecommunications, Inc. Cost for Unbundled Network Elements.
Docket No. 97-239-C: Intrastate Universal Service Fund.
1-12 Exhibit 1 to the Declaration ofDon J. Wood
Docket No. 97-124-C: BellSouth Telecommunications, Inc. Revisions to its General Subscriber Services Tariff and Access Service Tariffto Comply with the FCC's Implementation ofthe Pay Telephone Reclassification and Compensation Provisions ofthe Telecommunications Act of 1996.
Docket No. 1999-268-C: Petition ofMyrtle Beach Telephone, LLC, for Arbitration Pursuant to Section 252(b) ofthe Telecommunications Act of 1996 to Establish an Interconnection Agreement with Horry Telephone Cooperative, Inc.
Docket No. I999-259-C: Petition for Arbitration of ITCADeltaCom Communications, Inc. with BellSouth Telecommunications, Inc. Pursuant to the Telecommunications Act of 1996.
Docket No. 2001-65-C: Generic Proceeding to Establish Prices for BellSouth's Interconnection Services, Unbundled Network Elements and Other Related Elements and Services.
Tennessee Public Service Commission
Docket No. 90-05953: In Re: Earnings Investigation of South Central Bell Telephone Company.
Docket Nos. 89-11065, 89-11735, 89-12677: AT&T Communications ofthe South Central States, MCI Telecommunications Corporation, US Sprint Communications Company -- Application for Limited IntraLATA Telecommunications Certificate ofPublic Convenience and Necessity.
Docket No. 91-0750 I: South Central Bell Telephone Company's Application to Reflect Changes in its Switched Access Service Tariff to Limit Use ofthe 700 Access Code.
Tennessee Regulatory Authority
Docket No. 96-01152: In Re: Petition by AT&T Communications ofthe South Central States, Inc. for Arbitration under the Telecommunications Act of 1996 and Docket No. 96-01271: In Re: Petition by MCI Telecommunications Corporation for Arbitration ofCertain Tenns and Conditions ofa Proposed Agreement with BellSouth Telecommunications, Inc. Concerning Interconnection and Resale Under the Telecommunications Act of 1996 (consolidated).
Docket No. 96-01262: In Re: Interconnection Agreement Negotiations Between AT&T ofthe South Central States, Inc. and BellSouth Telecommunications, Inc. Pursuant to 47 U.S.C. § 252.
Docket No. 97-01262: Proceeding to Establish Permanent Prices for Interconnection and Unbundled Network Elements.
Docket No. 97-00888: Universal Service Generic Contested Case.
Docket No. 99-00430: Petition for Arbitration of ITCADeltaCom Communications, Inc. with BellSouth Telecommunications, Inc. pursuant to the Telecommunications Act of 1996.
Docket No. 97-00409: In Re: All Telephone Companies TariffFilings Regarding Reclassification ofPay Telephone Service as Required by Federal Communications Commission Docket No. 96-128.
Public Utility Commission of Texas
1-13 Exhibit 1 to the Declaration ofDon J. Wood Docket No. 12879: Application of Southwestern Bell Telephone Company for Expanded Interconnection for Special Access Services and Switched Transport Services and Unbundling of Special Access DS 1 and DS3 Services Pursuant to P. U. C. Subst. R. 23.26.
Docket No. 18082: Complaint of Time Warner Communications against Southwestern Bell Telephone Company.
Docket No.2 I982: Proceeding to Examine Reciprocal Compensation Pursuant to Section 252 ofthe Federal Telecommunications Act of 1996.
Docket No. 23396: Joint Petition ofCoServ, LLC d/b/a CoServ Communications and Multitechnology Services, LP d/b/a CoServ Broadband Services for Arbitration ofInterconnection Rates, Terms, Conditions, and Related Arrangements with Southwestern Bell Telephone Company.
Docket No. 24015: Consolidated Complaints and Requests of Post-Interconnection Dispute Resolution Regarding Inter-Carrier Compensation for FX-Type Traffic Against Southwestern Bell Telephone Company.
State of Vermont Public Service Board
Docket No. 6533: Application ofVerizon New England Inc. d/b/a Verizon Vermont for a Favorable Recommendation to Offer InterLATA Services Under 47 U.S.C. 271.
Virginia State Corporation Commission
Case No. PUC920043: Application of Virginia Metrotel, Inc. for a Certificate ofPublic Convenience and Necessity to Provide InterLATA Interexchange Telecommunications Services.
Case No. PUC920029: Ex Parte: In the Matter of Evaluating the Experimental Plan for Alternative Regulation of Virginia Telephone Companies.
Case No. PUC930035: Application ofConteI ofVirginia, Inc. d/b/a GTE Virginia to implement community calling plans in various GTE Virginia exchanges within the Richmond and Lynchburg LATAs.
Case No. PUC930036: Ex Parte: In the Matter of Investigating Telephone Regulatory Methods Pursuant to Virginia Code § 56-235.5, & Etc.
Washington Utilities and Transportation Commission
Docket Nos. UT-941464, UT-94l465, UT-950146, and UT-950265 (Consolidated): Washington Utilities and Transportation Commission, Complainant, VS. US West Communications, Inc., Respondent; TCG Seattle and Digital Direct of Seattle, Inc., Complainant, vs. US West Communications, Inc., Respondent; TCG Seattle, Complainant, vs. GTE Northwest Inc., Respondent; Electric Lightwave, Inc., vs. GTE Northwest, Jnc., Respondent.
Docket No. UT-950200: In the Matter ofthe Request ofUS West Communications, Inc. for an Increase in its Rates and Charges.
Docket No. UT-000883: In the Malter ofthe Petition of US West Communications, Inc. for Competitive Classification.
1-14 Exhibit 1 to the Declaration of Don J. Wood
Public Service Commission of Wyoming
Docket No. 70000-TR-95-238: In the Matter ofthe General RatelPrice Case Application ofUS West Communications, Inc. (Phase I).
Docket No. PSC-96-32: In the Matter of Proposed Rule Regarding Total Service Long Run Incremental Cost (TSLRIC) Studies.
Docket No. 70000-TR-98-420: In the Matter ofthe Application of US West Communications, Inc. for authority to implement price ceilings in conjunction with its proposed Wyoming Price Regulation Plan for essential and noncompetitive telecommunications services (Phase III).
Docket No. 70000-TR-99-480: In the Matter ofthe Application ofUS West Communications, Inc. for authority to implement price ceilings in conjunction with its proposed Wyoming Price Regulation Plan for essential and noncompetitive telecommunications services (Phase IV).
Docket No. 70000-TR-00-556: In the Matter ofthe Filing by US West Communications, Inc. for Authority to File its TSLRIC 2000 Annual Input Filing and Docket No. 70000-TR-00-570: In the Matter ofthe Application of US West Communications, Inc. for Authority to File its 2000 Annual TSLRlC Study Filing.
Public Service Commission of the District of Columbia
Formal Case No. 814, Phase IV: In the Matter ofthe Investigation into the Impact ofthe AT&T Divestiture and Decisions ofthe Federal Communications Commission on Bell Atlantic - Washington, D. C. Inc.'s Jurisdictional Rates.
Puerto Rico Telecommunications Regulatory Board
Case No. 98-Q-000 I: In Re: Payphone Tariffs.
Docket No.: JRT-200 I-AR-0002: In the Matter of Interconnection Rates, Terms and Conditions between WoridNet Telecommunications, Inc. and Puerto Rico Telephone Company.
1-15 Exhibit 1 to the Declaration of Don J. Wood
COMMENTSIDECLARAnONS - FEDERAL COMMUNICATIONS COMMISSION
CC Docket No. 92-91: In the Matter of Open Network Architecture Tariffs of Bell Operating Companies.
CC Docket No. 93-162: Local Exchange Carriers' Rates, Terms, and Conditions for Expanded Interconnection for Special Access.
CC Docket No. 91-141: Common Carrier Bureau Inquiry into Local Exchange Company Term and Volume Discount Plans for Special Access.
CC Docket No. 94-97: Review of Virtual Expanded Interconnection Service Tariffs.
CC Docket No. 94-128: Open Network Architecture Tariffs of US West Communications, Inc.
CC Docket No. 94-97, Phase 11: Investigation ofCost Issues, Virtual Expanded Interconnection Service Tariffs.
CC Docket No. 96-98: In the Matter of Implementation ofthe Local Competition Provisions in the Telecommunications Act of 1996
CC Docket No. 97-231: Application by BeliSouth to Provide In-Region InterLATA Services
CC Docket No. 98-121: Application by BeliSouth to Provide In-Region InterLATA Services
CCB/CPD No. 99-27: In the Matter of Petition ofNorth Carolina Payphone Association for Expedited Review of, and/or Declaratory Ruling Concerning, Local Exchange Company Tariffs for Basic Payphone Services.
CC Docket No. 96-128: In the Matter ofthe Pay Telephone Reclassification and Compensation Provisions ofthe Telecommunications Act of 1996, CCB/CPD No. 99-31: Oklahoma Independent Telephone Companies Petition for Declaratory Ruling (consolidated).
CCB/CPD No. 00-1: In the Matter ofthe Wisconsin Public Service Commission Order Directing Filings.
CC Docket No. 99-68: In the Matter of Inter-Carrier Compensation for ISP-Bound Traffic
File No. EB-OI-MD-020: In the Matter of Sprint Communications Company, L.P., Complainant v. Time Warner Telecom, Inc. Defendant.
1-16 Exhibit 1 to the Declaration ofDon J. Wood
REPRESENTATIVE TESTIMONY - STATE, FEDERAL, AND OVERSEAS COURTS
Court of Commou Pleas, Philadelphia Couuty, Pennsylvania
Shared Communications Services of 1800-80 JFK Boulevard, Inc., Plaintiff, v. Bell Atlantic Properties, Inc., Defendant.
Texas State Office of Administrative Hearings
Office of Customer Protection (OCP) Investigation ofAxces, Inc. for Continuing Violations of PUC Substantive Rule §26.130, Selection of Telecommunications Utilities, Pursuant to Procedural Rules 22.246 Administrative Penalties.
United States District Court for the District of South Carolina, Columbia Division
Brian Wesley Jeffcoat, on behalf ofhimself and others similarly situated, Plaintiffs, v. Time Warner Entertainment - AdvancelNewhouse Partnership, Defendant.
Higb Court of tbe Hong Kong Special Administrative Region, Court of First Instance
Commercial List No. 229 of 1999: Cable and Wireless HKT International Limited, Plaintiffv. New World Telephone Limited, Defendant.
REPRESENTATIVE TESTIMONY - PRIVATE COMMERCIAL ARBITRATION TRIBUNALS
American Arbitration Association
Southwestern Bell Telephone Company, Claimant vs. Time Warner Telecom, Respondent.
CPR Institute for Dispute Resolution
Supra Telecommunications and Information Systems, Inc., Claimant vs. BeliSouth Telecommunications, Inc., Respondent.
1-17 ,. , .I
CERTIFICATE OF SERVICE
I hereby certifY that un March 25, 2002, I caused a copy of the foregoing Petition
tor Reconsideration of the Inmate Calling Service Providers Coalition to be sent via tirst-
class mail to the tollowing:
Lawrence Fenster Glenn B. Manishin MCI WorldCom Elise P.W. Kiely 1801 Pennsylvania Ave., N.W. Blumenfeld & Cohen - Technology Law Group Washington, DC 20006 1615 M Street, N.W., Suite 700 Washington, DC 20036
Casey B. Anderson Michael K. Kellogg Mintz, Levin, Cohn, Ferris, Glovsky Aaron M. Panner and Popeo, P.c. Kellogg, Huber, Hansen, Todd & Evans, 701 Pennsylvania Avenue, N.W. P.L.L.c. Suite 900 1615 L Street, N.W., Suite 400 Washington, DC 20004-2608 Washington, D.C. 20036
Charles Carbone Jack B. Harrison UCAN Christopher J. Wilson Utility Consumers' Action Network Frost & Jacobs, LLP 1717 Kettner Blvd., Suite 105 201 East Fifth Street San Diego, CA 92101 Cincitmati,OH 45202
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