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At&T's Post-Hearing Reply Brief

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At&T's Post-Hearing Reply Brief COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OF TELECOMMUNICATIONS AND ENERGY Investigation by the Department of Telecommunications and Energy on its own Motion into the Appropriate Pricing, based upon Total Element Long-Run Incremental D.T.E. 01-20 Costs, for Unbundled Network Elements and Combinations of Unbundled Network Elements, and the Part A (UNE Rates) Appropriate Avoided Cost Discount for Verizon New England, Inc. d/b/a Verizon Massachusetts’ Resale Services in the Commonwealth of Massachusetts AT&T’S POST-HEARING REPLY BRIEF REDACTED - PUBLIC VERSION Jeffrey F. Jones Kenneth W. Salinger Laurie Gill Jay E. Gruber Kevin Prendergast John Bennett Katie Davenport PALMER & DODGE LLP 111 Huntington Avenue Boston, MA 02199-7613 (617) 239-0100 Mary E. Burgess AT&T Communications of New England, Inc. 111 Washington Avenue Albany, NY 12210-0000 (518) 463-3148 March 29, 2002 Table of Contents Page Glossary of Acronyms and Short Forms........................................................................................xii Words and Phrases – Acronyms ........................................................................................xii Cases and Regulatory Decisions – Short Names ..............................................................xiv Verizon Briefs in Other Proceedings – Short Names .......................................................xvi I. INTRODUCTION. ....................................................................................................................1 A. An Overview of Key Rates. .....................................................................................3 1. Loops: The Statewide Average 2-Wire Loop Rate Should be Close to $7.00, as Both Loop Cost Models Show When Run With TELRIC-Compliant Inputs. .........................................................................3 a. Adjusting the 1996 Consolidated Arbitration Rates to Conform to the Record Evidence in This Case Confirms that a 2-Wire Loop Rate of Around $7.00 Is Proper........................3 b. There Is No Reason for Massachusetts Loop Rates to Exceed Those Recently Adopted in New Jersey, Which Verizon Ignores When Alluding to Old Loop Rates from Other States......................................................................................7 2. Switching: New FCC Pricing Guidance and New Information Pulled From Verizon Regarding Its True Switch Material Costs, All Ignored in Verizon’s Brief, Show that Switching Rates Should Be a Small Fraction of What Verizon Proposed........................................10 3. Non-Recurring Charges: Verizon’s Proposed NRCs Would be Anti-Competitive, Just Like the New Jersey Hot Cut Rates that Failed to Pass Muster Before the FCC.......................................................15 B. TELRIC: Verizon’s Effort to Rewrite or Replace TELRIC Is Improper and Should Be Rejected. ........................................................................................18 1. Verizon’s Theoretical Arguments are Attacks on TELRIC, Not an Interpretation of TELRIC, and Thus Are Improper and Irrelevant............19 2. The “Economic Principles” Touted by Verizon Conflict with TELRIC, and Cannot be Squared With Verizon’s Own Cost Studies........................................................................................................23 - i - Page a. Verizon’s Argument that Rates Should Reflect Continued Use of Existing Plant and Equipment Violates the Long- Run Assumption that is TELRIC’s Middle Name.........................23 b. Verizon’s Abstract Theory for Evaluating the Relative Efficiency of its Existing Network Versus a Redesigned Network with New Plant and Equipment Cannot be Squared With Verizon’s Own Cost Models...................................25 C. Verizon’s Upward Bias: Any Doubts Must be Resolved In Favor of Lower UNE Rates, and Verizon’s Efforts to Bias Rates Upward Should Be Rejected..................................................................................................................27 1. Verizon’s Claims Regarding “True Forward-Looking Costs” Are Spurious. .............................................................................................27 2. Low, Pro-Competitive UNE Rates Are Needed to Avoid a Price Squeeze and Resulting Barrier to Competitive Entry. ...............................28 II. GENERAL INPUTS: AT&T’S RECOMMENDATIONS AS TO COST OF CAPITAL AND DEPRECIATION LIVES ARE REASONABLE, BUT THOSE OF VERIZON ARE NOT. ..................29 A. WACC: Massachusetts UNE Rates Should Reflect a Cost of Capital In Line With That Adopted in Other Verizon-East States, Since Verizon Has Mustered No Evidence To Support a Higher WACC Here...................................29 1. Even the 9.54% WACC Discussed in AT&T’s Initial Brief is Too High. ...................................................................................................30 a. The Department Should Instead Set UNE Rates Based on a WACC At or Below 9.0%. ............................................................30 b. Verizon Ignores the Fact that All Other States Have Rejected its WACC Recommendations. ........................................31 2. Verizon’s Discussion of Risk Has Little Relevance, and Is Offered in Support of Only a Tiny Portion of Verizon’s WACC Overstatement. ...........................................................................................33 a. Dr. Vander Weide Admits that the Risk Faced by Verizon Has Very Little Impact on His Estimate of Verizon’s WACC............................................................................................33 b. The Department Should Reject Dr. Vander Weide’s Single- Stage DCF Model and His Incredible Assumption that Verizon Can Forever Grow Faster than the Economy As a Whole.............................................................................................34 - ii - Page 3. Though of Relatively Little Significance, Verizon’s Risk Assumptions are Unreasonable and Cause Verizon to Adopt an Improper Proxy Group and Capital Structure............................................37 a. Verizon Has Failed to Prove That the Wholesale Market for UNEs Is or Should Be Presumed to Be Highly Competitive.........37 b. Potential Risk from Future Competition is Already Reflected in the Market Prices for Telephone Holding Companies’ Stock, and There is No Basis for Using the S&P Industrials as a Proxy Group. ................................................42 c. Verizon Assumes a Capital Structure with Too Much Equity. ............................................................................................44 4. Verizon’s Further Attacks on Mr. Hirshleifer’s Recommendation are Unfounded............................................................................................45 a. An Old AT&T Internal Hurdle Rate for Investments in Local Telephony is Irrelevant. .......................................................45 b. Verizon’s Purported “Tests Of Reasonableness” Are Flawed............................................................................................46 B. Depreciation: The Department Should Adopt the FCC’s Forward-Looking Prescribed Lives, and Reject the Unreasonably Short Lives Used by Verizon...................................................................................................................48 1. The FCC Prescription Lives Recommended By Mr. Lee Are Forward-Looking and Are Not Outdated...................................................48 2. Verizon Unfairly Criticizes Mr. Lee for Relying on Facts that Underlie Verizon’s Own Cost Studies.......................................................52 3. Verizon’s Other Criticisms of Mr. Lee’s Position Are Invalid..................53 4. Verizon Tries to Ignore the Fact that the Overwhelming Majority of States Have Adopted Lives Identical or Quite Similar to the FCC’s Prescribed Lives. ............................................................................56 III. SWITCHING: VERIZON HAS NOT JUSTIFIED ITS GROWTH-ONLY SWITCH PRICING, ITS DUF CHARGES, OR ITS PLAN TO PRICE RECIPROCAL COMPENSATION TERMINATION DIFFERENTLY THAN UNBUNDLED SWITCHING.............................................57 A. Switch Material Prices: Verizon’s Growth-Only Discounts Violate TELRIC and Ignore the Evidence on What Verizon Actually Pays for Switches. ................................................................................................................57 - iii - Page 1. Verizon Violates TELRIC by Basing its Switch Cost Calculations on 100% Growth-Part Pricing....................................................................58 2. Verizon’s Arguments Against 100% New Switch Pricing Are Without Merit.............................................................................................60 a. The Precedent Cited by Verizon-MA Was All Based on Verizon-NY’s Now Discredited Misrepresentations About New Switch Pricing, and Thus No Longer Carries Any Weight............................................................................................60 b. The Department Must Rely on the Record Evidence Regarding What Verizon Pays for New Switches, and Cannot Credit Verizon’s Unfounded Conjecture that It Would Pay Higher Prices to Buy All New Switches for Massachusetts.................................................................................61 3. If the Department Assumes Some Growth Part Pricing, the Ratio of New Switch to Growth Pricing Should Be No Less Than 90/10. .........63 B. Other Switching Inputs or Assumptions Used by Verizon Also Improperly Inflate Switching
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