14. 15. 16. A cost of service study for all elements of cost A study containing a projection of cost for a a) traffic and revenues from the service to b) traffic and revenue from other services c) upon the overall traffic and revenue of the p. 1-2 (a)(i) Ip. 2-8 p. 8-17 | (a)(2)(i) p. 49-68 | p. 18-39 | |(a)(2)(ii) | Att. D Att. D EXHIBIT D-2: SAMPLE OF COST SUPPORT MATERIAL CHECKLIST Background: 61.38 of the Commission's Rules 61.38 was adopted by the Commission effective October 20, 1970 under Docket No. 18703. The need for an amendment to Part 61 in terms of requiring more comprehensive material to be filed with tariffs had been recognized for some time. The above proceeding was instituted by the Commission on its own motion by a Notice of Proposed Rule Making released on October 17, 1969. The main purposes of this notice were: 1) to give greater notice to the public of tariff changes and 2) increase the efficiency of the Commission and its staff through the submission of more detailed data by the carriers whenever tariff changes were submitted to the Commission for filing. Many of the carriers had been providing only the minimum amount of information necessary to comply with the existing requirements of Section 61.33 and the staff was unable to make an resolution of the tariff filings without requiring extension additional information and data to support the filing. It is the intent of the 61.38 rule reduce the number of tariff filings ordered for hearing. With better information available to the staff it is believed that many hearings might be avoided and the public interest better served. Even in cases when a hearing were ordered the availability of this information would shorten the time necessary for determining the lawfulness of a filing. EXHIBIT D-3: EXPLANATION OF 61.38 carrier, to check the format of a new tariff may take half an hour or 45 minutes depending on the length of the tariff, in order to make sure they have all the pieces, proper notations, symbology, etc. Western Union's format is standardized and might take only five minutes to check. However, total review time of Western Union tariffs may run into hours because of the monopoly situation at present. A revised tariff on the other hand might take only 5 minutes. Parts which must be clear and which are checked carefully are: what service the carrier is offering and what are the obligations and liability of both carrier and customer. Time required for a reviewer to analyze cost data also varied. A detailed analysis of AT&T can take half a day--or a year. Others can be done in half an hour. Mathematics is usually not checked. Another part of a reviewer's time is devoted to contact with the carriers themselves. Exact amount of time varies. With smaller carriers there may be a great deal of contact because the format of the tariff is checked before actual filing so that the filing does not have to be rejected and resubmitted because of a simple error. One tariff reviewer said that sometimes an entire day is spent assisting carriers and answering questions. A reviewer also engages in meetings with other FCC staff to discuss problem or disputed cases. As the above description indicates, no records are kept of how reviewers' time is spent. Unless some mechanism for measurement of this is built into the evaluation design, the evaluators will be unable to determine changes in this area except through staff interviews. There is also no formal system for tracking the tariffs and cost support sections through the review process. d. INFORMATION ABOUT THE CARRIERS FOUND IN TARIFF REVIEW Following are several tables and plots which show the types of information which can be gathered from an analysis of tariffs. Source: FCC: CBB Tariff Review Courtesy Logs: September 1976 through April 1978 (based on approximately 82% of total filings) Source: Tariff Courtesy Logs (Approximately 82% of Total Tariff Filings TABLE D-4: WESTERN UNION TARIFF ACTIVITY FROM SEPTEMBER 1976 THROUGH APRIL 1978 22 2314233 2 1 4 2 3 3 |