WPC: 2 BJ ZCourier3|jTimes New Roman Bold P6G;XPTimes New RomanLPT 1528 LPT328HPLAS5SI.PRSx  @\P& X@HP LaserJet 5Si LPT 1528 LPT328HPLAS5SI.PRSXj\  P6G;\P& XPÍ ÍX01Í Í#Xj\  P6G;ynXP#2B<KTXKCourierTimes New Roman"i~'^:DPddDDDdp4D48dddddddddd88pppX|pDL|pp||D8D\dDXdXdXDdd88d8ddddDL8ddddX`(`lD4l\DDD4DDDDDDdDd8XXXXXX|X|X|X|XD8D8D8D8ddddddddddXdbdddpdXXXXXlX~|X|X|X|XdddldldD8DdDDDdplld|8|P|D|D|8dvddddDDDpLpLpLpl|T|8|\ddddddl|X|X|Xd|DdpL|Dd~4ddC$CWxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNHxxH\dDXddddd8@d<@d<DDXXdDDxddxHxxHvppDXd<"dxtldpxxdTimes New RomanTimes New Roman BoldTimes New Roman ItalicTimes New Roman Bold ItalicTy.X80,ɒX\  P6G;PU2a=5,u&a\  P6G;&P7nC:,d<d<BBYYdBBddBYBdYzzzzBBBBqodYYYYYYYYYYY8888dddddddndddddddTimes New RomanTimes New Roman BoldTimes New Roman Italic P6G;,,,Y& sXPTimes New Roman (TT)Times New Roman (Bold) (TT)Times New Roman (Italic) (TT)Times New Roman (Bold Italic) (TT)2v v p kl X-#X\  P6G;/P#X01Í ÍX01Í Í#Xj\  P6G;XP#a8DocumentgDocument Style StyleXX` `  ` a4DocumentgDocument Style Style . a6DocumentgDocument Style Style GX  2k tvta5DocumentgDocument Style Style }X(# a2DocumentgDocument Style Style<o   ?  A.  a7DocumentgDocument Style StyleyXX` ` (#` BibliogrphyBibliography:X (# 25  r a1Right ParRight-Aligned Paragraph Numbers:`S@ I.  X(# a2Right ParRight-Aligned Paragraph Numbers C @` A. ` ` (#` a3DocumentgDocument Style Style B b  ?  1.  a3Right ParRight-Aligned Paragraph Numbers L! ` ` @P 1. ` `  (# 2  k3a4Right ParRight-Aligned Paragraph Numbers Uj` `  @ a. ` (# a5Right ParRight-Aligned Paragraph Numbers _o` `  @h(1)  hh#(#h a6Right ParRight-Aligned Paragraph Numbersh` `  hh#@$(a) hh#((# a7Right ParRight-Aligned Paragraph NumberspfJ` `  hh#(@*i) (h-(# 2e5a8Right ParRight-Aligned Paragraph NumbersyW"3!` `  hh#(-@p/a) -pp2(#p Tech InitInitialize Technical Style. k I. A. 1. a.(1)(a) i) a) 1 .1 .1 .1 .1 .1 .1 .1 Technicala1DocumentgDocument Style Style\s0  zN8F I. ׃  a5TechnicalTechnical Document Style)WD (1) . 2sa6TechnicalTechnical Document Style)D (a) . a2TechnicalTechnical Document Style<6  ?  A.   a3TechnicalTechnical Document Style9Wg  2  1.   a4TechnicalTechnical Document Style8bv{ 2  a.   2L K 3a1TechnicalTechnical Document StyleF!<  ?  I.   a7TechnicalTechnical Document Style(@D i) . a8TechnicalTechnical Document Style(D a) . Doc InitInitialize Document Stylez   0*0*0*  I. A. 1. a.(1)(a) i) a) I. 1. A. a.(1)(a) i) a)Documentg2%~ e$$g%PleadingHeader for Numbered Pleading PaperE!n    X X` hp x (#%'0*,.8135@8:a݅@  I.   X(# SubheadingSubheading30\ E A.  254p45qq46e47eG5Document[8]'Eg%Document StyleE O  O g% W4I O g4` ` ` Document[4]'Eg%Document Style W4A O g% W4I O g5  . Document[6]'Eg%Document Style W4A O g% W4I O g6  Document[5]'Eg%Document Style W4A O g% W4I O g7  28859pq6:6;s7Document[2]'Eg%Document Style W4A O g% W4I O g8*    Document[7]'Eg%Document Style W4A O g% W4I O g9  ` ` ` Right Par[1]Eg%Right-Aligned Paragraph NumbersO g% W4I O g:8 @  Right Par[2]Eg%Right-Aligned Paragraph NumbersO g% W4I O g;A@` ` `  ` ` ` 2:<@8=8>y9?&:Document[3]'Eg%Document Style W4A O g% W4I O g<0     Right Par[3]Eg%Right-Aligned Paragraph NumbersO g% W4I O g=J` ` ` @  ` ` ` Right Par[4]Eg%Right-Aligned Paragraph NumbersO g% W4I O g>S` ` `  @  Right Par[5]Eg%Right-Aligned Paragraph NumbersO g% W4I O g?\` ` `  @hhh hhh 2 >@;A;B<Cf=Right Par[6]Eg%Right-Aligned Paragraph NumbersO g% W4I O g@e` ` `  hhh@ hhh Right Par[7]Eg%Right-Aligned Paragraph NumbersO g% W4I O gAn` ` `  hhh@  Right Par[8]Eg%Right-Aligned Paragraph NumbersO g% W4I O gBw` ` `  hhh@ppp ppp Document[1]'Eg%Document Style W4A O g% W4I O gCF    ׃  2@DR>E>F\?G?Technical[5]Eg%Technical Document Style O g% W4I O gD&!"  . Technical[6]Eg%Technical Document Style O g% W4I O gE&#$  . Technical[2]Eg%Technical Document Style O g% W4I O gF*%&    Technical[3]Eg%Technical Document Style O g% W4I O gG''(   2 CH@ISAJBKBTechnical[4]Eg%Technical Document Style O g% W4I O gH&)*   Technical[1]Eg%Technical Document Style O g% W4I O gI4+$,     Technical[7]Eg%Technical Document Style O g% W4I O gJ&-.  . Technical[8]Eg%Technical Document Style O g% W4I O gK&/0  . 2QL ?CMLDNv EOoQCitatorFormat Secretary's Citator Output FileLW r5-#d6X@`7Ͽ@# XX  X B r5-S  BFormat DownloadFormat Downloaded DocumentMiޛ r5- XX    \ #d6X@`7Ͽ@#MACNormalN;     X` hp x (#%'0*,.8135@8:<    #:}D4P XP#T I. A. 1. a.(1)(a) i) a)T,0*ÍÍ,*Í ., US!!!! ! #:}D4P XP#     X` hp x (#%'0*,.8135@8:<    #:}D4P XP#,0*ÍÍ,*Í ., US!!!! ! #:}D4P XP#FootnoteOÍč2VP$RQiRR TS~Tfootnote tex#P'p #FxX  Pg9CXP#headerQAx 4 <D  #FxX  Pg9CXP# referenceR;#FxX  Pg9CXP#itemizeX1S&V 8F ` hp xr#FxX  Pg9CXP#2ZTiOVU^WVOYWpeZheader2TI ` hp x`    #FxX  Pg9CXP# heading 3UF` hp x #FxX  Pg9CXP# footer!V!!#d\  PCP#1t >.x(Dt—Document Style >f.RK+P—!t >f—+bW56` ` ` 2\Xq[Yex[Ze[[B\2t >/x(Dt—Document Style >f/RK+P—!t >f—+bX7 8 . 3t >0x(Dt—Document Style >f0RK+P—!t >f—+bY 9: 4t >1x(Dt—Document Style >f1RK+P—!t >f—+bZ ;< 5t >2x(Dt—Document Style >f2RK+P—!t >f—+b[*=>   29_\p]]w]^ ^_^6t >3x(Dt—Document Style >f3RK+P—!t >f—+b\?@` ` ` 7t >4x(Dt—Right-Aligned Paragraph NumbersK+P—!t >f—+b]8AB@   8t >5x(Dt—Right-Aligned Paragraph NumbersK+P—!t >f—+b^ACD@` `  ` ` ` 9t >6x(Dt—Document Style >f6RK+P—!t >f—+b_0E F    21b`k_a`b`cra10 >7x(Dt—Right-Aligned Paragraph NumbersK+P—!t >f—+b`JGH` ` @  ` `  11 >8x(Dt—Right-Aligned Paragraph NumbersK+P—!t >f—+baSIJ` `  @  12 >9x(Dt—Right-Aligned Paragraph NumbersK+P—!t >f—+bb\KL` `  @hh# hhh 13 >:x(Dt—Right-Aligned Paragraph NumbersK+P—!t >f—+bceMN` `  hh#@( hh# 2;edcbe+cfcgd14 >;x(Dt—Right-Aligned Paragraph NumbersK+P—!t >f—+bdnOP` `  hh#(@- ( 15 ><x(Dt—Right-Aligned Paragraph NumbersK+P—!t >f—+bewQR` `  hh#(-@pp2 -ppp 16 >=x(Dt—Document Style >f=RK+P—!t >f—+bfFST *  ׃  17 >>x(Dt—Technical Document Style>RK+P—!t >f—+bg&UV  . 2ghmeiejfk#g18 >?x(Dt—Technical Document Style?RK+P—!t >f—+bh&WX  . 19 >@x(Dt—Technical Document Style@RK+P—!t >f—+bi*YZ    20 >Ax(Dt—Technical Document StyleARK+P—!t >f—+bj'[\   21 >Bx(Dt—Technical Document StyleBRK+P—!t >f—+bk&]^   2Pjlgmhnioi22 >Cx(Dt—Technical Document StyleCRK+P—!t >f—+bl4_$`     23 >Dx(Dt—Technical Document StyleDRK+P—!t >f—+bm&ab  . 24 >Ex(Dt—Technical Document StyleERK+P—!t >f—+bn&cd  . Format DownlDt—Format Downloaded DocumentRK+P—!t >f—+boUgh XX    X\ #d6X@7@#2qpjqfWRK+P—!t >f—+bp1{1|#/x PX##/x PX#Normalx(Dt—Normal!wB( >fYRK+P—!t >f—+bq1}1~#x\  PCXP##/x PX#HEADING 7x(Dt—7!wB( >f[RK+P—!t >f—+br0p Zwp x (#DDDDDD#&n P&P# 4 hp x (##&n P&P# HEADING 6x(Dt—7!wB( >f]RK+P—!t >f—+bs0p Zwp x (#DDDDDD#&n P&P# 4 hp x (##&n P&P# 2uztFqusvdvwwwHEADING 5x(Dt—7!wB( >f^RK+P—!t >f—+bt0p Zwp x (#DDDDDD#&n P&P# 4 hp x (##&n P&P# HEADING 4x(Dt—7!wB( >f_RK+P—!t >f—+bu0 Zwp x (#rr#&n P&P# 4 hp x (##&n P&P# NORMAL INDENDt—7!wB( >f`RK+P—!t >f—+bv'4 <DL!T$#&n P&P##&n P&P#enumlev1x(Dt—7!wB( >faRK+P—!t >f—+bw$p  N hp x (#aa#&n P&P#4` hp x (##&n P&P#2|xzy={zv{{3|footnote refDt—footnote reference >fbRK+P—!t >f—+bx>#V\  P UP#Default ParaDt—Default Paragraph Font>fdRK+P—!t >f—+bypage number(Dt—page number( >feRK+P—!t >f—+bz26 >fx(Dt—footnote text >ffRK+P—!t >f—+b{* ??US2|}}}~]~+list>gx(Dt—list7!wB( >fgRK+P—!t >f—+b|*??endnote refeDt—endnote reference >fhRK+P—!t >f—+b}>>#XO\  P!UXP##c P"7P#line number(Dt—line number( >fjRK+P—!t >f—+b~;;#XO\  P#UXP##c P$7P#Highlightx(Dt—Middle Article HighlightlRK+P—!t >f—+b''#G x}'Y##\9> (P(YP#2OHeadlinex(Dt—Headline for newsletterfoRK+P—!t >f—+b''#> p})Y##\9> (P*YP#2nd line HeaDt—2nd line headline >fqRK+P—!t >f—+b''#b> p}+Y##\9> (P,YP#Graphics heaDt—Headlines for graphics>frRK+P—!t >f—+b** #o> P}-YP##\9> (P.YP# Graphics bodDt—chart data ( >ftRK+P—!t >f—+b** #Alo> P}/YXP##\9> (P0YP# 2ق2]2Article headDt—Headline for new articlevRK+P—!t >f—+b*'#r"zp1C# #\9> (P2YP# endnote textDt—endnote text( >fyRK+P—!t >f—+bE;#X}xP37XP##I2P4QP#toc 1|x(Dt—toc 17!wB( >f|RK+P—!t >f—+b(#`` hp x (#toc 2}x(Dt—toc 27!wB( >f}RK+P—!t >f—+b` (#`` hp x (#222%2W2toc 3~x(Dt—toc 37!wB( >f~RK+P—!t >f—+b` (#` hp x (#toc 4x(Dt—toc 47!wB( >fRK+P—!t >f—+b (#` hp x (#toc 5x(Dt—toc 57!wB( >fRK+P—!t >f—+bh(#` hp x (#toc 6x(Dt—toc 67!wB( >fRK+P—!t >f—+b(# ` hp x (#2 2w22ۖtoc 7x(Dt—toc 77!wB( >fRK+P—!t >f—+btoc 8x(Dt—toc 87!wB( >fRK+P—!t >f—+b(# ` hp x (#toc 9x(Dt—toc 97!wB( >fRK+P—!t >f—+b(#`` hp x (#index 1x(Dt—index 1wB( >fRK+P—!t >f—+b` (#` hp x (#2I2?2q{index 2x(Dt—index 2wB( >fRK+P—!t >f—+b` (#`` hp x (#toa heading(Dt—toa heading( >fRK+P—!t >f—+b(#` hp x (#captionx(Dt—captionwB( >fRK+P—!t >f—+bE;#X}xP57XP##I2P6QP#_Equation CaDt—_Equation Caption >fRK+P—!t >f—+b;;#X}xP77XP##I2P8QP#2h{q#գ27 >x(Dt—Default Paragraph Font>fRK+P—!t >f—+bOO#X}xP97XP##&sxP:7&P#HEADING 9x(Dt— 7!wB( >fRK+P—!t >f—+b'34 <DL!T$#c P;7P##c P<7P#HEADING 8x(Dt— 7!wB( >fRK+P—!t >f—+b'34 <DL!T$#c P=7P##c P>7P#a129f—+b—!tRight-Aligned Paragraph NumberswH(RK+P8@   2@6ۥa229f—+b—!tRight-Aligned Paragraph NumberswH(RK+PA@` `  ` ` ` a329f—+b—!tRight-Aligned Paragraph NumberswH(RK+PJ` ` @  ` `  a429f—+b—!tRight-Aligned Paragraph NumberswH(RK+PS` `  @  a529f—+b—!tRight-Aligned Paragraph NumberswH(RK+P\` `  @hh# hhh 2gr2ͩa629f—+b—!tRight-Aligned Paragraph NumberswH(RK+Pe` `  hh#@( hh# a729f—+b—!tRight-Aligned Paragraph NumberswH(RK+Pn` `  hh#(@- ( a829f—+b—!tRight-Aligned Paragraph NumberswH(RK+Pw` `  hh#(-@pp2 -ppp NORMAL INDENT ' 4 <DL!T$#&n P&P##&n P&P#2߭l%footnote referencefootnote reference4#V\  PUP#Default Paragraph FoDefault Paragraph Font footnote textfootnote text US????USendnote referenceendnote reference44#XO\  PUXP##B\  PUP#2ܰdˮ/D_Equation Caption_Equation Caption11#XX2PQXP##I2PQP#HIGHLIGHT 1Italics and Boldldedd+. DRAFT ONHeader A Text = DRAFT and Date X =8` (#FDRAFTă r  ` (#=D3 1, 43 12pt (Z)(PC-8))T2Dă  ӟDRAFT OFFTurn Draft Style off@@    2ҵ11?1p1LETTER LANDLetter Landscape - 11 x 8.5 3'3'Standard'3'3StandardLetter Portrait - 8.5 x 11 ;   LEGAL LANDLegal Landscape - 14 x 8.5f 3'3'Standard'A'AStandardZ K e6VE L"nu;   LETTER PORTLetter Portrait - 8.5 x 11L 3'3'Standard3'3'StandardZ K e6VE L"nU9   LEGAL PORTLegal Portrait - 8.5 x 14 3'3'StandardA'A'StandardLetter Portrait - 8.5 x 119   2nrdjWTITLETitle of a DocumentK\ * ăBLOCK QUOTESmall, single-spaced, indentedN X HIGHLIGHT 2Large and Bold LargeB*d. HIGHLIGHT 3Large, Italicized and Underscored V -q2E-W8LETTERHEADLetterhead - date/marginsu H XX  3'3'LetterheadZ K e VE L"n3'3'LetterheadZ K e VE L"nE9    * 3'3'LetterheadZ K e VE L"n3' II"n"Tv3'StandarddZ K e VE L"nU9 Ѓ   INVOICE FEETFee Amount for Math Invoice ,, $0$0  MEMORANDUMMemo Page FormatD.   ! M E M O R A N D U M ă r  y<N dddy   INVOICE EXPSEExpense Subtotals for Math Invoice:A ,p, $0$002}8&[["INVOICE TOTTotals Invoice for Math Macroz 4p, $0$00INVOICE HEADRHeading Portion of Math Invoice+C`*   4X 99L$0 **(  ӧ XX SMALLSmall TypestyleFINEFine Typestyle2C[[ [eLARGELarge TypestyleEXTRA LARGEExtra Large TypestyleVERY LARGEVery Large TypestyleENVELOPEStandard Business Envelope with Header+w ,,EnvelopeZ K e VE L"n,,EnvelopeLarge, Italicized and Under;    ,, 88+  `   2ulStyle 14Swiss 8 Pt Without Margins$$D Co> PfQ  )a [ PfQO Style 12Dutch Italics 11.5$$F )^ `> XifQ  )a [ PfQO Style 11Initial Codes for Advanced IIJ )a [ PfQK  dddn  #  [ X` hp x (#%'b, oT9 ! )^ `> XifQ ` Advanced Legal WordPerfect II Learning Guide   x )^ `> XifQ Advanced Legal WordPerfect II Learning Guide   j-n )^ `> XifQ    Copyright  Portola Systems, Inc. 1987, 1988`6 >Page  jBX )^ `> XifQ    Page ` Copyright  Portola Systems, Inc. 1987, 1988 Style 3oDutch Roman 11.5 with Margins/Tabs )a [ PfQO  ddn  # c0*b, oT9 !2v2|ZStyle 4 PSwiss 8 Point with MarginsDq Co> PfQ  dddd  #  Style 1.5Dutch Roman 11.5 Font4h )a [ PfQO  dddn Style 2Dutch Italic 11.5$ )^ `> XifQ Style 5Dutch Bold 18 Point$RH$L T~> pfQ_  )a [ PfQO 2HStyle 7Swiss 11.5$$V )ao> PfQ ]  )a [ PfQO Style 6Dutch Roman 14 Point$$N w [ PfQ   )a [ PfQO Style 10oInitial Codes for AdvancedƯ U )a [ PfQK  dddn  ##  [[ b, oT9 !b, oT9 !n )^ `> XifQ ` Advanced Legal WordPerfect Learning Guide   f )^ `> XifQ Advanced Legal WordPerfect Learning Guide   Q" )^ `> XifQ    Copyright  Portola Systems, Inc. 1987, 1988`6 >Page  QN~ )^ `> XifQ    Page ` Copyright  Portola Systems, Inc. 1987, 1988 Style 8PfInitial Codes for Beginninggǯi )a [ PfQK  dddn  # X` hp x (#%'b, oT9  [ &e )^ `> XifQ ` Beginning Legal WordPerfect Learning Guide   d )^ `> XifQ Beginning Legal WordPerfect Learning Guide   jH )^ `> XifQ    Copyright  Portola Systems, Inc. 1987, 1988`6 >Page  j )^ `> XifQ    Page ` Copyright  Portola Systems, Inc. 1987, 1988 2(-dClStyle 9Initial Codes for Intermediateȭ )a [ PfQK  dddn  # X` hp x (#%'b, oT9 Њ [ e )^ `> XifQ ` Intermediate Legal WordPerfect Learning Guide   3 )^ `> XifQ Intermediate Legal WordPerfect Learning Guide   jf )^ `> XifQ    Copyright  Portola Systems, Inc.`+ >Page  jX )^ `> XifQ    Page ` Copyright  Portola Systems, Inc. 1987, 1988 UpdateInitial Codes for Update Moduleɾ )a [ PfQK  dddn  #  [ X` hp x (#%'b, oT9 !n )^ `> XifQ ` Legal WordPerfect 5.0 Update Class Learning Guide   f )^ `> XifQ Legal WordPerfect 5.0 Update Class Learning Guide   Q" )^ `> XifQ    Copyright  Portola Systems, Inc. 1987, 1988`7 CPage  jN~ )^ `> XifQ    Page ` Copyright  Portola Systems, Inc. 1987, 1988 Bld/UnderlieBold and Underline Text/  Document 8Document 8 2xEll)lDocument 4Document 4  Document 6Document 6 Document 5Document 5 Document 2Document 2 2Gl3lDocument 7Document 7 Right Par 1Right Par 1` hp x (#X` hp x (#X` hp x (#` hp x (#Right Par 2Right Par 2` hp x (#X` hp x (#0X` hp x (#0` hp x (#Document 3Document 3 2yRight Par 3Right Par 3` hp x (#X` P hp x (#X` P hp x (#` hp x (#Right Par 4Right Par 4` hp x (#X` hp x (#0X` hp x (#0` hp x (#Right Par 5Right Par 5` hp x (#X` hp x (#X` hp x (#` hp x (#Right Par 6Right Par 6` hp x (#X` hp x (#0X` hp x (#0` hp x (#2#A(_$Right Par 7Right Par 7` hp x (#X` hp x (#X` hp x (#` hp x (#Right Par 8Right Par 8` hp x (#X` hp x (#0X` hp x (#0` hp x (#Document 1Document 1` hp x (#X` hp x (#X` hp x (#` hp x (#Technical 5Technical 5` hp x (#X` hp x (# X` hp x (#` hp x (#2$llm$Technical 6Technical 6` hp x (#X` hp x (# X` hp x (#` hp x (#Technical 2Technical 2 Technical 3Technical 3 Technical 4Technical 4` hp x (#X` hp x (# X` hp x (#` hp x (#2l/$$Technical 1Technical 1 Technical 7Technical 7` hp x (#X` hp x (# X` hp x (#` hp x (#Technical 8Technical 8` hp x (#X` hp x (# X` hp x (#` hp x (#WP Heading 2WP Heading 244#6X@C@##Xv6X@CX@#2   2 WP Heading 1WP Heading 144#6X@C@# #Xv6X@CX@#toatoa` hp x (#` hp x (#head1 #'d#2p}wC@ #para numnumbered indented paragraphs' Y- 1.(i) 1) 1.#Xw P7[hXP# 1. 1.Ҳ2f}05Paragraph[1]C^i1. a. i. (1) (a) (i) 1) a)C -2( -Ct )B$ab Paragraph[2]C^i1. a. i. (1) (a) (i) 1) a)C -2( -Ct )B/cd` ` ` Paragraph[3]C^i1. a. i. (1) (a) (i) 1) a)C -2( -Ct )B:ef` ` `  Paragraph[4]C^i1. a. i. (1) (a) (i) 1) a)C -2( -Ct )BEgh` ` `  2~AParagraph[5]C^i1. a. i. (1) (a) (i) 1) a)C -2( -Ct )BPij` ` ` hhh Paragraph[6]C^i1. a. i. (1) (a) (i) 1) a)C -2( -Ct )B[kl Paragraph[7]C^i1. a. i. (1) (a) (i) 1) a)C -2( -Ct )Bfmn Paragraph[8]C^i1. a. i. (1) (a) (i) 1) a)C -2( -Ct )Bqop 2(}-t25S&CMC^f1. a. i. (1) (a) (i) 1) a)CG -2( -Ct )$ 28S&CPC^f1. a. i. (1) (a) (i) 1) a)Cq -2( -Ct )E` ` `  29S&CQC^f1. a. i. (1) (a) (i) 1) a)C -2( -Ct )P` ` ` hhh 30S&CRC^f1. a. i. (1) (a) (i) 1) a)C -2( -Ct )[ 2ZZd=31S&CSC^f1. a. i. (1) (a) (i) 1) a)C -2( -Ct )f 32S&CTC^f1. a. i. (1) (a) (i) 1) a)C -2( -Ct )q 1, 2, 3,?@65NumbersO@/"=(1*1÷$t ?.E1.A, B,t ?@65Uppercase Letters1 ?*1÷$t ?.E .2~pqCee33`O5hT(G2PDocument Style&^aO5h.K+&,$@`O5Bȗ+&>` ` ` 34`O5iT(G2PDocument Style&^aO5i.K+&,$@`O5Bȗ+&>  . 35`O5jT(G2PDocument Style&^aO5j.K+&,$@`O5Bȗ+&>  36`O5kT(G2PDocument Style&^aO5k.K+&,$@`O5Bȗ+&>  25pCKE37`O5lT(G2PDocument Style&^aO5l.K+&,$@`O5Bȗ+&>*   38`O5mT(G2PDocument Style&^aO5m.K+&,$@`O5Bȗ+&>` ` ` 39`O5nT(G2PRight-Aligned Paragraph NumbersK+&,$@`O5Bȗ+&>8@   "i~'^5>I\\>>>\g0>03\\\\\\\\\\33gggQyyrg>Frgygrr>3>T\>Q\Q\Q>\\33\3\\\\>F3\\\\QX%Xc>0cT>>>0>>>>>>\>\3QQQQQwyQrQrQrQrQ>3>3>3>3\\\\\\\\\\Q\Z\\\g\QQQyQyQycyQtrQrQrQrQ\\\c\c\>3>\>>>\gcc\r3rIr>r>r3\l\\\\y>y>y>gFgFgFgcrMr3rT\\\\\\crQrQrQ\r>\gFr>\t0\\=!=WxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNBnnBT\>Q\\\\\3;\7;\7>>QQ\??n\\nBnnBmgg>Q\7"yyyy\njc\gnn\f7.7NS7JSJSJ7SS..S.SSSS7A.SSxSSJP!PZv7SJSS7]777JJ:S7A7xx*7SSSS!S7~.S^7~SC[227`K*724S}}}Jxxxxxxoffff7777xxxxxxx^xxxxxx]SJJJJJJoJJJJJ....SSSSSSS[SSSSSSS2'+KgKW"KG%K7("i~'^:DpddȨDDDdp4D48ddddddddddDDpppd|Ld|pȐD8DtdDdpXpXDdp8Dp8pdppXLDpdddXP,PhD4htDDD4DDDDDDdDp8dddddȐXXXXXJ8J8J8J8pddddppppddpddddzpdddXXhXXXXXdddhdptL8LpLDLpphhp8ZDP8pppddƐXXXpLpLpLphfDtppppppȐhXXXpDppLDd4ddC6CWxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNHxxHjdDddddddddzzzzzzzzzzBBBBozdddddddYYYYY8888dddddddndddddYd"i~'^#)0<8HH"&H>XHH8HB8>HH^HH>"".2",2,2,"222N2222"&22H22,006"6."""""""""2"2H,H,H,H,H,XAB,>,>,>,>,""""H2H2H2H2H2H2H2H2H2H2H,H2H1H2H2H282H,H,H,B,B,B6B,H?>,>,>,>,H2H2H2H6H2H6H2""2"""2F866H2>>(>">">H2;H2H2H2H2XHB"B"B"8&8&8&86>*>>.H2H2H2H2H2H2^HH6>,>,>,H2>"H28&>"H2?22!!WFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxN$<<$.2",2222`2 LL2 LL2L"",,2d""g\\>>>\g0>03\\\\\\\\\\>>ggg\yyrF\yrgyy>3>j\>\gQgQ>\g3>g3g\ggQF>g\\\QI(I_>0_j>>>0>>>>>>\>g3\\\\\QyQyQyQyQD3D3D3D3g\\\\gggg\\g\\\\pg\\\QQ_QyQyQyQyQ\\\_\gjF3FgF>Fgg__gy3ySy>yIy3ggg\\QQQgFgFgFg_y^y>yjgggggg_yQyQyQgy>ggFy>\0\\=2=WxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNBnnBa\>\\\\\\7>\7>\7>>\\\??n\\nBnnBsgg>\\7"yyyy\nlc\gnn\zB8BrdBddYdYBdo88d8odddNN8oYdYNE,ErBddddBoBBBddFdBNBz2Ndddd,dB5dyBdPn<  yO-ԍ AT&T Petition at 12.>  X- C.xReplies  X}-  Xf- x5.` ` Ameritech contends that its OSS costs meet the requirements of the Cost  XQ-Classification Order.? Q0  yO2-ԍ Ameritech Reply at 3.? Ameritech states that it has distinguished the OSS costs that were for  X<-the narrowly defined portability functions, as required by the Cost Classification Order, and explains in detail why each cost was required to provide number portability, and how it was  X-involved in the provision of number portability.?  yO!-ԍ Ameritech Reply at 3.? GTE states that it has sought to recover only those expenses associated with OSS that enable customers to retain their telephone numbers when they switch providers without degradation of service, in compliance with the"P 0*%%ZZ"  X-Commission's determination in the First Report and Order.9 yOy-ԍ GTE Reply at 3.9 GTE also states that any expenses for changes to OSS that could provide support for other products or services were  X-not included.9X yO-ԍ GTE Reply at 4.9  X-x6.` ` SBC contends that AT&T's claim that it has recovered $39 million in excess costs for operating expenses associated with end office tandem investments and OSS investments is erroneous and the result of AT&T's inaccurate reading of the Charts 1 and 2A  Xa-that SWBT provided with its tariff filing.9a yO -ԍ SBC Reply at 7.9  X3- D.xDiscussion  X -x7.` ` As a preliminary matter, we note that several carriers, as indicated below, submitted extensive confidential cost material with their filings. This confidential material was not discussed or explained either in the public Description and Justification accompanying the filings or in any confidential narrative accompanying the confidential cost materials. We require the carriers to supply a narrative explanation of how costs were developed in the confidential filings already filed, as well as in any other confidential filings to be made as part of their direct cases. These narratives will be subject to the same confidentiality arrangements  Xd-as the confidential filings.dx {O-ԍxSee In the Matter of LongTerm Telephone Number Portability Tariff Filings, CC Docket No. 95116,  {OW-Order, DA 99128 (para. 8) (Comp. Pric. Div., Jan. 8, 1999).  X6-x8.` ` In their confidential cost support, GSTC and GTOC appear to have miscalculated their costs by improperly inflating expenditures anticipated after 1999. They also appear to have used an improperly high rate of return by compounding the rate of return  X-monthly, producing an annual percentage rate above the 11.25 percent authorized in the Third  X-Report and Order. We direct GSTC and GTOC to correct these errors or to explain why their methods are correct.  X-x9.` ` In the Number Portability Suspension Order, we concluded that investigation of the incumbent LECs' OSS costs is warranted. The number portability tariff filings demonstrate that several incumbent LECs have included a substantial portion of OSS costs as number portability costs. For example, Ameritech seeks to recover costs incurred to equip its systems and network to perform ordering, provisioning, maintenance and repair, billing and"?0*%%ZZ"  X-911 calls for ported numbers. yOy-ԍ Ameritech Transmittal No. 1186, Description and Justification (D&J), Section B, "Cost and Rate Structure Requirements" at 6. GSTC and GTOC also claim a substantial amount of OSS costs in their tariff filings for modifications to existing ordering, maintenance and repair, and  X-911 systems.  yO-ԍ GSTC Transmittal No. 271, D&J, Section IV.C, "OSS Costs"; GTOC Transmittal No. 1190, D&J, IV.C, "OSS Costs." Based on our review of the record and the tariff filings, we here designate for investigation the issue of whether the Ameritech, GSTC, GTOC, Pacific, and SWBT number portability tariffs include costs the LECs incurred to adapt other OSS systems to number portability, in addition to the incremental portion of OSS upgrades that  Z&Z is Z&Z  directly related to number portability. We also designate whether the OSS costs Ameritech, GSTC, GTOC, Pacific, and SWBT claim in their number portability tariffs are reasonable.  X1-x 10.` ` We direct Ameritech, GSTC, GTOC, Pacific, and SWBT to file as part of their direct cases an itemized list of OSS costs, arranged by functional area (for example, provisioning, maintenance, repair, billing, etc.). For each OSS modification or augmentation, the LECs must provide: (1) the total cost; (2) the cost assigned to number portability; (3) the cost allocations among number portability services; (4) an explanation of how each OSS modification relates to performing queries; (5) an explanation of how each OSS modification relates to porting numbers between carriers; (6) an explanation of how each OSS modification relates to any other number portability function; (7) the basis for cost allocations between number portability and nonnumber portability services; and (8) the basis for cost allocations among number portability services. For functions other than provisioning of number portability, LECs should explain with specificity why they believe a particular OSS  X4-modification or upgrade qualifies as eligible under the Cost Classification Order.  X-x 11.` ` We further direct the LECs to explain for each OSS modification the manner in which it alters the nature of the task or function previously performed, and why this alteration is necessary "for the provision of portability." In addition, some OSS costs appear related to revising OSS systems to perform 10digit translations. LECs should identify these costs and demonstrate that they will not benefit CLASS services, area code overlays, or other services. In the alternative, LECs should show how costs were allocated among services that benefit from the changes. "~x0*%%ZZ"Ԍ X- III. CALCULATION OF SIGNALLING AND SWITCHING COSTS T  X-TP A.xBackground  X-x 12.` ` In the Cost Classification Order, the Bureau found that allowing embedded investments to be eligible number portability costs would amount to recovery of costs the  Xx-LECs already recover through standard recovery mechanisms.Zx {O-ԍ Cost Classification Order at 9 (para. 18).Z For this reason, we found it reasonable to bar recovery of costs incurred by LECs prior to longterm number portability  XJ-implementation.ZJZ {OU -ԍ Cost Classification Order at 9 (para. 18).Z  X - B.xPetitions  X -x 13.` ` AT&T alleges that Ameritech, Pacific, and SWBT have included embedded costs in calculating the incremental costs of number portability for their signalling and  X -switching capacity, contrary to the Cost Classification Order.?  yO]-ԍ AT&T Petition at 56.? Specifically, AT&T contends that Ameritech multiplied an estimate of its new incremental traffic by an average cost to  X-support the additional traffic on its network.=| yO-ԍ AT&T Petition at 5.= AT&T also contends that Pacific and SWBT calculated an average cost per query figure that is employed in their enduser and query  Xf-rates.=f  yO#-ԍ AT&T Petition at 6.=   X8- C.xReplies  X -x 14.` ` Ameritech responds that the cost model used to calculate number portability signalling costs only looked at the average incremental, forwardlooking costs of supporting  X-new number portability traffic and does not reflect embedded costs.? yO) -ԍ Ameritech Reply at 5.? Ameritech states that it has identified the cost to be allocated to number portability by determining the additional equipment, facilities or capacity required to support the new number portability generated  X-traffic.P,  yOt$-ԍ Ameritech Reply at 5, citing D&J at 7.P " 0*%%ZZo"Ԍ X-ԙx15.` ` SBC states that the charge used for SWBT's queries was developed through the use of the Switching Cost Information System (SCIS) and the Common Channel Signalling Cost Information System (CCSCIS) cost models, which represent forwardlooking incremental costs associated with demand placed on the SS7 network by the next number portability  X-query.; yO-ԍ SBC Reply at 23.; SBC argues that the charge only recovers the direct incremental costs associated with  X-implementing number portability and querying the number portability database.9X yO-ԍ SBC Reply at 2.9 SBC contradicts AT&T's assertion that Pacific calculated the costs of number portability and added  X_-the purported costs of its internal queries. SBC states that both SWBT and Pacific incur costs for their own queries in the same manner as costs are incurred for queries performed for other carriers, and that they will recover the costs of their own queries through the enduser  X -charge.9  yO-ԍ SBC Reply at 3.9  X - D.xDiscussion  X -  X -x16.` ` Our review of Ameritech's tariff filing shows that, while they used a Z&Z n Z&Z  "LNP Cost Tracking System" to track actual and planned expenditures for most components of their longterm number portability costs, they used the CCSCIS cost model to estimate SS7  Xy-Signalling costs.hyx yO-ԍ Ameritech Transmittal No. 1186, D&J at 13, filed Jan. 15,1999.h Ameritech's SS7 signalling costs appear to be a significant component of Ameritech's total longterm number portability costs, as well as significantly larger than other carriers' SS7related costs. Pacific and SWBT's tariff filings show that they used the SCIS and CCSCIS models, rather than actual and planned expenditures, to identify longterm  X-number portability costs related to both signalling and switching.  yO-ԍ Pacific Transmittal No. 2029, D&J, Appendix E, "Service Cost Development"; SWBT Transmittal No. 2745, D&J, Appendix E, "Service Cost Development."  X-x17.` ` We find that Ameritech, Pacific, and SWBT's use of cost models, rather than actual expenditures, raises substantial issues of lawfulness that warrant investigation. It is not clear that the use of these cost models does not result in the inclusion of some embedded costs for which recovery is already provided through other recovery mechanisms. Moreover, it is not clear that such models accurately estimate the actual additional costs incurred for the provision of local number portability. The use of these models may be inconsistent with the  Xe-Cost Classification Order requirement that only incremental costs may be recovered through"e` 0*%%ZZ" these federally authorized charges. We find, therefore, that the use of the cost models raises issues that warrant an investigation.  X-x18.` ` Based upon a review of the tariff filings, we here designate for investigation whether Ameritech's use of CCSCIS to estimate its signalling costs of number portability results in the inclusion of some embedded costs and, therefore, produces an inaccurate estimate of Ameritech's actual number portability costs. We also designate for investigation whether SWBT and Pacific's use of the SCIS and CCSCIS cost models to estimate switching and signalling costs results in the inclusion of some embedded costs and, therefore, produces an inaccurate estimate of their actual number portability costs.  X -x19.` ` We direct Ameritech, Pacific, and SWBT to file as part of their direct cases actual expenditures, including expenditures to date and planned actual expenditures within the recovery period, for the number portability costs that they estimated using CCSCIS or SCIS. The companies must explain the basis of each calculation of actual expenditures.  X-x20. ` ` Where Ameritech, Pacific, and SWBT intend to continue to rely on the information produced by the cost models in support of their tariffs, we further direct the LECs to explain how the use of cost models would produce more accurate estimates of the incremental costs generated by number portability than would be produced by an analysis of actual and planned expenditures. These LECs also must demonstrate that the use of the models does not produce double recovery of embedded costs already being recovered through other cost recovery mechanisms. This demonstration must also include, at a minimum, a comparison of the model's calculation of average costs of number portabilitytype queries and the model's incremental costs of these queries. The LECs also must demonstrate their total network switching and signalling costs with and without longterm number portability, or explain why their models cannot do so.  X|-x21.` ` With regard to both costs derived from cost models and costs produced from an analysis of actual expenditures, we also direct the LECs to identify costs for all land, buildings, administration, and maintenance expenses that are claimed. The LECs should identify costs that were derived either from model output or an allocation factor applied to actual costs on the basis that new investment has an impact on overall requirements. The cost documentation provided with the LECs' tariffs show Z&Z s Z&Z  that some endoffice and tandem switch costs appear related to reprogramming switches to perform 10digit translations. We require the LECs to identify these costs and demonstrate that other services will not benefit from such  X -reprogramming. In the alternative, LECs should show how costs were allocated, using either  X!-a cost model or actual expenditures, to the services that benefit from reprogramming. "! 0*%%ZZ "Ԍ X-T ř IV. CALCULATION OF OVERHEADS  X-TP  X- A.xBackground  X-x22.` ` In the Third Report and Order, the Commission held that "carriers may identify  X-as carrierspecific costs directly related to providing longterm number portability only those incremental overheads that they can demonstrate they incurred specifically in the provision of  Xa-longterm number portability."g!a {O-ԍ Third Report and Order, 13 FCC Rcd at 11740 (para. 74).g The Bureau interpreted the Commission's requirement in the  XJ-Cost Classification Order to require that only new overhead costs are eligible for recovery through the federal charge mechanisms and that no allocation of embedded overheads is  X -permitted.^" Z {O) -ԍ Cost Classification Order at 1415 (para. 33).^ The Bureau required, therefore, that the incumbent LECs must demonstrate that any incremental overheads claimed are actually new costs incremental to and resulting from  X -the provision of number portability.^#  {O-ԍ Cost Classification Order at 1415 (para. 33).^ With regard to the use of overhead allocation factors in determining number portability costs, the Bureau also stated that the use of unbundled network element overhead factors may serve as a useful check on the reasonableness of the  X -incumbent LECs' incremental overhead allocations.[$ ~ {O-ԍ Cost Classification Order at 16 (para. 37).[  X}- B.xPetitions  XO- x23.` ` AT&T argues that Pacific's use of a 21 percent overhead factor, the same factor used in state proceedings for pricing unbundled network elements (UNEs), is markedly higher than the factors used by the other incumbent LECs in their number portability tariff  X -filings.>%  yO-ԍ AT&T Petition at 12.> AT&T acknowledges that the Bureau held that the use of overhead allocation factors set by state commissions for UNEs would serve as a useful guide for reviewing the  X-reasonableness of incremental overhead allocations.>& yO- -ԍ AT&T Petition at 12.> AT&T argues that it would be unreasonable to permit one incumbent LEC to establish a significantly higher overhead rate  X-for its number portability tariff than the rates employed by other incumbent LECs absent a" 0 &0*%%ZZ" compelling showing that the incumbent LECs' incremental overhead costs for number  X-portability were in fact higher.>' yOb-ԍ AT&T Petition at 13.>  X- C.xReplies  X-x24.` ` SBC argues that the incremental overhead factor used by Pacific is appropriate and that AT&T, in prior filings, has endorsed the use of the overhead allocation factors used  X_-in the states to price UNEs.9(_X yOh -ԍ SBC Reply at 8.9 SBC further argues that since the Cost Classification Order fails to set forth a methodology to be used in determining incremental overheads, Pacific used  X3-the factor deemed reasonable by the Bureau's order.9)3 yO -ԍ SBC Reply at 8.9 SBC states that the factor Pacific used is the overhead allocation factor for UNE Z&Zs  pricing that is pending before the California Public  X -Utility Commission.:* x yO.-ԍ SBC Reply at 8.:  X -  X - D.xDiscussion  X -x25.` ` Our review of the tariff filings also shows that Pacific used a 21 percent allocation factor, the same factor used in state proceedings for UNEs, to allocate overhead  X{-costs to number portability services.u+{ yO4-ԍ Pacific Transmittal No. 2029, D&J, Section 2.6 "Rate Development" at 1314.u SWBT's Description and Justification states that it  Xd-accepts the loading factors used in the state proceedings for UNEs as a reasonable allocator.~,d yO-ԍ SWBT Tariff Filing, Transmittal No. 2745, D&J, Section 2.6 "Rate Development" at 14.~ SWBT also calculated incremental overhead attributable to number portability using the  X6-weighted average factor used to develop loading factors in the state UNE proceedings.~-6(  yO-ԍ SWBT Tariff Filing, Transmittal No. 2745, D&J, Section 2.6 "Rate Development" at 14.~  X-x26.` ` Although Pacific and SWBT have stated that the use of the same allocation factors used in the state proceedings to price unbundled network elements is reasonable, we conclude that the use of these UNE factors may include general overhead costs that do not  X-comport with the requirements of the Cost Classification Order. The Cost Classification  X-Order required the incumbent LECs to base their incremental allocation factors for number portability on information derived from a special study rather than solely on the allocation" -0*%%ZZ" factors used in state interconnection proceedings. The Bureau concluded that "the use of incremental allocation factors determined through a special study [of retail common costs] is a reasonable method of determining incremental overheads associated with number  X-portability."[. {O4-ԍ Cost Classification Order at 15 (para. 34).[ The Bureau referred to the overhead allocation factors used by state commissions to price UNEs as "a useful check on the reasonableness" of incremental overhead  X-allocations.[/Z {O-ԍ Cost Classification Order at 16 (para. 37).[  X_-x27.` ` We note that SWBT stated in its tariff filing that it "does not believe it to be practical to conduct a special study similar to that proposed by Ameritech and cited in the  X1-Cost Order."01 yO -ԍ SWBT Tariff Filing, Transmittal No. 2745, D&J, Section 2.6 "Rate Development" at 14. We find, however, that the Pacific overhead allocation factor of 21 percent is substantially higher than the overhead allocation factors used by the other incumbent LECs. We, therefore, find that Pacific's use of a 21 percent allocation factor and SWBT's use of a weighted average factor, in the absence of a special study or other information to confirm that these factors represent the incremental overheads attributable to number portability, raises issues of lawfulness that warrant an investigation. We designate for investigation whether Pacific's use of the overheads proposed to state commissions for unbundled network elements in calculating incremental overhead  Z&Z costs  Z&Z attributable to number portability is reasonable. We also designate whether SWBT's use of the weighted average factor in calculating incremental overhead attributable to number portability is reasonable.  X4-x28.` ` To determine whether the allocation factors used by Pacific and SWBT include only the incremental overheads attributable to number portability, we direct Pacific and  X-SWBT to provide their actual incremental overheads using an approach similar to the  X-approach employed by Ameritech as described in the Cost Classification Order.[1| {O-ԍ Cost Classification Order at 15 (para. 34).[  X-  X-=  V. ALLOCATION OF NUMBER PORTABILITY  X-0 COSTS AMONG NUMBER PORTABILITY SERVICES ă  X~- A.xBackground  XP-x29.` ` The Bureau provided specific, detailed guidance to the LECs in the Cost  X;-Classification Order as to the proper method of allocating eligible number portability costs between the enduser and query service Z&Zs  charges. First, the Bureau determined the proper"& 10*%%ZZ" allocation of costs incurred for specific number portability services. The Bureau stated that incumbent LECs should allocate any portion of eligible number portability costs that is  X-incurred specifically to provide N1 query services to the N1 query services.[2 {OK-ԍ Cost Classification Order at 17 (para. 40).[ Where the incumbent LECs intend to establish several types of N1 query services, the Bureau directed that the LECs allocate the eligible number portability costs incurred specifically to provide  X-each type of query service to that particular service.[3Z {O-ԍ Cost Classification Order at 17 (para. 40).[ Similarly, the Bureau directed the incumbent LECs to allocate costs incurred only to provide number portability functions to  X_-endusers to the enduser charge.[4_ {O -ԍ Cost Classification Order at 17 (para. 40).[  X1-x30.` ` The Bureau also determined the proper allocation of any remaining eligible  X -number portability costs.D5X ~ yOI-ԍ Remaining eligible costs are those costs that are incurred by an incumbent LEC in general to establish and provide number portability service. These costs are not incurred specifically to provide a particular query service but are incurred to provide number portability as a whole.D Generally, the Bureau directed the incumbent LECs to allocate  X -these remaining costs on the basis of the capacity requirements for each type of service.[6  {OR-ԍ Cost Classification Order at 17 (para. 41).[ For incumbent LECs that elect to provide several types of N1 query services, the Bureau directed that allocation of costs should be made to each service on the basis of the capacity  X -requirements for the service.[7 0  {O-ԍ Cost Classification Order at 17 (para. 41).[  X- B.xDiscussion  Xb-x31.` ` The incumbent LECs' number portability tariff filings show that each LEC has allocated eligible number portability costs in a different manner. Ameritech agrees that relative capacity is more costcausative than relative usage but contends that it has no evidence that traffic characteristics of number portability queries will vary in a way that will  X-place different demands on capacity per average unit of traffic.S8  yOy!-ԍ Ameritech Transmittal No. 1186, D&J at 8.S For this reason, Ameritech allocated eligible number portability costs between the enduser charge and the query service  X-charges using projected usage as a surrogate for capacity.S9R  yO$-ԍ Ameritech Transmittal No. 1186, D&J at 8.S " 90*%%ZZ"Ԍ X-ԙx32.` ` GSTC and GTOC allocated costs to the number portability services using the following method. First, the total busy query capacity of all number portability service control points was calculated. Next, the busy hour queries for each query service were divided by the busy hour capacity to determine the percent of busy hour capacity. Finally, the total number portability costs were multiplied by the percent of busy hour capacity to  X-determine the amount of number portability costs to be applied to each service.: yO-ԍ GSTC Transmittal No. 271, D&J, Section V. "Cost Study Explanation" at 34; GTOC Transmittal No. 1190, D&J, Section V. "Cost Study Explanation" at 34.  X_-x 33.` ` Pacific and SWBT allocated SS7 connection, SS7 links, and standard signal transfer point routing costs to the query services based on busy hour demand, as well as on  X1-the cost of equipment dedicated to queries.;1  yO -ԍ Pacific Transmittal No. 2029, D&J, Section 2.5 "Cost Development" at 1011; SWBT Transmittal No. 2745, D&J, Section 2.5 "Cost Development" at 1011. Pacific and SWBT allocated implementation  X -costs and the unrecovered costs of 1998 queries by their customers to the enduser charge.< x yOC-ԍ Pacific Transmittal No. 2029, D&J, Section 2.5 "Cost Development" at 12; SWBT Transmittal No. 2745, D&J, Section 2.5 "Cost Development" at 12.  X -x!34.` ` To determine whether each incumbent LEC has allocated number portability  X -costs consistent with the determinations made by the Bureau in the Cost Classification Order,  X -we designate for investigation the issue of whether Ameritech, GSTC, GTOC, Pacific and SWBT's methods of allocating number portability costs between the enduser and query service Z&Z s  charges are reasonable.  Xd-x"35.` ` We direct Ameritech, GSTC, GTOC, Pacific, and SWBT to provide more complete explanations of their bases for allocating number portability costs among services and why their methods are reasonable. In particular, Pacific and SWBT should address the question of whether it is reasonable to assign all "implementation costs" to the enduser surcharge. In addition, we direct the LECs to submit as part of their direct cases the  X-worksheet described in the Cost Classification Order, and specifically to include the allocation  X-of each cost among the number portability services as required by the order.[= {O]-ԍ Cost Classification Order at 20 (para. 49).[ The LECs must include sufficient data and calculations to show the assumptions used to allocate the costs of shared facilities, such as costs of the shared regional databases and links.  X-" b =0*%%ZZ3"Ԍ X- 3 _VI. QUERY SERVICES COSTS AND CHARGES TP  X- A.xBackground  X-x#36.` ` The Commission determined that incumbent LECs may query calls for N1 carriers, either by arrangement or by default, and may recover from the N1 carrier their carrierspecific costs directly related to providing_ prearranged and default query services in a  X_-federally tariffed queryservice charge.k>_ {O-ԍ Third Report and Order, 13 FCC Rcd at 1177879 (para. 147).k The Commission also required carriers to indicate in the cost support section of their tariffs that portion of their carrierspecific costs that  Z&Z is a Z&Z ttributable to the number portability services they provide endusers, and that portion  X -attributable to the number portability query services they provide on behalf of other carriers.k? Z {O% -ԍ Third Report and Order, 13 FCC Rcd at 1177879 (para. 147).k  X -As discussed in detail above, the Cost Classification Order required incumbent LECs to allocate any portion of eligible number portability costs that is incurred specifically to provide  X -N1 query services directly to those services.[@  {Ot-ԍ Cost Classification Order at 17 (para. 40).[ The Bureau also determined that remaining eligible number portability costs should be allocated to each service on the basis of the  X -capacity requirements for each service.[A ~ {O-ԍ Cost Classification Order at 17 (para. 41).[  X{-x$37.` ` In addition, the Bureau recognized in the Cost Classification Order that some incumbent LECs query all calls, even in NXXs where no telephone number has been ported,  XO-and charge endusers and carriers for whom they perform query services accordingly.[BO {O-ԍ Cost Classification Order at 19 (para. 48).[ The Bureau directed the incumbent LECs to state in their supporting documentation whether their demand assumptions included performing queries for all calls in NXXs where no number had  X -been ported and to explain why it is necessary to query all calls in this situation.[C  {O]-ԍ Cost Classification Order at 19 (para. 48).[  X- B.xPetitions  X-x%38.` ` AT&T recommends that the Bureau investigate Pacific and SWBT's inclusion of several "nonrecurring" charges for default query services. Specifically, AT&T states that both Pacific and SWBT have failed to adequately explain why they must impose certain"4 C0*%%ZZP"  X-charges each month when processing a customer's bill for default query services.=D yOy-ԍ AT&T Petition at 9.= AT&T  X-notes that the other incumbent LECs have not proposed similar "nonrecurring" charges.>EX yO-ԍ AT&T Petition at 10.>  X-x&39.` ` Time Warner petitioned the Commission to suspend Pacific and SWBT's number portability tariffs, alleging that the carriers have not clarified whether they intend to impose default query charges on all calls to NXXs in which no telephone number has been  Xv-ported.DFv yO -ԍ Time Warner Petition at 1.D Time Warner urges the Commission to investigate and declare unlawful any tariff  X_-that imposes default query charges on calls to NXXs with no ported numbers.FG_x yO -ԍ Time Warner Petition at 12.F AT&T also argues that Pacific and SWBT should not be permitted to charge for default queries performed  X1-before a number has been ported in an NXX.=H1 yO-ԍ AT&T Petition at 8.= According to AT&T, SWBT and Pacific's  X -tariff filings also fail to comply with the Cost Classification Order's requirement that incumbent LECs include an explanation as to why it is necessary to query all calls in this  X -situation.=I  yO7-ԍ AT&T Petition at 8.=  X - C.xReplies  X -  X-x'40.` ` SBC contends that the "nonrecurring" charges proposed by Pacific and SWBT will occur only one time, or one time each month if the carrier chooses never to prearrange  Xd-for query service.9Jd(  yO=-ԍ SBC Reply at 6.9 SBC states that if carriers prearrange for query service this charge will not be imposed. SBC argues that where an N1 carrier chooses not to prearrange its queries and, as a result, causes default queries each month, the incumbent LEC has little choice in  X-how to recover the additional costs that are caused by the default queries.9K  yO -ԍ SBC Reply at 6.9 SBC concedes that it omitted the explanation of the charge from the tariff filing, but states that it is willing to revise the tariff language to clarify that the charge will only be billed to N1 carriers who  X-have not prearranged with either SWBT or Pacific to perform queries on the carrier's behalf.LH  {O$-ԍ SBC Reply at 67 (citing Third Report and Order, 13 FCC Rcd 11711, 1172829 at paras. 15 and 46)."L0*%%ZZ"Ԍ X-ԙx(41.` ` SBC further contends that the query service charges included in Pacific and  X-SWBT's tariffs are consistent with the Cost Classification Order.9M yOb-ԍ SBC Reply at 4.9 SBC argues that the issue of whether an incumbent LEC may query all calls to NXXs where a number has not been  X-ported was resolved in the Third Report and Order.9NX yO-ԍ SBC Reply at 5.9 SBC states that the Third Report and  X-Order requires carriers to query all interswitch calls to an NXX once number portability is available for that NXX, to determine whether or not the terminating customer has ported a  X|-number.9O| yO -ԍ SBC Reply at 5.9 SBC argues that the incumbent LECs must begin to translate their networks and must query the number portability database well before the first order to port a number is received, if the work is to be completed within the fiveday period prescribed by the  X7-industry.9P7x yO`-ԍ SBC Reply at 5.9   X - D.xDiscussion  X -x)42.` ` We note that Pacific's tariff states that several nonrecurring charges need to be applied to recover the costs of establishing a bill for default and prearranged queries and for  X -establishing the customer connection to Signal Transfer Points (STPs) for database queries.rQ  yOh-ԍ Pacific Transmittal No. 2029, D&J, Section 2.1, "Cost Development" at 5.r  SWBT's tariff filing states that default billing charges were developed to recover costs associated with establishing a billing account to bill carriers for default queries handled by the  Xj-SWBT database.qRj yO-ԍ SWBT Transmittal No. 2845, D&J, Appendix E, "Service Cost Development."q  X<-x*43.` ` Based on a preliminary investigation of the tariff filings, we find that Pacific and SWBT have not provided adequate explanations or documentation to support a nonrecurring charge for their query services. Moreover, Pacific and SWBT's supporting documentation does not identify additional costs created by billing for default queries on a monthly basis. The monthly "nonrecurring" charge for default queries appears to be a recurring charge that Pacific and SWBT will impose for the purpose of encouraging companies to request prearranged queries, and not for the purpose of covering costs that result from providing default query services. We find that Pacific and SWBT's inclusion of a monthly "nonrecurring" charge for their query services raises substantial issues of lawfulness"( R0*%%ZZP" that warrant an investigation. We designate for investigation whether SWBT and Pacific's monthly "nonrecurring" query service charges are reasonable.  X-x+44.` ` We also note that Pacific proposes monthly "nonrecurring" charges for database access that appear to be imposed when actual usage cannot be measured. No other carrier proposes a similar charge, and Pacific does not provide a sufficient explanation for the existence or level of this charge. We also designate for investigation whether this monthly "nonrecurring" charge for database access is reasonable. We direct Pacific to file in its direct case a full explanation of the circumstances under which this charge might arise and a justification of both its necessity and level. This explanation should include the reason usage measurement is not feasible and an explanation of why the proposed charge is an appropriate and reasonable proxy for measured usage. We direct Pacific to file a full explanation and justification for the other proposed "nonrecurring" charge, identified as a cost component of prearranged queries, as well as proposed tariff language that will clarify precisely when and under what circumstances this charge will apply.  X-x,45.` ` Pacific and SWBT's tariff filings state that they have provisioned their networks so that on the date an NXX is shown in the Local Exchange Routing Guide (LERG) to be number portable, each company will begin charging N1 carriers a query charge for all  XK-unqueried calls to that NXX.SK yO-ԍ Pacific Transmittal No. 2029, D&J, Section 2.4, "Demand Development" at 9; SWBT Transmittal No. 2745, D&J, Section 2.4, "Demand Development" at 9. Both Pacific and SWBT will begin billing the enduser charge to all endusers that use a particular switch when the first NXX in a switch is shown in the  X-LERG as number portable.T  yO-ԍ Pacific Transmittal No. 2029, D&J, Section 2.4, "Demand Development" at 9; SWBT Transmittal No. 2745, D&J, Section 2.4, "Demand Development" at 9.  X-x-46.` ` We do not read the Third Report and Order as mandating, as SBC implies, that carriers must query all calls where number portability is available, even in NXXs where no  X-numbers have been ported. In the Cost Classification Order, we directed incumbent LECs to explain why it is necessary to query each call to an NXX where a number has not been  X-ported.[Ux {O-ԍ Cost Classification Order at 19 (para. 48).[ Our review of the tariff filings indicates that neither Pacific nor SWBT has provided an adequate explanation as to why it must query each call to a particular NXX before a number has been ported from or to that particular NXX. We therefore designate for investigation whether Pacific and SWBT's demand calculations, which include queries for  X;-calls to NXXs where a number has not been ported, are reasonable. We direct Pacific and SWBT to provide a detailed explanation as to why their systems are required to operate in"$ U0*%%ZZz" this fashion and state why no other alternatives exist. Pacific and SWBT also should explain the differences between their systems and those of other LECs, such as Ameritech, that have not found it necessary to query all calls. The explanations must include a statement as to whether their proposed demand calculations include: (1) queries made on intraswitch calls; (2) queries on interswitch calls in NXXs where a number has been ported; and (3) queries made on interswitch calls in NXXs where a number has not been ported.  X_- VII. GENERIC UPGRADES  X1- A.xBackground x  X -x.47.` ` In the Third Report and Order, the Commission recognized that some upgrades to the carriers' networks would enhance their services generally, and at least some portion of  X -such upgrade costs is not directly related to providing number portability.fV  {OP-ԍ Third Report and Order, 13 FCC Rcd at 11740, para. 73.f The Bureau acknowledged the impact of general upgrades on the entire LEC network and required that the incumbent LECs distinguish between eligible number portability costs that are recoverable through the federal number portability charges from general upgrade costs in their number  X{-portability tariff filings.[W{Z {O-ԍ Cost Classification Order at 56 (para. 9).[ The Bureau concluded that general network upgrade costs should  Xd-not be recovered through the federal number portability charges.ZXd {O-ԍ Cost Classification Order at 6 (para. 11).Z  XM-  X6-B.xDiscussion  X-x/48.` ` The Bureau's initial review of Pacific and SWBT's tariff filings reveals that the LECs have included costs for software generics, which appear to be general network  X-upgrades, without adequate justification.Y~ yO -ԍ Pacific Transmittal No. 2029, Confidential Cost Support, Chart 1; SWBT Transmittal No. 2745, Confidential Cost Support, Chart 1.  Pacific and SWBT's tariff filings raise questions of reasonableness and lawfulness that warrant an investigation. We designate whether Pacific and SWBT's use of generic software upgrade costs is reasonable and whether these costs have been calculated correctly. We direct Pacific and SWBT to explain the methodology used to calculate generic upgrade costs and the allocation of costs between the number portability and nonnumber portability services. "PY0*%%ZZ"Ԍ X-  VIII. JURISDICTIONAL SEPARATIONS ă  X- A.XxBackground (#  X-x049.` ` In the Third Report and Order, the Commission found that section 251(e) authorizes the Commission to provide the distribution and recovery mechanism for all the  Xx-costs of providing longterm number portability.fZx {O-ԍ Third Report and Order, 13 FCC Rcd at 11720, para. 29.f The Commission concluded that an exclusively federal recovery mechanism for longterm number portability will minimize the administrative and enforcement difficulties that might arise were jurisdiction over longterm  X3-number portability divided.f[3Z {O> -ԍ Third Report and Order, 13 FCC Rcd at 11720, para. 29.f The Commission noted that under the exclusively federal number portability cost recovery mechanism, incumbent LECs' number portability costs will  X -not be subject to jurisdictional separations.f\  {O-ԍ Third Report and Order, 13 FCC Rcd at 11720, para. 29.f  X - B.XxDiscussion (#  X -x150.` ` Although the Commission established an exclusively federal recovery  X-mechanism for longterm number portability in the Third Report and Order, some LECs may have included, or may be including, some or all of these costs in their jurisdictional separations procedures. To the extent longterm number portability costs have been assigned to the intrastate jurisdiction, those costs also may have been recovered through intrastate rates. Recovery in the federal jurisdiction may, thus, constitute double recovery. Similarly, to the extent longterm number portability costs are assigned to the intrastate jurisdiction prospectively, and LECs seek to recover those costs through intrastate rates, recovery in the federal jurisdiction would constitute double recovery.  X-x251.` ` We designate as an additional issue the question of what separations treatment and what intrastate ratemaking treatment may have been or may be accorded longterm number portability costs. We direct the LECs to file an explanation of how prior year costs related to longterm number portability implementation were treated with respect to jurisdictional separations. The LECs should demonstrate that the longterm number portability costs booked in past periods and included in the development of federal number portability charges have not been recovered already in the state jurisdiction. Alternatively, the LECs should explain how state ratepayers will be made whole if the Commission allows federal recovery of costs previously assigned to the intrastate jurisdiction and included in the state ratemaking process. We also direct the LECs to file an explanation of how costs related"~\0*%%ZZ<" to longterm number portability implementation will be treated prospectively with respect to jurisdictional separations. The LECs should demonstrate that longterm number portability costs included in the development of federal number portability charges will not be recovered prospectively in the state jurisdiction.  X-T vIX. PROCEDURAL MATTERS ĐTP  X_- A.xFiling Schedules  X1-x352.` ` This investigation will be conducted as a notice and comment proceeding. We have designated CC Docket Nvo. 9935. The following companies are the parties designated to this investigation: Ameritech, GSTC, GTOC, Pacific, and SWBT.  X -x453.` ` These parties shall file their direct cases no later than March 29, 1999. The direct cases must present the parties' positions with respect to the issues described in this Order. Pleadings responding to the direct cases may be filed no later than April 13, 1999, and must be captioned "Oppositions to Direct Case" or "Comments on Direct Case." The companies may each file a "Rebuttal" to oppositions or comments no later than April 23, 1999.  X4-x554.` ` An original and six copies of all pleadings shall be filed with the Secretary of the Commission. In addition, parties shall file two copies of any such pleadings with the Competitive Pricing Division, Common Carrier Bureau, 445 12th Street, S.W., 5th Floor, Washington, D.C. 20554. Parties shall also deliver one copy of such pleadings to the Commission's commercial copying firm, International Transcription Service, Inc., 1231 20th Street, NW, Washington, DC 20036. Members of the general public who wish to express their views in an informal manner regarding the issues in this investigation may do so by submitting one copy of their comments to the Office of the Secretary, Federal Communications Commission, 445 12th Street, S.W., Room 222, Washington, D.C. 20554. Such comments should specify the docket number of this investigation. Parties are also encouraged to submit their pleadings electronically through the Electronic Tariff Filing System.  X -x655.` ` All relevant and timely pleadings will be considered by the Commission. In reaching a decision, the Commission may take into account information and ideas not contained in pleadings, provided that such information or a writing containing the nature and source of such information is placed in the public file, and provided that the fact of reliance on such information is noted in the order. ""\0*%%ZZf!"Ԍ X< B.xEx Parte Requirements  X-x756.` ` This tariff investigation is a "permit-but-disclose proceeding" and subject to the "permit-but-disclose" requirements under section 1.1206(b) of the rules, 47 C.F.R.   X-1.1206(b), as revised. Persons making oral ex parte presentations are reminded that memoranda summarizing the presentation must contain a summary of the substance of the presentation and not merely a listing of the subjects discussed. More than a one or two  Xb-sentence description of the views and arguments presented is generally required.]]b {O-ԍ See 47 C.F.R. 1.1206 (b)(2), as revised. ] Other rules pertaining to oral and written presentations are set forth in section 1.1206 (b), as well.  X - 6 X. ORDERING CLAUSES T  X -TPx857.` ` ACCORDINGLY, IT IS ORDERED that, pursuant to sections 4(i), 4(j), 201(b), 203(c), 204(a), 205, and 403 of the Communications Act, 47 U.S.C.  154(i), 154(j), 201(b), 203(c), 204(a), 205, and 403, and sections 0.91 and 0.291 of the Commission's rules,  X -47 C.F.R.  0.91, 0.291, the issues set forth in this Order ARE DESIGNATED FOR  X-INVESTIGATION .  Xe-x958.` ` IT IS FURTHER ORDERED that Ameritech Operating Companies, GTE Telephone Operating Companies, GTE Systems Telephone Companies, Pacific Bell, and  X7-Southwestern Bell Telephone Company SHALL BE parties to this proceeding.  X -x:59.` ` IT IS FURTHER ORDERED that each local exchange carrier that is a party  X-to this proceeding SHALL INCLUDE , in its direct case, a response to each request for information that it is required to answer in this Order.  X-x x` `  hh@FEDERAL COMMUNICATIONS COMMISSION  X:-x` `  hh@Yog R. Varma  xx 0(#(#Xx` `  hh@Deputy Chief, Common Carrier Bureau