Evaluation Of The United States Department Of Justice

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Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554


In the Matter of

Application by Verizon New England                 
Inc., Bell Atlantic Communications,
Inc. (d/b/a Verizon Long Distance),
NYNEX Long Distance Company
(d/b/a Verizon Enterprise Solutions),
Verizon Global Networks Inc., and
Verizon Select Services Inc., for
Authorization to Provide In-Region,
InterLATA Services in Maine


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WC Docket No. 02-61


_______________________________________________________
EVALUATION OF THE
UNITED STATES DEPARTMENT OF JUSTICE
_______________________________________________________
Charles A. James
Assistant Attorney General
Antitrust Division

Margaret A. Ward
Counsel to the Assistant Attorney General

R. Hewitt Pate
Deputy Assistant Attorney General
 

Michael L. Katz
Deputy Assistant Attorney General

Communications with respect to this document should be addressed to:
  Nancy M. Goodman
Chief
 
W. Robert Majure
Assistant Chief

John Henly
Jeffrey Prisbrey
Economists
Economic Regulatory Section

April 25, 2002

Benjamin D. Brown
Lauren J. Fishbein
Laura R. Starling

Attorneys
Telecommunications and Media
Enforcement Section


Table of Contents

Table of Contents

Index of Full Citations

Introduction and Summary

  1. State Commission Proceedings
  2. The Department's Evaluation
  3. Conclusion

INDEX OF FULL CITATIONS

Short Citation

Full Citation

DOJ Evaluations and Related Materials
DOJ Georgia/Louisiana I Evaluation Evaluation of the U.S. Department of Justice, In re: Joint Application by BellSouth Corporation, BellSouth Telecommunications, Inc., and BellSouth Long Distance, Inc. for Provision of In-Region InterLATA Services in Georgia and Louisiana, FCC CC Docket No. 01-277 (Nov. 6, 2001), available at .
DOJ Missouri I Evaluation Evaluation of the U.S. Department of Justice, In re: Application of SBC Communications Inc., Southwestern Bell Telephone Company, and Southwestern Bell Communications Services, Inc. d/b/a Southwestern Bell Long Distance for Provision of In-Region InterLATA Services in Missouri, FCC CC Docket No. 01-88 (May 9, 2001), available at .
DOJ Pennsylvania Evaluation Evaluation of the U.S. Department of Justice, In re: Application by Verizon Pennsylvania Inc., Verizon Long Distance, Verizon Enterprise Solutions, Verizon Global Networks Inc., and Verizon Select Services Inc., for Authorization to Provide In-Region, InterLATA Services in Pennsylvania, FCC CC Docket No. 01-138 (July 26, 2001), available at .
FCC Orders, Reports, and Related Materials
FCC Connecticut Order Memorandum Opinion and Order, In re: Application of Verizon New York Inc., Verizon Long Distance, Verizon Enterprise Solutions, Verizon Global Networks Inc., and Verizon Select Services, Inc., for Authorization to Provide In-Region, InterLATA Services in Connecticut, 16 FCC Rcd 14,147 (July 20, 2001), available at .
FCC Massachusetts Order Memorandum Opinion and Order, In re: Application of Verizon New England Inc., Bell Atlantic Communications, Inc. (d/b/a Verizon Long Distance), NYNEX Long Distance Company (d/b/a Verizon Enterprise Solutions) and Verizon Global Networks Inc., for Authorization to Provide In-Region, InterLATA Services in Massachusetts, 16 FCC Rcd 8988 (Apr. 16, 2001), available at .
FCC New York Order Memorandum Opinion and Order, In re: Application by Bell Atlantic New York for Authorization Under Section 271 of the Communications Act To Provide In-Region, InterLATA Services in the State of New York, 15 FCC Rcd 3953 (Dec. 22, 1999), aff'd, AT&T Corp. v. FCC, 220 F.3d 607 (D.C. Cir. 2000), available at http://www.fcc.gov/Bureaus/Common_Carrier/in-region_applications>.
FCC Pennsylvania Order Memorandum Opinion and Order, In re: Application of Verizon Pennsylvania Inc., Verizon Long Distance, Verizon Enterprise Solutions, Verizon Global Networks Inc., and Verizon Select Services, Inc., for Authorization to Provide In-Region, InterLATA Services in Pennsylvania, 16 FCC Rcd 17,419 (Sept. 19, 2001), available at .
FCC Rhode Island Order Memorandum Opinion and Order, In re: Application of Verizon New England Inc., Bell Atlantic Communications, Inc. (d/b/a Verizon Long Distance), NYNEX Long Distance Company (d/b/a Verizon Enterprise Solutions) and Verizon Global Networks Inc., for Authorization to Provide In-Region, InterLATA Services in Rhode Island, FCC 02-63 (Feb. 22, 2002), available at 2002 WL 257346and .
FCC Vermont Order Memorandum Opinion and Order, In re: Application of Verizon New England Inc., Bell Atlantic Communications, Inc. (d/b/a Verizon Long Distance), NYNEX Long Distance Company (d/b/a Verizon Enterprise Solutions) and Verizon Global Networks Inc., for Authorization to Provide In-Region, InterLATA Services in Vermont, FCC 02-118 (Apr. 17, 2002), available at 2002 WL 575615 and .
Maine State Commission Orders and Related Materials
Maine PUC Comments Report of the Maine Public Utilities Commission on Verizon Maine's Compliance with Section 271 of the Telecommunications Act of 1996, In re: Application by Verizon New England Inc., Bell Atlantic Communications, Inc. (d/b/a Verizon Long Distance), NYNEX Long Distance Company (d/b/a Verizon Enterprise Solutions), Verizon Global Networks Inc., and Verizon Select Services Inc., for Authorization to Provide In-Region, InterLATA Services in Maine, FCC CC Docket No. 02-61 (Apr. 10, 2002).
Maine PUC Pricing Order I Order, In re: Investigation of Total Element Long--Run Incremental Cost (TELRIC) Studies and Pricing of Unbundled Network Elements, Maine PUC Docket No. 97-505 (Feb. 12, 2002), attached to Verizon Br. App. E as Tab 9.
Maine PUC Pricing Order II Order, In re: Investigation of Total Element Long--Run Incremental Cost (TELRIC) Studies and Pricing of Unbundled Network Elements, Maine PUC Docket No. 97-505 (Mar. 8, 2002), attached to Verizon Br. App. E as Tab 10.
Maine PUC Pricing Order III Supplemental Order, In re: Investigation of Total Element Long--Run Incremental Cost (TELRIC) Studies and Pricing of Unbundled Network Elements, Maine PUC Docket No. 97-505 (Mar. 20, 2002), attached to Verizon Br. App. I as Tab 26.
Maine PUC Section 271 Compliance Letter Letter from Maine Public Utilities Commission to Edward B. Dinan, Verizon New England, In re: Inquiry Regarding the Entry of Verizon-Maine into the InterLATA Telephone Market Pursuant to Section 271 of the Telecommunications Act of 1996, Maine PUC Docket No. 2000-849 (Mar. 1, 2002), attached to Verizon Br. App. B as Tab 25.
Verizon's Application and Related Filings
PwC Sapienza/Bluvol Decl. Joint Declaration of Russell J. Sapienza and Catherine (Kate) Bluvol, attached to Verizon Br. App. B as Tab 3.
Verizon Br. Application by Verizon New England for Authorization to Provide In-Region, InterLATA Services in Vermont, In re: Application by Verizon New England Inc., Bell Atlantic Communications, Inc. (d/b/a Verizon Long Distance), NYNEX Long Distance Company (d/b/a Verizon Enterprise Solutions), Verizon Global Networks Inc., and Verizon Select Services Inc., for Authorization to Provide In-Region, InterLATA Services in Maine, FCCCC Docket No. 02-61 (Mar. 21,2002).
Verizon Dinan/Garzillo/Anglin Decl. Joint Declaration of Edward B. Dinan, Patrick A. Garzillo, and Michael J. Anglin, attached to Verizon Br. App. A as Tab D.
Verizon Guerard/Canny/Abesamis Decl. Joint Declaration of Elaine M. Guerard, Julie A. Canny, and Beht A. Abesamis, attached to Verizon Br. App. A as Tab C.
Verizon McLean/Wierzbicki/Webster Decl. Joint Declaration of Kathleen McLean, Raymond Wierzbicki, and Catherine T. Webster, attached to Verizon Br. App. A as Tab B.
Verizon Section 271 Compliance Letter Letter from Edward B. Dinan, Verizon New England, to Maine Public Utilities Commission, In re: Inquiry Regarding the Entry of Verizon-Maine into the InterLATA Telephone Market Pursuant to Section 271 of the Telecommunications Act of 1996, Maine PUC Docket No. 2000-849 (Mar. 4, 2002), attached to Verizon Br. App. B as Tab 26.
Verizon Torre Decl. Declaration of John A. Torre, attached to Verizon Br. App. A as Tab F.
Third-Party Comments and Affidavits/Declarations
AT&T Comments Comments of AT&T Corp., In re: Application by Verizon New England Inc., Bell Atlantic Communications, Inc. (d/b/a Verizon Long Distance), NYNEX Long Distance Company (d/b/a Verizon Enterprise Solutions), Verizon Global Networks Inc., and Verizon Select Services Inc., for Authorization to Provide In-Region, InterLATA Services in Maine, FCC CC Docket No. 02-68 (Apr. 10, 2002).
WorldCom Comments Comments of WorldCom, Inc. on the Application by Verizon for Authorization to Provide In-Region, InterLATA Services in Vermont, In re: Application by Verizon for Authorization Under Section 271 of the Communications Act to Provide In-Region, InterLATA Services in Maine, FCC CC Docket No. 02-7 (Apr. 10, 2002).

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554


In the Matter of

Application by Verizon New England                 
Inc., Bell Atlantic Communications,
Inc. (d/b/a Verizon Long Distance),
NYNEX Long Distance Company
(d/b/a Verizon Enterprise Solutions),
Verizon Global Networks Inc., and
Verizon Select Services Inc., for
Authorization to Provide In-Region,
InterLATA Services in Maine


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WC Docket No. 02-61


_______________________________________________________
EVALUATION OF THE
UNITED STATES DEPARTMENT OF JUSTICE
_______________________________________________________

Introduction and Summary

The United States Department of Justice ("the Department"), pursuant to Section 271(d)(2)(A) of the Telecommunications Act of 1996(1) ("the 1996 Act"), submits this evaluation of the application filed by Verizon New England Inc., Bell Atlantic Communications, Inc. (d/b/a Verizon Long Distance), NYNEX Long Distance Company (d/b/a Verizon Enterprise Solutions),Verizon Global Networks Inc., and Verizon Select Services Inc., on March 21, 2002, to provide in-region, interLATA services in Maine.

This application to the Federal Communications Commission ("FCC" or "Commission") is Verizon's first for the state of Maine, and follows its successful applications for long distance entry in Massachusetts, Rhode Island, and Vermont, other states in its New England region, as well as successful applications for Pennsylvania, Connecticut, and New York.(2) The Department concludes that Verizon has generally succeeded in opening its local markets in Maine to competition and recommends approval of Verizon's application for Section 271 authority in the state.

I. Maine Public Utilities Commission Proceedings

The Maine Public Utilities Commission ("Maine PUC") has facilitated the development of competition in the local telecommunications markets byestablishing carrier-to-carrier wholesale performance measurements, which incorporate improvements from New York and several other states(3); conducting extensive pricing proceedings that established wholesale rates for unbundled network elements ("UNEs")(4); and adopting a Performance Assurance Plan intended to ensure that an appropriate level of wholesale performance is maintained once Verizon's Section 271 application is approved.(5) In addition, the Maine PUC has established a Rapid Response Process ("RRP") in order to resolve certain disputes between Verizon and CLECs more quickly than traditional dispute resolution processes would allow.(6)

The Maine PUC's review of Verizon's state Section 271 filing included an independent third-party test by PricewaterhouseCoopers ("PwC") designed to determine whether the operations support systems ("OSS") that Verizon uses in Maine are the same as those it uses in Massachusetts.(7) PwC concluded that Verizon's assertions regarding the "sameness" of its "New England Region Operational Support Systems (specifically the pre-order, order, provisioning, maintenance & repair, relationship management infrastructure, and billing domains) and Performance Metrics Reporting" are "fairly stated in all material respects."(8)

On April 10, the Maine PUC recommended that the FCC approve Verizon's Section 271 application.(9)

II. The Department's Evaluation

In assessing whether the local markets in a state are fully and irreversibly open to competition, the Department looks first to the actual entry in a market.(10) But the Department does not broadly presume that all three entry tracks -- facilities-based, unbundled network elements ("UNEs"), and resale -- are open or closed on the basis of an aggregate level of entry alone.(11)

Together, according to Verizon's data, Verizon and CLECs serve a total of approximately 750,700 lines in Verizon's Maine service area as of December 2001.(12) Of the total lines in Verizon's service area in Maine, 32.7 percent, or approximately 245,300 serve businesses, and 67.3 percent, or approximately 505,500 serve residential customers.(13) For business and residential customers combined, Verizon estimates that CLECs using all modes of entry serve approximately 50,600 lines, or approximately 6.7 percent of all lines in Verizon's service area in the state.(14)

Competitors have made progressin penetrating the business market in Maine. CLECs serve approximately 19.5 percent of all business lines in Verizon's Maine service area.(15) CLECs serve approximately 3.6 percent of all business lines using primarily their own fiber optic networks that are either connected directly to the customer premises or connected through loops leased from Verizon.(16) CLECs resell Verizon's services to serve approximately 14.8 percent of all business lines.(17) CLECs use the UNE-platform (a combination of loop, switch, and transport elements) to serve 1.1 percent of such lines.(18)

Using the facilities-based and resale modes of entry combined, CLECs serve less than 1 percent of all residential lines in Verizon's Maine service area.(19) CLECs have yet to serve any residential lines in Maine by means of the UNE-platform.(20)

The amount of entry by competitive facilities-based carriers and resellers serving business customers in Maine and the absence of complaints regarding Verizon's fulfillment of its obligations to open its markets to these modes of entry, lead the Department to conclude that opportunities to serve business customers via the facilities-based and resale modes of entry are available there. Although there is significantly less competition to serve residential customers and to serve business customers via the UNE-platform, the Department does not believe there are any material obstacles to competition in Maine created by Verizon. Verizon has submitted evidence to show that its OSS in Maine are the same as those that the Commission found satisfactory in Massachusetts.(21)Moreover, there have been few complaints regarding Verizon's Maine OSS in this proceeding.(22)

The low levels of CLEC penetration of residential markets in Maine and, in particular, the lack of entry by means of CLECs' own facilities and by means of the UNE-platform, may reflect the higher UNE pricing that was in effect for most of the period preceding this application as opposed to the UNE prices on which the application is based. The Maine PUC issued orders that reduced certain UNE rates within two months of Verizon's filing of this application.(23)

III. Conclusion

The record in this matter suggests that Verizon has succeeded in opening its local markets in Maine to competition in most respects, and the Department therefore recommends approval of Verizon's application for Section 271 authority in Maine.

    Respectfully submitted,

Charles A. James
Assistant Attorney General
Antitrust Division

R. Hewitt Pate
Deputy Assistant Attorney General
Antitrust Division

Michael L. Katz
Deputy Assistant Attorney General
Antitrust Division

Margaret A. Ward
Counsel to the Assistant Attorney General
Antitrust Division

W. Robert Majure
Assistant Chief

  /s/ Nancy M. Goodman   
Nancy M. Goodman
Chief

Benjamin D. Brown
Lauren J. Fishbein
Laura R. Starling


Attorneys
Telecommunications and Media
Enforcement Section

 
John Henly
Jeffrey Prisbrey
Economists
Economic Regulatory Section

April 25, 2002

Antitrust Division
U.S. Department of Justice
1401 H Street, NW, Suite 8000
Washington, DC 20530
(202) 514-5621

Certificate of Service

I hereby certify that I have caused a true and accurate copy of the foregoing Evaluation of the United States Department of Justice to be served on the persons indicated on the attached service list by first class mail, overnight mail, hand delivery, or electronic mail on April 25, 2002.

     /s/ Benjamin D. Brown   
Benjamin D. Brown
Attorney
Telecommunications and Media
Enforcement Section
Antitrust Division
U.S. Department of Justice

Service List

Chairman Michael K. Powell
Commissioner Kathleen Q. Abernathy
Commissioner Michael J. Copps
Commissioner Kevin J. Martin
Federal Communications Commission
445 12th Street, SW
Washington, DC 20554

Marlene H. Dortch
Secretary
Office of the Secretary
Federal Communications Commission
445 12th Street, SW
TW-B204
Washington, DC 20554

Janice Myles
Common Carrier Bureau
Federal Communications Commission
445 12th Street, SW
Room 5-C327
Washington, DC 20554

Qualex International
Portals II
445 12th Street, SW
Room CY-B402
Washington, DC 20554

Christine Newcomb
Wireline Competition Bureau
Federal Communications Commission
445 12th Street, SW
Washington, DC 20554

Chairman Thomas Welch
Commissioner William Nugent
Commissioner Stephen Diamond
242 State Street
18 State House Station
Augusta, ME 04333-0018

Trina Bragdon
Staff Attorney
242 State Street
18 State House Station
Augusta, ME 04333

Michael E. Glover
Senior Vice President and
Deputy General Counsel
Verizon
1515 North Court House Road
Suite 500
Arlington, VA 22201

Lori Wright
Associate Counsel
Federal Advocacy
WorldCom, Inc.
1133 19th Street, NW
Washington, DC 20036

Marybeth M. Banks
H. Richard Juhnke
Sprint Corporation
401 9th Street, NW
Suite 400
Washington, DC 20004

Mark C. Rosenblum
Lawrence Lafaro
James Talbot
AT&T Corporation
295 North Maple Avenue
Basking Ridge, NJ 07920


FOOTNOTES

1. Pub. L. No. 104-104, 110 Stat. 56 (1996) (codified as amended in scattered sections of 47 U.S.C.).

2. See generally FCC Vermont Order; FCC Rhode Island Order; FCC Pennsylvania Order; FCC Connecticut Order; FCC Massachusetts Order; FCC New York Order.

3. Maine PUC Comments at 2, 91-95; Verizon Section 271 Compliance Letter at 1 (confirming Maine PUC's adoption of Performance Assurance Plan ("PAP") in March 1 letter entails adoption of carrier-to-carrier guidelines relating to reporting of wholesale performance); Verizon Br. at 92-93 (noting Verizon Maine performance measures are "virtually identical" to those developed in the New York PSC's collaborative carrier working group process and employed in New York, Massachusetts, Connecticut, and Rhode Island).

4. Maine PUC Comments at 3, 20-28; Maine PUC Pricing Order I at 1 (establishing UNE rates); Maine PUC Pricing Order II at 1 (revising switching rates, adopting interconnection rates, and correcting rates attached to Maine Pricing Order I); Maine PUC Pricing Order III at 1 (correcting rates attached to Maine Pricing Order II).

5. Maine PUC Comments at2-4, 88-91; Maine PUC Section 271 Compliance Letter at 3-5 (adopting PAP "modeled on the New York plan to which Verizon is subject in New York, Massachusetts, Rhode Island, and Connecticut," subject to certain modifications, including "any changes warranted by our [continuing] review, including adoption of a PAP modeled on the New Jersey PAP").

6. Maine PUC Section 271 Compliance Letter at 3 & Attach. A; see also Verizon Guerard/Canny/Abesamis Decl. ¶ 105. At the Maine PUC's request, Verizon agreed to participate in the Rapid Response Process ("RRP"). See Verizon Section 271 Compliance Letter at 3. Complaints will be resolved by an RRP team designated by the PUC and entrusted with limited, but sufficient, authority to impose penalties designed to ensure responsiveness. See Maine PUC Section 271 Compliance Letter Attach. A at 3. The RRP team will employ e-mails and conference calls to arrive at preliminary findings a mere four days after receipt of a CLEC complaint, and will attempt to issue an appealable final order shortly thereafter. Id. at 4-6. This novel approach implicitly acknowledges that competition can be meaningfully affected by conduct that cannot easily be quantified and addressed by means of a PAP or adequately remedied via more elaborate process. On or after September 1, 2002, the PUC plans to evaluate the effectiveness of the RRP and determine whether it should be codified in the commission's Rules. See Maine PUC Section 271 Compliance Letter at 3.

7. Verizon McLean/Wierzbicki/Webster Decl. ¶ 11; see also FCC Massachusetts Order ¶¶ 43-181 (concluding that Verizon provides CLECs non-discriminatory access to its OSS, including unbundled loops, in Massachusetts).

8. PwC Sapienza/Bluvol Decl.¶¶ 12-16.

9. Maine PUC Comments at115; see also Maine PUC Section 271 Compliance Letter at 5 (state commission expects to recommend approval of Verizon's application "[c]onditioned on Verizon Maine's assurance that it will satisfy the items specified above").

10. See DOJ Pennsylvania Evaluation at 3-4 ("The Department first looks to actual competitive entry, because the experience of competitors seeking to enter a market can provide highly probative evidence about the presence or absence of artificial barriers to entry. Of course, entry barriers can differ by types of customers or geographic areas within a state, so the Department looks for evidence relevant to each market in a state." (Footnote omitted.)).

11. See, e.g., DOJ Georgia/Louisiana Evaluation at 7 ("Although the Department presumes that fully facilities-based competition is not hindered in a competitively significant manner based on the entry recorded in Georgia, the amount of entry does not justify extending such a presumption to other modes of entry in Georgia."); DOJ Missouri I Evaluation at 6-7 ("The Department presumes that opportunities to serve business customers by fully facilities-based carriers and resellers are available in Missouri, based on the entry efforts reflected in SBC's application. There is significantly less competition to serve residential customers. There also is less competition by firms seeking to use UNEs, including the UNE-platform, and there are some indications that a failure by SBC to satisfy all of its obligations may have constrained this type of competition." (Footnotes omitted.)).

12. See Verizon Dinan/Garzillo/Anglin Decl. ¶ 39; Verizon Torre Decl. Attach. 1 at 3 tbl.1. Maine has several incumbent local exchange carriers other than Verizon.

13. See Verizon Dinan/Garzillo/Anglin Decl. ¶ 39; Verizon Torre Decl. Attach. 1 at 3 tbl.1.

14. See id.

15. See Verizon Dinan/Garzillo/Anglin Decl. ¶ 39; Verizon Torre Decl. Attach 1 at 3 tbl.1 (CLECs serve approximately 47,900business lines).

16. See Verizon Dinan/Garzillo/Anglin Decl. ¶ 39; Verizon Torre Decl. Attach. 1 at 3 tbl.1 (CLECs serve approximately 8,900business lines using at least some of their own facilities).

17. See Verizon Dinan/Garzillo/Anglin Decl. ¶ 39; Verizon Torre Decl. Attach. 1 at 3 tbl.1 (CLECs serve approximately 36,300business lines via resale).

18. See Verizon Dinan/Garzillo/Anglin Decl. ¶ 39; Verizon Torre Decl. Attach. 1 at 3 tbl.1 (CLECs serve approximately 2,700business lines through the UNE-platform).

19. See Verizon Dinan/Garzillo/Anglin Decl. ¶ 39; Verizon Torre Decl. Attach. 1 at 3 tbl.1 (CLECs serve approximately 260residential lines using at least some of their own facilities and 2,500 of such lines via resale).

20. Verizon Torre Decl. Attach. 1 at 3 tbl.1.

21. See supra note 8.

22. During the Maine PUC proceedings, "a number of carriers raised issues concerning their difficulty in effectively using Verizon's OSS as well as the lack of training or willingness of Verizon personnel to resolve CLEC-Verizon operational issues." Maine PUC Comments at 14. The Maine PUC reviewed these allegations and concluded that, although Verizon caused "much of the confusion, delay, and increased expense" associated with several incidents of OSS failures, Verizon's overall performance had improved and is sufficient to support a finding of non-discriminatory access to network elements. Id. at 14-20. The Maine PUC plans to rely on its RRP along with its PAP to continue to "scrutinize Verizon's wholesale operations." Id. at 19-20. The CLEC complaints regarding OSS that were raised in the state proceedings were not reiterated in this proceeding.

23. See supra note 4. In its pricing orders, the Maine PUC did not adopt a daily usage files ("DUF") rate. Id. Verizon acknowledges that this effectively set the DUF rate at zero unless and until the PUC modifies this rate. See Verizon Br. at 46 n.45; Verizon Dinan/Garzillo/Anglin Decl. ¶ 41. This acknowledgment should assuage AT&T's concerns that the DUF rate in Verizon's model and existing interconnection agreements, which AT&T alleges violates TELRIC principles, is still effective. See AT&T Comments at 14-17 & n.18. But see id. at 15 & n.18 (observing that "Verizon has apparently taken no steps to modify its interconnection agreements to reflect the zero rate" and expressing concern that Verizon may still propose a non-TELRIC-based DUF rate in the future); WorldCom Comments at 1 (same).

Updated June 25, 2015