Telecommunications

In Re: AT&T Louisiana Ex Parte, Petition for Modification of Rules and Regulations Necessary to Achieve Regulatory Parity and Modernization; Docket No. R-30347; Completed 2008. ACG assisted the Louisiana Public Service Commission in evaluating AT&T’s request to deregulate its business services, no longer be subjected to TSLIRC pricing requirements, no longer file tariffs, and to no longer be subject to service quality measures.

In Re: Application of Central Telephone Company d/b/a Embarq for Authority to Adjust Wholesale Prices for Unbundled Network Elements; Docket No. 06-11016; Completed 2007.  ACG assisted the Staff of the Nevada Public Utilities Commission with preparation of discovery and analysis of Company testimony and exhibits. ACG prepared direct testimony on TELRIC non-recurring rates for UNEs, rate banding, labor costs, and loop conditioning. ACG calculated recurring monthly UNE costs using Company model and Staff inputs.

In Re: BellSouth Telecommunications, Inc. Service Quality Performance Measurements; Docket No. U-22252-Subdocket C; Completed 2005.  ACG assisted the Louisiana Public Service Commission in conducting collaborative workshops with BellSouth and the CLECs in developing performance measurements, retail analogs and benchmarks, statistical testing for parity performance, and incentives for ensuring nondiscriminatory access to BellSouth’s operations support systems.

In Re:  Investigation into Network Operator Services, Inc. Based on Recent Allegations Against Network Operator Services, Inc. (“NOS”) Regarding Overcharges from Several Inmate Facilities within the State of Louisiana, the Commission will Institute an Investigation into Network Operator Services, Inc.; Docket No. U-27159; Completed 2005.  ACG assisted the Commission Staff with the performance of a detailed audit of NOS’ calling records for a 4-year period to determine the amount of overcharges to Louisiana customers.  ACG’s investigation re-rated all local and long distance payphones charged by the operator service company.  ACG developed a comprehensive program to re-rate charges and compare to original bills.  The original investigation was completed with ACG’s recommendations fully approved by the LPSC. .

In Re: Petition of Verizon California Inc., d/b/a Verizon Nevada, for Review and Approval of its Carrier-to-Carrier Performance Assurance Plan; Docket No. 04-2004; Completed 2005.  ACG assisted the Bureau of Consumer Protection of Nevada with a review and analysis of Verizon’s performance measurements plan and incentive plan. 

 

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2002 - 2004

In Re: Application of Nevada Bell Telephone Company, d/b/a SBC Nevada, to Reclassify Business Subscriber Access Services Which Are Currently Classified as a Basic Service to Competitive Services in its Reno and Carson City Exchanges Only; Docket No. 05-2012; Completed 2004.  ACG assisted the Bureau of Consumer Protection with preparation of discovery and testimony of Nevada Bell’s request to reclassify its Business Subscriber Access Service as competitive in two geographic areas, Reno and Carson City. Nevada Bell argued that CLECs had gained more than 15% of market in these areas and it therefore was eligible to reclassify these services as competitive consistent with Nevada’s Administrative Code. .

In Re: Investigation to Determine the Amount and Treatment of the Proceeds from the Sale of the Telephone Directory Business of Sprint Corporation and its Affiliates Including Sprint-Nevada; Docket No. 03-1022; Completed 2004. ACG assisted the Bureau of Consumer Protection of Nevada with the preparation of discovery and the preparation of testimony on the appropriate treatment of funds received by Sprint Corporation for the sale of its Directory Operations. ACG recommended returning the gain on sale to customers.  The case settled with a revenue imputation of $25 million attributed to ratepayers through the year 2017.

In Re: Application of Valor Telecommunications Of Texas, LP For Authority to Establish Expanded Local Calling Service (ELCS) Surcharges For Recovery of ELCS Residual Administrative Hearings; SOAH Docket No. 473-03-2882, PUC Docket No. 27363; Completed 2004.  ACG assisted in the filing of a Joint Affidavit on Behalf of the Cities of Texas and Staff of the PUC regarding Certified Issues before the Public Utilities Commission of Texas. ACG also assisted Cities of Texas with preparation of discovery; analysis of Company testimony; and preparation of prefiled direct testimony on cost issues, lost toll revenue, ELCS, and stimulation issues.

In Re: Filing of Nevada Bell Telephone Company for Review and Approval of its 2003 Performance Measurements Plan and 2003 Performance Incentives Plan; Docket No. 03-1036; Completed 2003.  ACG assisted the Bureau of Consumer Protection of Nevada with a review and analysis of Nevada Bell’s performance measurements plan and incentive plan.

In Re: Filing of Sprint of Nevada for Review and Approval of its 2003 Performance Measurements Plan and 2003 Performance Incentives Plan; Docket No. 03-1041; Completed 2003.  ACG assisted the Bureau of Consumer Protection of Nevada with a review and analysis of Sprint of Nevada’s performance measurements plan and incentive plan. This included a critiquing of Sprint’s performance plan, providing suggestions for improvements, examination of the incentive plan, and developing an alternative plan that was more competitive and fair to competitive local exchange companies.

In Re: Sprint of Nevada to Continue Participating in the Plan of Alternative Rate Regulation, Including a Request to Increase Basic Local Rates; Docket No. 01-12047 and 01-9029; Completed 2002. ACG assisted the Bureau of Consumer Protection of Nevada with the preparation of discovery and preparation of testimony on revenue requirements issues, including directory revenues, affiliate transactions, revenue projections, and various proforma adjustments.

In Re: The Filing of GTE Nevada for Approval of its Plan for the Reporting and Auditing of Performance Measures and a Plan for Establishing Performance Incentives; Docket No. 01-2039; Completed 2002.  ACG assisted the Bureau of Consumer Protection of Nevada with a review and analysis of GTE’s performance measurements plan and incentive plan.

 

2000 - 2001

In Re: Filing by Nevada Bell of Unbundled Network Element (UNE) Nonrecurring Cost Study Pursuant to the Order Issued in Docket No. 98-6004; Docket No. 99-12033;  In Re: Petition of Nevada Bell for Review and Approval of its Cost Study and Proposed Rates for Conditioning Digital Subscriber Line (DSL) Loops; Docket No. 00-4001; Completed 2001.  ACG assisted the Staff of the Nevada Public Service Commission with the preparation of discovery, cross-examination, and preparation of direct testimony on the following subjects: TELRIC nonrecurring costs for unbundled loops, ports, ordering, switching; labor rates; and cost recovery for recurring operations support systems.

In Re: Petition of Central Telephone Company – Nevada, d/b/a Sprint of Nevada, and Sprint Communications Company L.P. for Review and Approval of Proposed Revised Performance Measures; Docket No. 01-1049; In Re: Petition of Central Telephone Company – Nevada, d/b/a Sprint of Nevada, and Sprint Communications Company L.P. for Review of Performance Measurement Penalties Plan; Docket No. 01-3001; Completed 2001. ACG assisted the Bureau of Consumer Protection of Nevada with a review and analysis of Sprint’s performance measurements plan and incentive plan.

In Re: The Filing of Nevada Bell Telephone Company for Approval of its Plan for the Reporting and Auditing of Performance Measures and a Plan for Establishing Performance Incentives; Docket No. 01-1048; Completed 2001. ACG assisted the Bureau of Consumer Protection of Nevada with a review and analysis of Nevada Bell’s performance measurements plan and incentive plan.

In Re: Audit of GTE California’s Affiliate Transactions; Docket No. 01-009-01 and 01-009-02; Completed 2001. ACG assisted the California Office of Ratepayer Advocate with an historical analysis of GTE California’s affiliate transaction and cost allocations for the periods 1996 through 1999.  Issues examined included the pricing of services between affiliates; the standards by which affiliate transactions should be examined; the allocation of costs between the regulated and nonregulated operations of GTE California; asset transfers between affiliates; shared asset allocation methodology; royalty fee; marketing affiliate pricing; evaluation of  the adequacy of the cost allocation manual; lease arrangements between affiliates; gain on sale of affiliates; analysis of FCC and CPUC affiliate rules and regulations; Part 64 and 36 cost allocations; and recommendations for improvements to costing methods, procedures, and manuals.

In Re: Final Deaveraging of BellSouth Telecommunications, Inc., UNE Rates Pursuant to FCC CC 96-45 9th Report and Order on 18th Order on Reconsideration Released 11/2/99 to be Established and Submitted for the December Louisiana Public Service Commission Business and Executive Session; Docket No. U-24714-Subdocket A; Completed 2001.  ACG assisted the Staff of the Louisiana Public Service Commission with the preparation of discovery, direct testimony, and cross-examination on TELRIC costing principles. Analyses included entering appropriate inputs into TELRIC costing model for developing the costs and prices of unbundled network elements; evaluating depreciation rates, fill factors, cost of capital, shared and common costs, structure sharing percentages, cable costs, plant specific and plant nonspecific expenses, and switching costs; loading factors as inputs into costing models; preparing unbundled network element recurring costs using the BellSouth model; developing non-recurring costs and prices for unbundled network elements; examining costs and prices for operational support systems; and developing deaveraged rates.

In Re: Generic Issues Associated with Applications for Approval of Unbundled Cost of Service Rate Pursuant to PURA §39.201 and Public Utility Commission Substantive Rule §25.344l; Docket No. 22344; Completed 2001. Members of ACG assisted the City of Amarillo by providing an analysis of Southwestern Public Service Company’s proposed unbundling plan. This included an analysis of proposed generation capacity auction, impacts of capacity actions on purchased power factors, the relationship of fuel adjustment clauses on unbundled rates, market power, transmission pricing and governance issues, federal-state jurisdictional issues, and price forecasting.

In Re: Application of Southwestern Public Service for Approval of Unbundled Cost of Service Rate Pursuant to PURA §39.201 and Public Utility Commission Substantive Rule §25.344; Docket No. 22351; Completed 2001. Members of ACG assisted the City of Amarillo with the preparation of an analysis of the unbundled cost of service plan proposed by Southwestern Public Service Company and presentation before the Public Utilities Commission of Texas.  The proposed unbundled cost of service study was required under Senate Bill 7 in Texas to facilitate retail choice.  Analysis included the review of revenue requirement reasonableness; affiliate relationships, class cost of service, jurisdictional allocations, revenue distribution, and forecast billing determinants.

In Re: Filing by Nevada Bell of its Unbundled Network Element (UNE) Nonrecurring Cost Study Pursuant to the Order Issued in Docket No. 98-6004; Docket No. 99-12033; Completed 2000.  ACG assisted the Staff of the Nevada Public Service Commission with the preparation of discovery, cross-examination, and preparation of direct testimony on the following subjects: TELRIC nonrecurring costs for unbundled loops, ports, ordering, and switching; labor rates; and cost recovery for recurring operations support systems.

 

1997 - 1999

In Re: Sprint of Nevada Request for Continued Regulation Under the Plan of Alternative Regulation; Docket No. 99-2024; Completed 1999.  ACG assisted the Staff of the Public Utilities Commission of Nevada with preparation of discovery; analysis of Company Audit Packages; on-site audit; preparation of direct testimony on accounting issues, affiliate transactions, review of parent company charges for applicability to rates of regulated utility, taxes, revenue issues, rate base issues, and used and useful issues. .

In Re: Commission Investigation into Procedures and Methods Necessary to Determine Whether Interconnection, Unbundled Access, and Resale Services Provided by Incumbent Local Exchange Carriers are at Least Equal in Quality to that Provided by the Local Exchange Carrier to Itself or to any Subsidiary, Affiliate, or Any Other Party; Docket No. 97-9022; Completed 1999.  ACG assisted the Staff of the Nevada Public Service Commission in conducting collaborative workshops with Nevada Bell, Sprint, GTE, and CLECs in developing performance measurements, retail analogs and benchmarks, statistical testing for parity performance, and incentives for ensuring nondiscriminatory access to Nevada Bell’s operations support systems.  ACG assisted the Staff of the Nevada Public Service Commission with the preparation of Comments and Reply Comments on performance measurement issues.

In Re: Petition of Bell Atlantic - New Jersey for an Order Finding That Petitioner BA-NJ’s Pay Phone Operations Are Not Subsidized by Exchange or Exchange Access Services; Filing by the New Jersey Pay Phone Association for Board Approval of Certain Competitive Payphone Issues; Petition of Bell Atlantic - New Jersey to Discontinue Limited Inter Lata Dialing Features in Customer Provided Pay Phone Service Tariff and to Decrease Rates for the Line Side Supervision Feature in the CPPTS Tariff; the Filing by Bell Atlantic - New Jersey, Inc. Tariff Revision; Docket Nos. TT97050360, TT97010016, TO97100792, TO92121070; Completed 1999.  ACG assisted with the preparation of discovery and direct and rebuttal testimony on TSLRIC and TELRIC costing principles. ACG’s analyses included entering appropriate inputs into TELRIC costing model for developing the costs and prices of unbundled network elements; evaluating depreciation rates, fill factors, cost of capital, shared and common costs as inputs into costing models; developing an alternative cross-subsidy study showing that Bell Atlantic’s payphone operations were subsidized by its exchange and exchange access operations; developing alternative rates for payphone lines; and developing a cost study depicting the amount of subsidy provided to the payphone operations.

In Re: Petition of Bell Atlantic - New Jersey for an Order Finding That Petitioner BA-NJ’s Pay Phone Operations Are Not Subsidized by Exchange or Exchange Access Services; Filing by the New Jersey Pay Phone Association for Board Approval of Certain Competitive Payphone Issues; Petition of Bell Atlantic - New Jersey to Discontinue Limited Inter Lata Dialing Features in Customer Provided Pay Phone Service Tariff and to Decrease Rates for the Line Side Supervision Feature in the CPPTS Tariff; the Filing by Bell Atlantic - New Jersey, Inc. Tariff Revision; Docket Nos. TT97050360, TT97010016, TO97100792, TO92121070; Completed 1998.  ACG assisted with the preparation of discovery and direct and rebuttal testimony on TSLRIC and TELRIC costing principles. ACG’s analyses included entering appropriate inputs into TELRIC costing model for developing the costs and prices of unbundled network elements; evaluating depreciation rates, fill factors, cost of capital, shared and common costs as inputs into costing models; developing an alternative cross-subsidy study showing that Bell Atlantic’s payphone operations were subsidized by its exchange and exchange access operations; developing alternative rates for payphone lines; and developing a cost study depicting the amount of subsidy provided to the payphone operations.

In Re: Filing of Central Telephone Company - Nevada d/b/a Sprint of Nevada’s Unbundled Network Element Cost Study; Docket No. 98-6005; Completed 1998.  ACG assisted the Staff of the Nevada Public Service Commission with the preparation of discovery, cross-examination, and preparation of direct testimony on the following subjects: TELRIC nonrecurring costs for unbundled loops, ports, ordering, switching, labor rates, and cost recovery for recurring operations support systems.

In Re: Nevada Bell Telephone Company’s Unbundled Network Element Cost Study; Docket No.  98-6004; Completed 1998.  ACG assisted the Staff of the Nevada Public Service Commission with the preparation of discovery, cross-examination, and preparation of direct testimony on the following subjects: TELRIC nonrecurring costs for unbundled loops, ports, ordering, switching, labor rates, and cost recovery for recurring operations support systems.

In Re: Submission of the Louisiana Public Service Commission’s Forward-Looking Cost Study to the FCC for Purposes of Calculating Federal Universal Service Support Pursuant to LPSC Order No. U-20883; Docket No. U-20883- Subdocket A; Completed 1997.  ACG assisted the Staff of the Louisiana Public Service Commission with the preparation of discovery, cross-examination, and preparation of the Staff’s Recommendation on TSLRIC and TELRIC costing principles. Analyses included entering appropriate inputs into the Hatfield universal service costing model for developing the amount of universal service support at the federal level, and evaluating depreciation rates, fill factors, cost of capital, shared and common costs, structure sharing percentages, cable costs, plant specific and plant nonspecific expenses, switching costs, customer location issues, revenue benchmarks for determining universal service requirements, UNE prices relative to USF costs, and wire center versus census group disaggregation for purposes of calculating universal service support.

 

Prior to 1997

In Re: Review and Consideration of BellSouth's TSLRIC and LRIC Cost Studies Submitted per Sections 901.C and 1001.E of the LPSC Local Competition Regulations in Order to Determine the Cost of Interconnection Services and Unbundled Network Elements to Establish Reasonable, Non-Discriminatory, Cost-Based Tariffed Rates; Docket No. U-22022; Completed 1996.  ACG assisted the Staff of the Louisiana Public Service Commission with the preparation of discovery, direct testimony, and cross-examination on TSLRIC and TELRIC costing principles. Analyses included entering appropriate inputs into TELRIC costing model for developing the costs and prices of unbundled network elements; evaluating depreciation rates, fill factors, cost of capital, shared and common costs, structure sharing percentages, cable costs, plant specific and plant nonspecific expenses, and switching costs; loading factors as inputs into costing models; preparing unbundled network element recurring costs using the BellSouth model and the Hatfield model; developing non-recurring costs and prices for unbundled network elements; and examining costs and prices for operational support systems.

In Re: Petition of AT&T Communications of the Southwest, Inc., for Authority to Change Rates; Docket No. 6095; Completed 1995.  Members of ACG assisted Texas Cities with preparation of discovery; analysis of Company Minimum Filing Requirements; preparation of direct testimony on accounting issues, affiliate transactions, and cost allocations; and preparation of cross-examination questions.

In Re: Comprehensive Review of the Revenue Requirements And Rate Stabilization Plan of Southern Bell Telephone and Telegraph Company; Docket No. 920260-TL; Completed 1993.  Members of ACG assisted the Florida Office of the Public Counsel with preparation of discovery; preparation of direct testimony on accounting issues, cost allocations between regulated and nonregulated operations, affiliate transactions, charges from parent company, and asset transfers; review of cost allocation manuals; review of compliance with FCC’s affiliate transactions rules; review of employee transfers, affiliate lease arrangements, cross-subsidies, and royalty fees; an extensive examination of audits of affiliate transactions and cost allocations between regulated and nonregulated operations; and preparation of cross-examination questions.

In Re: Investigation into Cross-Subsidy Matters Relating to Southern Bell Telephone and Telegraph Company; Docket No. 3987-U; Completed 1992.  Members of ACG assisted the Georgia Office of Consumer Counsel with preparation of discovery; preparation of direct testimony on accounting issues, cost allocations between regulated and nonregulated operations, affiliate transactions, charges from parent company, and asset transfers; review of cost allocation manuals; review of compliance with FCC’s affiliate transactions rules, employee transfers, affiliate lease arrangements, cross-subsidies, and royalty fees; an extensive examination of audits of affiliate transactions and cost allocations between regulated and nonregulated operations; and preparation of cross-examination questions.

In Re:  Petition of the Citizens of Florida to Investigate Southern Bell's Cost Allocation Procedures; Docket No. 890190-TL; Completed 1991.  Members of ACG assisted the Florida Office of the Public Counsel with preparation of discovery and direct testimony on accounting issues, cost allocations between regulated and nonregulated operations, affiliate transactions, and charges from parent company; review of cost allocation manuals; review of compliance with FCC’s affiliate transactions rules, cross-subsidies, and royalty fees; and preparation of cross-examination questions.

In Re: Petition of Southwestern Bell Telephone Company for Authority to Change Rates - Rate Design Phase; Docket No. 6200; Completed 1985.  Members of ACG assisted Texas Cities with preparation of discovery; analysis of Company Minimum Filing Requirements; preparation of direct testimony on accounting issues, affiliate transactions, and cost allocations; and preparation of cross-examination questions.

In Re: Application of the Mountain States Telephone and Telegraph Company for a Hearing to Determine the Earnings and Fair Value of the Company, to Fix a Just and Reasonable Rate of Return, and to Approve Rate Schedules; Docket No. E-1051-84-100; Completed 1985.  Members of ACG assisted the Arizona Corporation Commission with preparation of discovery, analysis of Company rate filing, and preparation of direct testimony on accounting issues.

In Re:  The Application of American Telephone and Telegraph Communications of the Southwest for a Rate Increase; Docket Number 5540; Completed 1984.  Members of ACG assisted Texas Cities with preparation of discovery; analysis of Company Minimum Filing Requirements; preparation of direct testimony on accounting issues, affiliate transactions, and cost allocations; and preparation of cross-examination questions.

In Re: In the Matter of the Regulation of Operator Service Providers and Public Pay Telephone Service.  ACG assisted the Staff of the Commission in developing the appropriate price caps for operator assisted payphone calls through the development of surveys and compilation of financial data for New Jersey payphone providers.