3. Intrastate Originating Switched Access Charges a. Positions of the Parties i. AT&T While not directly implicated in participation in Verizon’s filing, AT&T’s this proceeding was designed largely to continue its advocacy before this Commission opposing and all intrastate originating switched access charges. AT&T Verizon’s ILECs’ asserts that access charges continue to subsidize basic local exchange service. Verizon’s As Section 3016(f) of the Code prohibits competitive services from subsidizing services, AT&T contends that the Commission is compelled to complete the process of the access reform that remains pending before it. AT&T St. 1 at 5. As panel witnesses is the reason for interest in this AT&T’s affirmed, “[t]his AT&T’s case.” While AT&T acknowledges that its proposal in this case is aimed at Verizon, it Id. contends that it would facilitate comparison and enforcement if CLECs were required to mirror access rate structure. at 9, n.3. Further, AT&T contends that, Id. Verizon’s “for consistency and fairness it would make to require all Rural ILECs to reduce their sense” intrastate originating access charges to parity as well. at 17, n.11. According to Id. AT&T, only by requiring Verizon, as a condition of this case, to reduce its intrastate originating access rates to parity with its interstate originating access rates can grant of Petition comply with Section 3016(f) of Chapter 30, which prohibits Verizon’s noncompetitive services from subsidizing competitive services. AT&T claims that this is of the price of admission to competitive AT&T M.B. at 1. “part reclassification.” AT&T proposes to accomplish this through a one-time, immediate, reduction of intrastate originating switched access charges to its interstate Verizon’s levels and rebalancing those lost revenues on a revenue-neutral basis against its current base of protected services. AT&T is of the opinion that this would a minimal “produce
3. Intrastate Originating Switched Access Charges a. Positions of the Parties i. AT&T While not directly implicated in Verizon’s filing, AT&T’s participation in this proceeding was designed largely to continue its advocacy before this Commission opposing Verizon’s and all ILECs’ intrastate originating switched access charges. AT&T asserts that Verizon’s access charges continue to subsidize basic local exchange service. As Section 3016(f) of the Code prohibits competitive services from subsidizing services, AT&T contends that the Commission is compelled to complete the process of the access reform that remains pending before it. AT&T St. 1 at 5. As AT&T’s panel witnesses affirmed, “[t]his is the reason for AT&T’s interest in this case.” Id. While AT&T acknowledges that its proposal in this case is aimed at Verizon, it contends that it would facilitate comparison and enforcement if CLECs were required to mirror Verizon’s access rate structure. Id. at 9, n.3. Further, AT&T contends that, “for consistency and fairness it would make sense” to require all Rural ILECs to reduce their intrastate originating access charges to parity as well. Id. at 17, n.11. According to AT&T, only by requiring Verizon, as a condition of this case, to reduce its intrastate originating access rates to parity with its interstate originating access rates can grant of Verizon’s Petition comply with Section 3016(f) of Chapter 30, which prohibits noncompetitive services from subsidizing competitive services. AT&T claims that this is “part of the price of admission to competitive reclassification.” AT&T M.B. at 1. AT&T proposes to accomplish this through a one-time, immediate, reduction of Verizon’s intrastate originating switched access charges to its interstate levels and rebalancing those lost revenues on a revenue-neutral basis against its current base of protected services. AT&T is of the opinion that this would “produce a minimal