from its provision of services to wholesale VoIP providers, permits Core to Talk America purchase these facilities at TELRIC rates. Accordingly, we directed the Parties to adopt language in the ICA consistent with this finding. at 105-106. December 2013 Order Core asserts that, although the Commission correctly ruled that entrance facilities must be priced at TELRIC rates, we did not stipulate what these rates should be. Core acknowledges that, during this proceeding, CTL submitted for entry into the record a cost study and proposed TELRIC rates for entrance facilities as an alternative to its position that all entrance facilities should be priced at tariffed special access rates. However, Core submits that cost study is flawed, is not TELRIC-based, is now CTL’s more than six years old, and in no way allows the Commission to establish TELRIC rates for the entrance facilities at hand. Therefore, Core argues that this cost study should be rejected and that the Commission should institute a generic investigation to determine the appropriate TELRIC rates that CTL may charge. Core points out that the entrance facility cost study CTL submitted is the first of its kind that CTL has brought before the Commission. Core notes that the issues rooted in such a study are complex and may include, issues related to cost study methodology, economic lives, cost of inter alia, capital, and accounting, engineering, and purchasing practices. For this reason, CTL’s Core suggests that, although entrance facilities are the only TELRIC element in question in this proceeding, the Commission should also examine the entirety of unbundled CTL’s network elements (UNE) and reciprocal compensation rates to ensure proper TELRIC pricing. Petition at 4-7, n.12. Core posits that, during the pendency of such an investigation, the Commission should order CTL to make its entrance facilities available at the TELRIC rates that have been established for Verizon Pennsylvania, LLC. Core points out that the Commission approved such TELRIC methodology in Generic Investigation Re Verizon Docket No. R-00016683, (Order Pennsylvania Element Rates, Inc.’s Unbundled Network entered July 16, 2004) (July In the alternative, Core asserts that the 2004 Verizon Order).
from its provision of services to wholesale VoIP providers, Talk America permits Core to purchase these facilities at TELRIC rates. Accordingly, we directed the Parties to adopt language in the ICA consistent with this finding. December 2013 Order at 105-106. Core asserts that, although the Commission correctly ruled that entrance facilities must be priced at TELRIC rates, we did not stipulate what these rates should be. Core acknowledges that, during this proceeding, CTL submitted for entry into the record a cost study and proposed TELRIC rates for entrance facilities as an alternative to its position that all entrance facilities should be priced at tariffed special access rates. However, Core submits that CTL’s cost study is flawed, is not TELRIC-based, is now more than six years old, and in no way allows the Commission to establish TELRIC rates for the entrance facilities at hand. Therefore, Core argues that this cost study should be rejected and that the Commission should institute a generic investigation to determine the appropriate TELRIC rates that CTL may charge. Core points out that the entrance facility cost study CTL submitted is the first of its kind that CTL has brought before the Commission. Core notes that the issues rooted in such a study are complex and may include, inter alia, issues related to cost study methodology, economic lives, cost of capital, and CTL’s accounting, engineering, and purchasing practices. For this reason, Core suggests that, although entrance facilities are the only TELRIC element in question in this proceeding, the Commission should also examine the entirety of CTL’s unbundled network elements (UNE) and reciprocal compensation rates to ensure proper TELRIC pricing. Petition at 4-7, n.12. Core posits that, during the pendency of such an investigation, the Commission should order CTL to make its entrance facilities available at the TELRIC rates that have been established for Verizon Pennsylvania, LLC. Core points out that the Commission approved such TELRIC methodology in Generic Investigation Re Verizon Pennsylvania Inc.’s Unbundled Network Element Rates, Docket No. R-00016683, (Order entered July 16, 2004) (July 2004 Verizon Order). In the alternative, Core asserts that the
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