The next step for implementation of access reform will be to further reduce terminating end office switched access rates in the preordained downward glide-path to the rate of $0.0007 per minute. As with last year’s reductions, the ILECs will calculate a new target composite terminating end office rates. The ILECs will then file their reductions to become effective on July 1, 2015 and CLECs will be capped at the new ILECs rates. The terminating end office composite encompasses the following rate elements, where applicable:
- Local Switching
- Common and Dedicated End Office Trunk Ports
- Information Surcharge
- Transport Interconnection
Last year the ILECs started with this new composite, and computed the amount of reduction required to bring the rate down by 1/3 of the difference between that composite rate and $0.0007. (See TMI's Blog "Further Switched Access Reductions Effective July 1, 2014" dated 4/1/14). Some reached the target rate by reducing individual rate elements, others created a single composite rate element to replace the original rate element set. This year the ILECs will make further reductions to those resulting rates such that the resulting rates will be the equivalent of 2/3 of the difference between the computed composite and $0.0007. Tandem switching and transport rates are not included in this reduction.
The actual ILEC tariff revisions that become effective on July 1, 2015, must be filed by June 16th for those filing on 15 days’ notice; and June 24th for those filing on seven days’ notice (reductions only). Petitions to suspend or reject the tariff filings made on 15 days’ notice are due June 23, 2015. Petitions to suspend or reject tariff filings made on seven days’ notice are due June 26, 2015.
Since CLECs are benchmarked (effectively capped) at the ILEC rates in the territories in which they compete, they do not need to make these calculations. Within 15 days of the effective date of the ILEC reductions (by July 16, 2015) the CLECs must file interstate rate revisions so as not to exceed the ILECs’ rates. They can match each ILEC’s rates individually, or create a composite in those states in which they compete with multiple ILECs. The rates CLECs file at the interstate level will also need to be filed for intrastate terminating end office rates, unless their tariffs already point back to their filed interstate tariffs. For those CLECs who need a preview of the ILEC rate changes, TMI has estimated the further reductions using the same rate elements that the ILECs changed last year. The estimate is combined into a tool that also assists in identifying the lowest price cap LEC rates that are the required cap for carriers that trip the traffic stimulation triggers. Please contact Karen Ritter at 407-740-3021 if you want more information about this tool.