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Docket No. 19129




32 F.C.C.2d 691




December 23, 1971 Released


Adopted December 21, 1971




 [*691] 1.  By our Order herein of January 21, 1971, 25 F.C.C. 2d 151, we directed that the issues involved in these proceedings be heard and determined in two phases.  In Phase I, we were to address the issue of the fair rate of return that should be allowed the Bell System companies on their interstate and foreign communications services.  The issues involved in Phase II call for an examination of those matters that could affect the revenue requirements of the Bell System, including the reasonableness of Western Electric's prices and profits, and the amounts claimed by the carriers for investment and operating expenses.  The Phase II issues also contemplated examination of the internal rate structure of the interstate and foreign message toll telephone service.  In addition, the Commission announced that it would retain jurisdiction of the proceedings herein until it has reached a determination in Docket No. 19143, In the Matter of the Petitions Filed by the Equal Employment Opportunity Commission, concerning the effect, if any, of alleged discriminatory practices of the Bell System companies on their revenue requirements.

2.  Related to the rate of return issue in Phase I herein are the proceedings in Docket No. 18128, in which consideration is being given to the principles that should govern the assignment of the Bell System's revenue requirements among its principal classes of interstate and foreign services.  Thus our Order of January 21, 1971, provided that the implementation of our findings in Phase I with respect to rate of return will be subject to the determinations to be made in Docket No. 18128 insofar as they relate to the assignment of any revenue requirements to interstate and foreign message toll telephone service.  The accounting and refund requirements of our Order of January 20, 1971, herein, will of course continue to operate until such implementing actions have been taken.

3.  Pursuant to our Order of January 21, 1971, the Hearing Examiner has submitted his Initial Decision on the over-all rate of return issue (Phase I).  Our Order stated that:

 [*692]  "After the parties have concluded their participation in the rate of return phase, they may address themselves to the remaining issues and every effort should be made to expedite that phase of this proceeding, although we do not, at this time, impose any time limitations on the conduct of that aspect of the matter." (paragraph 13a)

4.  With the submission of the Initial Decision, the immediate question is presented with respect to the further proceedings required to treat the issues involved in Phase II.  The question arises because we do not have sufficient resources to permit adequate staffing of the hearings that would be involved or to complete the preparatory staff work required for developing a meaningful evidentiary record on these issues.  This is the result of the continuing growth in the volume and complexity of regulatory problems within the common carrier field.  We need only mention as examples in this connection such matters as the many pending applications which have been filed with us for authorization for the establishment of competitive services and facilities in the field of intercity specialized common carrier communications; our pending proceeding looking toward the formulation of policy to guide our development of domestic satellite systems; further implementation of the Carterfone policy by expanding the interconnection options to communications users in the beneficial use of the existing common carrier networks; the initial determination of policies to govern ratemaking applicable to international services of the Communications Satellite Corporation; and the determination of rate making principles applicable to the rate levels and structures for the various classifications of domestic communications (Docket No. 18128).  This increased workload is, of course, aggravated by budgetary and staffing limitations and turnover over which we have no control.

5.  Under these circumstances, we find it necessary to revise our program priorities and to defer action on the Phase II issues until we are in a position to go forward with the proceedings in a meaningful manner.  Without minimizing the importance to the consumers of communications services of the issues involved in Phase II and the recognized need to seek their resolution as soon as we are able to do so, we believe it will make for a more orderly procedure to dismiss the proceedings with respect to Phase II issues, rather than simply deferring.  We will reinstitute further proceedings on the issues involved as and when we are in a position to treat them with the required effectiveness.

6.  IT IS ORDERED, That the proceedings are dismissed herein insofar as the issues in Phase II are concerned and jurisdiction is retained with respect to the aforementioned matters involved in and related to the issues involved in Phase I as discussed above.








I have joined in the action taken by the majority in this case although I deeply regret the underlying reasons that make this action necessary.

The Commission's action is a frank admission that we do not have the minimum capabilities to carry out our most fundamental statutory  [*693]  responsibilities to protect the interests of the public in fair and reasonable interstate rates.  It is also a forceful dramatization of the unrealistic and penurious budget and fiscal policies that have shackled the Commission's regulatory efforts in the past decade in the common carrier field.

The issues involved in Phase II, which we are dismissing, are addressed to the reasonableness of the billions of dollars of costs upon which the rates of the Bell System are based.  They also address the soundness of the rate structure for interstate telephone services.  In other words, these issues are dealing with the most basic matters of regulatory concern.

The common carrier industry has been growing at a faster pace than any other sector of our economy.  Public expenditures for common carrier services subject to Federal regulation exceed $6.5 billion a year and have been growing by more than 10% annually in the past decade.  In 1961 the plant of the telephone system in the United States represented an investment of some $32 billion.  Today that plant investment has more than doubled where it now exceeds some $76 billion and it, too, is growing at about an annual rate of 10%.

Advances in communications and related technologies, such as the electronic computer and communications satellites, have not only revolutionized the methods by which conventional communications services are supplied, but they have also generated consumer demands for new, expanded and improved services of all kinds.  This dynamic growth and have been growing by more than 10% annually in the past decade. faced by the country such as those examples cited in the Commission's majority opinion.

I think it is clear that there must be a change in the fundamental approach of Congress to the funding of the Commission's regulatory responsibilities.  n1 First, it is imperative that the Commission's resources be sufficiently and systematically augmented to a level which permits an on-going regulatory program to deal with issues, such as those involved in Phase 2, on a continuing basis.  Second, with respect to a matter as complex and far-reaching as Western Electric's relationship to the Bell System and the effects of that relationship on the cost of telephone service, it is my opinion that an investigation of this matter should be undertaken by the Congress itself or by a special task force functioning under the aegis of the Commission and financed through a separate appropriation.  Any such investigation should also examine the effects of vertical integration of telephone operations and manufacturing.  This industry structure no longer applies solely to the Bell System.  In recent years, it has also become a basic characteristic of the independent segment of the telephone industry as a result of mergers and consolidations of independent telephone operations within corporate systems which include manufacturing and marketing affiliates. 


n1 From my address, "Let's Abolish the FCC," (page 6), Illinois Broadcasters Association, May 23, 1968: "I believe there would be a more responsible administration of the differing functions now administered by the FCC if they were the responsibilities of separate agencies.  I think they would each fare better in their appeals for manpower and money; they would each be able to concentrate more and become more expertise in their more specialized filed; the members could give greater guidance to their staffs on policy planning and in supervision."


I dissent to these two actions by the majority but I admire my colleagues' candor.

The FCC has concluded that examination of the appropriateness of Bell's costs, the role of Western Electric, vertical integration in the telephone industry, and the internal rate structure of the long distance telephone schedule are matters of low priority given the Commission's present resources and activities.  The promises made in 1965, and reaffirmed in 1971, that these were matters that should be investigated are not to be fulfilled.  Rather than continuing the six-year-old charade of "deferring" proceedings the Commission does not plan to activate anyway, however, the majority now simply dismisses them.

I dissent on both management and substantive grounds.

On substantive grounds I believe these matters are of a higher priority than do my colleagues.  We have spent significant resources on determining the appropriate rate of return for the Bell System.  We have spent very little time in examining the appropriateness of the costs which the Bell System incurs and deducts from revenues before the Commission ever gets to the question of rate of return.  (See my opinion concurring to the designation for hearing of the present rate increase, Docket 19129, AT&T 27 F.C.C. 2d 151, 165 (1971).) Questions concerning the level of maintenance expenses, levels of managerial expenses, the appropriate treatment of accelerated depreciation and many others -- issues raised in prior proceedings -- will now not be examined.

The American people paid the Bell System companies over $17 billion last year.  The prices they paid were not determined by forces of free private enterprise operating in a competitive market -- in part because Bell has fought the possibility of marketplace competition at every turn.  Telephone rates are initially set by a monopolistic company at whatever level it wishes.  The reason the Federal Communications Commission and the state regulatory commissions are responsible for reviewing and approving those prices is because the public is otherwise left with no protection whatsoever.  For the FCC to say it does not have the "resources" to do this job -- a job which, of course, the Bell System hopes it won't do -- is like your bank telling you it doesn't have the resources to prevent other people withdrawing money from your checking account.

If an unemployed inner city resident breaks into a coin phone box and takes $3.20 to feed his family he is considered an outcast, his earning potential is cut off entirely, and he is sent to the jailhouse.  But if a wealthy telephone company executive succeeds in "breaking into" 100 million private telephones, taking $3.20 from each subscriber by manipulating the law, he is hailed as a pillar of the business community, his stock goes up, and he's invited to the White House.  I think it's about time that "law and order" -- not to mention wage-price control -- be applied to rich and poor alike.

There is considerable question whether a handful of professionals in an agency like the FCC can ever "regulate" the rates of a company with $40 billion in assets and a $17 billion gross.  But putting  [*695]  aside for a moment that well-founded skepticism, let's take a look at how those rates are set.

"Rate of return" -- the part of the proceeding to which the FCC is willing to turn its attention -- involves perhaps the least significant aspect of the public's monthly telephone bill.

There are at least four factors that go into fixing a phone bill.

(1) Expenses.  All the bills together will have to generate at least enough income to pay for the phone company's expenses of operation.

(2) Capital investment.  The company is entitled to some return on its "investment" -- the value of the lines, and poles, and telephones, and other equipment that goes into running a telephone company.  That investment, known as "rate base," has to be computed.

(3) Rate of return.  Once the amount of the rate base has been ascertained, the regulatory agency in question then has to address the question of "rate of return" -- what percentage return is the company entitled to have on that investment.  This is the aspect of utility rate hearings that often attracts the most public and media attention.

(4) Pricing.  Decisions must be made about rates for individual services within the guidelines determined for expenses, rate base, and rate of return.  How is the revenue to be generated?  Will the homeowner pay more for his service while the businessman pays the same -- in the way that postal increases tend to be lowest for junk mail and highest for first class?  It's little consolation to know the phone company's rate of return went from 8% to 9% (a 12 1/2% increase), if your own bill went up 20%.

Obviously, however high the phone company's profits may be, they do not represent a very large percentage of the average subscriber's telephone bill.  Most of that bill goes to pay expenses.  Are the expenses reasonable and fair?  The FCC doesn't know.  And, as of today, it makes clear it has no intention of finding out.  It's as if an employee would say to his boss, "I'll negotiate with you about my salary -- but of course I won't let you look at my unlimited expense account."

As for the portion of the bill that is profit, it is obviously as much affected by the size of the "rate base" as it is by the "rate of return." Let's look at an example.

Suppose the company's capital investment is considered to be $50 billion.  A 10% rate of return means $5 billion profit a year.  An 8% rate of return means a $4 billion profit a year -- a $1 billion difference.

But consider for a moment that the capital investment may be inflated -- or represent arbitrary decisions.  Suppose what would cost $50 billion to replace today only cost $30 billion when it was built and could only be sold for $20 billion if it had to be sold in its present condition.  What's the rate base?  Keeping the rate of return the same -- at the higher 10% figure -- the profit fluctuates from $5 billion to $2 billion, a $3 billion difference.

One example.  During the rate of return hearing it came out that Bell regularly puts in its rate base a cost -- which, of course, it computes internally within the company -- for turning on the telephone in an apartment when a new occupant moves in.  The value of the telephone (which Bell has bought from itself at whatever price it chooses) is, of course, also placed in the rate base.  There is no telling how many new telephones are turned on each year.  It is, obviously,  [*696]  far more than there are new telephone instruments manufactured and installed.  Whatever may be the most appropriate way of determining the cost to the company of turning on those telephones, it seems to me there is considerable question as to the propriety of treating that cost as a "capital" item on which the company will be permitted to earn a "rate of return" for years and years until entirely depreciated.  I could go on with the examples, but I trust this makes the point: to regulate telephone rates responsibly one simply must know the contents, and formulae used, in the rate base.  To "regulate" a rate of return without examining what's in the rate base is like agreeing to pay a merchant an 18% carrying charge on your unpaid balance, while leaving to him the discretion of "defining" unpaid balance to be the maximum amount you are ever permitted to charge, or any other level he chooses.

These issues need not be made sophisticated and obtuse.  They are simple and fundamental.

The FCC has not been regulating the Bell System as the law and common sense requires it to do.  It has been granting Bell's requested rate increases while procrastinating on the job of examining its costs and rate base.  I am as tired of the hypocrisy as my colleagues.  I commend them for their candor in abandoning publicly a task that has not, in fact, been tended to anyway.  Our difference lies in the fact that I would establish a management system to permit us to evaluate priorities, and then -- probably -- accord this crucial, first responsibility of the FCC more resources than they have.

Vertical integration also presents several important questions.  If the Bell System is correct, and Western Electric is the cheapest supplier of communications equipment, why shouldn't non-Bell companies buy from the lowest cost source?  The 1956 Consent Decree prohibiting such sales by Western Electric should be examined in light of developments in the past 15 years.  Alternatively, how does vertical integration affect the pace of technological innovation, and also the emergence of non-telephone common carriers who want to sell communications equipment?  Our Trial Staff urged in the rate of return proceeding that the rate of return for Western Electric is relevant to any determination of a rate of return for the Bell System overall.  The counterargument is that this is a question for a subsequent phase -- which is now dismissed.

In short, it borders on the irresponsible for the regulatory agency concerned with interstate telephone communications to ignore these questions.  The 1965 AT&T Investigation was thought important because no such investigation had been held in 30 years on the Bell System.  I do not see that six years have made the issues any less urgent.

I must admit that it is difficult to be confident about what the priorities of the FCC should be.  I am a little surprised that my colleagues can be so sure.  This agency has never attempted to determine what the totality of agency programs and projects are, what resources -- personnel, contractual studies, and consultant help -- are required to meet the program needs, what the outputs and goals of the various programs and projects are, what alternatives there are to doing the present programs and projects, and finally, what difference it makes  [*697]  to assign alternative priorities, in terms of the goals of the agency.  We do not now have this information for the agency as a whole, nor for the common carrier activity in particular.  No one questions that this agency cannot do all it would like with every project it might undertake.  My objection is that the decisions on what to do are not made rationally and systematically.  It has not been done in the budgetary process, it has not been done in managerial control of agency activity, and it is not being done here.

Continuation of Phase II -- whether in Docket No. 16258 or Docket No. 19129 -- has always been a step-child here.  Whenever the question of initiation of proceedings has been raised, it has met with significant resistance.  The Commissioners have not made a sophisticated presentation to the Office of Management and Budget or the Congress on this issue, describing with any particularity the resources required to do the job adequately, and the possible multi-billion-dollar benefits that could flow in terms of this Commission's responsibilities to the consuming public, the American business community in general, and the communications industry in particular.  We have not attempted to push vigorously a supplemental appropriation request that would focus on these matters.  It is wrong to blame, by implication, the Office of Management and Budget or the Congress by saying we don't have the resources, and they should have been provided to us.  Neither Congress nor OMB has ever been given the choice of giving us the resources we think we need, or watching these crucial proceedings be terminated.  We have no one to blame but ourselves.

I dissent.






I must dissent to the majority's action in dismissing further proceedings in Docket No. 16258 and in Phase II of Docket No. 19129.  While I am most sympathetic with the majority's position, especially in light of the current budgetary and staffing limitations (including restrictions imposed by the Office of Management and Budget), I cannot agree with the timing of the action taken.

The Commission intended these proceedings to serve as the vehicle for a thorough examination of the revenue requirements of the Bell System, including the reasonableness of Western Electric's prices and profits, and of the basis upon which such revenue requirements are  [*700]  to be determined.  The Phase II inquiry also contemplated an examination of the internal rate structure of the interstate and foreign message toll telephone service.  The majority's action in dismissing these highly important inquiries is based on the painful fact that the Commission does not now possess sufficient resources to ensure the development of meaningful records in these proceedings or even to staff the hearings that must be held.

The inquiries previously ordered by the Commission into the rate structure of the Bell System, including the amounts claimed by the carriers for investment and operating expenses and the relationship between the associated telephone companies and their equipment supplier, are much too important to the consumers of interstate and foreign communications services to permit a termination of these proceedings.  Moreover, our decision in the Phase I inquiry as to the appropriate rate of return for AT&T is closely interwoven with an existing rate structure that must be examined if we are to fulfill our regulatory responsibilities.

With the given restraints imposed upon this agency in the form of budgetary and average grade reductions and the current staff turnover in the Common Carrier Bureau, it seems unlikely that these proceedings will be reactivated in the near future.  Rather than be faced with such a prospect, I would have preferred to keep the proceedings alive by seeking from the OMB a specific exemption from the existing budgetary and average grade restrictions to the extent necessary to accomplish this task.  I believe it pertinent to point out that the Congress in the last session appropriated all the monies requested by the FCC that were cleared by the OMB.  This appropriation included funds for additional staff for the Common Carrier Bureau.  While this additional personnel may not have been adequate for the total tasks contemplated in this proceeding, it would have been enough to keep this proceeding alive until the next fiscal year.  I would then have presented to the OMB an adequate program for the 1973 fiscal year budget.

Quite simply, before taking such a drastic step as the majority is doing today, I believe that the Commission should have notified the Congress that without additional resources the Bell System, as well as other important utilities, will be entering into a period of effective deregulation in significant areas.  If after presentation to the OMB and the Congress, it is decided to follow this line of deregulation, I would certainly consider the majority's action to be appropriate.  But not until that time.



Now that the Commission has decided to designate this case for hearing, I want to indicate the issues I believe must be explored before the Commission can make a determination on this massive rate increase for the Bell System.  It is clear what the Bell System wants the Commission to do.  It would prefer a quick rate of return hearing where rate of return is the only issue.  It wants questions of costs, rate base questions, and questions of pricing allocation to be deferred to the hopefully distant future.  I believe we simply must not fall into this trap again.  In 1965 the Commission promised to explore costs, pricing policies, and rate base-Western Electric relationships in a full rate investigation.  On those particular issues the passage of six years has shown no real results.  When questions of quick rate decreases are at stake for the consumer, an argument can be made that ignoring time-consuming issues may delay deserved rate decreases, and the Commission should move ahead quickly.  But now that there are price increases to be paid by consumers, at a time when the highest national priority should be directed to reducing inflationary price increases, the Commission can no longer ignore important rate issues.  I yield to no one in my encouragement of expedition in expedition at the expense of thoroughness when hundreds of millions of dollars of the public's money are at stake.

The Commission has expressed a hoped-for time schedule.  I would expect that our staff would immediately tell us if its resources are inadequate to do a thorough job, and that it would then be up to the Commission to secure those resources if our staff lacks them.  The Commission has indicated in its January 12 letter to Bell the issues it particularly wishes to explore in the upcoming hearing -- issues on allocations of revenue requirements among Bell's services, and a speedy resolution of the issues in Dkt.  No. 18128 where those questions are already being litigated.  Other issues the Commission pointed to in its letter include Bell's estimate of the elasticity of the MTT service (message toll telephone, the "long distance" per-call pricing system), and its predictions on the increases in costs, particularly in maintenance expenses.  Naturally these are all issues the Commission must explore in the forthcoming hearing.

But there are other Bell costs which the Commission should evaluate before deciding that Bell can tax its subscribers an additional half billion dollars every year.  These should include Bell's advertising expenses, particularly expenses for institutional advertising and for service stimulation at times when Bell was already having problems meeting service demands.  Another category which should be examined is that of managerial expenses, and the possibility that the cost-plus contract of regulation has induced padding in this area.  And fundamental to any determinations about cost of capital, rate of return, and financing policies are evaluations of growth policies -- particularly in areas which might be considered peripheral to the provision of a basic telephone service.  The specter of other utilities, such as railroads like the Penn-Central, concentrating on expansion in exotic areas to the detriment of basic consumer services, should be explored in any expansion program as massive as that of the Bell System.

In my judgment, public utility regulation generally tends to be perceived by public, companies and commissions alike in a way that over-emphasizes profit ("rate of return") and under-emphasizes costs (and capital investment, or "rate base").  Bell earns a rate of return on its "rate base" (depreciated capital investment).  Subscribers' monthly bills are computed at levels sufficient to guarantee the company the recovery of all of its costs of operation plus a profit ("rate of return").  Of the total amount paid by the subscribers, something on the order of 80% represents costs rather than profits.

Assume the following ballpark figures for purposes of ease of illustration:

Rate base: $40 billion

Rate of return: 7%

Annual costs of operation: $10 billion

Subscribers would then have to pay telephone bills sufficient to raise $10 billion costs plus $2.8 billion profit (7% of a $40 million rate base as a rate of return) or $12.8 billion.

Now assume the rate of return is increased 10%, from $2.8 billion to about $3 billion, and costs remain constant.  The total subscriber burden increases from $12.8 billion to $13 billion.

If, on the other hand, costs increase by 10%, from $10 billion to $11 billion (while the rate of return remains constant), the subscribers' burden goes from $12.8 billion to $13.8 billion.

Moreover, even the amount of profit is affected as much by the amount of the rate base as by the "rate" of return.  A 7% rate of return on $40 billion is $2.8 billion of annual profit.  A 6% rate of return on $40 billion is $2.4 billion.  But a 7% rate of return on $30 billion is only $2.1 billion.

The only point of this discussion is that it is dangerously shortsighted for this Commission to be willing to accept the company's suggestion that it pass upon a half-billion-dollar annual increase by examining only the issue of rate of return while ignoring (or continuing to postpone for subsequent consideration -- which is the same thing) the 80% of the subscriber's burden represented by the company's unexamined multi-billion-dollar levels of costs, and the tens-of-billions-of-dollars of rate base to which the simple rate-of-return percentage would be applied.

The Equal Employment Opportunity Commission petition charging that Bell discriminates in its hiring practices is an issue the Commission cannot duck, no matter how strongly Bell cries "foul." EEOC's position is that no rate increases may be found by the Commission to be in the public interest while Bell discriminates in employment.  There is some concern by the Commission on the relevance of this issue to what is construed as the narrow issue of rate levels.  I do not now reach that question because I do not need to.  I would establish a separate proceeding, to be resolved concurrently with this one, to examine EEOC's charges.  EEOC should be permitted to file a brief subsequently, after the evidentiary proceeding, showing how its complaint is relevant to the Commission determination on the proposed rate increase.

It should also be noted that half of Bell's direct case in this proceeding, Bell statements 10 through 16, are directed toward justifying the present vertically integrated relationship with Western Electric.  This is another terribly important issue that the Commission promised it would explore in its 1965 rate investigation, but which it has never considered.  I do not believe the Commission can any longer shirk its duty in this area.  Vertical integration has increased in the domestic common carrier industry since 1965.  I believe the Commission must now open a new proceeding and undertake a full market study of vertical integration, particularly in this era of changing rates of technological innovation.  The Department of Justice has commented in another proceeding before the FCC:

The Bell System has traditionally relied on a captive equipment supplier, Western Electric, and has continued to rely extremely heavily on that supplier, thereby insuring that virtual nationwide monopoly in public message telephone service be repeated in the filed of telephonic equipment, whether or not there was any economic justification for such concentration at the manufacturing level.

DOJ Reply Comments in Dkt. No. 18920, p. 3.  [Emphasis supplied.] Under these circumstances, the question of vertical integration in the domestic common carrier industry is one the Commission simply must examine fully, particularly when the issues are related to the Bell half-billion-dollar rate increase.  Even Bell acknowledges the crucial importance of this relationship by devoting so much of its direct case to it.  A full market study of vertical integration should again proceed concurrently with the other proceedings related to the rate increases -- Dkt. No. 18128 on pricing; the EEOC proceeding; and the rate of return/cost justification proceeding.

For this Commission to do otherwise seems to me to leave it open to the charge that it acquiesces in Bell's setting the rules for Commission action, rather than the Commission setting the rules to protect the public.  In short, I believe the least the Commission can do on a rate increase of this magnitude is to conduct a proceeding no less thorough than some of those conducted by the state commissions -- for example, the California investigation in 1964 of Pacific Telephone.  Pacific Telephone & Telegraph Co., 55 P.U.R.3d 513 (1964), aff'd in major respects 62 Cal.2d 634, 58 P.U.R.3d 229 (1965).  I do not see how the Commission can maintain that it has done an adequate job of protecting the public without such an effort.  This is particularly so when it is apparently this Commission's destiny to preside over perhaps the largest proposed public utility rate increase in history.

Perhaps the Commission does not have the resources to undertake the job it should.  If true, then an estimate of the resources required should be made and a candid request for those resources made.  (And, of course, any "public interest" intervenors ought to be specially welcomed, rather than discouraged as has so often been the case in the past.) But I cannot believe that with a half-billion dollars at stake, the representatives of the public -- who must pay these prices -- will not give serious consideration to the Commission's needs.  And if statutory authority is thought to be lacking to protect the public and its own regulatory processes, I would expect the Commission to seek that authority with vigor.

It might be argued that pursuing these issues would risk "delays." I have heard these arguments, and I am not persuaded.  If an adequate hearing takes a little longer, the Commission has ample power to protect the interests of all parties, including Bell.  I would welcome a reasoned presentation as to why the Commission should not move in the manner I have suggested.  And I would especially like to hear any reason why an intervening six years have decreased the urgency of the issues the Commission should explore.

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