Please provide comments to the issue below as part of the 2012 WCB cost model virtual workshop for inclusion in the record. Comments are moderated for conformity to the workshop's guidelines.
Background
Hybrid Cost Proxy Model: The HCPM uses nationwide figures for plant mix based on the nine density zones laid out in Appendix A of the Inputs Order. It rejected the use of carrier-specific values and other alternatives that were available at the time.
| Distribution Plant Mix* | |||
| Density | Underground | Buried | Aerial |
| 0 | 0.00% | 60.00% | 40.00% |
| 5 | 1.00% | 62.00% | 37.00% |
| 100 | 2.00% | 68.00% | 30.00% |
| 200 | 4.00% | 66.00% | 30.00% |
| 650 | 8.00% | 62.00% | 30.00% |
| 850 | 20.00% | 50.00% | 30.00% |
| 2550 | 40.00% | 30.00% | 30.00% |
| 5000 | 60.00% | 10.00% | 30.00% |
| 10000 | 90.00% | 0.00% | 10.00% |
* The input values reflected in the chart are for illustrative purposes only
| Copper Feeder Plant Mix* | |||
| Density | Underground | Buried | Aerial |
| 0 | 5.00% | 50.00% | 45.00% |
| 5 | 5.00% | 50.00% | 45.00% |
| 100 | 5.00% | 50.00% | 45.00% |
| 200 | 20.00% | 40.00% | 40.00% |
| 650 | 40.00% | 30.00% | 30.00% |
| 850 | 60.00% | 25.00% | 15.00% |
| 2550 | 75.00% | 15.00% | 10.00% |
| 5000 | 90.00% | 5.00% | 5.00% |
| 10000 | 95.00% | 0.00% | 5.00% |
* The input values reflected in the chart are for illustrative purposes only
| Copper Feeder Plant Mix* | |||
| Density | Underground | Buried | Aerial |
| 0 | 5.00% | 50.00% | 45.00% |
| 5 | 5.00% | 50.00% | 45.00% |
| 100 | 5.00% | 50.00% | 45.00% |
| 200 | 20.00% | 40.00% | 40.00% |
| 650 | 40.00% | 30.00% | 30.00% |
| 850 | 60.00% | 25.00% | 15.00% |
| 2550 | 75.00% | 15.00% | 10.00% |
| 5000 | 90.00% | 5.00% | 5.00% |
| 10000 | 95.00% | 0.00% | 5.00% |
* The input values reflected in the chart are for illustrative purposes only
| Fiber Feeder Plant Mix* | |||
| Density | Underground | Buried | Aerial |
| 0 | 5.00% | 50.00% | 45.00% |
| 5 | 5.00% | 50.00% | 45.00% |
| 100 | 5.00% | 50.00% | 45.00% |
| 200 | 20.00% | 40.00% | 40.00% |
| 650 | 40.00% | 30.00% | 30.00% |
| 850 | 60.00% | 25.00% | 15.00% |
| 2550 | 75.00% | 15.00% | 10.00% |
| 5000 | 90.00% | 5.00% | 5.00% |
| 10000 | 95.00% | 0.00% | 5.00% |
* The input values reflected in the chart are for illustrative purposes only
CCQBAT: The CQBAT model, by contrast, has percent aerial, buried, and underground plant broken out by rural, suburban, and urban areas for the country overall, and for the 50 states, the District of Columbia, and Puerto Rico. The data has been supplied by CostQuest based on input from ABC Coalition companies. For illustrative purposes, here is a public sample of the plant mix inputs data being used by CQBAT for Alabama, Arkansas, and Arizona:
| CostFam>>* | Distribution | Feeder | Inter-Office | |||||||
| State | Density | Aerial | Buried | Underground | Aerial | Buried | Underground | Aerial | Buried | Underground |
| AL | Rural | 29.29% | 70.43% | 0.28% | 29.33% | 65.82% | 4.85% | 29.33% | 65.82% | 4.85% |
| AL | Suburban | 23.86% | 75.58% | 0.56% | 24.09% | 63.63% | 12.28% | 24.09% | 63.63% | 12.28% |
| AL | Urban | 31.87% | 65.90% | 2.23% | 20.74% | 47.85% | 31.41% | 20.74% | 47.85% | 31.41% |
| AR | Rural | 14.00% | 85.40% | 0.61% | 4.74% | 88.94% | 6.32% | 4.74% | 88.94% | 6.32% |
| AR | Suburban | 18.60% | 80.78% | 0.62% | 12.98% | 77.85% | 9.17% | 12.98% | 77.85% | 9.17% |
| AR | Urban | 23.55% | 74.81% | 1.63% | 14.13% | 64.81% | 21.07% | 14.13% | 64.81% | 21.07% |
| AZ | Rural | 27.10% | 69.17% | 3.73% | 25.35% | 60.66% | 13.99% | 27.57% | 58.49% | 13.94% |
| AZ | Suburban | 30.37% | 64.01% | 5.62% | 23.74% | 48.57% | 27.70% | 24.00% | 47.65% | 28.34% |
| AZ | Urban | 38.11% | 54.60% | 7.30% | 19.45% | 40.24% | 40.31% | 19.51% | 39.96% | 40.52% |
* The input values reflected in the chart are for illustrative purposes only.
Model Design Public Notice: The Bureau proposed to use provider-submitted plant mix data. Noting that variations in the costs to build plant have "a significant impact on the model," the American Cable Association argues that carriers should be required to document their plant mix. The National Association of State Utility Consumer Advocates (NASUCA) also agrees, suggesting that "state commission[s] could verify a stratified sample of the information." NASUCA urges the Commission to similarly de-average the expense calculation, claiming that "if the Commission retains national average expenses using carrier specific plant mix [this approach] could bias the resulting estimates."
Questions for Comment
- Is there any reason to deviate from the input values the CQBAT model uses for plant mix?
- Is CQBAT's use of national defaults for plant mix in some areas where there is no existing carrier-specific data reasonable? Is there any feasible means to fill in such data in the near term?
- Does the use of national defaults in some areas introduce any systemic bias (upwards or downwards) that would result in support amounts that are materially inaccurate for any particular states (and the providers who operate in them)? Are there ways to address any such problem in the near term?
Sources
- Federal-State Joint Board on Universal Service, Forward-Looking Mechanism for High Cost Support for Non-Rural LECs, CC Docket Nos. 96-45, 97-160, Tenth Report and Order, 14 FCC Rcd 20156, 20257, para. 233 (1999) (Inputs Order).
- Federal-State Joint Board on Universal Service, Forward-Looking Mechanism for High Cost Support for Non-Rural LECs, CC Docket Nos. 96-45, 97-160, Tenth Report and Order, 14 FCC Rcd 20156, App. A (1999) (via f99304a1.xls) (Inputs Order Appendix A).
- Wireline Competition Bureau Seeks Comment on Model Design and Data Inputs for Phase II of the Connect America Fund, WC Docket Nos. 10-90, 05-337, Public Notice, 27 FCC Rcd 6147, 6173-74, paras. 94-97 (Wireline Comp. Bur. rel. June 8, 2012) (Model Design Public Notice).
- Comments on Public Notice DA 12-911: Model Design and Data Inputs for Phase II of the Connect America Fund, WC Docket Nos. 10-90, 05-337, at 24-25 (filed July 9, 2012) (Comments of the ACA).
- Comments of the National Association of State Utility Consumer Advocates on Model Design and Data Inputs for Phase II of the Connect America Fund, WC Docket Nos. 10-90, 05-337, at 24-25 (filed July 9, 2012) (Comments of NASUCA).
Not seeing comment form in IE 8? Turn off IE compatibility mode to see comments.