Investigations on the intersection of music and architecture: the ...

Tevert

Description

• expression écrite - matière potentielle : by iannis xenakis
• expression écrite - matière potentielle : preface
• exposé - matière potentielle : about three things
• cours - matière potentielle : ar3a151
• fiche de synthèse - matière potentielle : the sources

Investigations on the intersection of music and architecture: the sources and works of Iannis Xenakis Ar3A151 History of Architecture student: Arjan de Nooijer teacher: Dr. C. Wagenaar january 2009

• result of xenakis
• xenakis
• iannis xenakis
• works of iannis xenakis ar3a151
• wherein post-xenakis composers
• space for medieval infl uences
• architectural press
• architecture
• hypothesis
• music

Sujets

• Préface
• Valéry
• 10968 Sterken

Informations

• Publié par: erre
• Nombre de lectures: 34
• Langue: English

Extrait

Before the
Federal Communications Commission
Washington, D.C. 20554


In the Matter of )
)
Connect America Fund ) WC Docket No. 10-90
)
A National Broadband Plan for Our ) GN Docket No. 09-51
Future )
)
Establishing Just and Reasonable Rates ) WC Docket No. 07-135
for Local Exchange Carriers )
)
High-Cost Universal Service Support ) WC Docket No. 05-337
)
Developing an Unified Intercarrier ) CC Docket No. 01-92
Compensation Regime )
)
Federal-State Joint Board on Universal ) CC Docket No. 96-45
Service )
)
Lifeline and Link-Up ) WC Docket No. 03-109
)
Universal Service Reform – Mobility ) WT Docket No. 10-208
Fund )


PETITION FOR RECONSIDERATION AND CLARIFICATION

of the

NATIONAL EXCHANGE CARRIER ASSOCIATION, Inc.;
ORGANIZATION FOR THE PROMOTION AND ADVANCEMENT OF SMALL
TELECOMMUNICATIONS COMPANIES; and
WESTERN TELECOMMUNICATIONS ALLIANCE




December 29, 2011TABLE OF CONTENTS

I. THE COMMISSION SHOULD ADOPT A SUFFICIENT AND PREDICTABLE
CONNECT AMERICA FUND MECHANISM BEFORE IMPOSING BROADBAND-
RELATED PUBLIC INTEREST OBLIGATIONS ON RATE-OF-RETURN
CARRIERS. ............................................................................................................................. 2
II. THE SUPPORT CUTS AND COST RECOVERY LIMITATIONS IN THE ORDER
MUST BE RECONSIDERED OR CLARIFIED SO AS TO AVOID CONFLICTS
WITH THE PUBLIC INTEREST OBLIGATIONS IMPOSED BY THE ORDER,
THE GOALS OF THE REFORMS, AND THE NEW UNIVERSAL SERVICE
PRINCIPLE ADOPTED BY THE COMMISSION. ........................................................... 6
A. The Commission Should Reconsider the Sufficiency of its Budget for High-Cost
Universal Service. .............................................................................................................. 6
B. The Commission Should Reconsider Several Aspects of its Caps on Capital and
Operating Expenses .......................................................................................................... 9
C. The Commission Should Reconsider Or Modify Several Of The Other Capping
Mechanisms Adopted In The Order. ............................................................................ 13
1. The Commission Should Determine Reasonably Comparable Rates on the
Basis of Standard Deviations, Rather than Arithmetic Average. .......................... 13
2. The Commission Should Reconsider Several Aspects of its Decision with
Respect to the Elimination of Safety Net Additive Support. .................................. 14
3. The Order’s Adoption of a Per-Line Cap on High-Cost Support Imposes
Substantial Damage on Small Companies with Little Aggregate Public
Interest Benefit. .......................................................................................................... 16
4. The Commission Should Not Begin Phasing Out Support in Areas with
Competitive Overlap Without Addressing Ongoing RLEC Obligations as
COLRs and ILECs. .................................................................................................... 18
III. THE ORDER ESTABLISHES UNREASONABLY STRINGENT STANDARDS
FOR OBTAINING WAIVERS OF THE SUPPORT REDUCTION RULES AND
FOR REQUESTING ADDITIONAL CAF ICC SUPPORT. ........................................... 19
IV. NEW RULES IMPOSING ANNUAL REPORTING REQUIREMENTS ON
RLECs ARE UNDULY BURDENSOME AND SHOULD BE SUBSTANTIALLY
REVISED. .............................................................................................................................. 22
V. THE COMMISSION MUST ESTABLISH CLEAR RULES GOVERNING THE
RATE OF RETURN REPRESCRIPTION PROCESS BEFORE INITIATING A
REPRESCRIPTION HEARING. ........................................................................................ 26
A. The FCC Must First Adopt New Substantive Rules Governing the Represcription
Process Before It Takes Evidence to Determine a Reasonable Rate-of-Return. ....... 26
B. The Abbreviated Informal Notice and Comment Procedures Described in the
FNPRM Will Not Satisfy Section 205(a)’s “Hearing” Requirement.......................... 27

VI. RECONSIDERATION AND/OR CLARIFICATION IS REQUIRED REGARDING
THE APPLICATION OF NEW INTERCARRIER COMPENSATION RULES
ADOPTED IN THE ORDER. .............................................................................................. 29
A. The Commission Must Provide a Reasonable Opportunity for Rate-of-Return
Carriers to Recover Interstate Costs Allocated to Switched Access Rate
Elements. .......................................................................................................................... 29
B. Mechanics of CAF ICC Support Calculations. ............................................................ 31
1. Rate-of-Return Baseline Interstate Revenue Requirements Should Be Based
on Actual Cost Studies Rather than Tariff Forecasts. ............................................ 31
2. Inclusion of Tandem/Transit Costs in Reciprocal Compensation Calculations. .. 33
C. Identification of “Toll” VoIP Traffic. ........................................................................... 33
D. Call Signaling Rules for VoIP Traffic. .......................................................................... 35
E. Application of Access Charges to IntraMTA Traffic Delivered by IXCs.................. 36
F. Phantom Traffic Issues. .................................................................................................. 37
VII. CONCLUSION ..................................................................................................................... 40




Summary
The Rural Associations listed above seek reconsideration and/or clarification of several
aspects of the Commission’s Order in the above-captioned proceeding.
RLECs are thoroughly committed to expanding broadband services to their customers.
However, any obligation to provide such services should be established only after a broadband-
oriented Connect American Fund (CAF) mechanism that provides sufficient and predictable
support is adopted for these carriers. The Associations accordingly first request the Commission
reconsider its decision to impose new, unfunded public interest obligations on rural rate-of-return
regulated local exchange carriers (RLECs) until such time that a new, sufficient CAF mechanism
is in place.
Second, the Associations seek reconsideration of the Commission’s imposition of various
new cost recovery caps and limitations on RLECs. In particular, the Commission should
reconsider the sufficiency of its overall high-cost support budget for RLEC areas and allow for
potential expansion of available funds to meet actual broadband needs. The Commission should
also reconsider its premature decision to adopt regression-based caps on recovery of capital and
operating expenses.
Several other aspects of the Order’s approach to cost recovery limitations should be
reconsidered as well. Specifically, the Commission should reconsider its decision to set an end-
user rate floor at the national average of such rates. By definition, an “average” rate cannot be
considered an “artificially low” rate. The Commission should also reconsider several aspects of
its decisions regarding phase-out or elimination of the safety net additive (SNA) support
mechanism. Additionally, the Commission should reconsider its decision to impose a per-line
cap on RLECs’ overall legacy high-cost support, as this will not accomplish any significant
i
savings for the universal service fund (USF), yet will have devastating effects on a small number
of RLECs and their customers.
Third, the Commission should abandon its unreasonably stringent approach to
considering waivers of rules governing USF disbursements and additional funding for access
replacement support. The waiver processes described in the Order will impose substantial
burdens on small companies, and appear designed primarily to discourage companies from
seeking relief. The Commission should instead continue to rely on the “good cause” standard
specified in section 1.3 of its rules, and provide a concrete and realistic path to obtaining such
waivers where needed to meet the objectives of universal service.
Fourth, the Commission should substantially revise the annual reporting requirements
imposed on RLECs by the Order. The Commission should instead continue to rely primarily on
existing monitoring mechanisms, including those established in cooperation with state
commissions under section 254 of the Act. The Commission should also refrain from requiring
RLECs to submit audit reports by April 1 of each year, as compliance with this rule may be
nearly impossible for most small companies. The burdensome performance reports required
under new section 54.313 should also be reconsidered, as regulatory requirements will require
RLECs to divert precious resources from providing service to customers to filling out reports.
Fifth, the Commission should reconsider its approach to represcribing the interstate rate
of return. The abbreviated notice-and-comment process adopted in the Order will not satisfy the
hearing requirement of section 205(a) of the Act. The Com