Access Rate ReductionThe New York Public Service Commission has ordered, in Case 09-M-0527, a reduction to intrastate originating access charges to bring them to the level of interstate originating access charges in two steps. By November 30, 2014, all LECs had to file tariffs reducing their intrastate originating access rates by 50% of the differential between those rates and the carrier’s interstate rates for comparable service in effect on January 1, 2015. The tariff changes must be effective January 1, 2015. (The second and final tariff filing is due by November 30, 2015. LECs must file tariffs to bring intrastate originating switched end office and transport rates to parity with the interstate access rates that will be in effect on January 1, 2016.)

In our discussions with NY Staff it was clear that they were allowing, and anticipating, allrate elements to be moved half-way to the interstate levels – even in the few cases where the interstate elements were higher than intrastate.

The compliance filing Verizon submitted to the NY PSC, however, Verizon chose to make no hit the one in the middleincreases, so Tandem Switching and CTP (night/weekend) – which were already lower than the interstate equivalents – were unchanged and other rate elements were reduced.  Oddly, though, Verizon’s posting of the filing on its website took these two rate elements all the way upto current interstate levels rather than just halfway!  The filing with the large rate increases was apparently posted by Verizon in error.

The complication is that an old NY PSC Order in Case 94-C-0095 caps CLEC access rates at the level of the largest carrier in the LATA (or make a showing that such rates are cost-based and in the public interest). Even though NY Staff feels that CLEC “meet in the middle” filings are compliant with the recent Order, Verizon’s decision to leave the Tandem Switching and CTP (night/weekend) rates unchanged imposes that decision on CLECs as well.

Consequently, CLECs have to re-evaluate their recent NY access filings in light of Verizon’s filing. They may be compliant with the Order in 09-M-0527 — but not the Order in Case 94-C-0095.


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