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NATIONAL ASSOCIATION OF STATE UTILITY CONSUMER ADVOCATES

RESOLUTION

Authorizing the National Association of State Utility Consumer Advocates to support a monthly recurring charge for the high frequency portion of the loop as utilized in the provision of digital subscriber line service through line sharing.

WHEREAS, The Telecommunications Act of 1996 requires that the services included in the definition of universal telephone service bear no more than a reasonable share of the joint and common costs of facilities used to provide those services;

WHEREAS, when digital subscriber line (DSL) service is provided through line sharing, a single telephone loop is utilized to provide voice telephone service on the low frequency portion of the loop and DSLon the high frequency portion of the loop and, therefore, the cost of the loop is joint and/or common to local exchange service and DSL service;

WHEREAS, telecommunications carriers providing DSL service, including incumbent local exchange carriers and competitive local exchange carriers, have tariffed digital subscriber line services at both the Federal Communications Commission and state commissions and many carriers are providing DSL service under federal tariff;

WHEREAS, the high frequency portion of the loop as utilized in DSL line sharing is deemed by the Federal Communications Commission to be an unbundled network element; and

WHEREAS, proceedings to adopt prices, terms and conditions pertaining to DSL line sharing have been, are being and will be conducted by the Federal Communications Commission and by state commissions;

THEREFORE, BE IT RESOLVED, that the National Association of State Utility Consumer Advocates (NASUCA) supports a reasonable allocation of loop costs to all services using the loop, including digital services, and opposes the allocation of zero loop costs to digital services provided over the loop;

THEREFORE, BE IT ALSO RESOLVED, that NASUCA may advocate before the Federal Communications Commission, and other appropriate forums, that the revenue accruing to incumbent local telephone companies from monthly recurring prices for the high frequency portion of the loop utilized in the provision of DSL line sharing should be attributed to the cost of the loop and that other rates and charges should be reduced to compensate for increased loop revenue from DSL line sharing; and

BE IT FINALLY RESOLVED, that the Executive Committee of NASUCA is authorized to take all steps consistent with this Resolution in order to secure its implementation.

APPROVED BY NASUCA: Submitted by:

Portland, Maine NASUCA Telecommications Committee
Place

June 7, 2000

National Association of State Utility Consumer Advocates
8380 Colesville Road, Suite 101, Silver Spring, MD  20910
Phone: (301) 589-6313 Fax: 589-6380
e-mail: nasuca@nasuca.org