FTC Staff Comment Before the Federal Communications Commission In the Matter of Expanded Interconnection with Local Telephone Company Facilities

us-ftc-advocacy-filings-1c20155f9d7aad369e630be25e598210FTC Staff Comment Before the Federal Communications Commission In the Matter of Expanded Interconnection with Local Telephone Company FacilitiesAdvocacy Filing

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COMMISS'ON 	AUTHORIZED
Before 	the
FEDERAL COMMUNICATIONS 	COMMISSION
Washington, 	D.C. 	20554
In 	the 	matter 	of
Expanded 	Interconnection with
Local 	Telephone Company 	Facilities
)
)
)
Amendment 	of 	Part 	36 	of 	the 	)
Commission's 	Rules 	and 	Establishment)
of a 	Joint 	Board 	)
CC 	Docket No. 	91-141
Transport
Phases 	I 	& II
CC 	Docket No. 	80-286
•
Comment 	of 	the 	staff 	of 	the
Bureau 	of 	Economics. 	. 	.of 	the 	Federal 	Trade 	Comm1SS10n
March 	5, 	1993
This 	comment 	represents 	the 	views 	of 	the 	staff 	of 	the
Bureau 	of Economics 	of 	the 	Federal 	Trade 	Commission. 	They 	are 	not
necessarily 	the 	views 	of 	the 	Commission 	or 	any 	individual
Commissioner. 	Inquires 	regarding 	this 	comment 	should 	be 	directed
to Richard Shin 	(202-326-3495) 	or Michael R. 	Ward 	(202-326-2096) 	of
the 	FTC's 	Bureau 	of 	Economics.
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I.
II.
IL
Introduction 	and 	Summary
Expertise 	of 	the 	Federal 	Trade 	Commission
Background 	.
· 	. 	. 	1
. 	6
• 	• 	• 	7
IV. 	LECs 	Should 	Be 	Required 	to 	Offer 	Expanded 	Interconnection 	13
V. 	Implications of Interconnection for the Long Distance to Local
Service 	sUbsidy · · · 	· · · · . . . . · 	· 	· 19
VI. 	LECs 	Should 	be 	Allowed 	Pricing 	Flexibility · 	· 	· . 	30
VII. 	Conclusion 	. · 	· 	· · · 	· 	· . . . 	. · · · · · · . 	32
References 	. · · · 	· 	· · · . . · 	· · 	· · 33
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Before 	the
FEDERAL COMMUNICATIONS 	COMMISSION
Washington, 	D.C. 	20554
In 	the 	matter 	of
Expanded 	Interconnection with
Local 	Telephone 	Company 	Facilities
)
)
)
Amendment 	of 	Part 	36 	of 	the 	)
Commission's 	Rules 	and 	Establishment)
of 	a 	Joint 	Board 	)
CC 	Docket 	No. 	91-141
Transport
Phases 	I 	& II
CC 	Docket 	No. 	80-286
1
Comment 	of 	the 	Staff 	of
the 	Bureau 	of 	Economics
of 	the 	Federal 	Trade 	Commission!
I. 	Introduction 	and 	Summary
The 	staff 	of 	the 	Bureau 	of 	Economics 	of 	the 	Federal 	Trade
f"ommission 	(FTC) 	appreciates 	thi.s 	opportunity 	to 	submit 	this
comment 	in 	response 	to 	the 	Federal 	Communications 	commission's
(FCC) 	Second 	Notice 	of 	Proposed 	Rulemaking 2 	("Second 	Notice")
concerning 	proposals 	to 	require 	certain 	local 	exchange 	carriers
(LECs) 	to 	offer 	expanded 	opportunities 	to 	interconnect 	with 	their
This 	comment 	represents 	the 	views 	of 	the 	staff 	of 	the
Bureau 	of Economics 	of 	the 	Federal 	T=ade 	Commission. 	They are 	not
necessarily 	the 	views 	of 	the 	Commission 	or 	any 	individual
Commissioner. 	Inquires 	regarding 	this 	comment 	should 	be 	directed
to Richard Shin 	(202-326-3495) 	or Michael R. 	Ward 	(202-326-2096) 	of
the 	FTC's 	Bureau 	of 	Economics.
2 	Second 	Notice 	of 	Proposed 	Rulemaking 	In 	the 	Matter 	of
Expanded 	Interconnection with 	Local 	Telephone 	Company 	Facilities,
CC Docket No. 	91-141 Transport Phases I 	& II, 	(Released October 16,
1992) .
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switched 	access 	networks 	for 	the 	provision 	of 	interstate 	switched
transport. 3 	The 	FCC 	anticipates 	that 	the 	measures 	contemplated
by the Second Notice will 	provide opportunities for efficient entry
into 	the 	provision of 	switched 	access 	services 	and 	reduce 	switched
access 	rates. 	The 	analysis 	contained 	in 	this 	comment 	supports
these views, 	and we therefore support the Second Notice's proposals
to 	introduce additional 	competition to the 	local 	transport element
of 	the 	switched 	access 	market.
Two 	basic 	issues 	raised 	by 	the 	Second 	Notice 	are: 	whether 	to
encourage 	competition 	for 	interstate 	local 	transport 	by 	requiring
LECs 	to 	offer 	interconnection 	to 	non-LEC 	entrants 	and, 	if 	so, 	how
much pricing 	flexibility to permit LECs 	in light of expected entry.
Our 	analysis 	suggests 	that 	permitting 	non-LEC 	firms 	to 	provide
local 	transport 	services, 	combined 	with 	requiring 	LECs 	to 	provide
the 	local 	loop 	access 	to 	end 	users 	necessary 	to 	complete 	long
distance 	calls, 	would 	benefit 	consumers. 	Our 	analysis 	also
suggests 	that 	permitting 	LECs 	greater 	flexibility 	to 	price 	their
services 	according 	to 	their 	costs 	will 	help 	insure 	that 	only
efficient 	entry 	occurs.
This comment addresses four specific points pertinent to these
two 	broad 	issues: 	(1) 	the 	condi~ions under 	which 	common 	carrier
obligations, 	such 	as 	requiring 	LECs 	to 	provide 	expanded
interconnection 	for 	switched 	access 	services, 	can 	be 	supported 	on
economic 	efficiency 	grounds; 	(2) 	the 	magnitude 	of 	the 	difference
3 	This 	comment 	addresses 	issues 	relating 	to 	economlC
efficiency 	and 	competition. 	It 	does 	not 	take 	a 	position 	on 	other
policy 	considerations 	that 	may 	be 	of 	relevance 	to 	the 	FCC.
2
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between 	the 	cost 	of 	providing 	switched 	access 	and 	its 	price; 	(3)
the 	degree 	to 	which 	special 	access 	is 	a 	substitute 	for 	switched
access; 	and 	(4) 	the 	importance 	of 	providing 	the 	LECs 	some 	pricing
flexibility 	at 	the 	same 	time 	they 	are 	required 	to 	provide 	expanded
interconnection 	opportunities 	to 	third 	parties. 	We 	believe 	that
the 	analysis 	and 	empirical 	findings 	contained 	in 	this 	comment 	are
consistent with the FCC's tentative conclusion that switched access
interconnection 	is 	likely 	to 	benefit 	consumers 	and 	competition.
Interstate switched access 	services can be 	separated 	into two
components: 	local 	transport 	services 	(Which 	connects 	the 	IXC 	POP
with 	the 	LEC central 	office) 	and 	local 	loop access 	(Which 	includes
necessary switching services 	and connecting the 	LEC central 	office
wi th 	end 	users.) 	Permitting 	entry 	into 	local 	transport 	services
can be 	justified 	if 	the 	cost 	of providing 	both 	local 	transport 	and
local 	access 	is 	no 	greater 	when 	two 	firms 	supply 	local 	transport
than 	when 	one 	firm 	supplies 	both 	services. 	If 	entry 	into 	local
transport 	i- 	permitte~. 	compelling 	LECs 	to 	provide 	expanded
interconnection 	can 	be 	economically 	justified 	if 	it 	can 	be	,
established that 	local telephone service is provided by a 	regulated
natural 	monopoly 	that, 	absent 	such 	a 	requirement, 	would 	have 	an
incentive 	to 	deny 	local 	loop 	access 	to 	some 	entrants 	in 	local
transport 	service 	that 	wish 	to 	purchase 	it. 	Recent 	empirical
results 	support 	these 	two 	conditions. 	It 	is 	likely, 	therefore,
that 	requiring LECs 	to provide 	such 	access would benefit 	consumers
and 	promote 	economic 	efficiency.
3
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Existing 	studies 	of 	LEC 	costs 	strongly 	suggest 	that 	switched
access 	prices 	currently 	are well 	above 	their marginal 	costs. 	This
comment 	provides 	estimates 	suggesting 	that 	the 	prices 	charged 	by
LECs 	for 	switched 	access 	services 	are 	several 	times 	their marginal
costs. 	The estimates also 	indicate that these differences are used
to subsidize local 	residential service, 	whose prices are well below
their 	marginal 	costs.
At 	the 	same 	time 	it 	issued 	this 	Second 	Notice, 	the 	FCC
released an order 	("Special Access Order") 	containing important new
regulations 	concerning. LEC-supplied 	special 	access. 4 	The
regulatory 	changes 	described 	in 	the 	Special 	Access 	Order 	will
increase the number of sellers offering special access services and
reduce 	the 	prices 	of 	these 	services. 	While 	it 	is 	generally
recognized 	that 	these changes will 	induce 	some end users 	currently
using 	switched 	access 	to 	opt 	for 	special 	access, 	no 	empirical
estimates 	of 	this 	demand 	sUbstitutability 	have 	previously 	been
available. 	In 	this 	comment, 	we 	report 	recent 	estimat~s of 	the
degree 	of 	sUbstitutability 	between 	switched 	and 	special 	access.
These estimates 	suggest 	that 	a 	significant amount 	of 	long distance
traffic would migrate to special access 	from switched access 	if the
proposed 	regulations 	covering 	switched 	access 	are 	not 	adopted.
If 	restrictions 	on 	entry 	into 	local 	transport 	services 	are
relaxed, 	as 	contemplated 	by 	this 	Second 	Notice, 	the 	difference
between the 	LEC's marginal 	cost 	of 	switched 	access 	service and 	its
4 	Expanded 	Interconnection 	with 	Local 	Telephone 	Company
Facilities, 	Report 	and 	Order, 	CC 	Docket 	No. 	9~-14l, 	FCC 	92-4409
(Release 	October 	16, 	1992) 	("Special 	Access 	Order").
4
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price 	will 	invite 	entry, 	possibly 	by 	firms 	with 	costs 	higher 	than
those 	of 	the 	LEC. 	Under 	such 	circumstances, 	the 	Second 	Notice
recognizes that the LECs must be permitted to respond to this entry
with 	lower 	prices. 	The 	Special 	Access 	Order 	will 	permit 	LECs 	to
establish "density pricing zones" under which special access prices
can 	better 	reflect 	costs. 5 	The 	Second 	Notice 	proposes 	to 	carry
this 	further, 	allowing 	LECs under price-cap regulation 	some degree
of 	flexibility 	in 	pricing 	switched 	access 	services 	within 	these
zones. 6 	While 	we 	do 	not 	address 	in 	detail 	how 	to 	structure 	such
flexibility, 	we 	strongly 	support 	the 	Second 	Notice's 	proposal 	to
provide 	greater 	pricing 	flexibility 	to 	the 	LECs, 	because 	suc~
flexibility 	is 	central 	to 	ensuring 	that 	entry 	will 	occur 	due 	to 	a
cost 	advantage 	of 	the 	entrant, 	and 	not 	a 	regulated 	price 	umbrella
for 	the 	incumbent.
5 	In 	general, 	it 	is 	less 	costly 	to 	serve 	dense, 	urban 	areas
than 	rural 	areas. 	Prior 	to 	the 	adoption 	of 	the 	Special 	Access
Order, 	LEC 	prices 	reflected 	the 	average 	cost 	of 	providing 	service
to 	end 	users 	located 	throughout 	its 	service 	area, 	both 	urban 	and
rural. 	By 	establishing 	density 	pricing 	zones, 	LEC 	prices 	can
better 	reflect 	the 	lower 	costs 	of 	serving 	urban 	areas.
6 	Second 	Notice, 	para. 	32-34.
5
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II. 	Expertise 	of 	the 	Staff 	of 	the 	Federal 	Trade 	Commission
The 	FTC 	is 	an 	independent 	regulatory 	agency 	responsible 	for
maintaining 	competition 	and 	safeguarding 	the 	interests 	of
7
consumers. 7 	The 	staff 	of 	the 	FTC, 	upon 	request, 	often 	analyzes
regulatory 	or 	legislative 	proposals 	that may 	affect 	competition or
the efficiency of the economy. 	In the course of this work, 	as well
as 	in 	antitrust 	and 	consumer 	protection 	research 	and 	litigation,
the 	staff 	apply 	established 	principles 	and 	recent 	developments 	in
economic 	theory 	to 	competition 	and 	consumer 	protection 	issues,
including 	efficiency 	rationales 	for 	rate 	and 	entry 	regulation. 8
In 	addition, 	the 	staZf 	of 	the 	Bureau 	of 	Economics 	of 	the 	FTC 	has
studied the effects of price and entry regulations on long distance
telephone 	service. 9
15 	U.S.C. 	§§ 	41 	et 	seq.
8 	For example, 	the 	staff of the FTC submitted comments 	to 	the
Postal 	Rate 	Commission 	concerning 	recent 	advances 	in 	the 	economic
theory 	of 	regulated 	monopolies. 	See 	Comments 	of 	the 	Staff 	of 	the
Bureau 	of 	Economics 	of 	the 	Federal 	Trade 	Commission, 	Before 	the
United 	States 	of 	America 	Postal 	Rate 	Commission, 	Monopoly 	Theory
Inquiry, 	Docket No. 	RM89-4 	(September 1, 	1989). 	See 	also Comments
of 	the 	Staff 	of 	the 	Bureau 	of 	Economics 	and 	the 	Chicago 	Regional
Office 	of 	the 	Federal 	Trade 	Commission, 	Before 	the 	Illinois
Commerce 	Commission, 	In 	the 	Matter 	of 	The 	Blue 	Ribbon
Telecommunications 	Task 	Force 	Outline 	of 	Purpose 	and 	Request 	for
Assistance 	(October 	19, 	1990).
9 	See 	Alan 	D. 	Mathios 	and 	Robert 	P. 	Rogers, 	The 	Impact 	of
State 	Price 	and 	Entry 	Regulation 	on 	Intra-State 	Long 	Distance
Telephone 	Rates, 	FTC 	Bureau 	of 	Economics 	Staff 	Report 	(November
1988) .
6
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III. 	Background
This 	proceeding 	is 	one 	of 	several 	dealing 	with 	the 	services
provided 	by 	local 	exchange 	carriers 	(LECs) 	to 	long 	distance
carriers 	(interexchange carriers or "IXCs"). 	Before discussing the
details of these proceedings, 	we provide a 	brief description of the
relationship 	between 	LECs 	and 	IXCs.
LECs 	provide 	local 	telephone 	services; 	IXCs 	provide 	long
distance 	services. 	To provide 	long distance service, 	IXCs 	require
"access" 	to 	end 	users 	(e.g., 	households, 	businesses). 	These 	end
users 	are 	already 	connected 	to 	the 	LEC, 	so 	IXCs 	typically 	obtain
access 	to 	them 	by 	cvnnecting 	with 	the 	LEC 	and 	purchasing 	end-user
access 	from 	it.
LECs 	offer 	two 	types 	of 	end-user 	access 	to 	IXCs: 	switched
access and special 	access. 	switched access can be broken down 	into
three 	components: 	connecting end 	users 	to 	the 	nearest 	LEC 	central
office; 	switching services performed at the LEC central 	office 	(to
route 	calls to 	the proper IXC); 	and 	transporting 	calls between LEC
central 	offices 	and 	the 	nearest 	IXC 	point-of-presence 	(POP).
switched 	access 	services 	represent 	a 	significant 	component 	of 	the
price 	of 	a 	long 	distance 	telephone 	call. IO
End 	users 	with 	greater 	demand 	for 	long 	distance 	services,
typically 	large 	businesses, 	can 	avoid 	much 	of 	the 	expense 	of
10 	In 	1990, 	long 	distance 	companies 	collected 	$52.1 	billion
in 	revenues 	for 	toll 	service and 	paid a 	total 	of 	$19.8 	billion 	for
end-user 	access. 	(This 	includes 	switched 	and 	special 	access 	for
interstate 	and 	intrastate 	toll 	service). 	Total 	access 	payments
represent 	approximately 	38% 	of 	toll 	revenues. 	(U.S. 	Federal
Communications 	Commission, 	1990/1991).
7
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switched 	access 	by 	connecting 	directly 	with 	the 	IXC 	POP. 	One 	way
to 	do 	this 	is 	to 	purchase 	special 	access 	services 	from 	the 	LEC,
which 	for 	sufficiently 	high 	calling 	volumes 	are 	priced 	lower 	than
switched 	access 	service. 	Special 	access 	service 	involves 	ordering
a 	dedicated 	line 	from 	the 	end 	user's 	premises 	to 	the 	LEC 	central
office, 	and 	then 	having 	the 	LEC 	transport 	the 	calls 	from 	its
central 	office 	to 	the 	IXC 	POP. ll 	In 	contrast 	to 	the 	minute-of-
use 	price 	for 	switched 	access, 	special 	access 	is 	priced 	as 	a
monthly 	rental 	that 	depends 	on 	the 	capacity 	of 	the 	line 	and 	not
actual 	usage. 	In 	terms 	of 	revenues 	collected, 	switched 	access 	is
considerably larger than 	special 	access. 	In 	1990, 	LEC charges 	for
interstate 	switched 	access 	and 	interstate 	special 	access 	totalled
approximately 	$11.0 	billion 	and 	$2.6 	billion 	respectively.U
It 	is 	also possible 	fer 	IXCs 	to 	obtain 	access 	to 	end 	users 	by
bypassing 	the 	LEC 	entirely. 	Recently, 	a 	number 	of 	firms, 	called
Competitive 	Access 	Providers 	(or 	"CAPs"), 	have 	constructed
localized 	fiber 	optic 	networks, 	usually 	in 	urban 	business
districts. 	CAPs 	connect 	their 	localized 	network directly with 	the
IXCs' 	POPs and with long-distance intensive end users, 	supplying an
alternative 	to 	LEC-provided 	access. 13 	The 	emergence 	of 	CAPs 	was
11 	The 	same 	line 	can 	transport 	both 	special 	access 	calls 	and
switched 	access 	calls 	from 	the 	LEC 	central 	office 	to 	the 	IXC 	POP.
See 	Second 	Notice, 	footnote 	4.
12 	LECs 	charged 	an 	additional 	$6.2 	billion 	for 	intrastate
switched 	and 	special 	access.
D 	NYNEX 	estimates 	that 	CAPs 	supply 	40% 	of 	the 	high-capacity
market 	in 	New 	York 	City.
8
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instrumental 	in 	the 	FCC I S 	decision 	in 	1991 14 	to 	reconsider 	its
regulations 	concerning 	access, 	both 	special 	and 	switched. 15
The 	FCC 	regulates 	the 	prices 	charged 	by 	LECs 	to 	IXCs 	for
switched 	and 	special 	access 	services. 16 	While 	the 	pricing
structures 	are 	complex, 	it 	is 	generally 	the 	case 	that 	switched
access 	prices 	are 	based 	on 	minutes-of-use 	while 	special 	access
prices are based on the capacity of the dedicated line 	(rather than
actual 	use). 	Over the past 	few 	years, 	switched access 	prices have
fallen 	considerably 	as 	the 	FCC 	permitted 	the 	LECs 	to 	lower 	the
charges 	imposed on 	the 	IXCs while 	at 	the 	same 	time 	permitting them
to 	introduce 	a 	fixed 	monthly 	fee 	(called 	the 	subscriber 	line
charge) 	on 	end 	users. 1? 	Special 	access 	prices 	also 	have 	declined
considerably 	partly 	because 	the 	FCC 	has 	permitted 	LECs 	to 	offer
substantial 	volume 	discounts 	in 	markets 	where 	CAPs 	emerged .18
Even 	with 	these 	price 	reductions, 	however, 	the 	prices 	for 	LEC-
14 	Special 	Access 	Order, 	para. 	4-6. 	Larson 	and 	Mudd 	(1992)
also 	provide 	a 	history 	and 	analysis 	of 	tnis 	issue.
~ 	A number 	of 	states 	had 	also 	responded 	to 	demands 	from 	the
LECs 	and 	from 	the 	CAPs 	to 	amend 	the 	regulatory 	structures
pertaining to 	intrastate 	long distance traffic. 	Chief among these
states 	are 	New 	York, 	Illinois, 	and 	Massachusetts. 	Special 	Access
Order, 	para. 	10.
16 	States regulate LEC prices for access services provided for
intrastate long distance traffic. 	Because the same physical assets
carry 	both 	interstate 	and 	intrastate 	long 	distance 	calls, 	some 	of
the LECs assets are allocated between the 	interstate and 	intrastate
jurisdictions 	in 	a 	necessarily 	arbitrary 	way. 	Regulated 	prices
depend, 	to 	a 	large 	extent, 	on 	these 	cost 	allocations.
17 	In 	essence, 	the 	subscriber 	line 	charge 	simply 	increased
local 	telephone 	rales 	relative 	to 	long 	distance 	rates.
18 	Special 	Access 	Order, 	para. 	173.
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supplied 	access 	are 	still 	well 	above 	their 	marginal 	costs. 	Given
their 	relative 	prices, 	it 	would 	appear 	that 	the 	gap 	between 	price
and 	marginal 	cost 	is 	larger 	for 	s~itched access 	than 	for 	special
access. 	The 	differences 	in 	the 	deviations 	between 	prices 	and
marginal 	costs 	provide 	end 	users 	incentives 	to 	substitute 	special
access 	for 	switched 	access, 	and 	to 	substitute 	CAP 	services 	(whose
prices 	are 	unregulated) 	for 	them 	both.
The 	FCC's 	Special 	Access 	Order
As a 	result 	of the Special Access Order, 	LECs, 	for the 	first
time, 	will 	be 	required 	to 	permit 	third 	parties 	-- 	such 	as 	end
users, 	IXCs, 	and 	CAPs 	to 	terminate 	their 	own 	transmission
facilities 	at 	LEC 	central 	offices. 	The 	ability 	to 	interconnect
directly 	with 	the 	LEC 	network 	for 	special 	access 	services 	will
greatly 	facilitate 	development 	of 	substitutes 	for 	them. 	For
instance, 	a 	CAP 	(or 	an 	IXC) 	will 	be 	permitted 	to 	install 	lines
connecting LEC central 	offices 	and 	IXC 	POPs. 	End 	users 	could then
bUy special access services 	from the LLC to transport the call 	from
their premises 	to the 	LEC central 	office, 	and 	then use 	the 	CAP 	(or
IXC) 	to 	transport 	the 	call 	to 	the 	IXC 	POP. 	The 	FCC 	believes 	that
"this 	growing 	competition 	will 	expand 	service 	choices 	for
telecommunications users, 	heighten incentives for efficiency, 	speed
technological 	innovation, 	and 	increase 	pressure 	for 	cost-based
prices. ,,19
19 	Special 	Access 	Order, 	para. 	2.
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Much 	of 	the 	Special 	Access 	Order 	specifies 	how 	the 	LECs 	must
accommodate the demands 	from 	third parties wishing 	to 	interconnect
with 	the 	LEC 	network 	at 	its 	central 	office. 	These 	complex
"architectural" 	issues 	have 	been 	considered 	in 	the 	Special 	Access
Order; 	we 	do 	not 	address 	them 	further 	in 	this 	comment. 	Of 	import
for 	this proceeding 	is that the FCC believes that the architectural
decisions described 	in the Special Access Order "laid the essential
groundwork 	for 	expanded 	interconnection 	for 	switched 	transport."W
The Special Access Order also contains 	regulations 	specifying
how 	LECs 	can 	price 	their 	new 	access 	services 	provided 	to 	third
parties, 	and 	how 	LECs 	can 	modify 	the 	prices 	they 	charge 	for
services they offer in competition with new suppliers. 	All-in-all,
these 	special 	access 	pricing 	regUlations 	are 	intended 	to 	move 	the
prices 	charged by 	LEcs 	for 	special 	access 	services 	closer to 	cost,
and to permit LECs 	to alter more easily their prices 	in response to
increased 	special 	access 	competition.
The 	switched 	Access 	Second 	Notice
In 	the 	Switched 	Access 	Second 	Notice, 	the 	FCC 	tentatively
concludes 	that 	the 	benefits 	likely 	to 	flow 	from 	expanded
interconnection 	in 	the 	special 	access 	market 	would 	also 	flow 	from
requiring expanded 	interconnection obligations 	for 	switched access
services. 21 	The 	FCC 	requests 	comment 	on 	this 	"tentative
W 	Special 	Access 	Order, 	para. 	3.
21 	"We 	believe 	that 	benefits 	will
interconnection 	for 	switched 	transport.
11
arise 	from 	expanded
The 	introduction 	of
(continued ... )
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conclusion, 	addressing the potential benefits of switched transport
expanded 	interconnection 	and 	possible 	drawbacks." 22 	This 	comment
addresses 	several 	issues 	pertinent 	to 	this 	proceeding: 	(1) 	the
condi tions under which expanded interconnection requirements can be
supported 	on 	economic 	efficiency grounds; 	(2) 	the magnitude 	of 	the
difference 	between 	the 	marginal 	cost 	of 	providing 	switched 	access
and 	its 	price; 	(3) 	the 	degree 	to 	which 	special 	access 	has 	been 	a
substitute 	for switched access; 	and 	(4) 	the 	importance of providing
the 	LECs 	some 	pricing 	flexibility 	if 	they 	are 	required 	to 	provide
expanded 	interconnection 	opportunities 	to 	third 	parties.
21 ( ••• continued)
expanded 	interconnection 	for 	interstate 	switched 	transport 	would
produce 	substantial 	benefits 	in 	addition 	to 	those 	to 	be 	realized
from 	interstate 	special 	access 	expanded 	interconnection.
Expanded 	competition 	and 	its 	associated 	pricing 	changes 	would
provide 	a 	stimulus 	on 	the 	switched 	services 	side 	for 	increased
efficiency 	in 	LEC 	operations, 	improved 	service 	provision, 	and
greater 	access 	to 	diverse 	facilities 	that 	could 	improve 	network
reliability." 	Second 	Notice, 	para. 	10.
22 	Second 	Notice, 	para. 	14.
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IV. 	LECs Should Be Required 	to 	Offer Expanded 	Interconnection
The 	FCC's 	proposej 	rule 	would 	require 	larger 	LECs n 	to
interconnect third 	parties with the 	LEC's 	switched 	access 	networks
in 	order 	to 	foster 	competition 	for 	local 	switched 	transport. 	For
purposes 	of 	analyzing 	this 	proposal, 	we 	believe 	it 	is 	useful 	to
separate switched access 	into its three components: 	the connection
between 	the 	IXC 	POP 	and 	the 	LEC 	central 	office 	(local 	transport),
the switching services performed at the LEC central 	office, 	and the
connections 	between 	the 	LEC 	central 	off ice 	and 	end 	users. 	For
expositional 	purposes, 	we 	will 	combine 	the 	latter 	two 	components
into 	one, 	ca 11 ed 	"1 oca 1 	loop 	access". 24
Currently, 	for switched access, 	LECs are the sole providers of
local 	transport 	and 	local 	loop 	access. 	The 	proposed 	rule 	would
require 	LECs 	first 	to 	unbundle 	these 	two 	services, 	and 	second 	to
provide 	local 	loop 	access 	to 	all 	parties 	wishing 	to 	purchase 	it,
even 	if local 	transport 	is purchased from other parties or provided
by 	the 	IXCs. 	Such 	requirements would be 	economically 	justified 	if
(1 ) 	permitting 	entry 	into 	local 	transport 	appears 	1 ikely 	to 	be
efficient and, 	if so, 	(2) 	requiring LECs to offer local 	loop access
on a 	"common carrier" 	basis appears necessary. 	We believe that the
evidence 	currently 	available 	suggests 	that 	both 	of 	these
requirements 	are 	met.
n 	That 	is, 	LECs 	with 	more 	than 	$100 	million
regulated 	revenues 	for 	a 	sustained 	period 	of 	time. in 	annual
24 	To 	be 	precise, 	there 	is 	one 	more 	possible 	component
included 	in 	local 	loop 	access: 	transporting 	the 	call 	between 	LEC
central 	offices.
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Restricting 	entry 	into 	local 	transport 	could 	be 	justified 	on
economic 	efficiency 	grounds 	if 	the 	cost 	of 	providing 	both
components 	of 	switched 	access 	(local 	transport 	and 	local 	loop
access) 	is 	minimized 	when 	a 	single 	firm 	supplies 	them, 	and 	if,
absent 	entry 	restrictions, 	a 	monopolist 	could 	not 	set 	prices 	that
simul taneously 	allow 	it 	to 	break 	even 	and 	deter 	all 	entry. 25
Recently, 	however, 	the 	view 	that 	LECs, 	as 	currently 	configured,
constitute a 	natural 	monopoly has 	been 	eroding. 	This 	is 	true 	even
though 	the 	provision 	of 	certain 	LEC 	services, 	e. g. 	local 	loop
access, 	are 	likely 	to 	exhibit 	substantial 	economies 	of 	scale 	and
scope. 	We next discu~s some of the recent economic 	research on LEC
cost conditions. 	In general, 	this research supports the conclusion
that 	permitting 	competition 	into 	local 	transport 	is 	likely 	to
benefit 	consumers.
Recent 	empirical 	analysis 	suggests 	that 	the cost 	of providing
both 	local 	loop 	access 	and 	local 	transport 	by 	one 	firm 	is 	not
likely 	to 	be 	less 	than 	the 	cost 	of 	providing 	the 	services 	by 	two
firms.~ 	Shin 	(1988) 	estimated 	a 	LEC 	cost 	function 	at 	the 	central
~ 	That 	is, 	if 	LECs 	are 	a 	nonsustainable 	natural 	monopoly,
entry 	restrictions 	could 	be 	efficient. 	Sharkey 	(1982) 	provides 	a
complete 	description 	of 	a 	natural 	monopoly, 	including 	the 	cost
conditions that 	imply 	its 	existence and 	that determine whether the
natural 	monopoly 	is 	sustainable.
~ 	A 	number 	of 	studies 	examined 	whether 	the 	predivestiture
Bell 	system 	was 	a 	natural 	monopoly. 	Resul ts 	have 	been 	mixed
largely 	because 	of 	data 	limitations. 	See 	Christensen, 	Cummings,
and Schoech 	(1983), 	Evans 	and Heckman 	(1983), 	Charnes, 	Cooper, 	and
Sueyoshi 	(1988), 	and 	Roller 	(1990). 	Shin 	and 	Ying 	(1992) 	cast
doubt 	on 	natural 	monopoly 	cost 	conditions 	in 	local 	telephone
service 	at 	the 	LEC 	level.
14
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office 	level. 27 	His 	estimated 	cost 	function 	included 	three
broadly 	defined 	outputs: 	the 	number 	of 	end 	users 	with 	local 	loop
access; 	the 	volume 	of 	local 	calls; 	and 	the 	volume 	of 	toll 	calls.
As 	expected, 	simulations 	show 	that 	for 	a 	representative 	central
office, 	there were economies of scope between local 	loop access and
local 	calls, 	and 	between 	local 	loop 	access 	and 	toll 	calls.
However, 	they 	also 	show 	diseconomies 	of 	scope 	between 	local 	calls
and 	toll 	calls. 	This 	result 	suggests 	that 	entry 	into 	the 	services
provided 	by 	central 	offices 	for 	toll 	calls 	(e.g., 	switching 	and
local 	transport) 	could 	be 	efficient. 	Designing 	the 	appropriate
policy 	is 	complicated, 	however, 	by 	the 	finding 	of 	economies 	of
scope 	between 	local 	loop 	access 	and 	toll 	calls. 	Under 	the
reasonable 	(but 	as yet empirically unexamined) 	assumption that the
economies 	of 	scope 	between 	local 	loop 	access 	and 	toll 	calls 	stem
from 	the 	switching 	services 	provided 	by 	the 	central 	office 	rather
than 	its 	local 	transport 	services, 	permitting 	entry 	into 	local
transport 	for 	toll 	calls 	would 	promote 	economic 	efficiency.
If 	entry 	is 	permitted 	into 	local 	transport 	services, 	new
entrants will still 	need to purchase 	local 	loop access 	from the LEe
to 	complete 	long 	distance 	calls. 	The 	proposed 	rule 	would 	require
LEes 	to 	provide 	local 	loop 	access 	to 	all 	parties 	wishing 	to
purchase 	it. 	Imposing 	such common carrier obligations, 	instead of
permitting LEes 	to 	decide whether to 	interconnect particular third
parties, 	appears 	sensible 	for 	two 	reasons. 	First, 	local 	loop
27 	In 	both 	Shin 	and 	Ying 	(1992) 	and 	Ying 	and 	Shin 	(1993) 	the
uni t 	of 	observation 	is 	the 	local 	exchange 	company 	and 	not 	the
individual 	central 	office.
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access 	at 	the 	central 	office 	level 	appears 	to 	be 	a 	natural
monopoly. 	Second, 	LEC 	prices 	currently 	embody 	a 	significant
subsidy 	from 	IOilg distance 	services, 	including 	local 	transport, 	to
local 	residential 	services. 	Thus, 	it 	seems 	unlikely 	that
significant 	entry 	will 	arise 	to 	offer 	local 	loop 	access.
Shin 	(1988) 	found that, 	at the central office 	level, 	economies
of 	scale 	and 	scope 	exist 	in 	the provision 	of 	local 	loop access, 	at
least 	outside 	dense 	urban 	areas. 	Scale 	and 	scope 	economies 	exist
because 	of 	excess 	capacity 	inherent 	in 	local 	loops 	(customer
connection 	to 	the 	LEC's 	switch), 	common costs 	in obtaining 	rights-
of-way, 	and 	large 	fixed 	costs 	to 	switching. 	First, 	doubling 	the
number 	of 	calls 	for 	a 	given 	number 	of 	customers 	in 	a 	typical
central 	office service area 	is 	likely to cause 	far 	less 	than a 	two-
fold 	increase 	in 	costs 	because 	the 	local 	loop 	contains 	a
significant 	degree 	of 	excess 	capacity. 	On 	average, 	only 	about 	50
minutes a 	day are spent making telephone calls 	for each local 	loop.
Thus, 	for 	the 	majority 	of 	end 	users, 	the 	average 	cost 	of 	a 	call
falls with calling volume. 	Second, 	local 	loops to nearby end users
are 	typically 	connected 	to 	the 	central 	office 	using 	common
telephone 	poles 	or 	conduit. 	Thus, 	increasing 	the 	number 	of 	local
loops 	in 	a 	typical 	central 	office 	service 	area 	also 	is 	likely 	to
cause 	a 	less 	than 	proportionate 	increase 	in 	costs. 	Finally, 	a
significant 	portion 	of 	the 	cost 	of 	switching 	is 	the 	software 	that
manages 	the 	communications 	within 	the 	switch. 	Software 	costs 	are
largely 	fixed 	and 	common 	to 	all 	calls, 	implying 	that 	average
software 	costs 	fall 	with 	calling volume.
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still, 	economies 	of 	scale 	and 	scope 	at 	the 	central 	office
level 	in 	the 	provision 	of 	local 	loop 	access 	need 	not 	justify 	a
regulatory requirement compelling LECs to provide local loop access
to any interested third party. 	This 	requirement appears 	justified,
however, 	because LECs will 	likely .have an 	incentive to discriminate
against 	third 	party 	local 	transport 	providers. 	If 	the 	regulated
prices 	of 	local 	loop 	access 	remain 	below 	the 	prices 	that 	maximize
switched 	access 	profits, 	then 	the 	LEC 	can 	increase 	its 	profits 	by
providing 	both 	local 	loop 	access 	and 	local 	transport 	services, 	if
the 	latter 	continue 	to 	be 	priced 	above 	marginal 	cost. 	The 	LEC
monopolist can maintain 	local 	transport prices 	above marginal 	cost
by 	denying 	or 	limiting 	local 	loop 	access 	to 	some 	third 	parties.~
Even 	if 	common 	carrier 	obligations 	were 	imposed, 	these
circumstances 	imply 	that 	LECs 	also 	would 	have 	an 	incentive 	to
discriminate 	in 	the 	quality 	of 	the 	local 	loop 	access 	services
provided 	to 	third 	parties. 	These 	quality 	concerns 	underlie, 	and
justify, 	the 	detailed 	architectural 	requirements 	and
interconnection 	standards 	contained 	in 	the 	Special 	Access 	Order
that 	the 	FCC 	plans 	to 	extend 	to 	the 	switched 	access 	market.
~ 	For a 	discussion 	of a 	regulated monopolist's 	incentives to
tie regulated and unregulated services together, 	or to discriminate
in the sales of 	its 	regulated services, 	see Brennan 	(1987). 	In the
Special Access Order, 	the FCC imposed common carrier obligations on
LECs 	for the provision of special access. 	See Special Access Order
at 	para. 	39. 	The 	justification 	for 	requiring 	LECs 	to 	provide
interconnection 	for 	switched 	access 	is 	identical 	to 	that 	for
requiring 	LECs 	to provide 	interconnection 	for 	special 	access. 	For
a 	more detailed 	an~lysis supporting this 	requirement, 	see the u.s.
Department 	of 	Justice's 	reply 	comments 	in 	the 	proceedings 	for 	the
Special 	Access 	Order, 	pp. 	17-20.
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V. 	Implications of Interconnection for the Long Distance to Local
service 	Subsidy
Requiring 	LECs 	to 	provide 	local 	loop 	access 	to 	new 	entrants
that 	provide 	local 	transport 	sE:r.'ices 	will 	likely 	cause 	local
transport 	prices 	to 	decline. 	Lower 	local 	transport 	prices 	would
reduce 	the 	subsidy 	from 	long 	distance 	service 	to 	local 	telephone
service, 	provided 	that 	the 	prices 	of 	the 	nonlocal 	transport
portions 	of 	switched 	access 	services 	were 	net 	raised. 	Currently,
the 	prices 	charged 	for 	local 	residential 	service 	are 	about 	half
their marginal 	costs, 	while 	the 	prices 	charged 	for 	switched 	access
are 	at 	least 	double 	their 	marginal 	costs. 	Switched 	access 	prices
cannot 	be 	maintained 	above 	marginal 	cost 	in 	the 	presence 	of
competition. 	To 	the 	extent 	that 	LEC 	interconnection 	introduces
competition 	for 	switched 	access, 	the 	cross-subsidy 	will 	be
diminished. 29
Local 	residential 	telephone customers appear to be subsidized
by 	users 	of 	other 	telephone 	services. 	Even 	including 	the 	full
$3.50 	per 	month 	residential 	subscriber 	line 	charge, 	local
residential 	prices 	may 	be 	as 	low 	as 	one-half 	of 	their 	marginal
costs. 	Local 	business 	telephone 	service, 	by 	contrast, 	is 	priced
well 	above 	marginal 	cost, 	thereby 	providing 	a 	subsidy 	to
residential 	service. 30 	Interstate 	long 	distance 	service 	also
29 	See 	Faulhaber 	(1975).
30 	See Palmer 	(1992). 	She estimates the sUbsidy from business
service 	to 	residential 	service 	is 	over 	$6 	per 	line 	per 	month.
18
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subsidizes local 	residential service because the IXCs typically pay
for 	access 	an 	amount 	as 	much 	as 	twice 	its 	marginal 	cost. 31
studies 	have 	suggested 	that 	the 	maintenance 	of 	these 	cross-
subsidies 	in 	the 	face 	of 	changing 	market 	conditions 	has 	imposed
large 	social 	welfare 	costs, 	although 	we 	do 	not 	analyze 	this
question 	directly. 32 	Studies 	also 	have 	suggested 	that 	a 	recent
reduction 	in 	cross-subsidies 	between 	long 	distance 	and 	local
services 	benefited 	residential 	customers. 33 	These 	studies 	address
the 	efficiency aspects 	of 	reductions 	in 	the 	toll 	to 	local 	subsidy.
We 	recognize 	that 	regulators 	may 	wish 	to 	consider 	public 	pOlicy
concerns 	other 	than 	economic 	efficiency 	when 	approving 	telephone
prices 	for 	low-income 	residential 	callers. 	By 	addressing 	the
31 	Kahn 	and 	Shew 	(1987), 	pp. 	196-197, 	provide 	evidence 	that
the 	price 	of 	access 	was 	four 	or 	five 	times 	its 	marginal 	cost.
32 	See Rohlfs 	(1979), 	Griffen 	(1982), 	Wenders and Egan 	(1986),
and 	Kasserman, 	Mayo 	and 	Flynn 	(1990) 	for 	evidence 	of 	the 	welfare
costs 	due 	to 	inefficient 	pricing 	of 	long 	distance 	and 	local
services. 	On 	the 	welfare 	costs 	of 	inef!icient 	telephone 	service
pricing: 	in 	1eneral, 	~~e Mitchell 	(1978) 	and 	Wenders 	(1987); 	for
directory 	assistance, 	see 	Daley 	and 	Mayor 	(1980); 	for 	local
measured 	service, 	see 	Griffen 	and 	Mayor 	(1987); 	for 	business 	and
residential 	service, 	see 	Palmer 	(1992).
33 	Imposition 	of 	the 	SubscLiber 	Line 	Charge 	and 	concurrent
reduction 	in 	switched 	access 	prices 	decreased 	the 	size 	of 	the
crOSS-SUbsidy. 	Larson, 	Makarewicz 	and 	Monson 	(1989), 	who 	studied
a 	large 	number 	of 	monthly 	bills 	for 	Southwestern 	Bell 	Telephone
Company 	customers, 	report 	that 	the 	imposition 	of 	subscriber 	line
charge 	significantly 	lowered 	the 	average 	subscriber's 	total
telephone 	bill. 	They 	also 	report 	that 	calling 	patterns 	do 	not
differ 	substantially 	between 	the 	average 	caller 	and 	low 	income
callers 	(i.e., 	average annual household income less than $15,000 	in
1988) 	and 	conclude 	that 	total 	telephone 	bills 	for 	average 	low
income 	subscribers 	also 	fell. 	Crandall 	(1991), 	pp. 	112-115,
reports 	that 	local/long 	distance 	repricing 	caused 	reductions 	in
telephone 	service 	costs 	of 	producing 	nontelephone 	goods 	and
services, 	resulting 	in 	customers 	gaining 	between 	$2.64 	and 	$11.82
per 	year 	in 	1987.
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relative prices of switched access and the possible local 	transport
alternatives, 	the 	proposed 	rule 	has 	implications 	for 	the 	size 	of
the 	long 	distance 	to 	local 	cross-subsidy.
Estimates 	of 	Marginal 	Cost 	and 	Contribution 	by 	Broad 	Category
Telephone 	service 	prices 	can 	be 	thought 	of 	as 	including 	the
marginal 	cost 	of 	the 	service and 	a 	contribution to 	overhead 	costs.
While 	first-best 	efficient 	prices 	equal 	marginal 	costs, 	such
pricing may not cover costs 	if marginal 	costs are 	less than average
costs. 	If 	the 	firm 	is 	to 	break 	even, 	prices 	must 	be 	set 	above
marginal 	cost 	to 	recover 	the 	residual 	fixed 	and common costs. 	For
second-best 	prices, 	the 	amount 	by 	which 	prices 	exceed 	marginal
costs 	will 	depend 	on 	the 	size 	of 	the 	residual 	revenue 	requirement
and, 	ideally, 	the 	demand 	elasticity 	of 	the 	service 	in 	question.~
We use the LEC cost function estimated by Ying and Shin 	(1993)
to 	calculate 	the 	marginal 	costs 	for 	three 	LEC 	outputs: 	customer
connections, 	local 	calls, 	and 	toll 	calls. 35 	These 	three 	services
represent 	a 	substantial 	degree 	of 	aggregation; 	data 	limitations
prevent 	further 	disaggregation. 	Nevertheless, 	the 	estimates,
properly 	interpreted, 	provide 	insight 	into 	the 	magnitude 	of 	the
~ 	See 	Brown 	and 	Sibley 	(1986), 	pp. 	39-44. 	In 	its 	simplest
form, 	second-best pricing, 	or Ramsey pricing, 	yields the price-cost
markup, 	(Pi 	- 	MCi ) /P i 	= 	A / 	-1'\i 	where 	Pj , 	MCj 	and 	1'\j 	are 	product 	i' s
price, 	marginal 	cost, 	and demand 	elasticity, 	respectively. 	A (the
"Ramsey number") 	increases with the size of the costs not recovered
through marginal 	cost 	pricing. 	This 	formula 	becomes 	significantly
more 	complex 	for 	a 	multiproduct 	firm.
35 	Shin and 	Ying 	(1992) 	and Ying and 	Shin 	(1993) 	are the 	only
cost studies that provide marginal cost estimates at the LEC level.
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cross-subsidy 	from 	toll 	service 	to 	local 	service. 	The 	estimated
marginal 	costs are 	long-run marginal 	costs, 	i.e., 	they assume 	that
LECs 	can 	minimize 	their 	total 	costs 	subject 	to 	their 	regulatory
constraints 	in 	providing 	the 	demanded 	telephone 	services. 	For
purposes 	of 	designing 	regulatory 	policy, 	we 	believe 	that 	long-run
costs 	are 	appropriate.~
It 	is 	necessary 	to 	be 	precise 	as 	to 	what 	these 	three 	outputs
represent. 	Customer 	connections 	include 	all 	local 	loops 	operated
by 	the 	LEC. 	These 	represent 	an 	aggregation 	of 	business,
residential, 	urban 	and 	rural 	connections 	which 	can 	have
substantially 	different 	marginal 	costs. 	The 	estimated 	marginal
cost 	of 	a 	customer 	connection 	represents 	a 	weighted 	average 	over
all 	such 	classifications. 	Local 	and 	toll 	calls 	are 	the 	number 	of
such calls handled by the LEC 	in the year. 	The total 	cost of local
calling 	increases 	with 	capacity 	(e.g., 	more 	local 	interoffice
trunks, 	larger 	switches) 	and 	not 	necessarily 	with 	usage. 	If
capacity 	utilization 	is 	relati.vely 	constant 	across 	LECs 	and 	over
time, 	then 	the 	number 	of 	local 	calls 	will 	be 	a 	fairly 	good 	proxy
for 	capacity. 	The 	same 	points 	can 	be 	made 	for 	toll 	calls. 	Toll
~ 	Other 	studies 	have 	estimated 	short-run 	marginal 	costs 	or
incremental 	costs. 	The 	marginal-cost 	estimates 	based 	on 	Ying 	and
Shin 	(1993) 	exceed 	those 	in 	other 	studies 	for 	three 	main 	reasons:
(1) 	these 	other studies estimate short-run marginal 	or 	incremental
costs: 	(2) 	they 	are 	done 	at 	the 	central 	office 	level: 	and 	(3) 	they
use different output variables. 	Incremental 	cost 	studies, 	such as
Mitchell 	(1990), 	assume 	that 	most 	of 	the 	costs 	(e.g., 	all
nonrecurring 	costs) 	are 	fixed: 	Ying 	and 	Shin 	(1993), 	by 	contrast,
allow 	these 	costs 	to 	vary 	in 	the 	long-run. 	The 	studies 	estimate
that 	costs 	at 	the 	central-office 	level 	exclude 	firm-level 	costs
that 	vary 	with 	outputs. 	We 	note 	that 	differences 	in 	output
measures 	make 	direct 	comparisons 	among 	studies 	difficult.
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calls 	here 	include 	intraLATA, 	interLATA 	intrastate, 	and 	interLATA
interstate calls. 	The costs 	included are only those costs 	incurred
by 	the 	LEC 	(e. g., 	switching 	and 	local 	transport 	for 	interLATA
calls) .
Table 	1
Estimated 	Real 	Marginal 	Costs 	for
Customer 	connections, 	Local 	Calls, 	and 	Toll 	Calls
1983 	Dollars, 	58 	Observations 	per 	Year
Year 	Customer 	Local 	Calls 	Toll 	Calls
Connections 	($ICall) 	($ICall)
($/Month)
Mean 	Standard 	Mean 	Standard 	Mean 	Standard
Error 	Error 	Error
1976 	25.07 	(0.82) 	0.036 	(0.0028) 	0.276 	(0.0171)
1977 	24.37 	(0.78) 	0.034 	(0.0025) 	0.253 	(0.0150)
1978 	25.05 	(0.77) 	0.032 	(0.0024) 	0.234 	(0.0138)
1979 	25.47 	(0.76) 	0.029 	(0.0019) 	0.206 	(0.0097)
1980 	26.78 	(0.75) 	0.026 	(0.0018) 	0.192 	(0.0087)
1981 	31.36 	(0.88) 	0.024 	(0.0014) 	0.179 	(0.0081)
1982 	33.79 	(0.99) 	0.026 	(0.0012) 	0.181 	(0.0088)
1983 	35.51 	(1.30) 	0.019 	(0.0011) 	0.173 	(0.0083)
1984 	42.96 	(1. 16) 	0.028 	(0.0016) 	0.175 	(0.0084)
1985 	38.56 	(0.92) 	0.023 	(0.0012) 	0.156 	(0.0065)
1986 	34.37 	(0.77) 	0.021 	(0.0012) 	0.141 	(0.0055)
1987 	33.15 	(0.81) 	0.021 	(0.0012) 	0.124 	(0.0053)
Estimates of LEC marginal 	costs are presented in Table 1. 	The
average 	estimated 	marginal 	cost 	of 	a 	customer 	connection 	(in 	1983
dollars) 	increased 	from 	1976 	through 	1984 	then 	declined. 	The
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average 	for 	all 	years 	is 	$31.13 	per 	month. 37 	This 	estimate 	may
understate the marginal cost of a 	residential connection because it
includes 	some business 	lines 	that 	typically 	are 	shorter and 	entail
a 	lower 	marginal 	cost 	per 	line. 	The 	estimated 	marginal 	cost 	of 	a
customer connection should 	not 	be 	confused with 	the 	cost 	of 	only a
local 	loop. 	To 	the 	extent 	that 	other 	services 	(e.g., 	directory
assistance 	and 	billing) 	are 	used 	in 	proportion 	to 	the 	number 	of
loops, 	but 	not 	the 	volume 	of 	local 	and 	toll 	calling, 	their 	costs
are 	also 	included 	in 	the 	estimated 	marginal 	cost 	of 	a 	customer
connection. 	Also, 	because 	additional 	loops 	typically 	require
addi tional 	switcl"' i.-tg 	and 	trunking 	capacity 	in 	anticipation 	of
calling 	volume, 	these 	costs 	are 	included 	in 	estimated 	marginal
costs. 	Table 1 also shows that the average estimated marginal 	cost
of 	a 	toll 	call 	fell 	from 	almost 	28 	cents 	to 	12.4 	cents during 	this
period. 38 	We 	interpret 	the 	marginal 	cost 	of 	a 	toll 	call 	as
providing 	an 	approximation 	for 	the 	cost 	of 	switched 	access. 39
37 	For 	over 	90 	percent 	of 	the 	sample 	points, 	the 	estimated
marginal 	cost 	of 	a 	customer 	connection 	is 	between 	$20 	and 	$48 	per
month.
38 	Again there 	are variations 	in the 	estimated marginal 	costs
for toll 	calls. 	However, 	over 90 percent of all estimated marginal
costs of a 	toll 	call were between $0.10 	and 	$0.35. 	In 	1987, 	all 	of
the 	estimated marginal 	costs 	were 	between 	$0.075 	and 	$0.22.
39 	This 	interpretation 	is 	sUbject 	to 	several 	qualifications.
The data aggregate 	interstate and 	intrastate calls; 	only the former
are 	regulated 	by 	the 	FCC. 	Further, 	the 	LEC 	provides 	different
services 	for 	interLATA 	calls 	and 	for 	intraLATA 	calls. 	For
interLATA calls 	(which can be either interstate or intrastate), 	the
LEC 	provides 	switching 	and 	local 	transport 	for 	the 	ends 	of 	a 	call
and does not provide the 	long distance transmission. 	For intraLATA
calls 	(which 	are 	predominately 	intrastate) 	the 	LEC 	provides
switching 	and 	trunking 	for 	the 	whole 	call. 	Notwithstanding 	these
(continued ... )
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Table 	2
Prices 	and 	Estimated 	Marginal 	Costs 	for
Local 	Residential 	Service 	and 	Switched 	Access
1983 	Dollars
Year 	Residential 	Local
Service 	($/Month)
switched 	Access
($/Call)
Average 	Marginal 	Average
Price 	Cost 	Price
Marginal
Cost
1983
1984
1985
1986
1987
1988
1989
1990
1991
11.63
12.85
13.51
14.72
14.67
14.01
14.14
13.61
13.66
35.51
42.96
38.56
34.37
33.15
0.833
0.770
0.671
0.526
0.445
0.372
0.293
0.261
0.173
0.175
0.156
0.141
0.124
• 	•	
Assum1ng 	that 	the 	average 	length 	of 	a 	toll
call 	is 	five 	minutes.
Estimated 	marginal 	costs 	are 	compared 	with 	average 	prices~
in 	Table 	2. 	The 	price 	of 	local 	service 	is 	always 	less 	than 	half
its 	marginal 	cost. 	While 	the 	price 	of 	switched 	access 	has 	fallen
dramatically 	since 	1987, 	it was 	four 	times 	its marginal 	cost prior
to 	1987. 	Even 	if 	the 	marginal 	cost 	of 	switched 	access 	did 	not
39 ( ... continued)
complications, 	it 	seems 	:..-easonable 	to 	interpret 	the 	estimated
marginal cost for toll calls generated in this analysis 	(12.4 	cents
per call 	in 1987) 	as the marginal cost of providing carrier access.
~ 	Price 	information 	is 	from u.s. 	Federal-State Board 	(1992),
pp. 	288, 	294. 	Prices 	are 	deflated 	using 	the 	CPl. 	For 	comFarison
purposes, 	switched 	access 	prices 	per 	minute 	were 	converted 	to
prices 	per call 	assuming 	an average 	call 	duration 	of 	five minutes.
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continue its downward trend, 	it is 	likely still to be significantly
below 	its 	price. 	This 	table 	provides 	evidence 	that 	the 	cross-
subsidy 	from 	long 	distance 	to 	local 	service 	is 	still 	large.
It 	is often argued that pricing toll 	calls above marginal 	cost
is 	necessary 	to 	cover 	the 	fixed 	costs 	of 	the 	local 	network. 	The
preceding 	discussion 	shows, 	however, 	that 	much 	of 	the 	difference
between 	the 	price 	and 	marginal 	cost 	of 	a 	toll 	call 	serves 	to
subsidize 	customer 	connections. 	It 	is 	possible 	to 	estimate 	the
"revenue shortfall" 	that would result 	if ~ outputs were priced at
marginal 	cost. 	"Revenue 	shortfall" 	for 	a 	given 	mix 	of 	outputs 	is
the 	difference 	between 	total 	costs 	and 	the 	revenues 	that 	would 	be
collected 	if 	prices 	equaled 	marginal 	cost. 	If 	actual 	quantities
are 	used, 	then 	estimated 	revenue 	shortfalls 	for 	1976-1987 	average
only 	about 	2 	percent 	of 	total 	costs. 41 	This 	percentage 	is 	fairly
stable 	over 	time. 42 	This 	indicates 	that 	efficient 	(e.g., 	Ramsey)
prices 	would 	have 	contribution 	elements 	quite 	small 	relative 	to
marginal 	cost. 	For 	switched 	access 	in 	particular, 	contribution
elements 	would 	be 	much 	smaller 	than 	current 	prices 	imply.
41 	Since 	toll 	prices 	are 	substantially 	above 	their 	marginal
costs, 	existing 	toll 	quantity 	will 	understate 	the 	quantity 	that
would 	occur 	if 	price 	equals 	marginal 	cost. 	Since 	toll 	service 	is
much 	more 	demand 	elastic 	than 	local 	service, 	adjusting 	for 	this
effect 	will 	tend 	to 	decrease 	the 	revenue 	shortfall. 	Shin 	(1988)
reports 	similarly 	defined 	revenue 	shortfalls 	of 	15% 	for 	a 	cost
function 	estimated 	at 	the 	central 	office 	level. 	However, 	this
marginal 	cost 	at 	the 	central 	office 	level 	does 	not 	include 	costs
incurred 	outside 	the 	central 	office 	due 	to 	actions 	taken 	by 	the
central 	office. 	This 	could 	account 	for 	the 	larger 	revenue
shortfall 	using 	marginal 	cost 	pricing.
42 	Before 	1984, 	Bell 	shortfalls 	were 	larger, 	in 	percentage
terms, 	than 	the 	nonBel1 	shortfalls.
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Cross-Subsidization 	and 	Bypass
Cross-subsidization 	of 	local 	residential 	service 	by 	long
distance 	service 	encourages 	end 	users 	and 	IXCs 	to 	bypass 	the 	LECs
because access prices are 	so far 	above their marginal 	cost. 	Bypass
concerns were the initial 	justification for 	reducing Carrier Common
Line 	Charges 	and 	implementing 	Subscriber 	Line 	charges. 43 	Yet,
despite 	the 	large 	reductions 	in 	switched 	access 	prices, 	switched
access 	avoidance 	has 	grown 	sUbstantially.~
The 	Special 	Access 	Order, 	which 	provides 	CAPs 	and 	IXCs
expanded 	interconnection 	opportunities 	for 	special 	access, 	seems
likely 	to 	foster 	additional 	bypass 	of 	some 	LEC 	facilities. 	The
magnitude 	of 	this 	bypass 	depends 	in 	large measure on the 	extent to
which special access and switched access are substitutes 	in demand.
While 	many 	commenters 	have 	noted 	this, 	none 	have 	presented
estimates 	of 	the 	degree 	of 	substi tutabil i ty. 	Parsons 	and 	Ward
(1993) 	estimate 	that 	the 	elasticity 	of 	substitution 	in 	demand 45
between switched and special 	access 	is 	-0.34 	for AT&T and -0.21 	for
the 	Other 	Common 	Carriers 	(OCCs).~ 	Tnese 	estimates 	imply 	that 	a
43 	See 	Bell 	Communications 	Research 	(1984),
Jackson 	and 	Rohlfs 	(1985) 	and 	USTA 	(1984). Brock 	(1984),
45
~ 	See Brittman, 	et ale 	(1989), 	Grandstaff and Watters 	(1989),
U.S. 	Federal-State 	Joint 	Board 	(1992), 	pp. 	299-306.
The 	elasticity 	of 	substitution 	in 	demand 	is 	not 	to 	be
confused 	with 	the 	more 	familiar 	cross 	elasticity 	in 	demand. 	The
elasticity of substitution in demand measures the percentage change
in 	the 	ratio 	of 	the 	quantity 	demanded 	of 	two 	goods 	due 	to 	a
percentage 	change 	in 	the 	ratio 	of 	their 	prices.
~ 	While 	the 	AT&T 	estimate
significant, 	the OCC estimate 	is 	not.
26
is 	highly 	statisticalJy
It 	is 	possible that the 	OCC
(continued ... )
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price 	increase 	in 	switched 	access 	relative 	to 	special 	access 	of
10%47 	would 	induce 	a 	3.4% 	decrease 	in 	the 	proportion 	of 	switched
to 	special 	access 	demanded 	by 	AT&T 	and 	a 	2.1% 	decrease 	for 	the
OCCs. 	Because 	the 	price 	markup 	over 	marginal 	costs 	is 	larger 	for
switched 	access 	than 	for 	special 	access, 	such changes 	could 	reduce
significantly 	the 	income 	that 	the 	LECs 	derive 	from 	sales 	to 	the
IXCs 	(the 	IXC 	"contribution") 	if 	switched 	access 	prices 	are 	not
reduced. 	These 	estimates 	suggests 	that 	delay 	in 	implementing 	the
proposals 	concerning 	interconnection 	for 	switched access will 	lead
to 	a 	significant 	reduction 	in 	the 	demand 	for 	switched 	access
services.
Parsons and Ward 	(1993) 	also show that when regulators require
that 	a 	LEC 	service 	with 	imperfect 	substitutes 	generate 	a 	fixed
dollar 	level 	of 	revenue 	recovery, 	because 	it 	has 	been 	allocated 	a
fixed 	amount 	of 	the 	common 	costs, 	end 	users 	with 	a 	greater 	demand
for 	the 	service have 	an 	incentive to 	remain with the 	LEC. 	In 	this
context, 	LECs 	typically have 	fixed 	dollar revenue 	requirements 	for
swi tched 	access. 	Larger 	IXCs 	(such 	as 	AT&T) 	have 	an 	additional
incentive 	to 	use 	LEC 	switched 	access 	because 	shifting 	some 	of 	its
purchases 	to 	special 	access 	or 	CAP 	bypass 	causes 	switched 	access
46 ( ... continued)
estimate 	is 	lower 	because, 	in 	some 	instances, 	special 	access 	is
used 	as 	a 	complement 	with 	switched 	access. 	To 	reduce 	switched
access 	local 	transport 	costs, 	some 	OCCs 	have 	installed 	"closet
POPs" 	in 	areas 	remote 	to 	their 	existing 	POPs 	and 	connected 	them
with 	LEC-provided 	special 	access.
47 	This 	figure 	is 	illustrative 	only. 	It 	is 	unclear 	just 	how
large the price decreases 	for special 	access will be as a 	result of
the 	special 	access 	interconnection 	order 	The 	FCC 	clearly 	expects
some 	price 	reductions 	(Special 	Access 	Order, 	para. 	2).
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prices 	to 	increase 	for 	the 	remaining 	purchases. 	If 	IXCs 	recognize
that 	using 	alternative 	services 	causes 	switched 	access 	prices 	to
rise, 	then 	they 	would 	include 	this 	price 	increase 	as 	a 	cost 	of
using 	the 	substitute.
In 	principle, 	this 	phenomenon 	(called 	the 	"Brandon 	Effect")
could 	diminish 	LEC 	concerns 	about 	the 	potential 	loss 	of 	revenues
due 	to users 	bypassing the 	switched network. 	However, 	two 	current
trends in telecommunications regulation could greatly attenuate the
Brandon 	Effect. 	First, 	increasing 	numbers 	of 	LECs 	are 	being
regulated 	via 	price-cap 	or 	incentive 	regulation. 	To 	the 	extent
that 	such 	approaches 	do 	not 	arbitrarily 	assign 	fixed 	and 	common
costs 	to 	different 	services 	for 	recovery, 	they 	render 	the 	fixed
dollar 	revenue 	requirement 	obsolete. 	Instead, 	prices 	would 	tend
toward 	the 	point 	where 	marginal 	revenue 	equals 	marginal 	cost 	and
rely 	less 	on 	an 	arbitrary 	assignment 	of 	fixed 	costs. 	Second,
expanded 	competition 	for 	carrier 	access 	could 	render 	the 	revenue
target 	unattainable. 	The 	Brandon 	Effect 	mechanism 	requires 	that
the 	LEe 	switched 	access 	demand 	elasticity 	be 	less 	than 	one 	(in
absolute terms) 	so that price increases generate revenue increases.
Increased competition between 	LECs, 	CAPs, 	IXCs 	and 	end-users could
cause 	the 	LEC 	switched 	access 	demand 	elasticity 	to 	exceed 	one.~
In sum, 	the 	important new regulations contained in the Special
Access Order will 	likely reduce, 	perhaps 	significantly, 	the demand
for 	switched 	access 	services. 	In 	some 	cases, 	the 	migration 	from
48 	See 	Landes 	and 	Posner 	(1981) 	for 	thg 	various 	factors
influencing 	the 	demand 	elasticity 	of 	a 	particular 	firm's 	product.
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switched 	access 	to 	its 	alternatives 	could 	occur 	even 	though 	the
LEC's costs of supplying switched access are 	less than those 	of the
new 	suppliers. 	Current 	regulations, 	however, 	inhibit 	LECs 	from
reducing switched access prices. 	This 	suggests that the FCC should
consider 	implementing 	its 	proposals 	concerning 	switched 	access
services 	as 	expeditiously 	as 	possible.
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VI. 	LEes 	Should 	Be 	Provided 	Pricing 	Flexibility
Competitive 	entry 	into 	previously 	monopolistic 	services
provides 	powerful 	incentives 	for 	the 	creation 	of 	an 	efficiently
operating 	market. 49 	In 	the 	short 	run, 	the 	threat 	of 	losing 	a
customer 	to 	a 	competitor 	induces 	the 	incumbent 	firm 	to 	maintain
prices 	close 	to 	marginal 	cost. 	The 	incumbent 	loses 	its 	monopoly
profits, 	but 	the 	increase 	in 	consumer 	welfare 	from 	lower 	prices
more than offsets this 	loss. 	In the 	long run, 	competition provides
incentives 	for the 	incumbent to become more productive. 	Firms that
use 	inputs more 	efficiently and 	continue to develop more 	efficient
production 	techniques 	can 	expect 	to 	be 	rewarded 	with 	greater
profits.
However, 	for 	the 	introduction of competition 	into 	a 	regulated
market 	to 	foster 	more 	efficient 	prices, 	the 	regUlated 	incumbent
must 	be 	allowed 	to 	set 	prices 	closer to marginal 	cost. 	Currently,
local 	transport 	prices 	are 	required to 	be 	the 	same 	even when 	their
marginal 	costs 	are 	sUbstantially 	different. 	For 	instance, 	it 	is
less 	costly to 	serve dense, 	urban 	areas 	than 	rural 	areas. 	without
the 	ability 	to 	set 	prices 	closer 	to 	the 	actual 	cost 	of 	service,
LECs will 	provide 	a 	pricing umbrella 	in the 	low cost markets 	under
which 	CAPs 	can 	enter 	at 	prices 	substantially 	above 	LEC 	costs. 	It
is 	possible that, 	in 	some 	of 	these 	cases, 	the 	LEC would 	be 	the 	low
cost 	provider 	but 	the 	price 	umbrella 	allows 	CAPs 	to 	enter
nevertheless. 	Some 	LEC 	pricing 	flexibility 	would 	be 	required 	so
49 	An 	exception 	is 	the 	case 	of 	an 	nonsustainable 	natural
monopoly, 	where 	prices 	and 	entry 	are 	regulated 	as 	discussed 	in
section 	IV 	above.
30
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that 	LECs 	could 	respond 	to 	potential 	CAP 	entry 	and, 	thus, 	induce
only 	efficient 	entry.~
Should less efficient entrants operate under a 	regulated price
umbrella, 	the 	regulatory 	response 	consistent 	with 	economic
efficiency 	would 	eliminate 	the 	price 	umbrella, 	not 	maintain 	or
reinstate 	entry 	barriers. 	Moreover, 	even 	if 	the 	price umbrella 	is
not 	eliminated, 	the 	social 	cost 	of 	inefficient 	entry 	must 	be
weighed 	against 	the 	social 	cost 	of 	the 	price 	distortion. 	An
inefficient entrant will 	produce 	its product at a 	cost greater than
the 	possible 	minimum 	and 	this 	represents 	a 	social 	cost. 	However,
it will 	also 	offer 	its 	product 	at 	a 	price 	below the 	LEC's 	alld 	this
represents 	a 	social 	gain. 	Depending 	on 	the 	actual 	market 	and 	cost
conditions, 	entry by a 	firm 	less 	efficient than 	the 	incumbent 	into
a 	market 	with 	a 	regulated 	price 	umbrella 	could 	be 	welfare
increasing.
In 	its 	interconnection 	order 	for 	special 	access, 	the 	FCC
recognized 	that 	LEC 	pricing 	flexibility 	was 	necessary 	to 	promote
eff icient 	entry. 51 	The 	same 	conditions 	are 	I ikely 	to 	hold 	for
switched 	access 	local 	transport 	indicating 	that 	some 	degree 	of
pricing 	flexibility 	is 	appropriate.
~ 	Palmer 	(1992) 	addresses 	the 	issue 	of 	efficient 	entry 	in
local 	telephone 	service 	relating 	to 	cross-subsidies 	from 	low-cost
high-priced 	local 	business 	service 	to 	high-cost 	low-priced 	local
residential 	service. 	If 	entry were 	to 	occur, 	it would be 	isolated
to 	business 	service 	where 	the 	divergence 	between 	prices 	and 	costs
are 	large 	enough 	to 	induce 	(potentially) 	inefficient 	entry. 	She
concludes 	that 	if prices 	better reflected costs, 	entry would occur
only 	where 	the 	entrant 	had 	lower 	costs.
51 	Second 	Notice, 	para. 	32.
31
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VII. 	Conclusions
The 	FCC 	anticipates 	that 	the 	measures 	contemplated 	by 	the
Second 	Notice 	':.'ill 	provide 	opportunities 	for 	efficient 	entry 	into
switched 	access 	services 	and 	reduce 	their 	prices. 	The 	analysis 	in
this 	comment 	supports 	these 	views, 	and 	we 	therefore 	support 	the
Second 	Notice's 	proposals 	to 	introduce 	additional 	competition 	to
the 	local 	transport 	element 	of 	the 	switched 	access 	market.
Four 	specific 	points 	were 	addressed 	in 	this 	comment. 	First,
prohibiting entry into local transport services cannot be supported
on 	economic 	efficiency 	grounds, 	and 	such 	entry 	should 	be
accompanied by a 	requirement that LECs provide local 	loop access on
a 	common 	carrier 	basis. 	Second, 	the 	price 	of 	switched 	access 	is
sUbstantially larger than 	(we estimate twice as large) 	its marginal
cost. 	Third, 	substantial migration from switched access to special
access 	will 	occur 	if 	implementing 	these 	proposed 	rules 	is
significantly delayed. 	Fourth, 	some degree 	of pricing 	flexibility
for 	the 	LECs 	is 	required 	to 	insure 	that 	only 	efficient 	entry
occurs. 	We 	believe 	these 	findings 	generally 	support 	the 	FCC's
proposals 	concerning 	expanded 	interconnection 	for 	interstate
switched transport, 	as 	well 	as 	the 	FCC's 	tentative conclusion that
expanded 	interconnection 	for 	switched 	access 	is 	likely 	to 	benefit
consumers 	and 	promote 	competition.
32
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Unregulated Markets: 	Understanding the 	Divestiture 	in U.s. 	v.
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Estimates 	and Natural Monopoly Tests 	for 	the 	Bell 	System," 	in
D. 	S. 	Evans, 	ed., 	Breaking 	Up 	Bell 	Amsterdam: 	North-Holland,
1983.
Faulhaber, 	Gerald R., 	Telecommunications 	in Turmoil 	Cambridge, 	MA:
Ballinger 	Publishing 	Co., 	1987.
Faulhaber, 	Gerald 	R., 	"Cross-Subsidization: 	Pricing 	in 	Public
Enterprise," 	American 	Economic 	Review 	65 	(1975) 	966-977.
Grandstaff, 	Peter 	J. 	and 	Watters, 	John 	S., 	"Switched 	Access
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Griffen, 	James 	M., 	"The 	Welfare 	Implications 	of 	Externalities 	and
Price Elasticities for Telecommunications Pricing," Review of
Economics 	and 	Statistics 	64 	(1982).
Griffen, 	James 	M. 	and 	Thomas 	H. 	Mayor, 	"The 	Welfare 	Gain 	from
Efficient pricing of Local Telephone Services," Journal of Law
and 	Economics 	30 	(1987) 	465-496.
Jackson, 	C. 	L. 	and 	Rohlfs, 	J. 	H., 	Access 	Charging 	and 	Bypass
Adoption 	Shooshan 	and 	Jackson, 	Inc., 	Washington, 	DC 	1985.
Johnson, 	Leland, 	Competition 	and 	Cross-Subsidization 	in 	the
Telephone 	Industry 	Santa 	Monica, 	CA: 	Rand 	Corporation, 	1982.
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Kasserman, 	David 	L., 	Mayo, 	John 	W. 	and 	Flynn, 	Joseph 	E., 	"Cross-
Substitution 	in 	Telecommunications: 	Beyond 	the 	Universal
Service Fairy Tale," Journal 	of Regulatory Economics 2 	(1990).
Kahn, 	Alfred 	E. 	and 	Shew, 	William 	B., 	"Current 	Issues 	in
Telecommunications 	Regulation: 	Pricing," 	Yale 	Journal 	on
Regulation 	4 	(1987).
Landes, 	Wiiliam 	M. 	and 	Richard 	A. 	Posner, 	"Market 	Power 	in
Antitrust 	Cases," 	Harvard 	Law 	Review 	94 	(1981).
Larson, 	Alexander 	C., 	Thomas 	J. 	Makarewicz, 	and 	Calvin 	S. 	Monson,
"The 	Effect 	of 	Subscriber 	Line 	Charges 	on 	Residential
Telephone 	Bills," 	Telecommunications 	Policy 	(1989) 	337-354.
Larson, 	Alexander 	C. 	and 	Mudd, 	Douglas 	R., 	"Collocation 	and
Telecommunications 	Policy: 	A Fostering-of Competition on the
Merits," 	California 	Western 	Law Review 	28 	(1992).
Mitchell, 	Bridger, 	"Incremental Costs of Telephone Access and Local
Use," 	Santa 	Monica, 	CA: 	Rand 	Corporation, 	1990.
Parsons, 	Steven 	G. 	and 	Ward, 	Michael 	R., 	"Bypass 	Incentives 	When
Regulators 	Impose 	a 	Fixed 	Dollar 	Revenue 	Requirement 	for
Access," 	Unpublished 	Manuscript 	(July 	1991).
Parsons, 	Steven G. 	and Ward, 	Michael R., 	"Telecommunications Bypass
and 	the 	'Brandon' 	Effect," 	FTC 	Bureau 	of 	Economics 	Working
Paper 	No. 	199 	(Feb 	1993).
Rohlfs, 	Jeffrey, 	"Economically Efficient Bell System Pricing," Bell
Laboratories 	Discussion 	Paper 	(1979).
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Revisited," 	Applied 	Economics 	22 	(1990) 	1661-1674.
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Sharkey, 	William 	W., 	The 	Theory 	of 	Natural 	Monopoly 	New 	York, 	NY:
cambridge 	University 	Press, 	1982.
Shin, 	Richard, 	"Econometric Estimation of Telephone Costs for 	Local
Exchange 	Companies," 	Ph.D. 	dissertation, 	University 	of
California, 	Berkeley, 	(1988).
Shin, 	Richard 	and 	John 	S. 	Ying, 	"Unnatural 	Monopolies 	in 	Local
Telephones," 	Rand 	Journal 	of 	Economics 	(1992).
Temin, 	Peter, 	The 	Fall 	of 	the 	Bell 	System 	New 	York, 	NY: 	Cambridge
University 	Press, 	1987.
U.S. 	Federal 	Communications 	Commission, 	Statistics 	of
Communications 	Common 	Carriers, 	Washington, 	DC: 	U. S.
Government 	Publishing 	Office, 	various 	years.
U.S. 	Federal-State 	Joint 	Board, 	Monitoring 	Report 	(CC 	Docket 	No.
87-339) 	Washington, 	DC, 	July, 	1992.
united 	States 	Telephone 	Association, 	Bypass 	Study 	1984.
Wenders, 	John 	T., 	The 	Economics 	of 	Telecommunications 	Cambridge,
MA: 	Ballinger 	Puhlishing 	Company, 	1987.
Wenders, 	John T. 	and 	Egan, 	Bruce 	L., 	"The 	Implications 	of 	Economic
Efficiency 	for 	US 	Telecommunications 	Policy,"
Telecommunications 	Policy 	10 	(March 	1986) 	33-40.
Ying, 	John S. 	and Richard 	Shin, 	"Costly Gains 	to 	Breaking Up: 	LECs
and 	the 	Baby 	Bells," 	Review 	of 	Economics 	and 	Statistics
(1993) .
36
Complete printed PDF page 38
WORKING
PAPERS
and 	the 	"Brandon Effect"
by
Steven G. 	Parsons
Southwestern Bell Telephone
and
Michael R. 	Ward
Federal Trad£ Commission
WORKING PAPER NO. 	199
February 	1993
FTC Bureau of Economic working papers are preliminary materials circulated to stimulate discussion and critical
comment. All data contained in them are in the public domain. This includes information obtained by the Commis-
sion which has become part of public record. The analyses and conclusions set forth are those of the authors and do
not necessarily reflect the views of other members of the Bureau of Economics. other Commission staff. or the Com-
mission itself. t:pon request. single copies of the paper will be provided. References in publications to FTC Bureau of
Economics working papers by FTC economists (other than acknowledgment by a writer that he has access to such un-
published materials) should be cleared with the author to protect the tentative character of these papers.
BUREAU OF ECONOMICS
FEDERAL TRADE COMMISSION
\VASHI~GTON. D.C.
Complete printed PDF page 39

Complete printed PDF page 40
Telecommunications Bypass and the "Brandon Effect"·
Steven G. Parsons
Southwestern Bell Telephone
Michael R. Ward
FederaJ Trade Commission
February, 1993
Abstract: 	The creation of a charge for long distance companies to access the local
telephone companies' switched network created the incentive to bypass the local switched network
in order to avoid access charges that were substantially above cost. 	This paper explores the
implications of a federal regulatory policy of a target total dollar switched access revenue
requirement. In particular, the paper focuses on the so called WBr-.,don Effect Win which bypass
incentives are attenuated when there is a target total dollar switched access revenue. 	Empirical
analysis confirms the wBrandon Effect Won bypass decisions.
• 	The views expressed here do not necessarily reflect those of either Southwestern BeU Telephone or the
Federal Trade Commission. This paper is an extension of Parsons and Ward (1991). We would like to thank Paul
Brandon, Tim Daniel, Peter Griffes, Alex Latson, Doug Mudd, Bob Rogers, Richard Shin and Ken Troske for
comments and suggestions and Dolly Howarth for research assistance.
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1. 	Introduction
The divestiture of AT&T and the FCC's order on access charges accentuated a conflict between
telecommuniCations policy and competitive forces. In particular, prior to the divestiture of AT&T, the price of long
distance service gradually grew in order to offset a growing fraction of the cost of basic local telephone service
assigned to long distance operations (Johnson (1982)). After 1983, the Federal Communications Commission (FCC)
maintained this subsidy by requiring long distance companies to pay a per-minute-of-use fee as part of the switched
access charge. I 	Since switched access charges are substantially in excess of local exchange company costs of
providing switched access, competitive pressures are driving long distance companies to seek: lower priced
alternative means of connecting to end users; they are seeking to "bypass" the local switched network: and its
attendant charges.
Long distance companies purchase telephone access, usually from the Local Exchange Companies (LECs),
since long distance networks generally do not reach customers' telephones. The decision to bypass essentially entails
a comparison of the long distance companies' cost of bypass and the price of switched access provided by the LEC.
Previous studies have focused on the lower cost of bypass for large and geographically concentrated customers (see,
for example, Dellcore (1984), Britman, et al. (1989), Brock: (1984), Grandstaff and Watters (1989), Jaclcson and
I'.vhlfs (1985) and USTA (1984)). In contrast, this study addresses the clifferences in the shadow price of switched
access across long distance companies. 	Shadow and nominal prices for switched access could differ for a long
distance company because its choice of access could affect the switched access price charged.
If the total long distance switched access revenue is known to be a constant sum, then (by regulatory fiat)
a shift toward bypass from switched access by one firm will raise switched access prices for all firms. 	If the
bypassing long distance company represents a small fraction of the switched access volume, most of the switched
access price increase is borne by its competitors. 	If it represents a large fraction, the long distance company
internalizes most of the switched access price increase. A long distance company's decision to bypass will depend,
I The long distance to local subsidy was reduced in 1985, when a Subscriber Line Charge was instituted as a
recurring monthly charge to local service subscribers. 	However, SLC revenues currently make up only about a
third of all interstate network access revenues.
Complete printed PDF page 42
in part, on the degree to which the attendant switched access price increase is internalized. 	Thus, larger long
distance companies have lower shadow prices for switched access.
The attenuation of the long distance companies' incentive to bypass due to the regulators' desire to capture
a fixed revenue requirement from switched access bas been labeled the "Brandon Effect" after the AT&T executive
who introduced the idea. 	Brandon (1982) is the first known reference of this phenomenon. 	Also, Brock (1984),
on page 4, implies a variant when he states ftlf some companies bypass the switched access facilities and the revenue
requirement to be provided by access remains constant, then access prices will be raised for the remaining
customers. The higher prices will then induce further bypass and further increases until either equilibrium access
price is reached ... or all customers find alternatives to switched access." 	In Brock's scenario, regulators seek
a fixed amount of revenue from access but the long distance companies do not consider this regulatory objective
when they make bypass decisions. 	Katz and Willig (1985) model a version of the Brandon Effect in the context
of determining if proposed long distance rates entail predatory pricing. 	Simnett (1988) captures a version of the
Brandon Effect by constructing differing switched access shadow prices to AT&T and the other long distance
companies, but he does not address the bypass implications. To our knowledge, no one has tested for the existence
of the Brandon Effect.
The principle contributions of this paper are a mathematically explicit model of the Brandon Effect and an
empirical verification of the existence and size of the Brandon Effect. Two variants of firm specific accesslbypass
demand substitution equations are estimated. 	The estimation procedures employed are extensions of existing
instrumental variable methods for simultaneous systems of equations. 	The resultS do not uniformly confirm, but
do suggest that regulators seek constant total dollar subsidies from long distance companies and these firms' bypass
decisions reflect a Brandon Effect.
The next section describes some of the features of access provision in the telecommunications industry in
more detail. 	Section 3 presents a simple model of bypass with an emphasis on the Brandon Effect and its
implications. In this model, the long distance companies shadow price for switched access is equal to the nominal
price times one minus the share of switched access purchased by the long distance company. 	Section 4 describes
the testable hypotheses implied by the model and the data with which the tests were conducted. The fifth section
2
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presents and discusses empirical findings for the existence and significance of the Brandon Effect. 1llis is followed
by a brief conclusion.
2. 	A Description of the Access Market
A long distance telephone company operates a communications network that connects local telephone
exchanges, hence, it is called an Interexchange Carrier (IC). 	The LECs, such as the regional Bell Operating
Companies and GTE, transport long distance telephone calls between customers' premises and the nearest
termination point of an JCs' network. These services are collectively called carrier access and represent nearly half
of all JC costs. 	AT&T's 1984 divestiture effectively precluded the Bell operating companies from offering long
distance service.
States regulate prices for intrastate services, and the FCC regulates prices for interstate services. such as
interstate switched access. 	Until recently, JCs and LECs operated under rate-of-retum regulation. 2 To accomplish
joint regulatory oversight, some LEC assets are allocated to the intrastate and interstate jurisdictions for cost
recovery in a necessarily arbitrary way. 	The costs assigned to the interstate jurisdiction are primarily recovered
through a switched access charge on each minute of long distance connection and, beginning in 1985, a Subscriber
Line Charge billed as a .~at rate monthly C~4I'ge on each telephone line. 3
In Smith v. Rlinois Bell Tel. Co. (1930), the courts ruled that since AT&T's long distance service used the
local exchange network, a portion of the cost of the local net-Nork should be recovered through 10Lg distance rates.
The portion of the local network assigned to long distance service steadily grew to 27% in 1982 4 with little relation
2 The FCC began development of the AT&T Price Cap Plan in 1987 with Policy and Rules Concerning Rates
for Dominant Carriers, CC Docket No. 87-313, Notice of Proposed Rulemaking, 2 FCC Red 5208 (1987). 	Price
cap regulation for AT&T took effect in July, 1989. 	As a result of the FCC's Second Report and Order in CC
Docket 87-313 released October 4, 1990, price caps for LECs became effective January 1, 1991. 	However, the
LECs are still strongly tied to rate-of-retum regulation, because earnings above certain thresholds results in lower
future LEC prices and, thus, rates-of-retum.
3 Most special access, as well as some smaller revenue services, are also assigned to the interstate jurisdiction.
4 Originally the proportion of the local network costs asc;igned to long distance operations was the fraction of
calls going over long distances. 	In the early 1950s, this was less than 3 % and by 1982 it was 8 %.
3
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to underlying economic costs. S The FCC's 1983 Access Charge Plan formalized this cost assignment and cost
recovery mechanism with an additional charge, called a CI~rrier Common Line Charge, on the switching function
of switched access. At first, the non-AT&T ICs had "nonpremium" connections to the LECs (e.g., customers were
required to dial extra digits to reach non-AT&T ICs); the additional charge for nonpremium access was set at 45 %
of that for premium service obtained by AT&T. The divestiture agreement required the LECs to install equipment
to provide equal access to any IC asking for it. 	The equal access equipment is currently in place for nearly all
(91 %) IC customers. 6
In devising its access charge plan, the FCC eventually recognized that if usage-sensitive access charges
greatly exceeded marginal costs, ICs and high volume customers would have an incentive to make alternate
connections between tbe customer's premises and the IC's network in order to bypass the LEC and avoid switched
access charges. 	Thus, the FCC decided that part of the basic local exchange costs allocated to the interstate
jurisdiction should be recovered through a fixed recurring monthly Subscriber Line Charge billed to the customer
rather than the usage sensitive switched access charges billed to the IC. 1 Economists bad argued that these costs
were incurred because customers had access to the network and did not rise with usage, thus movement toward a
recurring monthly charge increased efficiency by aligning prices more closely with costs.' 	A Subscriber Line
Charge was gradually institute4f that lowered switched access charges but did not eliminate them. 	In 1984, the
average switched access price was $.173 per conversation minute; by 1991 it was $.072 (U.S. Federal-State Joint
Board (1991).
S See also, Temin and Peters (1985a, 1985b), Griffen (1982), Kasserman, Mayo and Flynn (1990), Kahn and
Shew (1987) and Johnson (1982). 	With respect to the history of deregulation and telecommunications policy, see
generally, Brock(l981), Faulhaber (1987), Temin (1987) and Larson and Mudd (1992).
6 	However, nonpremium service still accounts for 5% of acc service and 20% of the ICs do not purchase
premium service f!'om Bell Operating Companies (Statistics of Communications Common Carriers (1991».
1 The Subscriber Line Charge was established in CC Dockets 78·72, and 80-28693 FCC 2d 241 (released
February 28, 1983).
, See Temin (1987) on the FCC's 1983 Access Charge Plan and Wenders (1987) and Wenders and Egan (1986)
on efficient pricing for access. 	Also see Kahn and Shew (1987).
9 The Subscriber Line Charge bas leveled off at a maximum mvnthly rate of $3.50 per line for residential and
single line business service and $6.00 per line for multi-line business service.
4
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The threat of bypass resulted in prices for access tbat more closely reflect the cost of service. 	One
response to this threat was the imposition of the Subscriber Line Charge and concurrent reductions in switched
access charges. 	Special access prices are based on circuit capacity rather than actual use, as with switched access,
and can be thought of as volume discounts for large and more demand elastic customers. Switched access rates are
averaged over geography and density, with substantial differences in the LEC's cost of service. 	Bypass bas
generally occurred where the cost of providing alternate access is the lowest. 	LECs have asked regulators for the
ability to set prices closer to actual costs in response to bypass competition. 	Originally, the competition was
relegated to the provision of dedicated carrier access. 	However, third-party access providers have asked regulators
for interconnection to LEC facilities primarily to offer switched transport service. 	If such interconnection is
granted, both the value of third-party-provided access and competition for access will increase.
Bypass of switched access falls into three categories: totally private networks, the use of non-LEC facilities
bypass between end users and ICs, and the use of LEC special access facilities between end users and ICs. 	A
number of totally private networks have been built. These were generally constructed for data communications or
other specialized needs however. Such networks are of tertiary significance as factor inputs for les and, therefore,
for our purposes, they are of liule concern. Facilities bypass can occur through an IC or customer owned line, but
it is increasingly obtained through third-party providers. 	Third-party or alternate access providers construct
localized fiber optic networks, usually in downtown or other business districts, which are connected to the ICs'
networks. 	Special access lines provided by the LECs are used for data and point-to-point private line service, as
well as switched acc/':ss charge avoidance. Altbough special access is thought to currently account for 70-80 percent
of total bypass (U .S. Federal-State Joint Board (1991», facilities bypass is sufficient to hold LEC prices in check.
Special access is purchased for a variety of llses, not all of which are consistent with switched access charge
avoidance. 	For instance, broadcasters lease audio and video transmission lines to link up to each other and to their
affiliated network. 	Also, computer communications are enhanced by digital data lines. 	These services require
features that switched access cannot provide (high speeds and digital transmission), and, in fact, they often do not
benefit from the ability to be switched. While data communications is growing, it does not represent a substantial
portion of the total LEC-bandled traffic.
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The types of special access more suited to switched access charge avoidance are voice grade lines, WATS
lines, and OSI (high capacity) connections. 	Voice grade lines and WATS lines are specifically designed to carry
voice traffic .. OSI connections have greater capacity, enabling up to 24 simultaneous voice-grade connections. A
higher capacity connection, OS3, is essentially equivalent to 28 OSI connections. However, quantity data for OS3
connections were unavailable for this study. 	WATS lines are a hybrid of special and switched access, since
customers are charged a monthly fee and a usage fee for local transport and switching but are not charged the
Carrier Common Line Charge. 	High speed data communications also use OSI connections. The fraction of OSI
connections used for data transmission is unknown however. While the mix of special access services changed since
1988, in aggregate, voice-grade lines, WATS lines and OS 1 connections comprise the great majority of special
access use for the time period of the data used in this study.
3. 	A Model of Inter-Exchange Carrier Bypass Incentives
The term "bypass· has been used to describe many activities; in this paper it is defined somewhat more
narrowly. The bypass decisions addressed here pertain to the method of connection the IC chooses for an end user.
For each customer connection, ICs are assumed to choose either to purchase switched access or bypass the LEC
switched network. 	An IC bypasser can build dedicated facilities between the IC's network and the customer's
premises, or it can gain connection through the lease of a dedicated line, usually from the LEC under a special
access arrangement. 	Both of these bypass alternatives represent continued use of the IC's network.
ICs :ue assumed to choose factor input levels to minimize the total costs; C, of providing a certain level
of service to their end users. Let i index ICs. If switched access, A;, and bypass, Bi , are closely substitutable factor
inputs, then the ICi will purchase these inputs in the proportion that equates their marginal costs,
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dC,
dA j
(1)
Initially, the marginal cost to the IC of switched access is assumed to be a fixed constant, ordinarily its nominal
price. The marginal cost of bypass is increasing with the amount of bypass. 10 Equation (I) bas an interior solution
if the marginal cost of bypass is below the marginal cost of LEC access for the first customer and above that for
the last.
Let r be the price of switched access and c be the constant marginal cost to the LEC of providing this
access. Then total switched access expenditures for ICi are r Ai and marginallC costs of LEC switched access are
act 	dr
.. r + A.-.
dA 	IdA.	j 	I
(2)
The derivative dr/dA i is determined by assuming that the total revenue, R, from switched access is constant, and
the price is determined by dividing switched aCce5'l revenue by the total switched access demanded, r = R / 1; Aj .
The effect of a change in Ai on r is derived by r differentiated with respect to A; while holding R ud Ak constant
for k ~ i, so that
dr
ciA j
= R 	r
- EjA j •
(3)
Finally, combining equations (1), (2) and (3) yields:
where Wi is lei'S share of switched access, Wi = Ai / 1:j Aj •
(4)
10 The marginal cost to the IC of bypass along any particular route is likely to decrease with respect to the
quantity of calls or even bypass circuits along that route. The marginal cost of bypass will be increasing as routes
are added; additional routes will be longer with less traffic.
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Equation (4) indicates that ICs choose the level of SVo'itched access and bypass such that the marginal cost
of bypass is equated with a •.Jue which can be less than the price of switched access. 	Moreover, this shadow price
varies inversely with the IC's share of LEC switched aCCe1>s. 	In essence, a fixed revenue level for LECs from
switched access causes an IC to have a diminished incentive to bypass, and this effect is greater for a larger IC.
Consider the monopsonist IC and the fringe IC as polar opposites. A monopsonist IC (Wi = I) has a shadow price
of switched access equal to zero and the revenue is transferred as a lump sum tax. 	The fringe IC (Wi::: 0) has a
shadow price close to the full switched access price, r.
The source of the difference in shadow prices between small and large ICs is important to understand. This
form of regulation, seeking a constant dollar amount of switched access revenue, confers a strategic compliment
attribute to switched access. 	As one IC uses more switched access, the switched access price to all users falls, and
thus, all ICs' costs fall. 	As an IC's share of switched access rises, the portion of the complementarily that is
internalized also rises. 	For a switched access monopsonist, this complementarity is completely internalized; for a
fringe competitor it, is trivial to its decision process.
This model is, of course, a simplification of the actual market for access, and real world factors may
abrogate the Brandon Effect. Some of the more obvious potential criticisms will be considered and reconciled with
the ;- xiel presented. 	These criticisms stem from: the different means of bypassing switched access charges, the
potential endogeneity of the switched access share and the move toward price-eap regulation.
First, bypass in the model applies to all forms of switched access avoidance, but, in the tests below, bypass
is identified with special access. The important issue is whether, absent the Brandon Effect, the size of the IC will
greatly affect the choice of the form of bypass. LEC provided special access is often provided in the same way with
the same technology as third-party or IC-provided facilities bypass. 	Special access should be an excellent prox.y
for bypass in total. In addition, as noted earlier, special access constitutes the great majority of bypass.
Second, the analysis takes IC switched access shares as exogenous, yet the Brandon Effect could be a
determinant of the shares. The feedback would tend to increase IC switched access share differentials, since smaller
ICs are more likely to opt for bypass instead of switched access. 	The endogeneity is likely to be small relative to
the effects of other factors in the telecommunications industry during this time period however (e.g., IC price
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differentials). 	Since AT&T's share of switched access has fallen dramatically, this feedback appears to be small
relative to other factoi'll. 	In addition. because the feedback would cause an accentuating rather than countervailing
effect. the model can still be unambiguously tested.
Third, the move to "price-eap regulation" at the Federal level does not affect the applicability of the
analysis. 	AT&T's incentives toward bypass should not have changed substantially when rate-of-return regulation
was replaced by ·price-eap regulation." 	LECs have only faced "price-eap regulation· since January of 1991.11
Moreover, in both cases. the form of "price-eap regulation" adopted contains strong rate-of-return features through
sharing mechanisms beyond certain rate-of-return levels. The fixed dollar revenue framework still exists.
4. 	Empirical Tests
The analysis above implies that the relevant switched access price measure to ICs is not the posted nominal
price. 	The shadow price depends on the nominal price and the IC's relative share of all switched access. 	The
determinants of IC access demand and supply are estimated in order to conduct two tests of this hypothesis. First.
a test for positive correlation between switched access demand and switched access share of expenditures. ceteris
paribus, is conducted. This is performed by a t test in a multiple regression. Second, specification tests comparing
a ri~mand model employing the shadow price of switched access to a demand model employing the nominal price
are conducted using a series of nonnested J tests.
The principle data source for these tests is proprietary to Southwestern Bell Telephone Co., obtained under
a nondisclosure agreement. 	These data are monthly purchases from January 1989 through December 1991 of
switched and special access usage from Southwestern Bell by various ICs for each state in which Southwestern Bell
operates. 12 Data are generally available for AT&T. MCI, Sprint and an aggregation of all other carriers. 	Special
access quantity data exist only for AT&T and the aggregation of non-AT&T camel'll (called the Other Common
Carriers or OCCs). The variables available are revenues and quantities of both switched and special access usage.
II 	Price-eaps for LECs were established in CC Docket No. 87-313 (Released Oct. 4, 1990).
12 These are Arkansas, Kansas, Missouri, Oklahoma, and Texas.
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Since special access is the primary mode of switched access avoidance, it is used as a surrogate for total bypass.
Also available, but not at the individual IC level, are price indices for switched and special access for each month
and state. Information on the demand for long-distance service and cost of inputs into the production of access are
also used.
Estimating individual factor demand equations for switched and special access is problematic for two
reasons. 	First, the data are not rich enough to estimate reliably the necessary parameters. 	The prices of both
factors of production are likely to enter both factor demand equations. 	Since these prices are likely to be
endogenous, separate instrumental variables would be required for each price variable. Such instrumental variables
are not available. Second, the switched access expenditure share by IC, a key explanatory variable, is almost surely
correlated to the level of switched access demand. 	Again, the advisable strategy is to find instrumental variables
for the share. 	However, it is difficult to imagine a variable that affects this share that does not belong in the
demand equation itself.
Alternatively, the ratio of the factors of demand is estimated as a function of the ratio of factor prices and
other variables. 	The coefficient of the price ratio yields an elasticity of substitution between. switched access and
bypass. 	Using this approach, instrumental variables are needed for only one variable, the price ratio, at the cost
of the assumption of a constant elasticity of substitution. An Ie's relative factor proportions of switched access and
bypass is not likely to be affected by the Ie's share of total switched access expenditures (other than through the
shadow price of switched access). 	Thus, for AT&T and the OCCs,
AlT[ PrcSwAcc:lT AlT] 	AlT	:I: f 	,SwAccShr b 	, X b 	+ EAr
PrcBypa.ss~lT
(5)
QrySwAcc:;CC 	IOCCI PrcSwAcc:;ce 	ace] 	occ
----occ- :I: J 	occ,SwAccShrb 	,XAr + Eb
QtyBypassb 	PrcBypassl:l
(6)
are estimated, where X is a vector of exogenous factor aemand shifting variables and k and r subscript "tate and
month.
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Economists often assume that factor input prices are determined exogenously from factor demand
determination. However, for two different reasons, the price ratios in equations (5)-(6) could be endogenous to the
quantity ratios. 	First, either the LEe could exercise market power in switched access usage or AT&T could
exercise a degree of monopsony power. 	If either of these is the case, price will be a function of the quantity
demanded. 	Second, both prices in these ratios are set by regulators seeking revenues to "recover" fixed costs; if
demand decreases, prices will rise in order to satisfy the fixed total revenue level or fixed revenue requirement.
Indeed, this is exactly the type of assumption necessary for tLe existence of the Brandon Effect. Thus, supply price
determination equations,
AfT
PrcSwAcc llI
PrcBypa.ss:rr
(7)
OCC 	[ 	AfT 	OCC]	PreSwAccllI 	.. 	OCC QtySwAcC tI 	+ QtySwAcc lr 	Z
oce 	g 	AfT 	occ ' 	Ir
PrcBypassb 	QtyBypasstl 	+ QtyBypassb
ace
+ Vir 	(8)
are also estimated, where Z represents a vector of exogenous LEe supply shifting variables correlated with the price
ratio. 	Equations (5)-(8) form a system of simultaneous equations to be estimated by instrumental variables
techniques.
Data Description
The data available provide measures of quantity and price ratios from which equations (5)-(8) can be
estimated. 	The appendix provides a description of the construction of the variables used in this study. 	Actual
expenditures are divided by actual quantities to obtain average prices for switched and special access demand. The
ratio of the actual quantities can be regressed against the ratio of these average prices paid. 	'This construction
suffers because aggregating various forms of special access is problematic. 	The most common types of special
access used to avoid switched access charges are single line WATS/voice grade connections and multiple circuit OS 1
connections. 	OS 1 trunks can handle up to 24 different voice grade lines (they are also used for high speed data
transmission), but since additional charges are incurred as additional lines are activated, often some lines are left
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unused. 	Concrete data on the average number of lines used per DSI trunk does not exist; however, conversations
with Southwestern Bell experts lead us to believe that, on average, approximately 16 circuits are used per DS I
connection. Obviously. this number can vary over time, across ICs, or across states; unfortunately, however, we
have no information on tbe size or direction of the variation. Thus, special access lines are aggregated as the sum
of the WATS lines, voice-grade lines and 16 times DSllines. The benefit of this construction is that digital data
lines are not included and the price measures are specific to the IC.
The construction of the switched access share variable requires some discussion. First, while tbe switcbed
access share for AT&T is directly ca.1cuJated as AT&T's switcbed access expenditure divided by total switcbed
access expenditure, the corresponding value for the accs is slightly more complicated. The switcbed access sbare
for the accs is calculated as the weighted average of the individual sbare's for MCI, Sprint and other ICs, where
the weights are tbe fraction of acc expenditure represented by MCI. Sprint or the other ICs. 	Furthermore, since
the other ICs share itself constitutes an aggregation of many small firms. its share is divided by ten in order to
approximate their average share. Second, the switched access share of revenue is possibly correlated witb the ratio
of switcbed to special access quantity by construction (rather than due to the BrandoD Effect). 	To avoid this
occurrence. for each IC and state in the sample, the IC's average share over the otber four states is substituted.
The variables in X. those that shift factor demand for switched access relative to special access. include
variables affecting end-user demand and variables measuring the level of other IC factor inputs. 	Real disposable
income per capita is used to capture income effects and the number of residential and nonresidential lines are
included to reflect the size of these markets. 	Bypass is much more likely to occur in the provision of IC service
to business rather than residential customers; business customers in different industries have greater opportunities
for bypass based on their use of telecommunications. 	To measure these industry differences. the number of
employees in ~h of eight broad industry categories are included as possible demand-shifting variables. While tbe
costs of other Ie factor inputs could affect the switched access to special access ratio. only data reflecting tbe
average cost of debt from the yields to maturity on the AT&Ts' corporate bonds are available.
The variables in Z, those that shift the relative prices of switched and special access. include prices of
inputs into the production of both types of access. the Subscriber Line Charge (SLC), and other variables intended
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to capture the workings of the regulatory process. 	For prices of inputs into the production of access, the wage of
telecommunications workers. the cost of debt for Southwestern Bell and the prices of nonbroadcast communications
transmission equipment and central office switching equipment are used. 	Since the SLC was intended to partially
replace the switched access charge as a method of local loop cost recovery, increases in the SLC are expected to
be concurrent with decreases in the price of switched access. 	Other regulatory variables include Wexcess· returns
to LEC switched and special access, and the equity income of large long distance companies and LECs. 	"Excess·
returns (actual returns above the target or allowed rate of return) are expected to lead to lower access prices in the
subsequent rate order. 	Finally, an increase in the switched access price can be thought of as a transfer from ICs
to LECs. 	If regulators are interested in maintaining the financial viability of both types of companies, then past
fmancial distress of LECs (ICs) wi1llead to future higher (lower) switched access prices (regulators are assumee
to have much less discretion with special access prices). 	Financial distress is measured for ICs and LECs as the
income (both dividends and capital gains) generated by holding stock in a portfolio including AT&T and MCI and
the seven regional Bell Holding Companies respectively. In order to allow for a form of regulatory lag, all of these
variables, except the SLC. are computed as moving averages of values over the past six months.
Estimation Issues
The applicability of instrumental variables methods to the existing data has already been noted.
Specifically, the variables exogenous to the system, X and Z. are used as instruments. First stage regression results
are not reported.
Other estimation issues include possible autocorrelation and heteroskedasticity. Existence of either of these
problems will lead to inefficient estimation and biased standard errors, rendering inference testing problematic.
First, estimated correlations between the error term and lags of the error term for the same state indicate that
autocorrelation is present. 	Autocorrelation is corrected for by quasi-first differencing the data. 	Second, since an
observation represents the average across individuals in a state, and the states in the sample have significant variation
in population, the standard error of a variable for a large state will be smaller than for a small state. 	This leads
to a smaller variance of the standard error of the regression for larre states relative to small states. 	The remedy
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employed here for this form of heteroskedasticity is to weight observations by the population of the state it
represents.
Almast all variables included in the regressions are the natural logarithm of the underlying variable; the
exceptions, the net income and "excess" returns variables in the price equations, are due to the existence of negative
values of these variables. Thus, coefficient estimates usually can be interpreted as elasticities and, specifically, the
coefficient on price in the quantity equations is interpreted as the elasticity of substitution. The magnitude of the
coefficients on the net income and "excess" returns are more difficult to interpret.
S. 	Empirical Results
This section presents results from estimation of equations (5)-(8) and nonnested tests. 	Generally, tests
strongly, but not uniformly, confirm the presence of the Brandon Effect.
Regression Results
Table 1 reports two stage least squares (2SLS) coefficient estimates of equations (S)-{8). 	Durbin-Wu-
Hausman tests reject at a high confidence level the hypothesis that endogeneity between the price ratio and the
auantity ratio will not cause OLS estiID8~es to be inconsistent (Hausman (1978». The specification presented is the
result of a number of specification tests.
In the quantity-ratio equations, the price ratio enters negatively and the switched access share enters
positively for both AT&T and the OCCs. 	However, these coefficients are significant only ~"r AT&T. The t tests
on the switched access share confirm the existence of the Brandon Effect, at least for AT&T. 	Also, the shadow
price of switched access is inversely related to the switched access share, suggesting that the elasticity of substitution
defined for shadow prices is larger (in absolute terms) than the coefficient of the price ratio suggests. 	A larger
shadow price elasticity of substitution is confirmed below.
Since the dependent variable is the quantity ratio, coefficients on other explanatory vanables measure the
effect of these variables on factor demand for switched access relative to the factor demand for special access. 	An
insignificant coefficient could imply that the variable does not have an appreciable effect on factor demand.
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Alternatively, insignificance could be interpreted as implying that the magnitudes of these variables for switched
and special access are comparable.
Higher per capita income increases the demand for switched access relative to special access for both
AT&T and the accs. 	The cost of debt (measured as the yield to maturity on corporate bonds) has no effect for
either AT&T or the OCCs. 	The effect of residential and nonresidential lines have opposite effects for AT&T and
the DCCs. 	A greater number of residential lines decreases the switched- to special-access ratio for AT&T and
increases it for the accs. 	However, a greater number of nonresidential lines increases the switched to special
access ratio for AT&T and decreases it for the DCCs. These nonresidential lines are almost exclusively nonspecial
access business lines. 	Since businesses tend to use more long distance than residences and long distance service
over these lines entails switched access, a positive coefficient is expected.
Measures of employment in different sectors of the state's economy are intended to capture differences in
demand by long distance customers. 	Generally. coefficients tend to have the same signs for both AT&T and the
acCs. 	A positive (negative) coefficient indicates that the sector uses more (less) switched access relative to special
access than the average sector. 	Construction and transportation and public utilities use relatively more switched
access, while trade, and, perhaps, finance, insurance and real estate and services, use relatively more special access.
Since larger telecommunications users (and the ICs that serve them) have the best opportunity and motive for
bypass, more of these users are expected to increase the relative share of special access. 	Our results are consistent
with this expectation, since many of the most telecommunications intensive sectors reported by Crandall (1991) can
be classified as trade and finance, insurance and real estate. I)
The coefficients also tend to have the same sign for both AT&T and the accs in the price ratio equation.
The quantity ratio enters negatively and significantly as expected if regulators attempted to maintain a constant
amount of revenue for LECs from switched access. The coefficient of the SLC is positive, contrary to expectation,
but not significant. 	The cost of debt and the price of transmission equipment raise the price of switched access
relative to special access, while the price of central office switching equipment lowers it. Industry wages have no
11 	The telecommunications intensive sectors reported in Crandall (1991) are financi.u services; retail and
wholesale trade; hotels and motels; health, education, and social services; transportation; eating and drinking places;
real estate and rentals.
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effect on relative prices. 	The excess returns coefficients generally have the expected signs. 	High past special
(switched) access excess returns tend to decrease the relative price of special (switched) access. 	However, the
equity income coefficients have mixed signs and never approach significance.
Nonnested Tests
Next, nonnested J tests (Davidson and MacKinnon (1981» of the nominal price versus the shadow price
constructed as one minus the Ie's switched access share times the nominal price ratio are presented. The competing
hypotheses are that the nominal and shadow price ratio constructions describe the process that generated the data.
Since the log of the switched to special access price ratio is not linearly nested within the log of the shadow price
ratio, nonnested testing techniques art" appropriate.
Generally, nonnested tests attempt to distinguish between two models of the data where neither model is
a linear extension of the other (e.g. nominal versus shadow price). This is accomplished by artificially nesting both
hypothesized models within a more general model. The dependent variable is regressed against one model plus ex
times the other model. 	However, when the two models share some exogenous variables, this leads to an
underidentified equation. 	The solution is to replace the unknown parameters of the model not being tested with
consistent estimates, usually the predicted values from this model's specification. A t test on whether ex is different
from zero indicates whether the information in the predicted values helps -explain- the data. 	An ex different from
zero implies that, without this information, the model being tested is missspecified. 	By reversing which model's
predicted values are included, both specifications can be tested. 	With these procedures, it is possible to reject
neither model or to reject both as missspecified.
10 the present application, the possible endogeneity of the switched access share can also he better addressed
by the use of J tests. 	Because the switched access share could be correlated with the error terms by construction,
equations (5) and (6) use the ratio of switched to special access demand as the dependent variable and switched
access shares for one state were computed using information from the other states. 	This purges the variables of
much of the presumed spurious correlation. 10 the] test specifications, the switched access shares are incorporated
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in the shadow prices and these, in tum, are projected onto the instrumental variables. These instrumental variables
purge both the nominal price and the switched access share of their possible correlation with the error term.
Table 2 reports the I test results. 	The nominal price model is rejected for AT&T but Dot for the accs,
and the shadow price model is not rejected for either AT&T or the accs. These tests imply that either the nominal
price or the shadow price describe the data for the accs, but only the shadow price describes the AT&T data.
The failure to reject eitber model for the oces is probably linked to the relatively small variation in the switched
access sbare for the average acc firm. For the accs, the constructed shadow price ratio and nominal price ratio
are highly correlated.
Given tbese results, examining the price ratio coefficients in the competing models is enlightening. These
are reported in table 3. 	Coefficie[lts for X are not reported but remain virtually unchanged from table 1. For the
accs, there is little difference in tbe estimated price elasticities. 	For AT&T, the estimated elasticities are
somewbat greater (in absolute terms) for the shadow price model tban for the nominal price. This is to be expected
if the Brandon Effect guides AT&T decision-making.
Other Specijicalions
Two other specifications of the data were also tested with qualitativ~ly the same results. First, as discussed
above, W ATS service only avoids a portion of the switched access charges. Equations (5)-(8) were estimated with
WA TS lines excluded from the special access quantity with nearly identical results. 	Second, Southwestern Bell
constructs indices of switched and special access prices aggregated across all purchasers that provide an independent
measure of the switched to special price ratio. 	Alsc, these indices provide a different measure of quantity by
dividing access revenue by the relevant price index. 	Specifications using these price and quantity indices yielded
results which were less precise, but, nonetheless, similar to those reported above.
6. 	Conclusion
This paper describes, models and tests for the so-aBed Brandon Effect. This effect arises when the price
for an input with close substitutes is set above marginal costs so as to generate a fixed dollar amount of revenue
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to the seller. 	The model presented is simple and similar to (although more explicit than) descriptions presented
elsewhere. 	The formula for an IC's shadow price for switched access is deduced from the model as the nominal
price times oQe minus the IC's share of the total switched access demand. 	Tests for the Brandon Effect center on
whether switched access share has the expected effect on the demand for switched access. 	While the test results
presented do not uniformly confirm this hypothesis, they clearly support it.
The results raise issues for business and public policy. 	First, models of bypass behavior that ignore the
Brandon Effect are likely to overstate actual levels of bypass. particularly bypass by AT&T. 	Second, over time
as AT&T's share of total switched access falls, AT&T's shadow price of switched access will rise and its incentive
to bypass will increase. 	The incentive to bypass by MCI and Sprint will fall over time as their switched access
shares rise. Third. regu;atory policy changes that render a constant dollar revenue target unrealistic or unattainable
would eliminate the Brandon Effect mechanism. A true form of price~ps or incentive regulation (without rate-of-
return elements) would eliminate the switched access fixed dollar framework. 	Likewise, competition from third-
party access providers could erode the market power necessary to achieve the fixed dollar amount if they are granted
favorable LEC interconnection opportunities by regulators. 	In either case, the incentive to bypass would increase
for all ICs because nominal prices, and not the lower shadow switched access prices constructed above, would
reflect true opportunity costs.
Aside from direct tests for the existence of the Brandon Effect, this paper raises some issues for access
demand estimation. 	Often, access demand estimates for regulatory proceedings are derived from single equation
OLS models. 14 The empirical work presented here suggests that both the price of switched access and the price
of special access are endogenous to the quantity of switcbed access demanded. Single equation models tbat ignore
these effects could be missspecified, leading to inconsistent estimates.
14 See Gatto, et al. (1988) and the studies cited therein.
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Hausman, Jerry A. ·Specification Tests in Econometrics,· Econometrica (Nov. 1978) 1251-1272.
Jackson, C. L. and Rohlfs, J. H., Access Charging and Bypass Adoption Shoosban and Jackson, Inc., Washington,
DC 1985.
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Johnson, Leland, Competition and Cross-Subsidization in the Telephone Industry The Rand Corporation, Santa
Monica. CA 1982.
Kasserman. David L., Mayo, John W. and Flynn. Joseph E., "Cross-Substitution in Telecommunications: Beyond
the Universal Service Fairy Tale." Journal of Regulatory Economics 2 (1990).
Kahn. Alfred E. and Shew, William B., "Current Issues in Telecommunications Regulation: Pricing," Yale Journal
on Regulation 4 (1987).
Katz, Michael and Willig, Robert D., "The Effects of Capped NTS Charges on Long Distance Competition:
mimeo (1985).
Larson, Alexander C. and Mudd, Douglas R .• ·Collocation and Telecommunications Policy: 	A Fostering of
Competition on the Merits," California Western Law Review 28 (1992).
Parsons, Steven G. and Ward, Michael R., "Bypass Incentives When Regulaton Impose a Fixed Dollar Revenue
Requirement for Access,· 	Unpublished Manuscript (July 1991).
Rohlfs, Jeffrey, "Economically Efficient Bell System Pricing, • Bell Laboratories Discussion Paper (1979).
Simnett, Richard E., ·Contestable Markets and Telecommunications,· in Deregulation and Diversification of
Utilities, Michael A. Crew (ed.) (Kluwer Academic Publishen Boston, MA, 1988).
Taylor, 	Lester D., Telecommunications Demand: A Survey and Critique (Ballinger Publishing Company,
Cambridge, MA 1980).
Temin, Peter, The Fall of the Bell System (Cambridge Vnivenity Press, New York NY 1987).
Temin, Peter and Peter, Geoffrey, "Cross-Substitution in the Telephone Network," Willamete LAw Review 21
(1985a).
Temin, Peter and Peter, Geoffrey, ·Is History Stranger than Theory? 	The Origins of Telephone Separations,"
Economic History 7S (l98Sb).
V.S. Federal Communications Commission, Statistics o/Communications Common Carriers, Washington, DC: V. S.
Government Publishing Office, various years.
V.S. Federal-State Joint Board, Monitoring Report (CC Docket No. 87-339) Washington, DC, January 1991.
Vnited States Telephone Association, Bypass SIIIdy 1984.
20
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Weisman, Dennis L., "Default Capacity Tariffs: Smoothing the Transitional Regulatory Asymmetries in the
Telecommunications Market," Yale Journal on Regulation 5 (1988) 149-178.
Weisman, Dennis L. and Kridel Donald J., "Forecasting Competitive Entry: The Case of Bypass Adoption in
Telecommunications," International Journal of Forecasting 6 (1990) 65-74.
Wenders, John T., The Economics of Telecommunications (Ballinger Publishing Company, Cambridge, MA 1987.
Wenders, John T. and Egan, Bruce L., "The Implications of Economic Efficiency for US Telecommunications
Policy,· Telecommunications Policy 10 (March 1986) 33-40.
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Appendix 	Definitions of Variables
Ratio of Switched to Special Access Quantity - is the number of minutes of use (MOV) of switched access divided
by the number of lines of special access. 	The number of special access lines was computed as the sum of
WATS, voice grade and sixteen times OSI (source: Southwestern Bell).
Ratio of Switched to Special Access Price - is the ratio of the average expenditure per MOV of switched access
divided by the average expenditure per line of special access. 	Special access expenditures used here are
total special access expenditures minus an estimate of digital data expenditures. 	The number of special
access lines was computed IS the sum of WATS, voice grade and sixteen times OS I (source: Southwestern
Bell).
Switched Access Share - is the ratio of the IC's switched access expenditures to the sum of all IC switched access
expenditures. To avoid possible spurious correlation with the dependent variable, the ratio for any state
is defined as this ratio computed for expenditures in all other states (source: Southwestern Bell).
Residential and Non-Residelllial Lines - are the number of residential and non-residential lines Southwestern Bell
serves in the state (source: Southwestern Bell).
Income per capita - is disposable personal income per capita in the state for the quarter (source: Survey of Current
Business).
Cost of Debt - is the average real yield to maturity on the firms' corporate bonds. Conversion from nominal to real
rates was accomplished by deflating a bond's yield to maturity by the yield to maturity on a comparably
lived government bond (source: Moody's).
Employment in a sector of the economy - is the number of people employed in the sector in the state. 	The eight
sectors are: Mining; Construction; Manufacturing; Transportation and Public Utilities; Finance, Insurance
and Real Estate; Services; and Government (source: Employment and Earnings).
Subscriber Line Charge - is the real national average subscriber line charge (source: Monitoring Report).
Telephone Worker Wage - is the real wage of nonprofessional telecommunications workers (source: Employment
and Earnings).
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Price of Central Office Switching Equipment and Transmission Equipment - are real price indices for central office
switc~g equipment and non-broadcast communications transmission equipment (source: Producer Price
Indexes).
Long Distance and Bell Operating Company Equity Income - are the real dollar returns, including capita! gains and
dividend payments, to holding, in proportion to their equity value. stock in AT&T and MCI and stock in
the seven Bell operating companies (source: Center for Research on Security Prices).
Special and Switched Access Excess Return - are the real values of actual returns in excess of the allowed return
for Southwestern Bell special and switched access service (source: Southwestern Bell).
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Table 1
Demand Determined by
Nominal Price and Switched Access Share
2SLS Estimates
Variable 	AT&T 	OCCs 	Variable 	AT&T 	OCCs
Quantity 	Quantity 	Price 	Price
Ratio 	Ratio 	Ratio 	Ratio
Intercept 	-2.13 	-5. S0 	Intercept 	0.44 	-7.63
(2.45) 	(2.39) 	(l.48) 	(4.29)
Price Ratio 	-0.22 7 	-0.20 	Quantity Ratio 	-0.12 2 	-1,()91
(0.12) 	(0.18) 	(0.05) 	(0.30)
Switched Access 	1.16 1 	0.22 	Subscriber Line 	0.23 	1.58
Share 	(0.30) 	(0.94) 	Charge 	(0.35) 	( 1.19)
Income per capita 	1.21 2 	1.984 	Telecommunications 	0.19 	-3.49
(0.50) 	(0.95) 	Worker Wage 	(1.32) 	(4.56)
Corporate &ond 	0.09 	SWBT Corp. Bond 	8.1Q3 	22.0S'
Yield to Maturity 	(l.22) 	Yield to Maturity 	(3.71) 	(12.63)
Residential Lines 	-1.0S 1 	1.67 	Price of Transmission 	1.38 	13.161
(0.61) 	(1.20) 	Equipment 	(0.S9) 	(3.70)
Non-Residential 	1.07 1 	-3.97 1 	Price of Switching 	-1.56 7 	1.63
Lines 	(0.32) 	(0.94) 	Equipment 	(0.86) 	(2.26)
Mining 	0.11 3 	0.49 1 	Special Access 	-1.58 1 	-6.25'
Employment 	(0.05) 	(0.10) 	Excess Returns 	(0.33) 	(1.67)
Construction 	0.36 1 	-0.08 	Switched Access 	0.19 	I.I~
Employment 	(0.12) 	(0.22) 	Excess Returns 	(0.14) 	(0.59)
Mar.ufacturing 	0.17 	0.27 	Long Dist. Company 	-1.03 	1.53
Employment 	(0.15) 	(0.41) 	Equity Income 	(3.01) 	(11.21)
Transportation & PubI. 	0.884 	2.08 2 	Bell Oper. Company 	1.51 	2.27
Util. Employment 	(0.43) 	(0.85) 	Equity Income 	(1.87) 	(657)
Retail & Wholesale 	-1.63' 	-1.19
Trade Employment 	(0.40) 	(0.78)
Finance. Insurance. & 	-0.71 1 	1.94 1
& Real Estate Empl. 	(0.24) 	(0.51)
Services 	0.41 	-1.55 1
Employment 	(0.28) 	(0.56)
Government 	0.16 	0.10
Employment 	(0.11) 	(0.20)
Rho 	0.11 	0.53 	0.59 	0.79
Number of Obs. 	175 	175 	Number of Obs. 	175 	175
Adjusted R2 	.92 	.92 	Adjusted R2 	.35 	.09
Standard errors are in parentheses and superscripts denote significance levels for a two-tailed test if less than 10 %.
Observations are weighted by state population.
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Table 2
Nonnested J Test Results
Nominal versus Shadow Price Models
Estimate of Alpha
AT&T
accs
Nominal 	Shadow
Price 	Price
Model 	Model
1.40 1 	-0.88
(0.40) 	(0.69)
1.53 	-0.56
(4.30) 	(4.48)
This table presents coefficients and standard errors of ex in the equation
Y" xliiI + CI.x,~2 + E
where subscripts denote the competing models describing the data generating process. 	Superscripts reported in the
table denote significance levels for a two-tailed test of ex greater than zero if less than 10 percent.
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Table 3
Elasticities of Substitution
in Competing Models
Elasticity of Substitution
AT&T
OCCs
Nominal 	Shadow
Price 	Price
Model 	Model
-0.28 3 	-{).34 1
(0.13) 	(0.09)
-0.19 	-0.21
(0.17) 	(0.18)
Standard errors are in parentheses and superscripts denote significance levels for a two-tailed test if less than 10%.
Observations are weighted by state population.
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Costly Gains 	to Breaking Up:
LECs and The Baby Bells
John S. 	Ying and Richard T. 	Shin*
Review of Economics and Statistics, 	forthcoming
*University of Delaware and Federal Trade Commission, 	respectively. 	This paper
does not necessarily represent the views of the Federal Trade Commission or any
of its members. 	Revisions on this paper were made while Ying was visiting the
University of British Columbia. 	We thank Hendrik Houthakker and the referees for
comments, 	and 	members 	of 	the 	Industry 	Analysis 	Division 	at 	the 	Federal
Communications Commission for data assistance.
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Costly Gains 	to Breaking Up:
LECs and The Baby Bells
John S. 	Ying and Richard T. 	Shin
Review of Economics and Statistics, 	forthcoming
Abstract
While the -.ivestiture 'I..- • AT&T was intended to produce benefits in the long-
distance market, 	the evidence suggests it has created an unexpected side benefit
in local telephone markets. 	Our results show that local exchange carriers have
realized immediate cost savings in responding to competitive pressures since the
breakup, 	with the Baby Bells experiencing generally larger gains. 	Dynamically,
these productivity gains have increased over time at a relatively constant rate.
Although 'gains of 	3-5\ of 	total 	cost 	are not 	that 	large, 	the 	absolutely large
costs of telephone companies imply significant cost savings of nearly $72 million
for 	the 	representative firm.
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Costly Gains 	to Breaking Up:
LECs and The Baby Bells
Even before 	the American Telephone and Telegraph Company 	(AT&T) 	divested
itself of its 22 	local Bell operating companies 	(BOCs) 	on January 1, 	1984, 	some
economists such as MacAvoy and Robinson 	(1983) 	believed that it had in fact won
by losing the court battle. 	A priori expectations were that consumers and AT&T
would benefit from increasing competition. 	Reorganized into 7 regional holding
companies 	(RBOCs or the Baby Bells), 	BOCs had received a bad or at best neutral
deal. 	However, 	the early evidence suggests the opposite. 	As pointed out in the
press and by Crandall 	(198B), 	the Baby Bells are emerging as formidable 	foes.
Available evidence indicates that RBOCs and other local exchange carriers
(LECs) 	have be~n responding to competitive pressures arising from the breakup.
Cost-cutting efforts 	in new unregulated markets 	are 	likely to 	spillover 	into
regulated 	telephone 	operations. 	Furthermore, 	the 	prospect 	of AT&T 	and 	other
carriers entering their lucrative 	intra-LATA toll market and threats of bypass
are 	forcing 	LECs 	to 	be 	more 	competitive 	with 	respect 	to 	costs, 	prices, 	and
The 	gradual 	introduction 	of 	incentive 	regulation 	by 	state	service 	quality.
regulators 	gives 	telephone 	companies 	material 	incentives 	to 	increase
productivity. 	For 	these 	and 	other 	reasons, 	there 	is 	a 	clear 	sense 	from 	LEC
executives that 	they need to be more competitive.
In 	this 	paper, 	we 	examine 	the 	extent 	to 	which 	the 	AT&T 	divestiture 	has
affected the efficiency of BOCs and other large LECs. 	Have gains in productivity
contributed to their strong performance? 	If so, 	this unexpected side benefit of
the breakup may be more or as important as expected benefits in the long-distance
market. 	To analyze this empirical question, 	we estimate a 	cost function with a
pooled cross section time series sample over 1976-87. 	Our results show that LECs
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have 	been 	improving 	their 	operational 	efficiency and have 	been 	able 	to 	do 	so
immediately. 	Dynamically, 	these productivity gains have increased over time at
a relatively constant rate. 	Although the gains as a percentage of total cost are
only in the 3-5\ range, 	the absolutely large costs of telephone companies suggest
that 	the 	cost 	savings 	have 	been 	significant. 	For 	the 	representative 	firm 	in
1987, 	the simulations find productivity gains of nearly $72 million.
I. 	Cost Model
To analyze 	the 	impact 	of 	the 	breakup on productivity, 	we 	use 	techniques
similar 	to 	those 	in 	Ying 	(1990), 	which 	studies 	the 	case 	of 	motor 	carrier
deregulation. 	A multiproduct cost function for telephone local exchange carriers
can be written as
C = C 	(w, 	y, 	a, 	b, 	d, 	t)
where C is 	long-run total 	costs, 	w is a 	vector of factor prices, 	y 	is a 	vector
of 	outputs, 	a 	is 	a 	vector of 	operating 	characteristics, 	b 	is 	a 	BOC 	indicator
variable, 	d 	is a 	divestiture variable, 	and t 	is a 	time trend.
To overcome data limitations in past studies, 	we estimate a 	cost function
for LECs, 	on which there are more extensive and reliable data. 	Our cost model
is modified from that 	in Shin 	(1988), 	which estimates a 	cost function for wire
centers and central offices. 	To determine the cost structure of LECs, 	we employ
the 	translog 	flexible 	functional 	form, 	which 	is 	jointly estimated with 	factor
share 	equations 	using 	Zellner's 	seemingly 	unrelated 	regressions 	procedure. 1
Please refer to Shin and Ying 	(1992b) 	or Ying 	(1990) 	for a detailed description
of the 	trans log and estimation technique.
To measure the direct impact of the AT&T divestiture on LEC productivity,
we calculate the percentage change 	in cost due 	to divestiture, 	given by
(C 1 -CO) IC o'100 	= 	[exp 	(In 	(C 1 /C o )) 	- 1 1 '100
2
(1)
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[exp 	(vd + Ei 	vdi 	In wi 	+ Ek vdk In Yk +
Ern vdrn In 8.m + 'ubd b 	+ Vdt 	t) 	- 	1)' 100
where C1 and Co are 	total 	costs with the divestiture variable evaluated at d=l
and d=O, 	respectively, 	and the parameters are from d and its interaction terms.
Besides 	this 	direct 	effect, 	the 	divestiture 	can have 	so-called indirect
effects 	on 	the 	outputs, 	inputs, 	and 	operating 	characteristics 	which 	in 	turn,
would affect productivity and cost. 	Although they are important and potentially
very interesting, 	Ying 	(1990) 	and an earlier version of Ying and Keeler 	(1991)
find 	them to be 	small 	relative 	to 	the direct 	effect. 	Given our direct 	effect
results, 	we 	leave 	the 	indirect effects 	for future 	research.
II. 	Data and Variables
The data set consists of a panel of local exchange carriers over 1976-87.
The 	primary 	data 	source 	is 	the 	Statistics 	of 	Communications 	Common 	Carriers,
published by the Federal Communications Commission 	(FCC). 	Because of omissions
and changing reporting requirements, 	some data have been collected from detailed
forms at the FCC. 	We consider only those firms with .... "ntinuously available data.
The sample comprises 46 large LECs, 	of which 22 are BOCs, 	and 546 observations.
To calculate total cost, 	all expenses excluding capital costs are given by
operating 	expenses 	minus 	depreciation. 	For 	capital 	expenses, 	a 	real 	capital
stock has 	been 	obtained by 	dividing gross 	communication plant 	by 	the 	20-year
average 	communications 	equipment 	implicit 	price 	deflator, 	available 	from 	The
National Income and Product Accounts. 	The annuity form of depreciation is used
to obtain annual 	interest and depreciation costs. 	The 	interest 	rate 	is 	taken
from 	the 	average 	price 	of 	new 	capital 	on 	domestic 	telephone 	bonds, 	listed 	in
Moody's 	Public 	Utility 	Manual.
assets minus 	liabilities.
Working 	capital 	is 	accounted 	for 	by 	current
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The price of labor 	(PL) 	is compensation per employee. 	Number of employees
data for 	1982-87 are 	taken from the pensions paid schedule 	(60B) 	of 	the Annual
Report, 	Form M or more detailed Annual Employment Reports, 	Form 395. 	Beginning
in 1985, 	compensation data are available as a footnote in the operating expenses
schedule 	(35) 	of Form M. 	Where reasonable, 	some labor prices have been generated
by 	averaging. 	The 	price 	of 	capital 	(PK) 	is 	capital 	expenses 	divided 	by 	the
average number of 	telephones 	or access 	lines. 	For 	the price 	of other 	factors
(PO), 	residual 	expenses 	are 	divided by the 	average 	number of 	telephones. 	The
factor 	shares are the corresponding expenses over total 	cost.
Output is represented by the average number of access lines or telephones
(TL), 	with output usage variables consisting of local calls 	(LO) 	and toll calls
(TO) . 	Due 	to 	changes 	in 	reporting 	practices 	after 	divestiture, 	the 	ratio 	of
local to toll calls has been regressed on time to generate compatible toll call
figures for some firms. 	For some missing observations, 	averages or ratios from
other years are used.
To 	capture 	output 	attributes, 	the 	vector 	of 	operating 	characteristics
includes the number of central offices 	(CO), 	the percentage of electronic access
lines 	(EA), 	and average loop length 	(AL) 	or miles of cable per telephone, 	which
indicates 	the 	density 	of 	service. 	EA 	serves 	as 	a 	proxy 	for 	technology 	or
quality. 	In the translog, 	zero values for EA have been changed to 0.00001. 	In
a few cases, existing EA data have been averaged or regressed on polynomial terms
of time, 	and an apparent change 	in classifications of electronic lines has 	led
to Borne adjustments.
Because the Bell operating companies were originally part of AT&T, 	they may
be considered different from the other LECs in the sample. 	While many of these
differences may be exhibited by existing variables, a variable indicating whether
the company is a BOC would capture other less tangible features. 	This variable
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(B) 	is a dummy variable equal 	to 1 	if 	the LEC is a BOC and a otherwise.
The divestiture variable 	(D) 	is also a 	dummy variable, 	with value 	a from
1976-83, 	and 1 from 1984-87. 	Our use of a 	~ranslog function captures lagged or
diffused effects over time 	through the 	interaction term between 0 and the time
trend. 	More 	generally, 	any 	measured 	productivity 	gains 	should 	be 	viewed 	as
arising from not only the divestiture itself, but also from increased competition
and state deregulation following the breakup. 	To prevent a downward bias in D,
a 	time 	trend 	(T) 	has 	been 	added 	to 	accuunt 	for 	possibly 	unmeasured 	dynamic
changes, 	such as 	technological progress.
We 	believe 	that 	we 	have 	constructed 	one 	of 	the 	most 	comprehensive
telecommunications data set to date. 	But even the best available data may have
shortcomings. 	For example, 	prior to 1984, 	most telephone companies only report
the 	number 	of 	telephones 	rather 	than 	access 	lines. 	Since 	telephones 	include
extension phones, 	they may overestimate the number of access 	lines. 	Thus, 	the
estimated productivity gains from divestiture are smaller than the true gains or
our estimates are biased upward. 	Nevertheless, even with minor shortcomings, our
r~ta are 	the best available for examining the costs of telephone companies.
III. 	Estimation Results
In Table 1, 	we provide the translog results for the first-order parameter
estimates and all terms involving the divestiture variable. 	Complete results are
available upon request. 	Of 	the 76 estimated parameters, 	36 are 	significant at
the 1\ level, 	8 are significant at the 5\ level, 	and 5 are significant at the 10\
level. 	Parametric tests using the quasi-likelihood ratio show that each of the
independent variables is highly significant, well beyond the 0.05\. 	They suggest
that although some of the individual parameters are not significant, none of the
variables should be deleted from the model. 2
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Next, 	we evaluate the plausibility of the parameter estimates, 	postponing
an analysis 	of 	the 	divestiture 	variable 	tc 	the 	next 	section. 	The 	first-order
output parameters 	are 	all 	positive, 	less 	than 	1, 	and 	significant 	at 	the 	0.02%
level. 	At 	the 	sample 	mean, 	summing 	the 	::JUtput 	cost 	elasticities 	yields 	an
overall 	scale 	elasticity 	of 	0.9621, 	implying 	slight 	economies 	of 	scale. 	It
suggests 	that 	the 	large 	LECs 	in 	our 	sample 	may not 	have 	exhausted sources 	of
scale economies given the market demand. 	However, 	it does not necessarily imply
that 	they are natural monopolies. 3 	Evaluating the 	sc&le elasticities with D=O
and 1 	indicates that the breakup has had no appreciable effect.
The 	cost 	elasticities 	with 	respect 	to 	the 	factor 	pr~ces or 	the 	factor
shares, 	at the sample means, 	are all positive and of plausible magnitudes. 	The
factor share for labor ~s 0.3170, 	for capital is 0.5196, 	and for other inputs is
0.1634. 	Overall, 	these estimates indicate that technological improvements have
led 	to 	substitution 	of 	capital 	and 	other 	inputs 	for 	labor, 	and 	that 	the
divestiture has 	somewhat accelerated this process.
Cost savings due to technological changes can be measured by the percentage
electronic access 	variable. 	Its 	small 	first-order 	as 	well 	as 	square 	term are
negat:l.ve and highly significant, 	indicating that as a higher percentage of access
lines are converted to electronic switches, 	cost savings will grow slightly. 	The
results are plausible since electronic access can reduce costs 	in many ways.
Average 	loop length 	(AL) 	has significant positive first-order and square
terms, 	indicating 	that 	costs 	rise 	rapidly as AL 	increases. 	I f 	demand 	is 	not
densely packed so that more miles of cables are needed per telephone, 	then costs
should rise 	accordingly. 	Central 	offices 	(COs) 	seem to only have 	an 	indirect
effect on costs, 	since their significance is derived from the interaction terms.
For instance, 	more COs will result in a decrease in the cost elasticity for AL.
The 	significance of 	the 	Bell 	indicator variable 	and the 	positive 	firRt-
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order parameter suggest that their costs are not only different but higher. 	This
difference has decreased with time. 	From the other interaction terms, 	BOCs tend
to use 	less 	capital and labor as compared to non-Bell 	firms. 	Increasing local
calls, 	COs, 	and average 	loop 	length are all more 	costly for 	the BOCs.
With 	a 	time 	trend 	variable, 	we 	can 	measure 	normal 	productivity 	changes
which 	would 	have 	occurred 	in 	the 	absence 	of 	di vesti ture. 	The 	first-order
coefficient 	is 	negative 	and highly 	significant. 	It 	suggests 	that 	failure 	to
include T in our model may have 	resulted in a 	biased estimate of the effect of
the divestiture. 	The positive square time term is significant, 	indicating that
normal productivity growth occurs at a 	decreasing rate over time.
Finally, 	we 	briefly 	present 	regularity 	conditions 	for 	the 	estimated
translog 	equation. 	Homogene~ty is 	imposed 	and 	continuity 	is 	automatically
satisfied. 	Our 	calculations 	show 	that 	only 	7 	of 	546 	observations 	violate
monotonicity, 	while 	90.0\ 	of 	the 	data 	points 	are 	concave 	in 	w, 	and 	regular.
These 	results are 	reassuring considering past problems with regularity.
IV. 	The Effect 	-f 	the Dives~'ture on LEC Productivity
We now turn to the focus of this paper, 	the effect of the AT&T divestiture
and subsequent competition on the productivity of local exchange carriers. 	The
first-order parameter estimate of the divestiture variable 	(D) 	is -0.0539, 	which
suggests 	that 	costs have 	decreased. 	It 	is 	significant at 	the 	5\ 	level. 	Also
accounting for the second-order terms, 	the quasi-likelihood ratio test indicates
that D is 	in fact quite significant, 	well beyond the 0.05\ 	level.
In 	applying 	equation 	(1) 	to 	calculate 	the 	effect 	of 	the 	breakup 	on
productivity, 	the variables are held at yearly mean values, 	so that they can be
interpreted as those of the representative firm in any given year. 	By simulating
the 	results 	over 	1984-87, 	we 	can 	observe 	dif~erential dynamic 	effects.
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simulations for 	the 	translog are presented in Table 	2. 	Components of equation
(1) 	before taking 	the exponential are 	included to indicate the primary sources
of 	the change. 	Since BOCs differ from non-Bell 	LECs, 	the percentage change 	in
costs has been calculated for each of their representative firms. 	Finally, 	these
computations 	were 	performed 	on 	individual 	observations 	in 	the 	sample. 	The
averages 	for non-Bell LECs, 	BOCs, 	and the 	sample 	in each year and the 	standard
errors are also given in 	this 	table.
The 	results 	indicate 	that 	LECs 	and 	the 	Baby 	Bells 	have 	been 	quick 	to
realize 	productivity 	gains. 	Within 	the 	first 	year 	of 	the 	breakup, 	the
representati ve 	firm 	has 	reduced 	costs 	by 	over 	2.5% 	more 	than 	otherwise. 	It
suggests 	that 	the 	local 	telephone 	companies 	have 	not 	had 	to make 	any 	drastic
initial changes 	in their operations, 	which would have probably increased costs
in 	the 	short 	run . 	In 	the 	following 	years, 	these 	advances 	in 	producti vi ty
continue 	to 	grow by 	approximately 	0.5% per year. 	In 	1987, 	costs 	are 	over 	4\
lower. 4 	Over time, 	LECs are better able to rein in costs, 	as they reduce 	their
reliance on less-skilled labor, 	modernize their plants, 	and develop other cost-
cutting techniques.
On 	a 	percentage 	basis, 	these 	cost 	savings 	could hardly be 	described as
large. 	However, 	given the capital-intensive nature of telephone technology and
the resultant absolutely high costs, 	the savings amount to substantial figures.
For example, 	in 1987, 	the representative firm in our sample has a 	total cost of
over $1.6 billion. 	A cost savings of even 4.138\ implies a productivity gain of
about 	$72 million. 	If aggregated across 	the large LECs 	in just our sample, 	it
represents savings of nearly $3 	billion.
The 	cost 	savings 	for 	the 	representative 	Bell 	and non-Bell 	firms 	show 	a
similar 	pattern. 	Of 	particular 	interest 	is 	that 	BOCs 	have 	achieved 	larger
productivity gains in each year. 	This 	is to be expected since the breakup did
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affect 	them most 	directly. 	Given 	that 	they faced more 	changes, 	they probably
have more areas for cost-cutting. 	Nevertheless, 	non-Bell carriers have reacted
to the divestiture too. 	Their productivity gains are more likely the result of
the host of 	changes 	that 	followed the breakup, 	rather 	than the breakup 	itself.
Simulations for each of the firms, 	averaged by year and categories, produce
similar 	though 	generally higher 	savings. 	They 	indicate 	that 	analysis 	of 	the
representative firms 	does convey the 	typical effect of divestiture on firms 	in
our sample. 	If these slightly larger gains are expressed in dollars, 	they imply
a 	savings of about $77 million for 	the representative firm in the sample. 	The
standard errors 	are 	about 	0.25\, 	suggesting 	that 	the productivity changes 	are
statistically different from zero. S
From the component 	terms 	in Table 	2, 	the 	specific sources 	of 	these 	cost
savings 	can 	be 	identified. 	The 	first-order 	divestiture 	coefficient 	and 	its
interaction term with time are of the largest negative magni tude. 	The only other
terms of the same order of magnitude are access lines and local calls, 	which lead
to higher costs. 	All other components are small, 	and on balance, 	can slightly
contribute to productivity gains or 10sses depending~n the year. 	Individually,
most are 	reasonably significant, 	especially the PL, 	TL, 	LO, 	and CO terms.
By differentiating the percentage change 	in cost with respect 	to the 	log
of a variable, we can decompose the direct effect of divestiture into ics various
components. 	These calculations have been simulated for the representative firm
and are presented in Table 3. 	Increasing all these variables by 1\ and time by
1 year would tend to increase the productivity gains arising from the breakup by
about 3\. 	Higher other input prices, 	more local calls, 	and more central offices
are the more important factors which tend to reduce the cost gains. 	On the other
hand, 	larger labor prices, more access lines, and longer average loop lengths all
produce 	more 	cost 	savings. 	Of 	these 	variables, 	the 	effects 	of 	PL and TL are
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especially large. 	They suggest that, 	holding all else constant, 	having higher-
skilled labor and more access lines or greater market penetration would lead to
lower post-divestiture costs.
V. 	Conclusion
U.S. 	regulation of 	telecommunications 	essentially 	is 	the 	story of AT&T.
When it divested itself of 	the BOCs in 1984, 	it was a monumental 	turning point
for U.S. 	regulatory policy as competitive long-distance service was severed from
the perceived natural monopoly of local telephone service. 	Although issues such
as 	subadditivity 	and 	economies 	of 	scope 	were 	never 	clearly 	resolved,6 	most
economists considered the breakup a pro-competitive change. 	The benefits were
primarily 	foreseen 	in 	the 	long-distance 	market. 	However, 	emerging 	evidence
suggests that 	the 	local exchange carriers have also been responding to changes
brought on by the divestiture. 	Our simulation results show that LECs have indeed
realized sizable cost savings. 	As noncommunications businesses contribute more
to 	revenues 	and 	LECs 	become 	full-fledged 	competitors 	in 	these 	and 	other 	new
markets, 	these costly gains to breaking up AT&T are 	likely to only grow.
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References
Crandall, 	Robert 	W., 	"Surprises 	from 	Telephone 	Deregulation 	and 	the 	AT&T
Divestiture," 	American Economic Review, 	78 	(May 1988), 	323-327.
Houthakker, 	Hendrik S., 	"Growth and Inflation: Analysis by Industry," Brookings
Papers on Economic Activity, 	1 	(1979), 	241-257.
MacAvoy, 	Paul W. 	and Kenneth Robinson, 	"Winning by Losing: 	The AT&T Settlement
and 	Its 	Impact 	on 	Telecommunications," 	Yale 	Journal 	on 	Regulation, 	1
(1983), 	1-42.
Shin, 	Richard T., 	"Econometric Estimation of Telephone Costs for Local Exchange
Companies: 	Implications 	for 	Economies 	of 	Scale 	and Scope 	and Regulatory
Policy, " Unpublisho=d doctoral dissertation, Uni v. of California, Berkeley,
July 1988.
Shin, 	Richard 	T. 	and 	John 	S. 	Ying, 	"On 	Estimating 	the 	Box-Tidwell 	Flexible
Functional 	Form," 	Working 	Paper No. 	90-16, 	Dept. 	of Economics, 	Univ. 	of
Delaware, 	Oct. 	1989, 	revised Mar. 	1992a.
Shin, 	Richard T. 	and John S. 	Ying, 	"Unnatural Monopolies 	in Local Telephone,"
RAND Journal of Economics, 	23 	(Summer 1992b). 	171-183.
U. S. 	Federal 	Communications 	Commission, 	Statistics 	of 	Communications 	Common
Carriers, 	Washington, 	DC: 	U.S. 	Govt. 	Printing Office, 	1976-87.
Ying, 	John 	S., 	"The 	Inefficiency 	of 	Regulating 	a 	Competitive 	Industry:
Productivity Gains in Trucking Following Reform," Review of Economics and
Statistics, 	72 	(May 1990), 	191-201.
Ying, 	John 	S. 	and Theodore 	E. 	Keeler, 	"Pricing 	in 	a 	Deregulated Environment:
The 	Motor 	Carrier 	Experience," 	RAND 	Journal 	of 	Economics, 	22 	(Summer
1991),264-273.
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Endnotes
1. 	To test the functional specification, 	we estimate a hybrid translog, 	which
transforms all 	independent variables except 	factor prices by the Box-Cox
metric. 	Although others 	have 	estimated Box-Tidwell 	functions, 	Shin and
Ying 	(199~a) have shown that correctly imposing homogeneity restricts the
function to the extent that it is no longer a second-order approximation.
2. 	In the hybrid translog, 	the Box-Cox metric is 	-0.0292 with an asymptctic
p-value of 0.0198, 	or little is gained by using a hybrid translog. 	Of 76
parameters, 	only 1 of 8 sign changes is significantly different from 0 and
the vast majority are of similar magnitude.
3. 	For an analysis of this 	issue, 	see Shin and Ying 	(1992b).
4. 	Note 	that 	these 	gains 	from 	the 	breakup 	are 	above 	and 	beyond 	normal
productivity growth, 	which some past studies using aggregate indexes have
found to be about 	6\ 	(see, 	for 	instance, 	Houthakker 	(1979)).
5 . 	Simulations 	for 	the 	hybrid 	translog 	are 	comparable 	to 	those 	for 	the
translog, 	with slightly larger magnitudes.
6. 	For some recent evidence suggesting that AT&T was not a natural monopoly,
see Shin and Ying 	(1992b).
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Table 1. 	Translog First-Order and Divestiture Second-Order Parameter Estimates
Parameter 	Estimate 	Std Error 	Parameter 	Estimate 	Std Error
PL 	0.38939 	0.00734 	PL :J 	-0.03041 	0.00712
PK 	0.47837 	0.00630 	Pi': :J 	0.00949 	0.00617
TL 	0.73024 	0.04025 	TL :J 	-0.10101 	0.02777
LO 	0.09602 	0.02581 	LO'D 	0.06917 	0.01799
TO 	0.12473 	0.01631 	TO'D 	0.01053 	0.01083
CO 	-0.00959 	0.01017 	CC'D 	0.02266 	0.00835
EA 	-0.00849 	0.00400 	EA'D 	-0.00034 	0.00421
AI. 	0.07794 	0.02768 	AL·D 	-0.02968 	0.01709
B 	0.04448 	0.01275 	B'D 	0.01553 	0.01039
T 	-0.01571 	0.00302 	T'D 	-0.00156 	0.00232
D 	-0.05389 	0.02624
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Table 2. 	Translog Simulations of 	the Effect 	of Divestiture on LEC Productivity
Components 	in Exponential
Year 	D 	PL'D 	PK'D 	TL'D 	LO'D 	To·r 	CO'O 	EA'O 	AL'D 	B'D 	T'O
1984 	-.0539 	.0077 	.0003.0313.0063.0013 	-.0028 	-.0000 	-.0099 	.0074 	-.0140
1985 	-.0539 	.0081 	-.0010 	.0278 	.0092 	.0022 	-.0088 	-.0001 	-.0096 	.0074 	-.0155
1986 	-.0539 	.0081 	-.0029 	.0255 	.0103 	.0832 	-.0088 	-.0002 	-.0096 	.0074 	-.0171
1987 	-.0539 	.0043 	-.0019 	.0085 	.0213 	.0058 	-.0058 	-.0002 	-.0101 	.0085 	-.0186
Percentage Change 	in Cost
Year
1984
1985
1986
1987
Representative Firm
non-Bell 	Bell 	Sample
-2.313 	-2.467 	-2.521
-2.727 	-3.367 	-3.373
-2.984 	-3.787 	-3.739
-3.520 	-4.100 	-4.138
Individual 	Firm Averages
non-Bell 	SE 	Bell 	SE 	Sample 	SE
-2.930 	0.288 	-2.542 	0.269 	-2.744 	0.200
-3.207 	0.317 	-3.630 	0.257 	-3.409 	0.208
-3.539 	0.341 	-4.039 	0.257 	-3.778 	0.219
-4.391 	0.309 	-4.426 	0.263 	-4.410 	0.201
Table 3. Derivatives of the Percentage Change in Cost for the Representative Firm
Year 	PL 	PK 	PO 	TL 	LO 	TO 	CO 	EA 	AL 	T
1984 	-2.961 	0.924 	2.037 	-9.836 	6.736 1.025 2.207 	-0.033 	-2.890 	-0.152
1985 	-2.938 	0.917 	2.022 	-9.760 6.684 	1.017 2.190 	-0.032 	-2.868 	-0.150
1986 	-2.927 	0.913 	2.014 	-9.723 	6.658 1.014 	2.181 	-0.032 	-2.857 	-0.150
1987 	-2.915 	0.910 2.006 	-9.683 	6.631 1.009 	2.172 	-0.032 	-2.845 	-0.149
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