Members of The Brattle Group advise clients on a range of regulatory and policy issues facing the telecommunications industry, and we have earned a reputation for objectivity and thoroughness throughout the industry. We provide expert testimony and litigation support in regulatory policy proceedings, ranging from access pricing and network service unbundling to market structure and regulatory frameworks.
For a provider of local exchange telephone services in New Zealand, The Brattle Group analyzed the competitive implications of the interconnection pricing proposals submitted by the incumbent local exchange carrier. The New Zealand government issued a report largely incorporating our recommendations. Our findings were also published in the Yale Journal on Regulation.
The Brattle Group has worked on issues surrounding utility and telephone company pole attachments, including FCC Orders and U.S. Supreme Court decisions. Our work has spanned the analysis of the economic issues associated with pole attachment policy, as well as calculation of appropriate pole attachment rates. We have provided analysis and expert testimony to several clients in the determination of rates for pole attachments under the FCC's Cable Rate and Telecom Rate Formulas.
Our experts have worked extensively and testified in various state proceedings on the appropriate economic principles for determining the price of unbundled network elements and an efficient wholesale discount. We have developed comprehensive models and provided expert testimony concerning the costs and prices of unbundled network elements (UNEs), using the Total Element Long Run Incremental Cost (TELRIC) methodology.
We have analyzed performance measurement plans (PMPs) to ensure that wholesale services and unbundled network elements (UNEs) were provided to competitive local exchange carriers (CLECs) in a non-discriminatory manner by incumbent local exchange carriers (ILECs). These plans were implemented as a means of promoting local exchange competition assuming that such competition would lead to improvements in consumer welfare. We have shown, however, that existing PMPs may not be consistent with the development of an efficient local exchange market and that such plans, as currently designed would:
- Result in taxes and subsidies that may distort economic decision-making
- Provide little incentive for ILECs to continue to improve wholesale service quality
- Have no defined relationship to changes in consumer welfare