tariff inflation increases regulatory obligations

Publicly filed tariffs have been an important element of federal economic regulation in the U.S. since the formation of the Interstate Commerce Commission in 1887.   U.S. local exchange telephone companies currently file federal tariffs for their interstate access services.   These tariffs are publicly available through the U.S. Federal Communications Commission’s Electronic Tariff Filing System (ETFS).

The number of rate elements in interstate access rate-detail filings is a measure of the size of interstate access tariffs.   Among the seven former regional Bell operating companies, the historic Nynex operating company has had the greatest rate-detail growth.   In 1993, Nynex’s filing contained about 1,500 rate lines.  In 2009, the filing had grown to about 92,000 rate lines.  The Bell Atlantic and BellSouth operating companies also showed strong filing growth from 1992 to 2009.   Ameritech, Southwestern Bell, US West, and Pacific Bell, in contrast, did not expand their rate-detail filings after the mid-1990s.  Measured by rate elements actually used (rate elements with non-zero revenue), rate-detail filing sizes vary much less across operating companies.

Complete tariff filings are more comprehensive compilations of tariff rates.   Complete tariff filings include rates not included in the rate-detail filings.   For example, Ameritech has many pages of contract tariffs in its complete base tariff on ETFS.   Rate elements in these contract tariffs are not included in its rate detail filing.   The size of complete tariff filings could be measured in tariff pages.  On those pages, the number of dollar signs might provide a crude indicator of the number of rates.

Unlike normal commercial prices, tariffs are associated with regulatory obligations.   To the extent that tariffs expand, they increase regulatory obligations.  Tariffs expanding rapidly relative to regulatory resources can produce a regulatory crisis or regulatory insolvency.

Data: counts of elements in U.S. local-exchange telephone companies’ interstate access rate detail filings (Excel version); full rate-detail compilations for seven former Regional Bell operating companies.

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