BELLS URGE FCC TO INVOLVE ALL CARRIERS IN CARE PROCESS

Verizon urged the FCC to require all CLECs to support CARE. It said customer migration to competitors affected the ability of long distance carriers to bill for their services, because some CLECs don’t exchange information with the interexchange carriers using the industry standard CARE process. It said the FCC shouldn’t impose obligations on the incumbents, which already support CARE, to inform the long distance carriers about the identity of the CLEC serving the customer. “The Commission should not require the [ILECs] to make up for the deficiencies of their competitors,” Verizon said.

CARE is an industry-set process of exchanging customer data -- required for establishing and maintaining customer accounts and billing -- between LECs and long distance carriers. The CARE standards were developed by the Ordering Billing Forum (OBF) after divestiture to aid LEC provision of equal access to LD carriers. Many commenters agreed CLEC entry into the local services market undermined the effectiveness of the exchange of CARE data between LECs and IXCs, because most of the CLECs don’t participate in CARE.

SBC said the Commission should require all carriers to participate in the exchange of customer data using the CARE standards. It said the CARE process had proved “the most effective and efficient method of exchanging data between carriers,” and requiring all carriers to participate in it would “ensure uniformity in both the type of data exchanged and the manner of such exchange, thereby substantially minimizing the billing and provisioning concerns raised in this proceeding.” SBC said the Commission should adopt minimum data exchange obligations applicable to all LECs and IXCs. Specifically, it recommended that, at a minimum, all LECs should notify the presubscribed IXC when: (1) “The LEC becomes the new local provider.” (2) “The customer disconnects dialtone with the LEC.” (3) “A customer is put on the IXC’s network, including billing name, address (BNA) and telephone number.” (4) “The LEC’s customer is removed from the IXC’s network.” SBC also recommended that an IXC should notify the LEC when “a LEC customer wants to change IXCs through contact with the IXC and confirmation by the LEC of the completion of that change.” SBC said a LEC should notify the IXC regarding “why a PIC change order was rejected.”

BellSouth urged the FCC to replace the current voluntary CARE standard with a mandatory process applicable to all interexchange and local exchange carriers. It recommended that the Commission: (1) Require all IXCs, CLECs and ILECs to participate in CARE in accordance with the OBF’s standards. (2) Not require compliance with the overly detailed standards and codes proposed by AT&T, Sprint and WorldCom. “Mandating the use of particular codes would be counter to the realities of the way carriers utilize CARE today and would constitute unjustified micromanagement of the CARE process by the Commission.” (3) Expand the obligations to exchange end user account information beyond presubscription for interexchange services. Specifically, it said the Commission should require CLECs and ILECs to share customer record information for changes involving a customer’s local service.

USTA urged the FCC not to require minimum mandatory CARE obligations. “There is no reason for the FCC to act independently of the [OBF] to create new regulation to provide for minimum mandatory CARE obligations,” it said: “The OBF is the proper forum for vetting issues concerning CARE.” USTA said adopting any requirements would “create unnecessary regulation, impose unreasonable costs and personnel burdens, infringe on customer privacy, require system changes that are costly, and are unnecessary for wireline-to-wireless portability.” It also said the Commission should “dissuade states from implementing CARE guidelines.”

The Bells also said the Commission shouldn’t adopt performance standards for exchange of CARE information between carriers. “There has been no showing that carriers who already support CARE are not meeting each other’s expectations,” Verizon said. SBC said “with the minimum CARE obligations defined, the industry… is in the best position to manage the development, implementation and modification of CARE used to exchange the required customer data.” BellSouth said requiring IXCs, CLECs and ILECs to participate in CARE in accordance with industry-developed guidelines would significantly improve the exchange of information.

The Bells also urged the FCC not to require the industry to develop a database of customer line information, including credit information, to address dial-around traffic billing issues. Verizon said it would require “a huge database” to provide information about every customer line nationwide, and “the effort to keep it updated for all carriers on a real- time basis would be enormous.” SBC said “multiple vendors offer services to identify local providers for local lines,” and a single industry database was “not only unnecessary, but would eliminate any competition for this service.”

In a joint filing, AT&T, MCI and Sprint urged the FCC to impose minimum CARE obligations on all local and interexchange carriers. They said some ILECs and CLECs that do exchange CARE don’t provide it promptly, consistently and with enough detail.

CTIA urged the FCC not to impose CARE obligations on wireless carriers. The Commission has raised wireless questions with respect to intermodal number portability. No procedures are in place requiring notification of a LD carrier when its customer switches to a wireless carrier to provide long distance service. As a result, those customers may continue to be billed by their former LD carrier. But CTIA said the implementation of intermodal number porting did “not justify imposing the CARE obligations on CMRS carriers.” It said notification issues didn’t arise in the case of wireless-to-wireline porting because wireless carriers usually don’t have a separate commercial relationship with an LD carrier.

NTCA urged the Commission to consider “less burdensome” alternatives to requirements for small rural ILECs. It said the proposed changes would impose significant costs on rural ILECs, which would have to modify their processes to comply with a uniform standard. It also said the LD carriers that “stand to benefit from the uniform standards should bear the costs.” SBC said smaller carriers unable financially to implement the internal processes and system needed to participate in CARE should be able to seek an exemption. But it said they should still be required to comply with the minimum data exchange obligations.

The National Assn. of State Utility Consumer Advocates (NASUCA) said it supported minimum CARE obligations for IXCs and LECs. “A process that ensures that all affected carriers are notified when a customer changes carriers would benefit consumers and promote competition,” it said. NASUCA recommended the Commission require that: (1) LD carriers be required to notify the LECs when informed by customers they want to cancel service with the IXC. (2) When a customer switches IXCs because of switching local service, the former local carrier notify the former presubscribed IXC. (3) When a customer doesn’t switch LD carriers while switching local services, the former local carrier notify the presubscribed IXC. (4) When a customer switches IXCs but not local service, the LEC notify the former IXC.

NARUC said the FCC should set “minimum requirements requiring mandatory exchange of customer account information, but still allow the carriers some flexibility in the format of the exchange of the customer information provided all the necessary data is exchanged.”