FCC Record, Volume 2, No. 1, Pages 1 to 409, January 5 - January 16, 1987 Page: 68
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Federal Communications Commission Record
end user of two bills for an interstate call, one from a
LEC and another from a IXC, would be confusing because
such bills allegedly would be neither reconciled nor
reconcilable.64 Several state commissions, however, filed
comments asserting that, although the potential for customer
confusion existed, this was not a fundamental flaw
in the end user billing concept.65 These commissions
argued that such potential was more on the order of a
marketing problem, and could be addressed adequately in
the future by a LEC proposing an interim end user
plan.66
56. In the initial pleadings filed in the current proceeding,
public officials and state commissions throughout the
NYNEX region opposed implementation of the NYNEX
plan on the grounds that customer confusion problems
are not adequately addressed therein.67 In addition, those
who would obtain the greatest benefits under the NYNEX
plan
large users and large user groups
also oppose the
plan, at least in part because of the customer confusion
potential.68 Although two state commissions subsequently
filed supplemental comments asserting that NYNEX has
demonstrated to them that it "has taken seriously its
customer education obligation,"69 the majority of public
officials in the NYNEX region commenting on the proposal,
including those from the states with the largest
populations, oppose the plan due to concerns about its
effects on the public.
57. NYNEX claims that its proposal to permit an end
user to designate a single third party to coordinate its long
distance charges is an adequate response to the customer
confusion problem. NYNEX also claims that multiple
IXC billing is not possible under its plan because its taper
applies to an end user's aggregated access minutes, and
revenues associated with individual IXC minutes are unidentifiable.70
We are not persuaded by these claims. With
regard to the first claim, we note that every end user,
large or small, who filed comments in this proceeding
contends that NYNEX's current proposal will cause customer
confusion, not cure it. The NYNEX claim that
multiple IXC billing would not be possible is not persuasive.
The implied assertion that NYNEX cannot identify
revenues associated with individual IXC minutes as they
pass through the taper is at odds with NYNEX's claim
that it is capable of providing end users with detailed
billing information on a call-by-call basis, including the
name of the IXC used to place the call and the date, time,
duration and called number.7' Against this background,
and in view of the widespread belief among public officials
and end users that the NYNEX plan will generate
significant customer confusion, we conclude that the single
IXC billing option in the plan is not an adequate
solution to the concerns expressed in the Guidelines Order.72
58. A further potential customer confusion point we
wish to address is the treatment of calls that are billed to
a person other than the subscriber over whose line the
call is placed. Included in this category of calls are
collect, credit card, and third-party-billed calls. While it is
not perfectly clear, it appears that most calls of this
nature would not be included in the NYNEX plan and
thus would not be assessed end user charges. Instead, the
charge for originating access associated with such calls
would continue to be billed to the IXC and subsequently
recovered in the charge it assesses the billed party. We
agree that this is the proper treatment of such calls.
Consumers derive considerable utility from being able toplace these calls in certain circumstances, as evidenced by
the demand for such calls despite the fact that IXCs
charge more for these calls than for direct dialed calls.
We would be very concerned about any end user plan
that did not provide consumers with the opportunity to
make such calls without causing a charge for originating
access to be billed to the local exchange subscriber over
whose line the call is placed.73
2. Impacts On IXC Competition
59. In the Guidelines Order, we concluded that the New
England Telephone Company (New England) appeared to
have provided an adequate response to concerns that its
end user plan would have negative effects on full and fair
competition among IXCs.74 Many of the specific methods
New England proposed for mitigating negative impacts on
IXC competition, including an offer to convert FGA lines
to FGB at no charge to IXCs, have been incorporated into
the current NYNEX plan. The more complete record in
the current proceeding, however. illuminates certain flaws
in these methods, which we address below. More importantly,
this record illuminates certain other issues that
require further consideration.
60. Allegations that the NYNEX plan will have significant
negative impacts on IXC competition are based, in
large measure, on the fact that equal access is not available
throughout the NYNEX region. IXCs commenting
on this issue note that only a bare majority of the total
lines in the NYNEX region have been converted to equal
access.75 NYNEX asserts in response that only about 10
percent of all traffic in New York originates over FGA
and FGB lines.76 We believe that NYNEX's apparently
low figure understates the problem. All the IXC traffic
originating over FGA and FGB is OCC traffic. While
originating FGA and FGB traffic may represent only 10
percent of the total originating traffic in the New York, it
undoubtedly represents a much higher percentage of
OCC originating traffic. Thus, the differential impact the
NYNEX plan could have on these competitors of AT
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United States. Federal Communications Commission. FCC Record, Volume 2, No. 1, Pages 1 to 409, January 5 - January 16, 1987, book, January 1987; Washington D.C.. (https://digital.library.unt.edu/ark:/67531/metadc1597/m1/75/?rotate=90: accessed May 14, 2024), University of North Texas Libraries, UNT Digital Library, https://digital.library.unt.edu; crediting UNT Libraries Government Documents Department.