20010130_jh.doc

January 30, 2001

To: All Interested Parties

RE: Updated Staff Redline Version of Operator Services and Pay Telephone Rules

Dear Interested Party:
On November 20, 2000, the Commission Staff requested that final comments on the Operator Services and Pay Telephone Rules, IDAPA 31.51.01, be made on or before December 11, 2000. Qwest Corporation was the only party to file comments. Qwest requests that the following revisions be made to Rules 212 and 213.

212. PAYMENT OF BILLING DEPOSITS-PAY TELEPHONES (Rule 212).
The PSP customer of record for the public access line to which the pay telephone is connected is responsible for payment of all billings to that the public access line to which the pay telephone is connected, . . . .

213. RESPONSIBILITY FOR COMPLIANCE-PAY TELEPHONES (Rule 213).
.01 LEC termination with Notice. The PSP customer of record for the public access line to which the pay telephone is connected is responsible for compliance with the LEC’s and Commission’s rules for the provisions of pay telephone service. . . .

Comments of Qwest Corporation at 2.

Staff has no objection to these changes and no other interested parties has raised concerns about them. Therefore, they will be incorporated into the finalized draft of the Operator Services and Pay Telephone Rules.

In addition, the Staff notes an omission which was made when the last version of these Rules was drafted. Specifically, that Rule 104.04 was omitted The language of this section is as follows:

Disclose, audibly and distinctly to the consumer, at no charge and before connecting any call for which there is a charge, how to obtain the total cost of the call, including any aggregator surcharge, or the maximum possible total cost of the call, including any aggregator surcharge, before providing further oral advice to the consumer on how to proceed to make the call. The oral disclosure required in this subsection shall instruct consumers that they may obtain applicable rate and surcharge quotations either, at the option of the provider of operator services, by dialing no more than two digits or by remaining on the line.

Staff’s record in this proceeding does not indicate that there was any objection to this language. However, because of its omission Staff welcomes any further comments which the parties feel are necessary.

As you are probably aware there is a moratorium on the submission of proposed rules while the Legislature is in session. Once the session is concluded Staff will move quickly to bring these Rules before the Commission for their review. If you have any questions please feel free to contact me at [phone].

Sincerely,

John R. Hammond
Deputy Attorney General

cc: Jean Jewell
Joe Cusick
Wayne Hart

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January 30, 2001
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