II. Position of Applicant
Cable & Wireless states that its request to withdraw from the local resale market is a strategic business decision based upon the Company's plans for future growth, and not due to corporate financial constraints or an inability to continue to provide service to its interexchange and other enhanced service customers. Cable & Wireless has reevaluated its local business plan and has concluded that it is in the Company's best interests, at this time, to streamline its service offerings and to focus its attention and financial strength on the provision of interexchange and other enhanced IP services to business customers instead of the local exchange market.
To facilitate customer transfer and facilitate its request for expedited treatment, Cable & Wireless states that it has developed a comprehensive three-step customer notification plan to ensure a seamless transition for its current local resale customers. An initial notice was sent to customers concurrent with the filing of this application. The notice informed customers that Cable & Wireless has requested permission to discontinue service and that no action will be taken until the Commission has approved the application. The notice informed customers of the need to make other arrangements for local phone service and provided customers with a toll-free customer assistance number to address any questions or concerns.
Cable & Wireless' three-step plan also provides for two additional notifications. The second will be sent upon approval of the Company's withdrawal application and will give customers 30 days from the date of the second notification letter to transition to another local provider. The third letter will be sent two weeks before the discontinuance of service as a final reminder. Finally, one week before the discontinuance, Cable & Wireless will verbally follow-up with any customer that has not changed its local provider to personally assist in the transition. Cable & Wireless states that this plan provides customers with more than the 30 days' notice required by D.97-06-096.2
As further support for its withdrawal from local service, Cable & Wireless states that it does not owe any outstanding regulatory surcharges to the Commission.
2 Notice requirements for transfer of a customer base from one carrier to another, adopted in D.97-06-096, established the following minimum requirements:
1. The notice must be in writing; 2. The carrier must provide it to customers no later than 30 days before the proposed transfer; 3. The notice must contain a straightforward description of the upcoming transfer, any fees the customer will be expected to pay, a statement of the customer's right to switch to another carrier, and a toll-free number for questions; and 4. The notice and the carrier's description of service to customers must be included in the advice letter.
