Verizon California Inc.

Verizon California Inc. and Verizon Long Distance (collectively, Verizon) support a 5% error rate, stating that an error rate of 0% is unreasonable and would have the effect of eliminating the use of predictive dialers. Verizon also urges that the rules adopted here either should not apply to automatic dialing-announcing devices covered by Pub. Util. Code § 2871 or provide for exemptions when such devices are used to contact existing customers to inform them that a service or repair request has been completed or that service may be terminated due to nonpayment. Automatic dialing-announcing devices dial numbers and provide the caller with a pre-recorded message. The exemptions noted by Verizon apply to such devices pursuant to Pub. Util. Code §§ 2872(f) and 2872(d)(4).

Verizon suggests one change to the proposed record-keeping requirements: retention for one year instead of three or four years. Apart from that, Verizon recommends a 60-day phase-in of the record-keeping requirements to give it time to program changes in its tracking systems and train its personnel.