TD recommends that the Commission vote occur on July 12 to ensure sufficient time for bill inserts and tariff revisions. Changes in the schedule specifically related to payphones will be discussed in the subsequent payphone section of this report.
Comments
Hale Zukas comments that the uncertainty associated with the status of the primary provider for the California Relay Service was likely to create problems with the implementation of 711 including perceptions of long term unreliability. He suggests instead a November 1, 2001 implementation date.
Comments
Hale Zukas comments that the uncertainty associated with the status of the primary provider for the California Relay Service was likely to create problems with the implementation of 711 including perceptions of long term unreliability. He suggests instead a November 1, 2001 implementation date.
In order to ensure maximum public awareness of 711 both within the community traditionally served by relay services and those outside of it, consumer education and outreach efforts should be undertaken. TD proposed a freestanding insert (separate sheet) be included in consumer bills of all carriers. This insert must detail the 711 service in the state of California as well as the existence of alternative relay providers, be free of advertisements or endorsements and approved by the Commission's Public Advisor prior to release. The insert must be distributed at least 30 days prior to the implementation date of October 1, 2001.
Workshop responses
AT&T Wireless (ATTW) plans to include information regarding 711 as a regular bill attachment and asked for clarification of the wording of the education and outreach proposal to provide it direction with regard to inserts. ATTW hopes the inclusion of 711 information on its monthly bills precludes any need for an additional insert.
Some carriers indicated they had already included inserts related to N11 services such as 711 and believed these inserts eliminated the need for additional inserts specifically for 711.
Discussion
The efficacy of bill inserts over printed billing instructions is of great concern to TD. TD believes that ATTW's intended monthly inclusion of information related to 711 on consumer bills is admirable and TD commends their decision. TD believes that the inclusion of 711 information as proposed by ATTW has two significant shortcomings. The first concern is that information related to the availability of alternative relay service providers has been omitted from the language of the information. Secondly, TD questions the efficacy of billing line items similar to those proposed by ATTW as compared to separate informational inserts free of advertising.
