Part 3: Reserved

Former Part 3 concerned rules governing privacy in addition to the existing Public Utilities Code § 2891 privacy requirements. The original staff report in Rule 12, had proposed requiring carrier compliance with "...P.U. Code Section 2891, 2891.1 and 2893, and any other applicable state or federal statues or regulation... that pertain to customer privacy" without addressing the need to harmonize state and federal law. As a result, parties have expended a great effort to address state privacy protection under California law in light of federal regulations promulgated pursuant to Section 222 of the Telecommunications Act, and First Amendment requirements that restrictions on commercial free speech meet certain criteria. Questions about the implementation of Section 2891 in this environment would benefit from the development of a more extensive record.
We will therefore endeavor to resolve this issue in the Phase of this proceeding immediately following initiation of these rules.