Discussion

In D.89-11-039, the Commission granted Sierra Telephone Company's (Sierra) request to withdraw from the CCCS on the basis that Sierra's costs outweighed its benefits. The Commission held that "[a]ny utility participating in the CCCS program which can show that it is not cost-effective to continue in the program should file an application with the Commission for authority to withdraw from the program."

Verizon states that it has been a member of the CCCS since its inception, but that the CCCS is no longer cost-effective for the company. Verizon does not currently utilize CCCS data in making California credit decisions and has no plans to use CCCS data in the future. In fact, Verizon asserts, while the CCCS was developed to allow carriers to determine credit risk to utilities and, based on that credit risk, to determine the level of a deposit to require from the customer, Verizon does not currently take deposits from any of its California residential customers. Thus, Verizon concludes, there is no benefit to Verizon from participating in the CCCS.

Verizon, however, continues to incur costs related to the premium it must pay to be a member of the CCCS and for the privilege of being able to use the CCCS, which must be paid even if the carrier does not actually use it.

We see no point in requiring Verizon to remain a member of a service it does not use and has no intention of using. Any payment for something that is not used at all is not a cost-effective use of resources. Thus, while Verizon did not provide data on the amount it pays to be a CCCS member, such data is unnecessary because Verizon receives no compensating benefit from such payment.

Further, our precedent makes clear that participation in the CCCS was voluntary after the initial three-year trial. We presume Verizon stuck with the program thereafter because it gained a benefit from it. However, we see no reason for Verizon to use the program if it provides no such benefit now.