IV. Billing Disputes

SBC-CA proposes that any billing disputes arising from true-up payments should be handled in the same manner as billing disputes are handled today, i.e., through existing interconnection agreements, which describe a process of escalation and formal dispute resolution. AT&T, CALTEL, MCI, and Pac-West agree with this position.

Covad, MPower and RCN contend SBC-CA has not provided them the backup information necessary to evaluate SBC-CA's calculation of true-up amounts. These carriers generally ask the Commission to order SBC-CA to provide appropriate supporting information and sufficient time for review of billing records before rendering any bill for the true-up. Arrival maintains the Commission should play an active role in resolving disputes over the calculation of true-up payments because the dispute resolution process in interconnection agreements is onerous and expensive. Covad contends SBC-CA has failed to recognize contract amendments incorporating ISDN and DS-1 rates in true-up calculations. SBC-CA disagrees with Covad's assertion that ISDN rates are subject to true-up.

Discussion. We agree with SBC-CA and the other carriers that billing disputes over true-up payments should be handled through the procedures set forth in interconnection agreements. We decline to insert the Commission into the process of resolving any disputes when interconnection agreements already address this issue. Arrival has made an unsupported assertion that the dispute resolution process is onerous and expensive. We doubt it could be any more onerous or expensive than Commission involvement on the same topic. As to the ISDN issue raised by Covad, this is a contractual true-up dispute, similar to those raised by XO/Allegiance, which is beyond the scope of the true-up ordered in D.04-09-063.

Several carriers ask the Commission to ensure that SBC-CA provides adequate information to verify their true-up bills. SBC-CA contends it has provided the information requested. Again, we will refrain from involvement in these disputes, but we strongly urge SBC-CA to provide adequate supporting information for its bills.