11. Third-Party Verification Compliance Survey

In D.98-02-009, the Commission ordered an audit of all California telephone corporations to ensure industry-wide compliance with the statutory requirement that all residential customer transfers from one long distance carrier to another be verified by an independent third party. The decision included a questionnaire that all interexchange carriers and competitive local carriers were to complete and return to the Commission staff.

Despite a reminder notice, the response rate was unsatisfactory, to say the least:

IEC/CLC Survey Response (as of 5/26/98)

Surveys Completed 287 46.6%

Surveys Incomplete 67 10.9%

Postal Returns 51 8.3%

No Response 212 34.2%

Over one-third of the Commission-certificated carriers that were ordered by a Commission decision to respond to this survey failed to do so!

Due in part to the lack of carrier response to the third-party verification questionnaire, the Commission staff has become aware of the unacceptably high rate of carrier noncompliance with this and other filing requirements. In investigating the cause of the problem, staff has discovered that its list of names and addresses of carriers may be inaccurate and incomplete. To cure this first level of causation, Commission staff have undertaken an aggressive effort to locate the carriers whose notices were returned by the post office as undeliverable. The 51 carriers from this effort and 20 additional carriers from another inquiry were assigned to analysts that are using all available resources to obtain correct addresses for these carriers. While staff located many carriers and resent the survey, the carriers that were not found or did not respond will have their CPCN suspended via the Commission Resolution process. After the analysts completed these "undeliverable" carriers, they followed the same process with the 212 nonresponsive carriers. Again, carriers that did not cure their lack of a response will have their CPCN suspended via the Commission Resolution process.

To date, Commission staff have identified 48 carriers which have not filed responses. Diligent efforts to locate these carriers have been unsuccessful. Resolutions suspending these carriers' CPCNs are pending on the Commission's agenda. Additional such suspension resolutions are expected in the future.