IV. Reply of VSSI

On April 2, 2001, VSSI filed a response to the customers' comments made at the public participation hearing (PPH), addressing both general objections to the application and responding to individual service-related complaints raised by certain customers at the PPH. ³ VSSI provided a report on steps it has taken to address the individual service-related complaints since the PPH. VSSI also provided a general discussion explaining in more detail the measures it has taken to provide additional internal company support systems to assist customers in the transition process. VSSI claims that it has devoted significant resources to provide customers with the maximum opportunity to select a carrier of their choice, and to ensure as smooth a customer transition as possible. VSSI believes that the vast majority of customers in California and nationwide have been transferred smoothly and without incident.

VSSI states complaint calls to VSSI call centers received prior to the third notification letter were generally minimal and of a routine nature. VSSI states that it was after the mailing of the third-customer notification letter that a number of complaints about the timing of the withdrawal were brought to VSSI's attention by Commission staff. VSSI states that the third notification letter sent to its customers, unlike the first two letters, was mailed without internal regulatory or legal review. Had it received such review, VSSI states that the third notification letter would not have been sent. VSSI concedes that, in retrospect, the third letter was confusing and conveyed the impression that service would be transferred independent of Commission approval. VSSI expresses regret for this result.

Prior to the issuance of the third letter, VSSI records show that 65% of its customers had already selected another service provider. As of April 2, 2001, an additional 55% (or roughly 35,000) of remaining customers have selected another carrier. VSSI reports that virtually all customers outside of California have already switched to other carriers. VSSI argues that it would be extremely costly and unreasonable to require VSSI to maintain adequate staff resources to continue to provision service to a customer base of 28,000, which is further dwindling. VSSI reiterates its request for prompt approval of its application.