Golden Belt Telephone Association, Inc. - Page 15

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          reflection in the light of experience that B & C services are               
          "communication services" should be accorded weighty                         
          consideration, particularly in view of the FCC's expertise in               
          this field.                                                                 
               The Government also contends that billing and collection               
          "lacks any true connection to the act of completing long distance           
          calls and remains a service that many companies, not just                   
          telephone cooperatives, could perform for nonmember telephone               
          companies."  The point is without merit.  It erroneously assumes            
          that billing and collection  consists merely of sending out a               
          bill and depositing a check.  Although the Government is correct            
          that any company could perform such limited services, there are             
          certain services included within B & C services that only the               
          cooperative can perform.                                                    
               Unlike an outside entity, only local telephone cooperatives            
          can record the time, duration, and destination of a call.  Local            
          cooperatives also can disconnect service for nonpayment.                    
          Further, local cooperatives handle customer inquiries about a               
          range of matters relating to a customer's bill--a function that             
          cannot be performed by an outside entity. Thus, only the                    
          cooperative can verify the accuracy of the bill first-hand.  See            
          1989 FCC Decision, 4 FCC Rcd at 4005 n.76.                                  
               Based on the history of telephone cooperatives, the                    
          treatment of B & C services by the FCC as a "communication                  
          service", and the breadth of B & C services, B & C services                 




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