Golden Belt Telephone Association, Inc. - Page 10

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               service and hence the rates that IXCs [interexchange or                
               long-distance carriers] must charge their interstate                   
               customers.  Moreover, * * * DNP [disconnection for                     
               nonpayment] is integral to the billing and collection                  
               service that C&P provides to interstate carriers. * * *                
                   Finally, * * * AT&T must rely on the LECs to                      
               perform recording of call detail information * * *.                    
               * * * IXCs cannot, as a practical matter, offer                        
               interstate telephone service without obtaining recorded                
               call detail information sufficient to collect payment                  
               from customers * * * .                                                 
                    Besides "affecting" interstate communications, the                
               billing and collection service that C&P provides for                   
               AT&T are also "closely related to the provision of                     
               [such] services," since billing and collection must                    
               occur accurately and efficiently for an interstate                     
               carrier to offer its services on an economically sound                 
               basis.  From a technical perspective, DNP and the call                 
               detail recording function are two integral components                  
               of the billing and collection services that C&P                        
               provides to interstate carriers that are closely                       
               related to the interstate communication services of                    
               those carriers.  DNP and recording are each performed                  
               as a function of the LECs' provision of interstate                     
               communications service * * * that other, non-carrier                   
               vendors of billing and collection services cannot                      
               provide.                                                               
                    * * * When one interstate carrier is performing                   
               billing and collection for the interstate services of                  
               another interstate carrier under circumstances like                    
               those involved in C&P's relationship with AT&T the                     
               billing and collection service is incidental to                        
               interstate communications and subject to our Title I                   
               jurisdiction.  [Fn. ref. omitted; emphasis supplied.]                  
          4 FCC Rcd at 4005.                                                          
               Finally, in 1992, the FCC formally reversed the position it            
          had taken in the 1986 Detariffing Order.  In In the Matter of               
          Policies and Rule Concerning Local Exchange Carrier Validation              
          and Billing Information for Joint Use Calling Cards, 7 FCC Rcd              
          3528 (1992) (1992 FCC Decision), the FCC stated affirmatively               




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