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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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