15 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 servicesPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011