Large business customers of this type generally have numerous competitive alternatives and are, by definition, afforded adequate consumer protection since they can always return to an ILEC or switch to a different CLEC if there are service or other problems with the CLEC they have chosen. A definition of a business customer with 25 access lines in a building would be administratively burdensome and extremely costly for Sprint to implement. Sprint s billing and reporting systems are not designed to identify the number of access lines by building or location. Such access line identification would require major modifications to Sprint billing and reporting systems with concomitant labor and expense outlays. The proposed rule requires carriers to determine creditworthiness of applicants based on payment history with any public or municipal utility, employment record, dwelling status, etc.
Sprint believes such requirements are overly restrictive and limiting.
These provisions would require time-consuming and expensive validation measures. Sprint uses a credit scoring process for determining creditworthiness that is an effective, consistent, equitable, and objective credit assessment. Sprint believes each carrier should have the flexibility to establish its own method of determining creditworthiness using its best business judgment, provided that such method is equitable and nondiscriminatory to all applicants, and is appropriate to the needs of the applicants. The proposed rule requires e ach utility to mail to each customer on an annual basis, without charge, a brief summary of the customer s rights and responsibilities contained in this rule. In addition, each utility shall forward a copy to the commission annually to be kept on record with the commission s consumer affairs division.