STATE OF WASHINGTON
WASHINGTON UTILITIES AND TRANSPORT COMMISSION

Re: Notice of Preproposal Rulemaking )
Inquiry Regarding Prepaid Telephone )  Docket No. UT-971469 
Services and Notice of Comments Due )
March 18, 1998    )

COMMENTS OF WORLDCOM, INC.

 WorldCom, Inc. ("WorldCom"), on behalf of its operating subsidiaries WorldCom 
Technologies, Inc. and BLT Technologies, Inc., hereby submits its comments in 
the above captioned docket, pursuant to the Commission's notice dated February 
17, 1998. 
INTRODUCTION
 WorldCom, which is the largest provider of prepaid phone cards to the retail 
industry, welcomes this opportunity to comment.  Given that the company agrees 
with the comments filed by the International Telecard Association ("ITA"), of 
which it is a member, WorldCom will limit its comments to two areas in which it 
wishes to highlight several issues.  Those areas are the disclosure to the 
customer of  the underlying carrier's name, and limits on debit card 
denominations.
RECOMMENDATIONS
Disclosure of Underlying Carrier's Name
 As ITA aptly stated, the intent of this requirement is unclear.  Presumably 
the purpose of the proposal is to require the name of the phonecard issuer to 
be disclosed on the card.  Such a requirement would be appropriate.   However, 
a rule requiring that the name of the underlying facility based carrier be 
disclosed on the card would be entirely inappropriate.  The reason for this 
becomes apparent when you consider that it is the phonecard issuer, and not the 
underlying carrier, that is entirely responsible for the retail offering.  The 
card issuer determines the retail usage rates 
1
and charges, calling area limitations, phonecard design, and deals with 
customer service issues.  The network on which the calls are carried is 
transparent to the retail customer.  Disclosing the underlying carrier's name 
in such instances would be inappropriate and confusing to the customer.
Limit of Debit Card Denominations
 While staff may not have made a specific recommendation on the limit of debit 
card denominations, a de facto rule has been established through the 
commission's various Authorizing Registration decisions.  That rule being a $50 
denomination limit for cards purchased by residential customers and $200 for 
business customers.  Such a regulation is problematic in that it is extremely 
difficulty to police in the retail sales channels (e.g. the local grocery store 
or retail outlet).  How can a merchant validate if the customer that just 
walked into his/her store is going to use a card for business or residential 
services?   There is no way to police the consumer's usage.  In addition, how 
are customers to be handled that use the card for both business and residential 
purposes? 
 Given the problems with limits on card denominations set forth above and 
raised by ITA in their comments, WorldCom recommends that the commission not 
establish limits on card denomination, and certainly not at the $50 level 
previously established.  Instead, the commission should let the market forces 
determine phone card denominations as they have in other areas of the country.
 WorldCom appreciates this opportunity to comment and is looking forward to 
discussing the issues in greater detail at the upcoming workshop.
 
 
 
      Respectfully Submitted,
 
 
 
      _____________________
      Robert Munoz
      WorldCom, Inc.
      Assistant Director
      Western Region Regulatory Affairs
      225 Bush Street, Suite 1900
      San Francisco, CA 94104
      415-743-4959
      415-743-4975 (fax) 
        
 
      Dated March 17, 1998