Date:         March 29, 2000
Items:          2F, 2G, 2H, 2I, 2J, 2K, and 2L
   
Dockets and Companies:
        UT-000372          Toledo Telenet Long Distance Company                 
 (Toledo)
        UT-000373         Coin Telecom, 
Inc.                                             (St. John)
        UT-000374  Pioneer Telephone Long Distance Company (Pioneer) 
        UT-000375         Tenkal 
Company                                             (Tenino/Kalama) 
        UT-000376         Inland Long Distance 
Company                           (Inland)
        UT-000377          Hood Canal Communications Long Distance, 
Inc.         (Hood Canal)
        UT-000378         Western Long Distance, 
Inc.                                    (Whidbey)
Staff Team:           Tim Zawislak, Policy Research Specialist
                    Jing Roth, Regulatory Consultant
                    David Dittemore, Utilities Engineer
              Tami Schultz, Telecommunications Analyst
              Teri Wallace, Telecommunications Analyst
                         Tani Thurston, Consumer Program Specialist
                    Penny Hansen, Public Involvement Coordinator
Recommendation :
Issue an Order Granting Limited Waiver of WAC 480-120-139, for the initial 
transfer of intraLATA toll customers from U S WEST Communications, Inc., on 
March 31, 2000.
Background: 
On March 1, 2000, the above-named companies filed petitions with the Commission 
to provide intrastate, intraLATA, interexchange toll service, through resale. 
The seven companies listed above are new companies which are affiliated with 
well-established small, rural, independent incumbent local exchange companies 
(ILECs)1 in Washington. These new companies seek registration, competitive 
classification, and price list approval in order to offer intraLATA toll 
service to customers scheduled to be abandoned by U S WEST Communications, 
Inc., at the end of this month.2 The registration, classification, and price 
list filings are all standard filings and are therefore on the consent agenda 
of this open meeting under Dockets UT-000288, UT-000289, UT-000290, UT-000291, 
UT-000292, UT-000299, and UT-000300.
Although other intraLATA toll providers are available in these areas, the 
above-named applicants = affiliates see this change as an opportunity to better 
serve related local customers by providing service as a carrier of last resort, 
in place of U S WEST. Other independent ILECs who are not pursuing this 
opportunity are requiring customers (who have
U S WEST as their intraLATA toll carrier) to choose a new carrier. The 
above-named applicants are, in effect, offering themselves as the default 
carrier in the event a customer does not wish, or fails, to make a choice. 
Additionally, the companies have committed in their transmittal letters to give 
all new customers a choice of all available intraLATA and interLATA carriers. 
Discussion of Waiver Request:
On March 14, 2000, the above-named companies filed a petition requesting that 
the Commission grant a limited waiver of WAC 480-120-139 for the initial 
transfer of customers from U S WEST Communications, Inc. (U S WEST). 
Essentially, the request for limited waiver would enable the companies to 
switch customers from U S WEST, to themselves, without the customer 
authorization required in the Commission = s slamming rule, WAC 480-120-139. 
Staff supports this approach, in this instance, because the companies have 
notified affected customers, and have all agreed to replace U S WEST as the A 
carrier of last resort @ in their respective serving areas.
The customer notices were sent to customers earlier this month and were 
reviewed by the Commission = s Public Affairs Section staff prior to mailing. 
Customers have been informed of their options, and have been given the 
opportunity to change to another carrier (besides the new affiliates), without 
incurring a presubscribed interexchange carrier change (PIC) charge,
up to June 1, 2000. This process is similar to what the Commission has 
previously granted through Docket UT-990976. A sample notice is included as an 
attachment to this memo.
Conclusion: 
Staff therefore recommends that the Commission issue an order granting limited 
waiver of
WAC 480-120-139, for the initial transfer of intraLATA toll customers, on March 
31, 2000.
        1 The ILEC associated with each new company is listed to the right of 
each, in parentheses.
        2 U S WEST Communications, Inc., (U S WEST) has elected to exit the 
intraLATA toll market in all independent local exchange company areas, except 
that of CenturyTel, effective March 31, 2000. U S WEST continues to provide 
intraLATA toll to customers in local exchange areas where it provides local 
service.