VIA AIRBORNE OVERNIGHT October 2, 1997 Mr. Steve McLellan Secretary Washington Utilities and Transportation Commission 1300 S. Evergreen Blvd, S.W. Olympia, Washington 98504-7250 Re: Draft of Pay Telephone Rules Changes UT-970301 Dear Mr. McLellan: This letter sets forth Sprint Communications Company L.P.’s (Sprint’) Comments regarding Docket UT-970301 Draft Pay Telephone Rule Changes provided to Sprint in your September 12, 1997 letter. Sprint is submitting this original and 11 copies as well as a 3 ½ inch IBM formatted high-density disk in Word 7.0. Page 2, the description of “Pay phone, payphone, or pay telephone” The inclusion of the statement “any telephone made available to the public on a fee-per-call basis…” should be modified to read “any telephone made available to the public on either a fee-per-call or toll free basis…” This will make the verbiage consistent with other references in the proposed changes. Page 5, WAC 480-120-138 subsection 7 This section should be modified to read: “The telephone number, including area code, of the pay phone must be displayed on each pay phone. When the pay phone is in an area that has had an area code change, that area code change shall be promptly reflected on the pay phone within 30 days of the initial area code conversion”. This will eliminate the confusion with potential area code changes in Washington. Page 5, WAC 480-120-138 subsection 12 This section should be modified to read: “Pay phones shall be connected only to pay phone access lines (PALs) in accordance with the approved tariffs offered by the local exchange company. This PAL shall pass the appropriate screening codes to the connecting carrier to indicate that the call is originating from a pay phone”. This will ensure that losses based on fraud will be minimized. Page 6, WAC 480-120-138 subsection 15 This section should be modified to read: “Involuntary changes in telephone numbers of pay phones are prohibited unless that change only involves the area code portion of the line number and is required for the implementation of an authorized area code change”. This will ensure that these rules do not have to be updated simply to facilitate an area code change. Page 6, WAC 480-120-138 subsection 20 This section should be modified to read: “Pay phones shall provide, without charge, access to all available subscriber 800/888 or other toll free services”. This change is being suggested so that the rules do not have to be modified when the new toll free area code is established in 1998. Page 8, WAC 480-120-141 subsection 5 (iv) This subsection appears to contain a typographical error, should read: “Directions to all the consumer to reach their preferred carrier; and,” Page 8, WAC 480-120-141 subsection 4 (eb) This section should be modified to read: “Provide access from every instrument to all available subscriber 800/888 or other toll free services and all interexchange carriers at no charge to the consumer.” This change is being suggested so that the rules do not have to be modified when the new toll free area code is established in 1998. Page 10, WAC 480-120-141 subsection 12 (a) This section should be modified to read: “…if the originating line subscribed to outgoing call screening and the call was placed after the effective date of the outgoing call screening order. If the local exchange carrier provided a PAL without appropriate call screening, then the local exchange carrier shall be liable for any unbillable calls.” No line should be connected to a pay phone that does not have the capability of passing call screening information indicating that the call originated from a pay phone. The customer and the company providing the PAL are the only people who know if the line screening features are on the line and they should be held accountable for any errors in the provisioning of this service. Page 10, WAC 480-120-141 subsection 12 (d) This section should be modified to read: “If the local exchange company, after investigation, determines that call screening would have protected the call, which is offered by the LEC and was subscribed to by the call aggregator (the call aggregator must have the technical capability to utilize these screening codes), was not operational at the time the call was placed, the OSP shall bill the LEC and the LEC shall pay for the call.” This simply clarifies that the LEC is liable for the error if the screening was not functioning properly. If you have any additional questions related to these inputs, please feel free to contact me. Sincerely, Geoff Grigsby Group Manager State Regulatory Affairs/West pc Nancy Judy Carol Matchett Richard Purkey