BEFORE THE
WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION

UT-971514



Proposed Revision of  )  COMMENTS OF UNITED TELEPHONE
Customer Provided Network )  COMPANY OF THE NORTHWEST
Information (CPNI) Rules )  dba SPRINT AND SPRINT
 COMMUNICATIONS COMPANY L.P.
 dba SPRINT







 United Telephone Company of the Northwest dba Sprint and Sprint Communications 
Company L.P., dba Sprint (collectively referred to herein as “Sprint”) welcome 
the opportunity to comment on the proposed revision to Customer Provided 
Network Information (CPNI) rules at WAC 480-120-139(5), 140, 150, 151, 152, and 
153.
 First of all, Sprint heartily commends the staff for proposing to adopt rules 
that mirror the FCC’s rules and for including language that is nearly 
verbatim.  The addition of any consequential state-specific variations from the 
federal rules would be extremely burdensome to a company such as ours that 
operates throughout the country.
 Sprint wants to stress most strongly in this response, however, that 
Washington should not adopt any new CPNI rules until the FCC docket is closed.  
The FCC currently has several elements of its recent order under 
reconsideration, most notably  the sweeping system-related safeguard 
requirements also prescribed in the WUTC proposal (WAC 480-120-153).  These 
proposed requirements have caused significant concern to, and drawn 
overwhelming criticism from, nearly every party involved in the federal 
rulemaking.  Sprint believes that the FCC is seriously reconsidering, among 
other provisions, the requirement to modify all customer representative 
interface tools and the requirement to design, develop, and implement a 
detailed customer account activity monitoring mechanism which audits all 
possible contact with a customer’s records .  In fact, the FCC has issued an 
order within the last several weeks extending the deadline for compliance with 
the system safeguards.  It is Sprint’s position that the systematic safeguards 
ordered by the FCC are excessive, highly administratively burdensome, and would 
result in a price tag in the tens of millions of dollars to implement.  In 
fact, if the other rules and guidelines prescribed are followed, the systematic 
safeguards would be unnecessary and only result in driving up costs, possibly 
having an adverse affect on consumer prices.  In light of these significant 
operational and financial concerns being critically reviewed at the federal 
level, it would be both awkward and inappropriate for the Washington Commission 
to adopt standards that may well be changed in the very near future.
 Furthermore,  in order to ensure accurate interpretation of any WUTC rules and 
avoid any misconstrued or costly state-specific requirements relating to CPNI, 
Sprint suggests that clarifying language be included describing the 
relationship to the FCC rules.  Sprint recommends that  the Washington CPNI 
rules be adopted after the FCC docket is concluded and that the following, or 
similar, language be added:  
“These rules, as issued by the Washington Utilities and Transportation 
Commission, are intended to be internally consistent with those issued by the 
Federal Communications Commission.  Nothing contained herein should be 
construed as contradicting or undermining the guidelines and requirements as 
promulgated in the Federal Communications Commission’s proceeding on CPNI (CC 
Docket No. 96-115).”
 In summary, Sprint applauds the efforts of the WUTC in its aim to remain 
entirely consistent with the rules being promulgated at the federal level.  
This demonstrates an awareness, on the part of the commission staff, of the 
burdens and difficulties caused by state requirements that conflict with, or 
are in addition to, federally issued rules.  However, in light of the fact that 
several important facets of the FCC’s rules are currently under 
reconsideration, and given the foundational nature of those discussions, Sprint 
asks that the WUTC refrain from finalizing Washington’s CPNI rules until after 
the FCC rules have been reconsidered and the docket closed.

Respectfully submitted this 2nd day of October, 1998 by

      ___________________________________
      Nancy L. Judy, AVP – External Affairs