BEFORE THE
WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION

UT-970301


Proposed Pay Phone  )  Comments of United Telephone
and Operator Services )  Company of the Northwest
Rule Changes   )  dba Sprint




 United Telephone Company of the Northwest dba Sprint (“Sprint”) appreciates 
the opportunity to comment on the August 17, 1998, “Draft of Pay Phone and 
Operator Services Rule Changes” in Docket No. UT-970301.
 Sprint understands and supports the Commission’s intention that the customer 
clearly understand the rates and conditions for each pay phone, along with 
options for contacting the provider or the Commission in the event of a problem 
or complaint. We do have a few suggestions concerning the proposed rule changes 
as currently drafted, however.
 Our concerns center on some of the proposed amendments to WAC 480-120-138.  It’
s proposed, for instance, that the placard include the FCC number, the 
number(s) of the intra-  and interLATA long distance provider(s), the customer 
service and repair numbers of the payphone provider, and (in contrasting 
colors) the WUTC’s number.  We respectfully suggest that the average pay phone 
user is likely to be more confused than assisted by so many choices and that 
the payphone provider’s customer service representative could easily provide a 
caller with any of the other phone numbers if needed.  This would also 
substantially reduce costs to nation-wide companies that cannot easily 
accommodate state-specific information on payphone placards.
 Sprint is also concerned about the expense associated with the requirement 
that the rate(s) for intra- and interLATA presubscribed directory assistance 
calls be posted.  Both the information content and durability of placards that 
would be required by these proposed rule changes necessarily require relatively 
expensive placards.  Every time directory assistance rates—intrastate, 
interstate or national—change, the placards would have to be replaced.  This is 
not very cost effective, in Sprint’s view, when one considers that there are 
few directory assistance calls placed from any other kind or location of phone 
for which the caller knows the rate in advance.
 Our final concern focuses on the proposed changes in the process for 
restricting a payphone.  The current method of securing a letter from law 
enforcement and posting the phone as “one way” has been working well.  The 
proposed new process would be more burdensome and lengthy, requiring much more 
labor and paperwork.  Additionally, payphone providers would not be able to 
address any problems, no matter how serious or disruptive, at a location in 
less than thirty days.  We also note that, especially in the high crime areas 
where payphone restriction is most often requested, it would be highly unlikely 
that the required posting of notice would remain in place for thirty days.
 Sprint suggests that the current method be retained, possibly with the added 
requirement that the letter from law enforcement be kept on file by the 
payphone provider to be produced upon request from the Commission.
 As always, Sprint appreciates the thought and effort Commission staff has put 
into these proposals and also the opportunity to comment on them.

Respectfully submitted this 18th day of September, 1998, by

      ___________________________________
      Nancy Judy – AVP External Affairs