BILL ANALYSIS                                                                                                                                                                                                    



                                                                       



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                                 THIRD READING


          Bill No:  SB 1068
          Author:   Escutia (D), et al
          Amended:  3/30/05
          Vote:     21

           
           SENATE ENERGY, UTIL. & COMMUNICATIONS COMM.  :  7-3, 4/5/05
          AYES:  Escutia, Alarcon, Bowen, Dunn, Kehoe, Murray,  
            Simitian
          NOES:  Battin, Campbell, Cox
          NO VOTE RECORDED:  Morrow

           SENATE APPROPRIATIONS COMMITTEE  :  7-4, 4/25/05
          AYES:  Migden, Alquist, Ashburn, Bowen, Escutia, Ortiz,  
            Speier
          NOES:  Aanestad, Battin, Dutton, Poochigian
          NO VOTE RECORDED:  Florez, Murray


           SUBJECT  :    Telecommunications:  consumer protection

           SOURCE  :     Author


           DIGEST  :    This bill requires the Public Utilities  
          Commission to develop and enforce telephone consumer  
          protection rules reflecting specified policies by July 1,  
          2006.

           ANALYSIS  :    Existing law provides the Public Utilities  
          Commission (PUC) with regulatory authority over public  
          utilities, including telephone companies.

                                                           CONTINUED





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          This bill states the intent of the Legislature to establish  
          telephone consumer protections that are at least as  
          protective as those established by the PUC in its May 2004  
          decision.

          This bill requires the PUC to establish and enforce  
          telephone consumer protection rules by July 1, 2006 that  
          achieve the following policies:

          1. A consumer has a right to receive clear and complete  
             information about rates, terms, and conditions for  
             service.

          2. A consumer has a right to select services and vendors,  
             and to have those choices respected by telephone service  
             providers.

          3. A consumer has a right to personal privacy.

          4. A consumer has a right to participate in public policy  
             proceedings, to be informed of her rights, and to have  
             effective recourse if those rights are violated.

          5. A consumer has a right to accurate and understandable  
             bills.

          6. A consumer has a right to be treated equally with all  
             other similarly situated consumers.

          7. A consumer has a right to safety and security of person  
             and property.

          This bill requires the rules adopted by the PUC to include  
          all of the following:

          1. A telephone corporation shall disclose its rates, terms  
             and conditions of service.

          2. A telephone corporation shall make no deceptive or  
             misleading statement about its rates and services.

          3. A telephone corporation shall provide a customer with  
             written confirmation of every order for service and a  
             written copy of each contract.  A customer may cancel  







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             any new service within 30 days without termination fees  
             or penalties.

          4. Telephone corporations shall provide customer contracts  
             and make required disclosures in the language used to  
             advertise the product or service upon the customer's  
             request.

          5. For prepaid calling cards, every advertisement of price  
             shall include disclosure of any limitations, minimum  
             charges, and any other relevant fees or surcharges.

          6. Bills must be clearly organized and contain only charges  
             which have been authorized by the customer.  Only  
             government imposed fees and taxes may be identified as  
             government fees and taxes.

          7. For charges for non-communications services:

             A.    The telephone bill can contain those charges only  
                if the customer has authorized the charge.

             B.    The telephone corporation must take reasonable  
                precautions to screen out unscrupulous vendors.

             C.    The charges must be separately identified and  
                clearly labeled.

             D.    Basic telephone service cannot be disconnected for  
                non-payment.

           Background
          
           On February 3, 2000, the PUC commenced what has so far been  
          a more than five year effort to establish telephone  
          consumer protection rules.  After numerous opportunities  
          for written comment, over 20 public meetings in 13  
          locations throughout the state, additional opportunities  
          for written comment, creation of consumer and industry  
          working groups to attempt to settle differences, and more  
          public comment, the PUC on May 27, 2004 approved telephone  
          consumer protection rules that apply to all telephone  
          companies, including cellular companies.  Telephone  
          companies were given at least 180 days to implement the  







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          rules.

          Toward the end of 2004, most of the telephone companies had  
          implemented most of the rules.  However, many companies  
          requested a time extension to implement certain rules, and  
          pursuant to PUC procedures those extensions were granted  
          first for 30 days, then for an additional 30 days, and then  
          for an additional period of up to a year.  On January 5,  
          2005 a PUC Commissioner proposed staying the PUC's May 2004  
          decision, with the intent to vote on staying the rules the  
          following week.  During this time, the PUC had only three  
          members as two members' terms had expired at the end of  
          2004 and new commissioners had not been sworn in.  Rather  
          than attempt to stay the rules with a procedurally suspect  
          two to one majority, the Commission waited until a fourth  
          commissioner was sworn in.  Shortly thereafter, on January  
          27, 2005, the PUC voted to indefinitely stay their June 7  
          decision.  On March 10, 2005 the PUC issued a ruling to  
          follow up on the stay.  That ruling asked parties to  
          comment on several questions including:

          1. Which of the stayed rules cause little or no hardship to  
             telephone companies?

          2. To what extent have voluntary actions by telephone  
             companies eliminated the need for any of the stayed  
             rules?

          3. Are there equally effective but less restrictive  
             alternative approaches to providing consumer protection?

           Comments
          
          The intent of this bill is to enact telephone consumer  
          protection rules that are at least as stringent as the  
          rules adopted by the PUC in May 2004.  The bill provisions  
          reflect the policies contained in those rules but lack some  
          of the specificity.  There is one provision that is much  
          stronger than was contained in the PUC's rules.  That  
          provision requires that if a service is marketed in a given  
          language then the contract and disclosures must be in that  
          same language if requested by the customer.

          Supporters express exasperation at the PUC.  They note the  







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          difficulty in dealing with telecommunications companies and  
          the need for enforceable consumer protections.
                     
           Opponents are concerned that this bill is duplicative of  
          the PUC's process, and that the PUC should be permitted to  
          complete its process.  If the PUC's  
          March 10 ruling is any indication of the PUC's inclination,  
          it is little wonder that opponents prefer the PUC process.

          Opponents argue that adequate consumer protections already  
          exist, both in the form of a Wireless Code of Conduct and  
          through existing laws of general  
          applicability.  The Code of Conduct is voluntary, created  
          by the cellular carriers in response of consumer  
          complaints.  The laws of general applicability require  
          enforcement.  Is it reasonable to rely on the Attorney  
          General or District Attorneys to make enforcement of those  
          laws with regard to telecommunications service a priority,  
          given the other law enforcement matters they face?  The  
          author's office argues that better enforcement of telephone  
          consumer protection rules will occur if that job is given  
          to the PUC where it has historically resided and made a  
          priority.

          Opponents are concerned about state by state regulations  
          which they believe will impair the economies of scale that  
          some of the wireless carriers enjoy.  They point to a March  
          18, 2005 order by the Federal Communications Commission  
          (FCC) which bars states from requiring or prohibiting  
          discretely identified charges on a cellular bill.  That  
          order also includes several proposed rules on which the FCC  
          seeks comment.  Certain of those  
          rules could preempt California's ability to establish and  
          enforce consumer protection rules.  In its proposal. the  
          FCC noted that it believes that limiting state regulation  
          of  billing practices in favor of a uniform federal regime   

          "will eliminate the inconsistent state regulation that is  
          spreading across the country, making nationwide service  
          more expensive for carriers to provide and raising the cost  
          of service to consumers."

          While it is true that the FCC narrowly preempted the states  
          with regard to discretely identified charges, the broader  







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          FCC preemptions are proposed, not adopted.  Comments from  
          parties have yet to be considered.  Importantly, two of the  
          five commissioners expressed strong concerns over state  
          preemption and one of the remaining three commissioners has  
          resigned.  It is not certain whether the states will be  
          more broadly preempted.  

          The FCC order does have a lot to say about telephone  
          consumer protection, particularly with respect to cellular  
          companies.  Specifically, the FCC  
          concluded that cellular companies should no longer be  
          exempt from the requirement that billing descriptions be  
          brief, clear, non-misleading, and in plain language.  The  
          FCC reached this conclusion because "recent data indicates  
          that complaints regarding wireless 'billing & rates' and  
          'marketing & advertising' have increased significantly"  
          since 1999."  The FCC is "concerned that some (cellular)  
          carriers may be disguising rate increases in the form of  
          separate line item charges and implying that such charges  
          are necessitated by governmental action."  The FCC noted  
          that "the record reflects that consumers still experience a  
          tremendous amount of confusion regarding their bills, which  
          inhibits their ability to compare (cellular) carriers'  
          service and price offerings, in contravention of the  
          pro-competitive framework of the 1996 (Federal  
          Telecommunications) Act."  It seems that the FCC supports  
          the need for stronger consumer protections, recognizing  
          that voluntary measures and market forces have been  
          inadequate.  

           FISCAL EFFECT  :    Appropriation:  No   Fiscal Com.:  Yes    
          Local:  Yes

          PUC staff estimate unknown costs, but probably in the range  
          of $50,000+ to several hundred thousand dollars annually.   
          Increased costs depend on the extent to which this bill (1)  
          imposes additional duties that the PUC would not have  
          otherwise adopted, and (2) drives up enforcement costs by  
          applying protections to all customers, rather than only  
          residential and small commercial customers (as was the case  
          with the PUC's 2004 decision).  Public Utilities  
          Reimbursement Account revenues are derived from an annual  
          fee imposed on utilities.  Therefore, any increased costs  
          to the PUC should be offset by fee revenues. 







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           SUPPORT  :   (Verified  4/27/05)

          AARP California
          Asian Law Caucus
          California Alliance For Consumer Protection
          California Small Business Association
          Canal Alliance
          Chinese for Affirmative Action
          Chinese Newcomers Service Center
          Community Technology Policy Council
          Consumer Federation of California
          Lao Family Community Development Inc.
          Latino Issues Forum
          Little Tokyo Service Center
          Office of the Attorney General
          The Utility Reform Network
          Utility Consumers' Action Network

           OPPOSITION  :    (Verified  4/27/05)

          CTIA - The Wireless Association
          California Broadcasters Association
          California Chamber of Commerce
          California Manufacturers and Technology Association
          California Retailers Association
          Cingular Wireless
          Cricket Communications
          Los Angeles Economic Development Corporation
          Nextel Communications
          San Diego Telecom Council
          Sprint Communications Company
          T-Mobile
          Verizon Wireless


          NC:mel  4/27/05   Senate Floor Analyses 

                         SUPPORT/OPPOSITION:  SEE ABOVE

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