The Lifeline reporting requirements proposed by the Massachusetts...

The Lifeline reporting requirements proposed by the Massachusetts Department of Telecommunications and Cable (DTC) are reasonable, said eligible telecommunications carriers in their comments. ETCs and Massachusetts Attorney General Martha Coakley submitted comments on proposed rulemaking procedures for state implementation of the FCC’s Lifeline program (CD Aug 26 p8). The requirements to report non-usage disconnections and the number of customer complaints to DTC are reasonable because these data are already required by the FCC, said TracFone (http://1.usa.gov/16uWApG). The DTC’s proposal to require wireless ETCs to provide notice of any material changes to rates, terms and conditions of the ETC’s Lifeline service at least five business days prior to implementation is unnecessary because wireless service is not subject to rate regulation, said TracFone. T-Mobile said it supported the five-day proposed requirement because “implementation minimizes the operational burden and risk of competitive harm” (http://1.usa.gov/18g9iMO). However, the competitive environment of Lifeline services prevents “any significant risk of carriers implementing changes that may harm consumers,” said T-Mobile. TracFone said it has no “philosophical objection” to providing DTC contact information on Massachusetts Lifeline applications, but the resulting call volume “may impose a substantial burden” on the DTC. Boomerang disagreed with TracFone in its comments (http://1.usa.gov/18GCUVH), and said putting the DTC’s contact information on “generic” marketing and advertising content is “not intended to be state-specific.” The DTC-specific complaint information to the Lifeline application “may prevent Boomerang and other ETCs from maintaining the current one piece of paper application,” which is important to Boomerang’s “customer identification and anti-fraud efforts.” The DTC’s proposed rulemaking procedures require the ETCs to provide responsive customer service, said Coakley in her comments (http://1.usa.gov/15IuIBK). The DTC should “revive its proposals” dealing with the training of customer service representatives, prompt processing of Lifeline subscriber applications and access to person-to-person customer service assistance, said Coakley. These proposals for the ETCs could “decrease the number of subscriber complaints and the delay in resolving those complaints,” said Coakley. The requirement of the ETCs to report the number of customer complaints would impose additional compliance costs on the ETCs with “little resulting public benefit, said Verizon in its comments (http://1.usa.gov/16MjrjV).