******************************************************** NOTICE ******************************************************** This document was converted from WordPerfect to ASCII Text format. Content from the original version of the docu ment such as headers, footers, footnotes, endnotes, graphics, and page numbers will not show up in this text version. All text attributes such as bold, italic, underlin ing, etc. from the original document will not show up in this text version. Features of the original document layout such as columns, tables, line and letter spacing, pagina tion, and margins will not be preserved in the text version. If you need the complete document, download the WordPerfect version or Adobe Acrobat version, if available. ********************************************************** ******* Bell Atlantic - Legal Department 1095 Avenue of the Americas New York, NY 10036 37th Floor Tel 212 395-6509 Fax 212 768-7569 Joseph A. Post Regulatory Counsel [[BELL ATLANTIC LOGO HERE]] May 11, 1999 Elaine Bartley, Esq. New York State Department of Public Service Three Empire State Plaza Albany, New York 12223 Re: PIC/LPIC Freeze Procedures Dear Ms. Bartley: Pursuant to our telephone discussion last week, I have attached (a) a revised ver sion of the "Extra" bill insert concerning VRU implementation; and (b) a detailed descrip tion of the VRU system and how it operates. Please let me know if you would like any further revisions on either of these documents. Very truly yours, cc: Mr. Steven Sokal Mr. Daniel Martin Ms. Mary Monaco Ms. Penny Rubin ATTACHMENT A PROPOSED COPY FOR BILL INSERT New Automated System Lets You "Freeze" or "Unfreeze" Your Carrier Choices Starting ________, it will be easier for you to "freeze" or "unfreeze" the telephone company you choose to carry your regional toll and/or long distance calls. Freezing your selection means that your choice of carrier cannot be changed unless you contact us to change it. This may provide additional pro tection against unauthorized changes, also known as "slamming." There is no cost to freeze or unfreeze your choice of carrier. You will be able to freeze or unfreeze your choice of regional and/or long distance carrier by dialing our new automated system, toll-free, on 1-800-305-4838 (1-800-288-4197 in Spanish). The system is available 24 hours a day, seven days a week, except for brief daily maintenance periods and the period from 7 PM on Saturday to 7 AM on Sunday. You can call from any number. When you use the system, you will be requested to enter your ten-digit telephone number and your customer code. Your customer code is the six digit number that directly follows your telephone number on page one of your Bell Atlantic bill. This six-digit code appears only on your bill, and should not be known to anyone who does not have access to your bill. We ask you to provide the code in order to pre vent anyone other than you from using the system to freeze or unfreeze your choice of carrier. You can separately freeze or unfreeze your choice of regional carrier and your choice of long distance carrier as often as you choose. The automated system will guide you through three basic options: Press 1 to freeze your current regional service provider and/or long distance provider Press 2 to unfreeze your current regional service provider and/or long distance provider. Press 0 to speak to a service representative (during business hours). A touchtone phone is necessary to use the system (rotary phone customers must speak with a service representative). Currently, the system will freeze or unfreeze all the telephone numbers billed to the same account. If you want to freeze or unfreeze individ ual telephone numbers under the same account, you must speak to a service representa tive. ATTACHMENT B DESCRIPTION OF BELL ATLANTIC NEW YORK'S PROPOSED SYSTEM FOR IMPLEMENTATION OF PIC AND LPIC FREEZES AND UNFREEZES Pursuant to a recent order of the New York Public Service Commission, Bell At lantic New York ("BA-NY") has been developing an automated system, commonly re ferred to as the "VRU", that customers can use to freeze or unfreeze their choice of intraLATA or interLATA carrier. BA-NY will be able to put the VRU system "on line" in June, 1999, although, as described below, additional modifications to the system are being developed that would not be in place for a few months after the initial implementation date. BA-NY proposed the VRU in response to the general recognition that the three-way call procedure that had previously been used to pro cess PIC unfreeze requests was unsatisfactory. From BA-NY's perspective, the procedure, in which a customer called a BA-NY service representative with an interexchange carrier representative on the line, was inconvenient for the customer, wasteful of service representative time, and rife with oppor tunities for friction between interexchange carrier personnel and BA-NY personnel. Accordingly, when the NY-PSC solicited comments on possible alternatives to three-way calls, BA-NY recommended the elimination of the "live" three-way call procedure and its replacement with an automated sys tem. In effect, three-way calls could still be conducted, although BA-NY's end of the call would be handled by the automated system instead of by a live representative. Moreover, while the original three-way call procedure was only available when a customer wanted to change a carrier choice on a frozen line, the automated system is available either to impose or to lift freezes. The key characteristics of the VRU, as it will be implemented by BA-NY, are as follows: The system is easy to access. A customer can access the VRU by dialing a toll-free number. The system is available 24 hours a day, seven days a week, except for a brief daily maintenance period and the period from 7 PM on Saturday to 7 AM on Sunday. Perhaps most importantly, the customer can call the system from any phone, and is not limited to calling from home. The system is easy to use. The VRU "script" is easy for the customer to follow. (A flow-chart of the proposed script is attached.) The system is available in both Spanish and English, on separate toll-free numbers. The customer indicates choices at each stage of the process by pressing specified touchtone keys. The system protects the user by verifying his/her identity. Although the system can capture the caller's ANI, this is not used as the pri mary means of verifying the caller's identity, since BA-NY wanted the customer to be able to call from his or her office or from any other convenient number. Accordingly, the customer is asked to enter a six-digit code that follows the telephone number of the first page of the customer's monthly bill. Thus, only someone who has access to the customer's bill can use the system to freeze or unfreeze the customer's line. The system provides the customer with a number of choices that can be exercised independently. A customer can freeze his or her choice of presubscribed intraLATA carrier, or his or her choice of presubscribed interLATA carrier, or both; or can unfreeze the intraLATA carrier, or the interLATA carrier, or both. The system allows freeze/unfreeze orders to be processed without human intervention. Orders entered through the VRU are automati cally fed through to the ICRIS system. The customer's instructions thus will not be misunderstood, mistranscribed, or incor rectly transmitted. This is more convenient for the consumer, and avoids unnecessary disputes between BA-NY and interexchange carriers over whether a statement made by a BA-NY representative on a three-way call constituted impermissi ble "marketing" of BA-NY's services. The system does not require the customer to make separate calls for each telephone number included in a single billed account. Any freeze or unfreeze order entered through the VRU is implemented for all of the lines that are billed to a single number. This avoids the necessity of separate calls for each line. We recognize that some customers may want to freeze some lines but not others, although we anticipate that such situations will be relatively rare. Nevertheless, we have been developing a modifica tion to the VRU that will enable customers who so desire to freeze or unfreeze each line separately. This modification will not be available, however, until a few months after initial VRU implementation. The system provides options for customers who are unable to use it. If a customer has trouble using the VRU, he or she can be trans ferred to a service representative queue or prompted to call the Service Center during normal hours. This can also be done if the customer wants to change the freeze status of individual lines within a billed account. (Transfer to a live representative would be unnecessary in the latter situation once the system modification described in the preceding paragraph is implemented.) The system would automatically generate an electronic "audit trail" confirming that the customer requested the change in freeze sta tus. These features of the system make it one that is beneficial to consumers, interexchange carriers, regulators, and BA-NY. It eliminates or avoids the disadvantages associated with alternative freeze/unfreeze systems. BA-NY continues to urge its implementation in New York for both inter state and intrastate freeze-change requests. Bell Atlantic PIC/LPIC Freeze/Unfreeze Interactive Automated System Typical Call Flow & Prompt Wording [[CALL FLOWCHARTS OMITTED]]