TELECOMMUNICATIONS ACT



House Bill 5721 as enrolled

Public Act 295 of 2000

Second Analysis (7-6-00)


Sponsor: Rep. Mary Ann Middaugh

House Committee: Energy and Technology

Senate Committee: Technology and Energy



THE APPARENT PROBLEM:


Telecommunication has become an all but unavoidable part of most people's daily existence. From telephones to answering machines to pagers to cellular phones, people are rarely far from a phone and thereby are rarely far from access to just about anyone, anywhere in the world. Further, recent years have seen rapid expansion of services which vastly increase the telephone's usefulness, including facsimile machines, teleconferencing, call forwarding, voice mail, and speed dialing, just to name a few.


In Michigan, the provision of telecommunications service is regulated under the provisions of the Michigan Telecommunications Act. However, the act will be repealed by a sunset provision within the act on January 1, 2001. Without legislation to regulate the telecommunications industry, many believe it is likely that chaos would ensue and consumers would be the ones to suffer the consequences.


At the time the most recent incarnation of the telecommunications act was enacted, it was expected to accelerate the introduction of new technology in both products and services, increase competition, and result in lower prices for customers. Some argue that many of the deregulation provisions in the 1995 amendments to the act have worked less well than was hoped or expected and the competition level in local telephone markets is such that further regulation is warranted to protect against abuses by existing monopolies. However, the extremely positive results of deregulation in the toll or long-distance markets, which have lowered long distance rates for most consumers, are evidence to some that continuing the path of deregulation will continue to have a positive impact on service to consumers, both in quality and cost.


As the deadline for the expiration of the act rapidly approaches, legislation has been proposed to provide a new framework for regulating the extremely important and very lucrative telecommunications industry.


THE CONTENT OF THE BILL:


The bill would amend the Michigan Telecommunications Act (MTA) (MCL 484.2101et al.) to do all of the following:


Jurisdiction and Authority. Under current law the Public Service Commission (PSC) has the jurisdiction and authority to administer the act, but is limited to the powers and duties that are prescribed within it. The bill would give the commission the jurisdiction and authority to administer not only the act, but all federal telecommunications laws, rules, orders, and regulations that are delegated to the state. The commission's exercise of its jurisdiction and authority would have to be in accordance with the act and all federal telecommunications laws, rules, orders, and regulations. While current law requires the PSC to establish rules to implement the act, the bill would permit the commission to establish rules under the Administrative Procedures Act, subject to the above delineation of its jurisdiction and authority.


In addition, the bill would give the PSC the authority to regulate all directory assistance services until the commission determined that directory service was a competitive service (current law allows the PSC only to regulate local directory assistance). Further, the PSC would have the authority to approve or deny any proposed addition, elimination, or modification of an area code within the state. Before any changes were made to an area code, the commission would be required to give public notice and conduct a public hearing in the affected geographic area. To the extent technologically and economically feasible, the commission would be required to order that modification of all area code boundaries conform to county lines.

Competitiveness Report. The PSC would be required to submit an annual report on the status of competition in telecommunication services, including, but not limited to, toll and local exchange service markets in Michigan. The report would have to be submitted to the governor and the House and Senate standing committees that oversee telecommunications issues.


Emergency Relief. The bill would allow a complainant to request an emergency relief order, if a complaint filed under the MTA alleged facts that warranted emergency relief. A complaint and request for emergency relief would have to be hand delivered to the opposing party or respondent at its principal place of business in Michigan. That party would then have five business days to file a response to the request for emergency relief.


The PSC would have to review the complaint, the request for emergency relief, the response, and all supporting materials, and then determine whether the request should be denied or an initial evidentiary hearing should be conducted. If an initial evidentiary hearing was conducted, it would have to occur within five days after notice had been provided. After the hearing, an order granting or denying the request for emergency relief would have to be issued.


An order for emergency relief could require a party to act or refrain from action to protect competition. Any action required by an order for emergency relief would have to be technically feasible and economically reasonable, and the respondent would have to be given a reasonable period to comply. At a hearing for emergency relief, the respondent would have the burden of showing that the order was not technically feasible or economically reasonable.


If extraordinary circumstances existed that the PSC determined warranted expedited review before the PSC's final order would be issued, the PSC would have to set a schedule that would allow for the issuance of a partial final order as to all or part of the issues for which emergency relief was granted within 90 days from the issuance of the emergency relief order.


An order for emergency relief could be granted if the PSC found all of the following:


-- The party had demonstrated exigent circumstances that warranted emergency relief.


-- The party seeking relief would likely succeed on the merits.

-- The party would suffer irreparable harm in its ability to serve customers if emergency relief were not granted.


-- The order was not adverse to the public interest.


The PSC could require a complainant to post a bond in an amount that would be sufficient to make the respondent whole in the event that the order for emergency relief was later determined to have been erroneously granted.


An emergency relief order would expire upon the soonest of the following: 90 days after it was issued; when the PSC's partial order was issued; or an earlier date set by the PSC. The PSC could extend the emergency relief order up to the date on which a final order was issued in the proceeding.


The losing party would have the right to seek immediate review of an order granting or denying emergency relief. The review would have to comply with Michigan Court Rules on motions for immediate consideration and the review would be as a new case, rather than a review of the record of the prior hearing. The court of appeals could stay the emergency relief order upon posting of a bond or other security in an amount and on terms set by the court. Regardless of whether an appeal was made, the PSC would have to proceed with the case and issue a final order as otherwise required under the MTA.


Hearings. The bill would specify that an application or complaint would have to include all information, testimony, exhibits, or other documents and information within the applicant's or complaining party's possession. However, if that party needed information that was in the possession of the respondent, the PSC would have to allow that complainant or applicant a reasonable opportunity for discovery.


In addition to any other relief allowed in the act, the PSC or any other interested person could seek to compel compliance with a commission order by proceedings in mandamus, injunction, or by other appropriate civil remedies in the circuit court or other court of appropriate jurisdiction.


Finally, the bill would also provide that the changes to the hearings provisions and the emergency relief provisions would not amend, alter, or limit any case or proceeding that was commenced prior to the effective date of the bill.


Alternative Dispute Process. The MTA requires the use of an alternative dispute process for disputes involving an amount of $1,000 or less. Under the bill, the PSC would be required to compel parties in an interconnection dispute between telecommunications providers to use the act's alternative dispute resolution, unless there had been a request for emergency relief. In addition, unless there was a request for emergency relief, the PSC would have an additional 45 days past the usual deadline for issuing an order in a dispute involving $1,000 or less, or an interconnection dispute between providers.


Licensing Requirements. The MTA provides that, after notice and a hearing, the PSC must approve an application for a license as a basic local exchange provider if it finds that the applicant possesses sufficient technical, financial, and managerial resources and abilities to provide basic local exchange service to "every person" within the geographic area of the license and that granting a license would not be contrary to the public interests. The bill would change "every person" in that requirement to "all residential and commercial customers", and would require the PSC to also find that the applicant intended to provide service within one year from the date the license was granted. The PSC could revoke a provider's license if it determined, within two years of the date the license was granted, that the provider had not marketed its services to all potential customers or had refused to provide service to certain customers.


End-User Line Charges. Basic local exchange service providers, except those with 250,000 or fewer customers in this state, would be prohibited from assessing or imposing an intrastate subscriber line charge or end-user line (or access) charge.


Toll access rates. Under the MTA, the PSC may not review or set the rates for toll access services. Except for the above provision against the imposition of intrastate end-user or subscriber access charges by basic local exchange providers, toll access services providers must set the rates for toll access. The MTA specifies that access rates that exceed those allowed for the same interstate services by the federal government are not just and reasonable, and that providers may agree to a rate less than that allowed by the federal government. The bill would provide that rates for end-user or subscriber line charges charged to basic local exchange customers could not exceed the rates allowed by the federal government as of May 1, 2000 for the same interstate services.


Further, if a toll access service rate is reduced, the MTA requires the provider receiving the reduced rate to reduce its rate to its customers by an equal amount. The bill would require that the PSC investigate and ensure that a provider had complied with the requirement to pass along rate reductions to its customers.


None of these provisions would apply to basic local exchange providers with 250,000 or fewer customers in this state, and neither would existing provisions requiring a provider of toll access service to offer services under the same rates, terms, and conditions, without unreasonable discrimination, to all providers, to make any technical interconnection arrangements available for intrastate access services, and allowing two or more providers with fewer than 250,000 access lines to agree to joint toll access service rates and pooling of revenues.


Mandatory Minimum Charge Prohibition. Unless otherwise approved by the commission, the bill would prohibit a toll service provider from charging a mandatory minimum monthly or mandatory flat-rate charge for toll calls, except in connection with an optional discount toll calling plan.


Toll Rates. Under the bill, a call made to a local calling area that is adjacent to the caller's local calling area could not be considered a toll call and would be have to be considered a local call and be billed as a local call. Providers of toll service would have to make adjacent exchange toll calling plans available to their customers, after review and approval of the PSC. All toll service providers would be required to inform their customers of the availability of these plans and the plans would remain in effect until altered by order of the PSC. However, this provision would not apply to those providers who met the requirements to be exempted from the act's provisions governing basic local exchange rate alteration (see below).


Basic Local Exchange Rate Alteration. The bill would require that the PSC exempt a provider from the MTA's provisions governing basic local exchange rate alteration and the setting of toll access rates if it found that the provider did all of the following:


-- Provided basic local exchange service or basic local exchange and toll service to fewer than

250,000 end-users.


-- Offered to end-users single-party basic local exchange service, tone dialing, toll access service, including end-user common line services and dialing parity, at a total price of no more than the amount charged as of May 1, 2000.


-- Provided dialing parity access to operator, telecommunication relay, and emergency services to all basic local exchange end-users.


"Slamming" and "Cramming." Public Acts 259 and 260 of 1998 added slamming prohibitions and penalties to the MTA. ("Slamming" is the term commonly used to refer to the unauthorized switching of a telecommunications subscriber from one provider to another. ) Under the slamming provisions, the PSC must issue orders to ensure that an end user is not switched to another provider without the end user's oral authorization, written confirmation, confirmation through an independent third party, or other verification procedures subject to PSC approval confirming the end user's intent to make a switch and that the end user has authorized the specific details of the switch. The PSC may conduct a contested case upon receiving a complaint alleging a slamming violation. If the PSC finds that a slamming violation has occurred, it must order remedies and penalties to protect and make whole end users and other persons who suffered damages as a result of the violation.


In addition to the existing "slamming" provisions, the bill would prohibit a telecommunications provider from including or adding optional services in an end-user's telecommunications service package without the express oral or written authorization of the end user (commonly referred to as "cramming"). Upon receiving a complaint filed by a person alleging a cramming violation or upon the PSC's own motion, the PSC could conduct a contested case hearing.


Slamming and Cramming Complaints and Hearings. The bill would require that the PSC create and, upon request, supply a form affidavit designed to enable an end-user to provide all the information needed to promote efficient resolution of slamming and cramming complaints. Hearings would have to be conducted in a manner that optimized expediency, convenience, and the ability of the end-user to bring and prosecute, without assistance of counsel, complaints alleging slamming or cramming while preserving the rights of the parties. If possible, the PSC would have to hold the hearing at a location near the end-user's residence or place of business.


Slamming and cramming penalties. If the PSC found that a slamming or cramming violation occurred, it would have to order remedies and penalties to protect and make whole end users and other persons who suffered damages as a result of the violation. Remedies could include fines (see below), refunds, reimbursement, revocation of licenses, and cease and desist orders.


Fines for slamming and cramming. Currently, a first offense of slamming is subject to a fine of at least $10,000 but not more than $20,000; a second or subsequent offense is subject to a fine of at least $25,000 but not more than $40,000. If the PSC finds that a second or subsequent slamming offense is made knowingly in violation of the prohibition, the maximum fine is $50,000. Each switch made in violation of the MTA is a separate offense.


The bill would increase the fines and apply them both to slamming and cramming. Under the bill, a first slamming or cramming offense would be punishable by a fine of at least $20,000 but not more than $30,000; a second or subsequent offense would be punishable by a fine of at least $30,000 but not more than $50,000. For a slamming or cramming offense committed knowingly in violation of the MTA, the maximum fine would be $70,000. Each switch or added service would be treated as a separate offense. In addition, the bill would allow the PSC to order between 10 and 50 percent of the fines assessed to be paid to the person who was the victim of the slamming or cramming violation.


The PSC could not impose a fine for slamming or cramming if the provider had otherwise complied with the provisions against slamming and cramming and was able to show that the violation was an unintentional and good faith error that occurred in spite of procedures that had been adopted to avoid such errors. (This exception already exists for slamming violations.)


Prohibited practices. In addition to the existing prohibitions, a provider of telecommunication services would be prohibited from the following: