Via Fax
October 29, 2003
The Honorable Michael C. Powell
Chairman
Federal Communications Commission
445 Twelfth Street, S.W.
Washington, D.C. 20554
Dear Chairman Powell:
RE: Ex Parte Notice. CC Docket No. 96-149. In the Matter of Petition of Verizon for Forbearance from the Prohibition of Sharing Operating, Installation, and Maintenance Functions Under Section 53.203(a)(2) of the Commission’s Rules
The Communications Workers of America (CWA) encourages the Commission to approve Verizon’s Petition for Forbearance in the above-captioned proceeding.
The prohibition against sharing technicians among the local operating company and the long-distance affiliate imposes costs and inefficiencies on the BOCs that inhibit new services and thereby discourage investment. The requirement is burdensome and anachronistic as the BOCs move into a broadband environment, which does not have a clear demarcation between “local” and “long-distance.” The requirement interferes with quality service, forcing customers to navigate separate systems for installation, repair, and maintenance services.
Of particular concern to CWA, the prohibition negatively impacts the Verizon workforce. Verizon has chosen to use outside contractors to perform OI&M functions for its long-distance affiliate. Absent the prohibition, this work would be staffed by Verizon’s union workforce, thereby expanding career opportunity and growth of
high-wage union jobs.
The Commission can protect against cross-subsidization by requiring cost accounting safeguards. Costly, inefficient structural safeguards are unnecessary.
Sincerely,
Morton Bahr
President
cc: Commissioner Jonathan Adelstein
Commissioner Michael Copps
Commissioner Kathleen Abernathy
Commissioner Kevin Martin
