Calling Party Identification and how it
is utilized by carriers and customers.
GTE believes CPID should be delivered to
the called party on virtually all telephone
calls.

GTE believes that a policy of permitting
any calling party, nonpublished or published,
to control CND delivery directly conflicts
with the same subscriber's rights to receive
the calling number.

GTE supports anonymity solutions for special
situations.

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10

GTE supports Baer's proposal to separate the
tariff offerings of ANI and CND.

GTE supports the concept of Alternate Identity
but is concerned whether the LECS and IXCs have
the technical ability to incorporate it into
the network.

CONCLUSION

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14

- iii

SUMMARY

GTE believes the issues raised in the Petition are important and deserve attention by the FCC. GTE urges the Commission to issue a Notice of Inquiry ("NOI") to generate the data on how local exchange carriers, their customers, and state public utility commissions are addressing the concerns raised by the introduction of Caller ID. This will allow the Commission to respond to inquiries that may be generated by Congress as it also addresses these concerns.

GTE believes the public interest is best served by delivery of calling party identification on virtually all telephone calls. GTE is willing to work with others, including its equipment manufacturers, to come up with alternatives that meet identified concerns when deploying these new services. GTE is concerned that the proper balance be struck in safeguarding the

privacy of the called party. The FCC in the past has agreed with the position that the identity of the party making the call is not a protected "right" and, thus, has authorized tariffs requiring this condition or providing this as a service.

The FCC is also aware of the legal requirements for the provision of Automatic Number Identification to interstate

access customers, and the current technology in use in the network to provide this capability.

GTE supports some aspects of the Petition and has provided comments on some of the proposals. However, there are unknown issues about the technical capability of the network to support some of the Petition's proposals. GTE believes the FCC needs more data about this specific proposal and other proposals before it makes any tentative decisions.

Thus, GTE urges the FCC to issue an NOI to gather the facts necessary to make any decisions.

GTE Service Corporation, on behalf of its affiliated domestic telephone, equipment, and service companies ("GTE"), offers its Comments to the Petition of Joseph Baer for Rulemaking regarding Calling Number Delivery filed March 16, 1990 ("Petition") and set out for public comment by a Public Notice released June 18, 1990, Report No. 1817. In his Petition, Mr. Baer proposes that the FCC establish uniform, nationwide Rules for the delivery of calling numbers by providing that

any non-business telephone subscriber who has taken
telephone service on an unlisted basis [be provided]
the means, at reasonable charges, of substituting a
confidentially registered alphanumeric designation for
the billing number on a call-by-call basis.
(Petition, Annex A)

Absent invoking this capability, which Mr. Baer designates Alternate Identity ("AI"), the network should deliver the normal directory number of the line, which Mr. Baer refers to as the Default Identity ("DI"). (Petition, pp. 11-12) Further, Mr. Baer asks the Commission to request the states to withhold any action on state-related proceedings until the FCC acts on the Petition. (Petition, p. 1)