Legislature(2011 - 2012)BELTZ 105 (TSBldg)

02/02/2012 01:30 PM LABOR & COMMERCE

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* first hearing in first committee of referral
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Heard & Held
Heard & Held
+ Bills Previously Heard/Scheduled TELECONFERENCED
         SB 138-THIRD-PARTY CHARGES ON TELEPHONE BILLS                                                                      
1:58:12 PM                                                                                                                    
CHAIR EGAN announced  SB 138 to be up for  consideration [SB 138,                                                               
version 27-LS1002\D, was before the committee].                                                                                 
1:58:23 PM                                                                                                                    
SENATOR WIELECHOWSKI,  sponsor of  SB 138,  said this  bill would                                                               
ban  the practice  of placing  unauthorized charges  on telephone                                                               
bills. Many  people don't know  about this, and he  didn't either                                                               
until  it was  brought to  his attention,  but this  is a  multi-                                                               
billion dollar industry that  harms small businesses, governments                                                               
and individuals.  He said this  is a consumer protection  bill to                                                               
protect people  from unauthorized cramming of  charges onto their                                                               
telephone bills.                                                                                                                
He said the intent of this bill  is not to ban all cases of third                                                               
party billing;  there are  legitimate cases  when people  want to                                                               
place other bills on their telephone  bill. The intent of this is                                                               
to target those  services and vendors who do  not obtain approval                                                               
from customers before charging their bill.                                                                                      
SENATOR   WIELECHOWSKI   explained    that   the   industry   for                                                               
unauthorized  charges on  telephone bills  is large.  The process                                                               
for charging bills  is often made intentionally  complex, and the                                                               
dispute process  is extremely difficult.  They will  hear stories                                                               
about people  who have  had charges placed  on their  phone bills                                                               
who have spent hundreds of  thousands of dollars trying to remove                                                               
companies  and  who  have  taken months  to  have  those  charges                                                               
He said this  is a big problem  in the Lower 48  and doesn't seem                                                               
to  be as  big in  Alaska where  this is  more of  a preventative                                                               
measure. But  it is probably  happening here to some  extent, and                                                               
he  said   people  should  check  their   phone  bills.  Vermont,                                                               
Minnesota, New York and Virginia have passed similar laws.                                                                      
2:01:12 PM                                                                                                                    
THOMAS  PRESLEY, Intern  for Senator  Wielechowski,  said SB  138                                                               
bans the  practice of adding unauthorized  third-party charges to                                                               
consumers' telephone  bills. He explained that  cramming began in                                                               
the  1990s and  it was  an unintended  consequence of  regulatory                                                               
action that opened telephone bills  to other charges. Following a                                                               
spike in  complaints, regulatory  agencies opted for  a voluntary                                                               
approach  by telecommunications  companies to  end the  practice.                                                               
However,  current  evidence   indicates  that  telecommunications                                                               
companies place approximately 300  million third-party charges on                                                               
customers' telephone bills, equaling over $2 billion per year.                                                                  
One example of cramming is of  a woman who noticed charges on her                                                               
phone bill,  and when she  called to  dispute them, she  was told                                                               
her husband authorized  the service, but he had been  dead for 13                                                               
years. Clearly authorization was not obtained.                                                                                  
MR.   PRESLEY  said   that  cramming   occurs  either   by  never                                                               
interacting  with   customers  or  by  using   abusive  marketing                                                               
techniques  to  get  customers   to  give  them  their  telephone                                                               
numbers.  The consumer's  phone  number then  becomes  a form  of                                                               
tacit authorization.                                                                                                            
2:02:44 PM                                                                                                                    
He said that satellite TV  and long distance coverage charges are                                                               
legitimate, but  these services contract directly  with telephone                                                               
companies. The  process for contracting cram  services onto bills                                                               
is different.  Of 500 people  with crammed charges  who responded                                                               
to inquiries,  not a  single person or  business stated  they had                                                               
authorized charges.  Unauthorized charges occur for  bank vaults,                                                               
elevators, 911  systems, fire  alarms, governmental  agencies and                                                               
schools. Obvious  examples are of  a modem incurring  charges for                                                               
voice mail and of an  emergency line incurring charges for online                                                               
diet services.                                                                                                                  
MR. PRESELY  said a  telephone auditing  company found  more than                                                               
800  third-party  vendors  placed  unauthorized  charges  on  its                                                               
clients' telephone bills. Consumers  used words like fraud, theft                                                               
and  stealing  to  describe  their  experience.  An  FCC  graphic                                                               
indicated  that 15  to 20  million  Americans households  receive                                                               
cram  charges on  their landline  bills each  year, but  very few                                                               
customers, 1 in 20, are aware of the charges.                                                                                   
MR. PRESELY  presented a  graphic of  the complexity  of cramming                                                               
charges.  One  third-party  vendor,  My S&S  Voice  Mail  Service                                                               
showed only 975 unique numbers  dialed into their service. At the                                                               
time at  least 97,000 customers  were enrolled in  their service.                                                               
Another  was  an  on-line  photo   storage  service  with  64,000                                                               
telephone  customers enrolled  and less  than 2  percent of  them                                                               
uploading their photos or took  advantage of the service. And the                                                               
US Senate  committee staff  was the  first to  log onto  a casual                                                               
gaming  service offered  by Easy  Phone Bill  despite its  having                                                               
enrolled  more  than  20,000  customers  and  earning  almost  $1                                                               
He said  the way it works  is that hub companies  subcontract out                                                               
enrollment and  authorization to lead generators,  companies paid                                                               
exclusively to  obtain enrollments.  The lead generator  passes a                                                               
phone number  along to the hub  companies who in turn  pass these                                                               
onto  the   billing  aggregators  through   third-party  vendors.                                                               
Charges  are only  then forwarded  onto  telephone bills.  Third-                                                               
party vendors offer services like  electronic fax, photo storage,                                                               
and online  backup. To gain  access to bills, they  contract with                                                               
billing  aggregators.  Despite   their  offers  many  third-party                                                               
vendors are  actually front  companies. This  relationship allows                                                               
hub companies which can have  hundreds of front companies beneath                                                               
them to shift enrollments to  other vendors to mask large numbers                                                               
of complaints.  Billing aggregators, the entities  which contract                                                               
with  phone  companies to  access  bills,  act as  intermediaries                                                               
between phone companies and third-party vendors.                                                                                
2:06:02 PM                                                                                                                    
DaData,  one hub  company  interviewed by  the  US Senate  staff,                                                               
appears  to have  inter-relatedness with  40 third-party  vendors                                                               
for  which  they claim  to  provide  "support services  including                                                               
marketing, quality control,  customer service, billing regulatory                                                               
and accounting  services." DaData  eventually admitted  that they                                                               
controlled the  actual electronic  fax service  offered by  25 of                                                               
their clients. He  provided a list of the 45  companies who offer                                                               
electronic  fax service  yet appear  to be  entirely operated  by                                                               
2:06:59 PM                                                                                                                    
He  said the  US Senate  staff interviewed  the president  of WVM                                                               
Network  and  he  admitted  that  he "only  signed  his  name  to                                                               
documents and  knew nothing about  the company." By having  a hub                                                               
company  with  smaller entities  beneath  it  you can  shift  the                                                               
complaint  threshold making  it difficult  to track,  dispute and                                                               
remove charges.                                                                                                                 
MR. PRESELY  reiterated that disputing cram  charges is difficult                                                               
and cost consuming. A national  retail chain reported $550,000 in                                                               
unauthorized  charges  on  its  telephone  bills  over  the  past                                                               
decade.  The retail  chain  estimated it  had  spent $400,000  in                                                               
resources   battling   unauthorized  third-party   charges.   One                                                               
customer said it  was his fifth time having charges  added to his                                                               
bill and  every time he  has spent at  least a half  hour getting                                                               
the services removed.                                                                                                           
Of  the  almost 20,000  customer  calls  for another  third-party                                                               
vendor,  More  International,  about 9,000  were  categorized  as                                                               
"issue  credit"  and 4,000  as  "cancelation."  Of the  calls  to                                                               
DaData-related  vendors,   about  202,000  were   categorized  as                                                               
2:07:53 PM                                                                                                                    
MR. PRESLEY said  section 1 of SB 138   enforces truth in billing                                                               
guidelines;   it   requires   carriers   to   disclose   detailed                                                               
information  on   the  bill,  precludes  carriers   from  billing                                                               
customers  without  including   details  of  third-party  billing                                                               
services  and forbids  a carrier  from  discontinuing service  to                                                               
customers who use  the contact information to  dispute or contest                                                               
a charge.  Section 2  adds a  paragraph to  the list  of unlawful                                                               
acts  and  practices  under  the  Consumer  Protection  statutes.                                                               
Section 3  creates a  new section that  precludes a  carrier from                                                               
billing for  another vendor of  goods and/or services  unless the                                                               
services fall under a list of  exemptions. Section 4 adds the new                                                               
unlawful  act  or  practice  from  section  2  to  the  exclusive                                                               
jurisdiction of the state, a regulatory board or a commission.                                                                  
2:09:10 PM                                                                                                                    
CHAIR  EGAN  said he  was  a  victim  of  this practice  when  he                                                               
answered a  travel questionnaire  and started getting  charges on                                                               
his VISA bill; he had a heck of a time getting it off his bill.                                                                 
SENATOR GIESSEL moved to bring  CSSB 138( ), labeled 27-LS1002\E,                                                               
before the committee.                                                                                                           
CHAIR EGAN objected to take public testimony.                                                                                   
2:10:49 PM                                                                                                                    
MARIE DARLIN,  AARP, noted  their letter of  support for  SB 138.                                                               
She  said consumer  protection  is  one of  the  things they  are                                                               
concerned about  and a lot of  this kind of activity  is directed                                                               
toward seniors  and retirees who  aren't necessarily  paying that                                                               
much attention to  their telephone bills. Getting ahead  of it is                                                               
a good idea.                                                                                                                    
2:12:50 PM                                                                                                                    
NORMAN PHIPPS,  CFO, Billing Services  Group (BSG),  San Antonio,                                                               
Texas, said  they are  the country's  largest provider  of third-                                                               
party billing  services and work  closely with  service providers                                                               
and local telephone  companies to have charges  aggregated onto a                                                               
single phone bill  for consumers. He said he was  joined by BSG's                                                               
general  counsel, Kelly  Cubetta, whose  responsibilities include                                                               
overseeing regulatory and compliance matters for the company.                                                                   
He  stated   that  BSG  shares  the   committee's  commitment  to                                                               
protecting  consumers from  cramming.  He said  as  this bill  is                                                               
considered,  it  is  important   to  understand  how  third-party                                                               
billing  works  and  the  steps industry  has  already  taken  to                                                               
prevent cramming.                                                                                                               
MR. PHIPPS  explained that  third-party billing  is fundamentally                                                               
about consumer choice. Each year  thousands of Alaskans choose to                                                               
have   charges  for   various  services   provided  by   multiple                                                               
competitors  aggregated onto  a single  phone bill.  The services                                                               
include  long  distance,   operator  services,  collect  calling,                                                               
computer  technical support  and charitable  contributions. There                                                               
are  many  reasons  consumers  make  this  choice;  for  one,  it                                                               
provides  them with  access  to the  services  of many  different                                                               
competitors to  which they wouldn't  otherwise have  access. This                                                               
means  they  have  more  choices   among  service  offerings  and                                                               
providers.  This  broader  market  place leads  to  greater  cost                                                               
competition and  lower prices  for services.   He  said consumers                                                               
appreciate the simplicity and convenience  of viewing, paying and                                                               
managing  a single  bill rather  than many  different bills  from                                                               
many different  providers. They can  see all of their  charges in                                                               
one place  and pay  for all  services through  a single  check or                                                               
other method of payment. And  unlike credit cards, this method of                                                               
payment is free of interest.                                                                                                    
He explained  when consumers  buy a  service, they  authorize the                                                               
provider  of  that  service  to  have  charges  placed  on  their                                                               
telephone bill. The provider then  submits the charge to a third-                                                               
party billing services  company, like BSG (also  called a billing                                                               
aggregator), which  works with  the local  phone company  to have                                                               
charges included  on the consumers'  telephone bill.  The billing                                                               
aggregator is  responsible for accounting, record  formatting and                                                               
data transmission to have charges  included on a consumer's phone                                                               
bill.  He is  also  responsible for  reviewing sales,  marketing,                                                               
verification, fulfillment  and inquiry processes. The  phone bill                                                               
is sent  to the consumer and  the consumer sends payment  back to                                                               
the  phone company.  The  phone company  works  with the  billing                                                               
aggregator to  ensure service providers are  paid. Without third-                                                               
party billing, consumers would have  access to fewer services and                                                               
fewer providers;  their costs would  likely go up and  they would                                                               
suffer the headache  of having to manage multiple  bills. Just as                                                               
shop keepers fight hard to  stop shoplifters from pillaging their                                                               
stores, BSG has fought hard  to stop crammers since incorporation                                                               
almost 23 years ago. They have  many checks and balances in place                                                               
to thwart cramming.                                                                                                             
2:16:22 PM                                                                                                                    
He said  their efforts  to prevent  cramming begin  as soon  as a                                                               
provider applies  to become an  approved merchant with  BSG. With                                                               
their initial application BSG begins  a 100-point review process,                                                               
which  includes  an  evaluation   of  the  provider's  board  and                                                               
executives, a  visit to  its locations and  an evaluation  of the                                                               
provider's sales  processes. They  also ensure that  the provider                                                               
has  a  system  in  place  to supply  consumers  with  terms  and                                                               
conditions of  each sale  and to  document consumers'  consent to                                                               
the purchase  of these services.  It is a very  extensive process                                                               
which often takes up to nine months to complete.                                                                                
After  a provider  is approved,  they closely  analyze the  first                                                               
file of transactions they send  for inclusion on consumers' phone                                                               
bills.  From this  first file,  they  select a  random sample  of                                                               
charges  and  confirm  that  every   charge  in  the  sample  was                                                               
authorized. If they  are unable to confirm  authorization for any                                                               
charge in that  sample, they reject the provider,  and no charges                                                               
are submitted to the telephone  company. Even after a provider is                                                               
accepted, they  continue to monitor  its performance  each month,                                                               
evaluating inquiries they receive  through their customer service                                                               
centers, regulatory  bodies, and  the local  telephone companies.                                                               
Any  provider that  exceeds their  inquiry thresholds  is closely                                                               
evaluated  and  their  most recently  refunded  transactions  are                                                               
tested.  If a  provider fails  these tests,  the relationship  is                                                               
terminated immediately.                                                                                                         
MR.  PHIPPS said  in addition  to their  own processes,  they are                                                               
committed  to helping  consumers recognize  and join  their fight                                                               
against  cramming. In  that effort,  BSG spearheaded  a coalition                                                               
that  launched  Knowyourphonebill.org   that  educates  consumers                                                               
about how  to read their phone  bills and how to  investigate any                                                               
charges  that  may  be  unfamiliar   to  them.  With  these  best                                                               
practices,  they  have  achieved  remarkable results.  Of  the  8                                                               
million  households for  which they  provide third-party  billing                                                               
nationally,  less   than  .25  percent  inquired   about  charges                                                               
included  on  their  bill.  Additional  investigation  frequently                                                               
finds  that  charges were  in  fact  authorized, so  that  actual                                                               
cramming is  a very small  portion of  the total number  of these                                                               
complaints. In Alaska, the incidence  of inquiries is even lower.                                                               
In 2011, BSG  processed 13,536 transactions; of  that number they                                                               
receive just  14 inquiries and  from consumers and  about charges                                                               
on  their  bill,  .10  percent   of  all  records.  Of  these  14                                                               
inquiries, not  a single customer  claimed they had  no knowledge                                                               
of the charge that was included on their bill.                                                                                  
MR.  PHIPPS said  they  applaud the  Senate's  goals of  stopping                                                               
cramming  and  as  the  industry leader  they  have  fought  hard                                                               
against  it and  they have  been successful.  They would  applaud                                                               
other  third-party billing  companies  who would  adopt the  same                                                               
best practices to achieve the same results.                                                                                     
However, Mr.  Phipps said,  a portion of  the Senate's  bill does                                                               
raise  concerns.  While  SB 138  appears  to  permit  third-party                                                               
billing  for telecommunications  offered  under tariff,  customer                                                               
initiated  direct   dial,  dial  around  services   and  operator                                                               
assisted calls, the legislation  would prohibit billing for other                                                               
services unless  "the vendor has provided  the telecommunications                                                               
carrier    with   verification    of   the    customers   express                                                               
authorization."  Such  a requirement  would  be  contrary to  how                                                               
third-party  billing works.  They work  with hundreds  of service                                                               
providers that  are too small  to maintain their own  billing and                                                               
collection  platforms  and  do  not  have  systems  that  connect                                                               
directly   with    local   exchange   carriers.    Creating   the                                                               
infrastructure  necessary  to  comply  with this  bill  would  be                                                               
extremely  costly for  these small  businesses  and would  either                                                               
negate the cost savings they are  able to provide to consumers or                                                               
result  in these  small business  being forced  to shut  down. In                                                               
addition,  the local  telephone companies  are not  equipped with                                                               
the resources to  receive and review the  authorizations prior to                                                               
billing.  In  the  end  there  would be  little  to  no  consumer                                                               
protection added  as a result  of this legislation.  Thousands of                                                               
consumers across  Alaska, many of  whom depend on  these services                                                               
to connect with  their loved ones and save money,  would lose the                                                               
benefits  of competition,  a greater  variety of  services, lower                                                               
costs and  convenience. This  is simply  too high  a cost  to ask                                                               
Alaska's citizens to pay.                                                                                                       
He said there are unscrupulous  actors out there and BSG supports                                                               
the goal  of preventing them  from engaging in cramming,  but the                                                               
best way  to do that  would be  to have the  industry investigate                                                               
new  ways  to  adopt  proven   best  practices  and  not  through                                                               
legislation that  would needlessly punish Alaska's  consumers and                                                               
CHAIR EGAN asked if he opposed SB 138.                                                                                          
MR. PHIPPS answered yes, in its current form.                                                                                   
2:22:11 PM                                                                                                                    
MATT   WALLACE,  Executive   Director,  Alaska   Public  Interest                                                               
Research Group  (AKPIRG), Anchorage, said they  supported SB 138.                                                               
He  said that  cramming is  insidious, because  people are  often                                                               
unaware of these charges. Many of  these charges are very easy to                                                               
miss, like a voice mail  service. Those services often provide no                                                               
real value to  the consumer, and because they look  like they may                                                               
be part of the regular phone bill, they are easy to miss.                                                                       
2:23:46 PM                                                                                                                    
He  emphasized  that  many consumers  have  great  difficulty  in                                                               
disputing  charges   that  are   either  unauthorized   or  whose                                                               
authorization  is in  question,  another  reason that  addressing                                                               
this practice head on is important.  He said this bill focuses on                                                               
eliminating the  practice and not just  on additional disclosures                                                               
which would have a more limited impact.                                                                                         
2:24:34 PM                                                                                                                    
STUART GOERING,  Assistant Attorney General, Commercial  and Fair                                                               
Business  Section,  Department of  Law  (DOL),  said his  primary                                                               
responsibility  is  advising   and  representing  the  Regulatory                                                               
Commission  of  Alaska  (RCA),  and  it  has  responsibility  for                                                               
overseeing  telecommunications  carriers  in Alaska  among  other                                                               
things.  His  primary  reason  for being  online  was  to  answer                                                               
questions as they  might relate to RCA duties, but  not to take a                                                               
position. He  said he  had been  working with  the sponsor  for a                                                               
long time  and he had been  very responsive to his  comments. The                                                               
CS reflects a number of his comments.                                                                                           
2:26:03 PM                                                                                                                    
SENATOR   GIESSEL   said   she  understood   that   the   Federal                                                               
Communications Commission (FCC) has an  open docket on this issue                                                               
and asked if he knew what the timeline for their decision was.                                                                  
MR. GOERING replied that he was  aware that the FCC has a docket,                                                               
but he  didn't think they had  a timeline for its  resolution. He                                                               
noted that the Federal Trade  Commission (FTC) has also opened an                                                               
investigation of this practice, as well,  but he didn't know of a                                                               
timeline for that either.                                                                                                       
2:26:55 PM                                                                                                                    
CINDY   DRINKWATER,   Assistant    Attorney   General,   Consumer                                                               
Protection Unit, Department of Law  (DOL), said she was available                                                               
to answer questions on SB 138.                                                                                                  
HOWARD  WALTZMAN, partner,  Mayor Brown  LLP, outside  counsel to                                                               
BSG, Washington,  D.C., said  the presentation  refers to  the US                                                               
Senate  Commerce Committee  report on  cramming. That  report was                                                               
rather  limited  in  scope  and  relied on  a  lot  of  anecdotal                                                               
evidence. A  telephone survey  that was  limited to  customers of                                                               
three  third-party service  providers  and  their affiliates  who                                                               
were the ones  that had been accused of cramming.  So, the notion                                                               
that anything  discerned from it  is indicative of industry  as a                                                               
whole is  not accurate. He also  said the FCC's 15  to 20 million                                                               
person figure for  cramming seems to be extremely  high given the                                                               
number of people who subscribe to third-party billing services.                                                                 
2:29:15 PM                                                                                                                    
CHAIR EGAN  commented as an  FCC licensee  for over 40  years, it                                                               
seems to him  that when the FCC opens a  docket there's an issue;                                                               
and in this  case the FTC had opened a  docket as well. Obviously                                                               
consumers have  complained, and they  are trying to get  a handle                                                               
on unscrupulous people.                                                                                                         
MR. WALTZMAN said there are  unscrupulous actors in this field as                                                               
in  others. He  explained  the  FCC opened  a  docket largely  to                                                               
refresh an activity  that had been going on since  the early 90s.                                                               
It hasn't had any major action  since 1999. With the existence of                                                               
cramming,  the  FCC  decided  to  seek comment  on  a  number  of                                                               
proposals,  some  of  which  they  specifically  endorsed  as  to                                                               
whether or  not these proposals  would help reduce  cramming even                                                               
further.  He  said the FTC doesn't have a  formal open proceeding                                                               
and  both  have  gone  after  specific  bad  actors  and  brought                                                               
enforcement action against them. He  didn't view the existence of                                                               
the  FCC  docket as  indicative  of  an  epidemic in  this  area.                                                               
Looking at the evidence presented  during the FCC's comment cycle                                                               
in  2011, he  saw  that  the actual  incidents  of cramming  were                                                               
extremely low.                                                                                                                  
2:31:31 PM                                                                                                                    
SENATOR  WIELECHOWSKI said  he wanted  to make  it clear  that he                                                               
supports legitimate third-party charges,  and it's not his intent                                                               
to  ban them.  He was  trying to  get to  the unauthorized  ones.                                                               
However,  a gentleman  from San  Antonio suggested  that industry                                                               
adopt best  practices, but  that was tried  and didn't  work. So,                                                               
it's up to the legislatures of  the states to protect the people.                                                               
Many charges are  legitimate, but he has seen  evidence that many                                                               
He said  this bill does  two things: it requires  phone companies                                                               
to clearly identify  where charges come from because  that is one                                                               
of the  big problems, and  it requires express  authorization for                                                               
specific charges rather  than if you accept that  free sample and                                                               
they take that  as an authorization to charge you  $49.95 a month                                                               
under  something   that  says  voice   mail  or   electronic  fax                                                               
servicing. That is inappropriate and should not be tolerated.                                                                   
SENATOR WIELECHOWSKI  said he  is happy  to work  with legitimate                                                               
third-party  agents who  have concerns  and he  is not  trying to                                                               
harm any  legitimate small businesses.  On that subject,  he said                                                               
someone said  this would hurt  small business because  they don't                                                               
have the accounting practices set  up, but that's the point. They                                                               
have seen evidence that dozens  of small businesses have been set                                                               
up, and it's  all a ruse. The  purpose is to go out  and use them                                                               
as shields so you can't identify who is actually charging you.                                                                  
SENATOR  GIESSEL   asked  how  many  states   are  enacting  this                                                               
MR. PRESELY replied Vermont, Virginia, New York and Minnesota.                                                                  
SENATOR GIESSEL asked the status of the FCC and FTC dockets.                                                                    
SENATOR WIELECHOWSKI replied they would get that for her.                                                                       
CHAIR EGAN held testimony open until the next hearing.                                                                          
SENATOR WIELECHOWSKI said he didn't object to that.                                                                             
[SB 138 was held in committee.]                                                                                                 

Document Name Date/Time Subjects
CSSB 122 (CRA).pdf SL&C 2/2/2012 1:30:00 PM
SB 122
SB 122 Sponsor Statement.pdf SL&C 2/2/2012 1:30:00 PM
SB 122
SB122-DCCED-INS-01-19-12.pdf SL&C 2/2/2012 1:30:00 PM
SB 122
SB122 lttr supporting, First Am. Title.pdf SL&C 2/2/2012 1:30:00 PM
SB 122
SB 122 lttr supporting, Yukon Title 012312.pdf SL&C 2/2/2012 1:30:00 PM
SB 122
SB 122 lttr supporting, Mat-Su Title 012312.pdf SL&C 2/2/2012 1:30:00 PM
SB 122
SB 122 lttr supporting, Fidelity Title 012312.pdf SL&C 2/2/2012 1:30:00 PM
SB 122
SB 122 lttr opposing, Old Republic Title 1-31-12.PDF SL&C 2/2/2012 1:30:00 PM
SB 122
SB 122 lttr opposing, Old Repub. Title 1-10-12.PDF HJUD 4/11/2012 1:00:00 PM
SL&C 2/2/2012 1:30:00 PM
SB 122
SB 122 lttr opposing, AKUSA Title 1-24-12.PDF SL&C 2/2/2012 1:30:00 PM
SB 122
SB138-Sponsor statement.pdf SL&C 2/2/2012 1:30:00 PM
SB 138
SB138-Sectional Analysis.pdf SL&C 2/2/2012 1:30:00 PM
SB 138
SB138-LAW-CIV-01-27-12.pdf SL&C 2/2/2012 1:30:00 PM
SB 138
SB138-Fact Sheet.pdf SL&C 2/2/2012 1:30:00 PM
SB 138
SB138-Exhibit II -Sample Residential Bill.pdf SL&C 2/2/2012 1:30:00 PM
SB 138
SB138-Exhibit II - Sample Enterprise Bill.pdf SL&C 2/2/2012 1:30:00 PM
SB 138
SB138-DCCED-RCA-01-27-12.pdf SL&C 2/2/2012 1:30:00 PM
SB 138
SB138 VT Asst. AG Testimony.PDF SL&C 2/2/2012 1:30:00 PM
SB 138
SB138 Media-phone cramming msnbc.pdf SL&C 2/2/2012 1:30:00 PM
SB 138
SB138 Media-Phone Cramming APM.pdf SL&C 2/2/2012 1:30:00 PM
SB 138
SB138 Media-Juneau Empire Story, 1-10-12.pdf SL&C 2/2/2012 1:30:00 PM
SB 138
SB138 lttr supporting, AKPIRG.pdf SL&C 2/2/2012 1:30:00 PM
SB 138
SB138 backup material- US Senate Committee Findings.PDF SL&C 2/2/2012 1:30:00 PM
SB 138
SB 138 DRAFT CS v E.PDF SL&C 2/2/2012 1:30:00 PM
SB 138