20120223Frontier Comments.pdf

.ç ~J~.Qnt!~r.RECEIVED
2011 FEB 23 AM 9: 46
IDAHO PUBUC
UTILITIES COMMISSION
Jean Jewell
Commission Secretar
Idaho Public Utilities Commission
472 W. Washington
Boise, ID 83702
RE: QWE-T-12-01, CEN-T-12-01, CGS-T-12-02 Petition of the CenturyLink
Companies for Exemption from Rule 31.41.01.502
Dear Ms. Jewell,
Please find enclosed the original and seven copes of Frontier's comments in the above
mentioned case. Please contact me at [phone] if you have any questions.
Sincerely,
't 1H It,Mr
Renee Wiler
Frontier Communications
20575 NW Von Neuman Drive
Beaverton, OR 97006
[phone]
renee. willer~ftr .com
CENTURYLINK COMPANIES
PETITION FOR AN EXEMPTION OF
COMMISSION RULE 31.41.01.502
REceIVED
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COMMENTS OF
FRONTIER COMMUNICATIONS
Frontier Communications Northwest Inc. and Citizens Telecommunications Company of
Idaho d//a Frontier Communications of Idaho (collectively, "Frontier") submit the
following comments.
On January 25, 2012, the Idaho Public Utilties Commission issued a Notice of
Modified Procedure, asking interested parties to comment on CenturyLink's Petition for
an exemption of the Commission's Telecommunications Customer Relations Rule 502
(31.41.502). Specifically, the Commission asked parties to state in written comments
whether a broader rulemaking procedure is appropriate, and whether an exemption to
Rule 502 should be granted to Century Link in the meantime.
Frontier supports CenturyLink's request for waiver of Rule 502 both for the Out of
Service restoral commitments for basic local exchange service and the elimination of
mandatory Out of Service credits. Frontier, like CenturyLink, faces the challenges of
retaining and capturing new customers in a highly competitive market where our
competitors are not held to the same regulatory requirements. Frontier agrees with
CenturyLink that these rules were created at a time when Incumbent Local Exchange
Carriers (ILEC) had the ability to be dominant in the market and did not face local
exchange competition. Sweeping changes in the communications market, particularly the
rise of wireless, cable telephony and VoIP technologies has shifted the paradigm of basic
local service. The market is now more competitive and consumers have more choices.
Rules developed during a time of fewer choices are not in-step with today's customer
expectations and not in the public interest.
Because ILEC competitors are not held to the same stadards, Frontier, CenturyLink
and other Title 62 companies are put at a competitive disadvantage, and customers suffer.
For these reasons, Frontier respectfully requests the Commission open a rulemaking to
discuss necessary changes to Rule 502 to meet the statutory mandate that non-economic
regulatory requirements relating to basic local exchange service be technologically and
competitively neutral 1. In addition, Frontier supports granting CenturyLink and all
similarly situated companies, including Frontier, a temporary exemption to Rule 502
while the broader rulemaking is considered Like CenturyLink, Frontier also faces the
challenge of balancing workforce needs to provide a superior customer experience and
meet regulatory requirements. Frontier's Idaho operations are similar to those
CenturyLink in that the areas served cover a large, non-contiguous geographic area ofthe
state, requiring technicians to drive hours to get to the location for an out-of-service
commitment. Further, customers have not complained to the Commission or Frontier that
their needs are not being met. Rule 502 protected customers in the past because they had
no other means of communication when voice service was impacted. Today, customers
rely on wireless phones and their broadband connections for alternate means of
communication. Many Idahoans have dropped landline service completely and
substituted wireless, VoIP and Cable alternatives. These newer technologies compete
directly with Frontier but are not required by the Rules to meet to out-of-service
mandates and provide automatic credits.
Frontier and other providers realize that competitive choices and a superior customer
experience wil drive consumer decisions. Mandating regulatory requirements that apply
to some providers and not to others creates an imbalance in regulation, which limits the
flexibilty with which regulated companies can respond to customers. For these reasons,
Frontier requests that the Commission open a rulemaking to discuss these important
issues and immediately grant a waiver of Rule 502 to CenturyLink and all similarly
situated companies.
Dated February 20, 2012
'i 1H It&r
Frontier Communications
Authorized Representative
1 Idaho Code § 602-605 (5) (b)
2