20200724Decision Memo.pdf

DECISION MEMORANDUM
TO COMMISSIONER KJELLAIIDER
COMMISSIONER RAPER
COMMISSIONER ANDERSON
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM:MATT HUNTER
DEPUTY ATTORNEY GENERAL
DATE: JULY 23,2020
SUBJECT:IN THE MATTER OF QWEST CORPORATION DBA CENTURYLINK
QC'S TARIFF FILING DISCONTINUING PRORATING OF CLOSING
BILLS FOR RESIDENTIAL CUSTOMERS; CASE NO. QWE-T-20-04
IN THE MATTER OF CENTURYTEL OF IDAHO, INC. DBA
CENTURYLINK'S TARIFF FILING DISCONTINUING PRORATING OF
CLOSING BILLS FOR RESIDENTIAL CUSTOMERS; CASE NO. CEN-T.
20-03
IN THE MATTER OF CENTURYLINK COMMUNICATIONS LLC'S
TARIFF FILING, DISCONTINUING PRORATING OF CLOSING BILLS
FOR RESIDENTIAL CUSTOMERS; CASE NO. QCC-T-20-01
IN THE MATTER OF CENTURYTEL OF THE GEM STATE, INC. DBA
CENTURYLINK'S FILING DISCONTINUING PRORATING OF
CLOSING BILLS FOR RESIDENTIAL CUSTOMERS; CASE NO. CGS.T-
20-03
On July 1,2020, Qwest Corporation dba CenturyLink QC, CenturyTel of Idaho, Inc.
dba CenturyLink, Centurylink Communications, LLC, and CenturyTel of the Gem State, Inc. dba
CenturyLink (collectively "CenturyLink") filed changes to its tariffs with the Commission.
CenturyLink proposed to discontinue prorating for the final bills of residential customers.
CenturyLink proposed a July 17,2020 effective date for the modified tariffs.
At the July 7, 2020 Decision Meeting, Commission Staff noted the adverse impact
CenturyLink's modified tariffs would have on residential customers, and suggested the
Commission initiate a formal proceeding to determine whether the proposed tariffs comply with
the Commission's regulatory requirements.
1DECISION MEMORANDUM
On July 15,2020, The Commission issued a Notice of Application and Modified
Procedure, converting CenturyLink's proposed tariff revisions into an Application and suspending
the proposed effective date of CenturyLink's proposed tariff revisions for 60 days. The Notice also
directed that the Application be processed by Modified Procedure, with an August 3, 2020
comment deadline and an August 10,2020 reply comment deadline. Order No. 34722.
Since Order No. 34722 was issued, CenturyLink has communicated with Staff about
the Commission's potential concerns with its proposed modified tariffs. CenturyLink clarified to
Staff that a residential customer will receive a prorated bill if the disconnection is due to one of
the following circumstances :
. Military deploymento Customer is vacating premises prior to end of billing cycle dateo Death of customer. Local number portability requesto Financial hardship
The above circumstances cover most reasons a residential customer would cancel service.
On July 22, 2020, CenturyLink filed new tariff revisions for each of its tariffs,
incorporating the five circumstances listed above. The proposed effective date for the new tariff
revisions is August 14,2020. The following day, CenturyLink requested to withdraw its July l,
2020 tariff revisions.
STAFF RECOMMENDATION
Staff recommends the Commission close this case. Staff brought CenturyLink's July
1,2020 tariff revisions to the Commission's attention because it was concerned the revisions might
not comply with the Commission's regulatory requirements. Staff voiced its concerns knowing the
Commission has no economic regulatory authority over CenturyLink and only limited
noneconomic regulatory authority over CenturyLink. See ldaho Code $ 62-605(5Xb).
CenturyLink's July 22,2020 tariff revisions, which incorporate the circumstances under which a
residential customer will still receive a prorated bill, assuage Staff s concerns. Staff believes
further process is unnecessary in this case. If the Commission chooses to close this case,
CenturyLink's new tariff revisions will take effect on August 14,2020.
DECISION MEMORANDUM 2
COMI\ISSION DECISION
Does the Commission wish to close this case?
Matt Hunter
Deputy Attorney General
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3DECISION MEMORANDI.JM