19990826Comments.doc

CHERI C. COPSEY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
Idaho Bar No. 5142

Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983

Attorney for the Commission Staff

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF CENTURYTEL OF IDAHO, INC.’S REVISION TO IDAHO RURAL EXCHANGE CARRIERS TARIFF NO. 2 -- EQUAL ACCESS RECOVERY CHARGE. )
)
)
)
)
)
CASE NO. CEN-T-99-2

COMMENTS OF THE COMMISSION STAFF
)

COMES NOW the Staff of the Idaho Public Utilities Commission, by and through
its Attorney of record, Cheri C. Copsey, Deputy Attorney General, and in response to the
Notice of Tariff Revision, Notice of Modified Procedure and Notice of Suspension issued on August 5, 1999, submits the following comments.

BACKGROUND
Section 251(b)(3) of the Telecommunications Act of 1996 requires all LECs to provide dialing parity. By Order dated March 23, 1999, in FCC Docket No. 96-98, the FCC requires all LECs to file their dialing parity plans with state commissions by April 22, 1999. Toll dialing parity, also referred to as “1 plus equal access” or carrier presubscription, allows a customer to pre-select a carrier for intraLATA toll calls and then access his chosen carrier simply by dialing 1 plus the telephone number. Without dialing parity, a customer wishing to use a specific toll carrier may be required to dial a series of numbers before dialing the telephone number. Upon implementation of toll dialing parity, customers will be able to presubscribe to a carrier for both their interLATA and intraLATA toll calls. This means that originating customers will be able to dial toll calls without having to use any extra digits or access codes (other than the prefatory “1” or “0”). This is often referred to as “full 2-PIC” capability. In addition, originating customers will continue to be able to use “dial-around” 101-XXXX to route their specific calls to a carrier other than their presubscribed carrier if they so choose.
On April 22, 1999, CenturyTel filed an Application with the Commission for an Order approving its intraLATA toll dialing parity implementation plan and on June 8, 1999, the Commission approved CenturyTel’s plan. Order No. 28066.
There are costs associated with implementing dialing parity and local exchange carriers are allowed to recover those costs, called Equal Access Recovery Charges (EARC), from the participating interexchange carriers. The Commission did not address the amount of the EARC in Order No. 28066. This proposed revision to the Idaho Rural Exchange Carriers Tariff No. 2 sets forth the proposed EARC in conformance with Order No. 28066.
On July 13, 1999, CenturyTel of Idaho, Inc. filed a revision to its Idaho Rural Exchange Carriers Tariff No. 2 adding an equal access recovery charge (EARC). The EARC adds the terms, conditions, and rates for providing intraLATA toll dialing parity in Idaho pursuant to the Commission’s Order No. 28066. CenturyTel proposed that incremental expenses relating to intraLATA toll dialing implementation (EARC) be recovered through a surcharge of $0.006873 per originating intraLATA access minute imposed on the participating intraLATA interexchange (IXC) companies over a 24-month period beginning August 13, 1999. In response, the Commission suspended the Tariff Advice for a period of thirty (30) days, or until such time as the Commission may issue an Order accepting or rejecting or modifying the Tariff Advice. Order No. 28112.
CenturyTel offers local telephone exchange service in the Idaho exchanges of Leadore and Salmon. CenturyTel mailed separate customer notifications regarding intraLATA equal access and executed the intraLATA conversion as of July 13, 1999.

STAFF FINDINGS
Gem State projects an annual demand of approximately 2.9 million intraLATA toll minutes; CenturyTel proposes to recover $20, 071 annually for two years. Staff reviewed CenturyTel’s submitted incremental costs including the supporting workpapers and cost model. Staff contacted the Wyoming PUC where this cost model has been used before and believes the cost model is appropriate for this particular application in Idaho dialing parity.
Staff notes that Order 28066 requires CenturyTel to recover the waived PIC change charges during the free PIC period via the issuance of a one-time bulk bill to each participating carrier. This bill will assess the $5.00 PIC change charge for the total number of lines changed to those carriers’ PIC.

STAFF RECOMMENDATION
Staff supports CenturyTel’s proposed dialing parity costs and method for recovery. Staff believes that, in accordance with FCC 96-333 and DA 98-2534, CenturyTel’s method of recovery from all intraLATA toll providers is competitively neutral and that these incremental costs would not have been incurred “but for the implementation of dialing parity.” Because dialing parity creates equal access to intraLATA toll, Staff believes that cost recovery based on intraLATA toll usage is reasonable. Staff accepts the 24-month recovery period but recommends a review period at the end of the first year to determine the effectiveness and, if necessary, adjust the recovery rate.
Therefore, Staff recommends approval of CenturyTel of Idaho, Inc.’s Application which modifies its local exchange tariff to include intraLATA equal access and the introduction of an equal access recovery charge (EARC). Staff further recommends the order approving CenturyTel’s plan be made effective September 13, 1999.
In addition, Staff recommends that CenturyTel’s cost recovery method include an adjustment period at or near the end of the first year of recovery.
Finally, Staff recommends that the approval of CenturyTel’s toll dialing parity implementation plan does not set precedent for other Idaho companies that are required to file. Those recovery proposals may require more or less modifications depending on the individual company situation.

Respectfully submitted this day of August 1999.

___________________________
Cheri Copsey
Deputy Attorney General

Technical Staff: Doug Cooley

CCC:DC:gdk:i:word/umisc/comments/cent992.ccd

STAFF COMMENTS 1 AUGUST 26, 1999