20210715Reply Comments.pdf

Columblne Telephone Company, !nc.
Michelle Motzkus, Legal & Regulatory Admlnistrator
PO Box 226
Freedom, WY 83120
Ph:307-883-5590
Farc 307-883-2575
Email : mamotzkus@sllversta r.net
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF COLUMBINE TELEPHONE
coMpANY, tNC.'s APPLICATION TO CHANGE
THE MANNER IN WHICH FACILITIES
EXTENSIONS ARE HANDLED
Case No. COL-T-21-01
REPLY OF COLUMBINE TETEPHONE COMPANY, INC. TO COMMENTS OFTHE COMMISSION STAFF
Columbine Telephone Company, lnc. dba Silver Star Communlcations (the "Company'') hereby
replles to the Comments of Commlssion Staff, as follows.
As noted in the Companfs tariff advice filing made on May 14, 2021, the purposes of the
proposed changes are to (11 simplify the drop extension process to the customer and (2) substantially
decrease the time to delivery of services to the customer. These changes have been developed in part
based on customer request and feedback that the current process is complicated and hinders
customerc' timely access to services.
A flat fee substantlally simpllfies the customer process by ellmlnating the need fior multiple slte
visits, extension cost calculations, and customer pre-payment of costs exceedlng the 51,600 aid to
construction prior to construction completion and any resultinB true-up. ln turn, a slmpllfied process
substantially decreases the time to deliver services, down from two-three weeks to two-three days.
Whlle Staff is technlcally correct in its analysis that under the outdated scheme of accounting for
line extensions a customer would typically not pay if the cost did not exceed the stated aid amount, the
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Company's analysis shows that a majority of customer extenslons do exceed the stated aid amount,
ranging from SS0O to S1,2(D, with the average line extension exceeding the aid to construct by
approximatety $+OO (reference Confidential Attachment A, representing an analysis of historical drop
costs and customer Payments).
Further, responding directly to Staffs concern that the proposed changes increase a charge,
since the average amount a customer will pay for a line extension is Sa00 and the Company proposes a
flat fee of 5350, the proposed change effectlvely decreases a charge. Streamlining the process is more
cost effective than the current process which savlngs are reflected in the 535O rather than S4{D,
proposed flat fee. ln addition, customers may still elect for the Company to excavate and place the
facllitles, whlch would be done at the Company's current hourly rate, and which is no different than its
current process. However, allowing customerc the option to excavate the desired facilities route
further streamlines the process and creates cost-efficiencies, since it is often the case that power and
phone facilities are in the same trench and the power companies generally require the customer to
provide their own trench, this process further aligns with utility industry standards.
The Company's proposed changes seek to align its operational across the Jurlsdictlons ln which it
provides service, and these changes do allgn with its commisslon-approved practice in Wyoming.
The mere fact that a practlce is different compared to others in the industry does not prohibit
said practlce, nor is it a foregone conclusion that the practice is not in the best lnterest of the
consumers. Whether or not the Companfs practices are the same as other similarly situated providers
is not a determining factor of whether or not the Company's proposed changes are best for its
customers and its business operations. Each Company is different, has different geographic
characterlstics, a different customer base, and different operational needs. The Company agrees with
the Commission Staff analysis with respect to the language included in its comments; however, placing
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this into context for Commission consideration, most of the tariffs have been on file slnce as early as
1991, with no substantive changes since - which is at individual companies' discretion. The same is
true in this case, with respect to the practice the Company proposes to modify, and this change is
consistent with monitoring and implementing best practice tariff updates in order to remain current
and relevant in an ever<hanging industry. The Company has not modified its line extension practices
in over 20 years; processes, costs, services and operational needs have substantially changed over that
time - a line extension is no longer a copper drop for a party line volce servlce; it !s now a highly
technical flber cable connection enabling voice and broadband service. Modified practlces reflect the
industry changes.
No public comment has been received in this matter, and the Company believes further
delaying the implementation of the Company's updated practice could in fact harm its customers for
the reason that the Company's operations will be under disparate customer practices, potentially
causing confuslon and a higher margin of error in determining facilities extension costs. The
Commission has already set a comment and reply comment deadline in this docket and further
extendint the timeframe will negatively impact the Company and its customers, because it wlll not be
able to proceed with the updated practices for some period of time down the road, pendlng
Commission approval.
The Company's customers have requested, on numerous occasions, that the Company slmplify
its line extension practices; over the past hilo years, a substantial nurnber of new construction
customers have made comment on the complicated and seemingly archaic practice the Company uses
to extend facilities.
For the reasons stated herein, Columbine Telephone Company, lnc. respectfully submits lt has
met its burden of proof justfiing its request to modify its line extension practices as represented in its
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tariffadvhe fillng and rcspectfrrlly requests.the Commlssion approve the Gompany's proposed tariff
changes, as submitted, effectfue immedhtely upon the Commlsslon's Order.
Dated:
lnc.
/
Mtchclle Motzkus
legal & Regulatory Admlnlstrator
307-883-6690
FO Box 226
Freedom, WY83120
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Certificate of Service
I hereby certify that I have this day of July, 202L, served the foregoing Reply of
Columbine Telephone Company, lnc.ments of the Commission Staff, in Case
No. COL-T-?L-OL by emailing a copy thereof to the following:
MATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, I DAHO 837 20-007 4
Attn: Jo Nelson, Secretary: [e-mail]
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