20211012Response.pdf

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October LL,2O2L
VIA FEDERAL EXPRESS
Jan Noriyuki, Secretary
ldaho Public Utllities Commission
11331 W. Chinden Blvd. Building 8, Suite 201-A
Boise, lD 83714
Re Case No. COL-T-21-01, ln the Matter of Columbine Telephone Company, lnc.'s
Application to Change the Manner in which Facilities Extensions are Handled
Response of Columbine Telephone Company, lnc. to Commission Notice of
lnquiry
Dear Ms. Noriyuki:
Pursuant to Rule 67 of the ldaho Public Utilities Commission's Rules of Procedure,
enclosed are the Confidential Attachments in the above filling. The enclosed materials contain
highly confidentia! financial and proprietary information which, if disclosed, could harm the
business operations of the Company. Request is respectfully made that these materials be
maintained by the Commission confidentially and public disclosure disallowed.
Questions regarding this filing may be directed to my attention as shown below
Sincerely,
Michelle Motzkus
Legal & Regulatory Administrator
phone: [phone]
email : ma motzkus@silverstar. net
Enclosures
SilverStar.com I PO Box226 | Freedom, WY831201877.883.2411
Columbine Telephone Company, lnc.
Michelle Motzkus, Legal & Regulatory Administrator
PO Box 226
Freedom, WY 83120
Ph:307-883-6690
Fax: [phone]
Email: mamotzkus@silverstar. net
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
rN THE MATTER OF COLUMBTNE TELEPHONE )
COMPANY, INC.'S APPLICATION TO CHANGE )
THE MANNER tN WHTCH FACIL|TIES )
EXTENSTONS ARE HANDLED )
Case No. COL-T-21-01
RESPONSE OF COLUMBINE TELEPHONE COMPANY, INC. TO COMMISSION NOTICE OF ]NQUIRY
Columbine Telephone Company, lnc. dba Silver Star Communicataons (the "Company") hereby
responds to the Notice of lnquiry issued by the Commission on August L6,}OZL, as follows.
lnquiry No. 7. Pleose provide documentotion of the customer requests and feedbock thot led to
the proposed changes in the Compony's line ertension section of the toriff.
Response to lnquiry No. 1. Written documentation of customer requests and feedback
precipitating the Company's filing of its proposed changes to the line extension section of its Local
Exchange Service Tariff No. 3 are not maintained in the ordinary course of its business. However, Silver
Star staff have on numerous occasions received feedback from customers on the burdensome and
complicated methodology of determining the cost for a line extension. As more fully described in response
to lnquiry No. 4 below, a customer request for new line extension under the existing process is lengthy,
time consuming and resource intensive.
lnquiry No. 2. Pleose report how mony new line extensions the Compony hos instolled in its ldoho
service territory in the lost two years. Please include the averoge lengths of the line extensions.
Response to lnquiry No. 2. Confidential Exhibit No. 1, attached, provides detail on new line
extensions and calculated line extension lengths, placed by the Company in its service territory over the
previous five yearsl. Referenced on Exhibit No. 1 is the average length for a new line extension, calculated
based on a five year and two year historical average.
lnquiry No. 3. Under the existing line extension toriff, provide documentation showing how mony
feet of fiber, on overage, the current $7600 allowance will cover. Please provide the Commission
a schedule showing how the cost of providing copper compores to the cost of providing fiber.
Response to lnquiry No. 3. The attached Confldential Exhibit No.2 contains detailon the average
amount of fiber covered under the S1,500 aid to construction. Also provided is a cost comparison of
copper over fiber. As illustrated, the calculated average footage provided under the 51,500 aid to
construct varies depending on mode of construction and material costs, and regardless of the type of
construction is significantly less than what is proposed by the Company under its pending tariff revision.
lnquiry No. 4. Please exploin how the new proposed line extension tariff will cut instollotion time
down from 2-3 weeks to 2-3 doys.
Response to lnquiry No. 4. Under the existing line extension process, construction of a new line
extension can take up to three weeks, because of the multiple steps and touch points with the customer
prior to actual installation. Confidential Exhibit No. 3 illustrates a typical installation request and timeline
under the existing process compared to the proposed process.
As illustrated, the proposed process substantially reduces the time to construction completion. The
time saved benefits the customer resulting in earlier service activation; benefits the Company resulting in
more time to address more customer requests, reduced engineering staff time to calculate routes and
1 2021 is included as a reference and counts are subject to change following construction season end and work order
closeout.
costs, and fewer truck rolls to engage with customers at initial request; and, benefits the customer through
implementation of a simplified process and overall lower cost to the customer.
lnquiry No. 5. Pleose provide o cost breokdown exomple for a SAo-foot line extension using both
the existing and the new proposed line ertension methodology.
Response to lnquiry No. 5. The cost breakdown using both the current line extension and the
proposed line extension methodologies for a 50O foot line extension is detailed on the attached
Confidential Exhibit No. 4. As illustrated, the difference in a lower cost to the customer is significant under
the proposed new line extension methodology.
As demonstrated, new line extension costs can vary widely; however, based on the average cost to
construct, a customer is more likely than not to contribute to the construction cost under the existing
methodology. Transitioning to a fixed fee methodology results in certainty to the customer of the cost
involved to construct, less confusion and saves the Company and the customer in both time and financial
resource expense.
The Company respectfully requests the Commission approve its application to modify its Tariff No.
3 with respect to line extensions, as detailed in its filings herein.
Dated:
Columbine Telephone Company, lnc.
Michelle Motzkus
Legal & Regulatory Administrator
307-883-6590
PO Box 226
Freedom, WY 83120