20020628Summons and Complaint.pdf

IDAHO Dirk Kempthome,GovemorPUBLICUTILITIES
commission P.O.Box 83720,Boise,Idaho 83720-0074
Paul Kjellander,President
Marsha H.Smith,CommissionerDennisS.Hansen,Commissioner
June 28,2002
Via Certified Mail CASE
Lance A.Tade
Manager,State Regulatory
Citizens Telecommunications Companyof Idaho
dba Frontier
4 Triad Center,Suite 220
Salt Lake City,UT 84180
Re:Case No.CTC-T-02-01
Dear Mr.Tade:
Enclosed please find a Summons and Complaint issued against CitizensTelecommunicationsCompanyofIdahodbaFrontierinCaseNo.CTC-T-02-01.As
directed in the Summons,you are to file a written answer or motion in defense of saidComplaintwiththisCommissionwithin21days.
To assist you in preparing an answer,I have enclosed background information related tothecomplaint.
J Jewel
Commission Secretary
Enclosures
Cc:Boise County Board of County Commissioners (w/o enc.)
Located at 472 West WashingtonStreet,Boise,ldaho 83702
Telephone:[phone] Facsimile:[phone]
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
BOISE COUNTY BOARD OF )COUNTY COMMISSIONERS,)
Complainant )SUMMONS
vs.)CASE No.CTC-T-02-01
CITIZENS TELECOMMUNICATIONS )COMPANY OF IDAHO dba FRONTIER )
Respondent.)
THE STATE OF IDAHO SENDS GREETINGS TO THE ABOVE-NAMED RESPONDENT.
YOU ARE HEREBY NOTIFIED that a Complaint has been filed with the IdahoPublicUtilitiesCommissionbytheabove-named Complainants;and
YOU ARE HEREBY DIRECTED to file a written answer or written motion indefenseofsaidComplaintwithintwenty-one (21)days of the service of this Summons;and
YOU ARE HEREBY NOTIFIED that unless you do so within the time hereinspecified,the Idaho Public Utilities Commission may take such action against you as is prayedforintheComplaintorasitdeemsappropriateunderTitle61oftheIdahoCode.
WITNESS MY hand and the seal of the Idaho Public Utilities Commission this
477 day of June,2002.
J D.Jewel
mission Secretary
BOISE COUNTY BOARD OF COUNTY COMMISSIONERS
ROGER B.JACKSON DALE HANSONDistrictICommissionerDistrictIIICommissioner
JOHNS.FOARD,JR.RORA A.CANODYDistrictIICommissionerClerktotheBoard
June 17,2002 Gå ,1 o
PUC Commissioners
472 W.Washington St.co
Boise,ID 83720-0074
Re:Citizens/Frontier 911 Charges
Dear Sirs:
Please accept this letter as a formal complaint againstCitizen/Frontier Communications
by the Boise County Board of Commissioners.
Enclosed are the followingattachments:
A copy of letter written to Frontier/Citizens Communications requesting a full
refund of the overcharges paid them over the past five years.
A copy of the breakdown showing the amount owing Boise County from Citizens.
Summary of attemptsto correct this problem with Citizens.
Communication record with Citizens.
As stated in the letter sent to Frontier/Citizens we would like a full refund of the$44,997.22 owed to us.Citizens has refunded us a total of $18,968.49.We have not
cashed these checks.
Sincerely,
Board of County Commissioners
hn S/Foard,Jr.Dale Hanson R r B.Ja onChairmanCommissionerCommissior
Cc:File
P.A.
P.O.Box BC,Idaho City,Idaho 83631 Office [phone] FAX [phone] 
BOISE COUNTY BOARD OF COUNTY COMMISSIONERS
ROGER B.JACKSON DALE HANSONDistrictICommissionerDistrictIIICommissioner
JOHN S.FOARD,JR.RORAA.CANODYDistrictIICommissionerClerktotheBoard
April 15,2002
Mr.Scott W.Jeffrey
Frontier /Citizens Communications
201 Lenora
McCall,lD 83638
Re:911 Refund amount to Boise County '
Dear Mr.Jeffrey:
Thank you for attendingthe meeting with us on March 18,2002.
As we indicated at the conclusion of that mee,ting,the Boise County Board ofCommissionersneededtotaketimetoreviewthe911rateinformationprovided byCitizens/Frontier Communications during the meetingand to compare that rateinformationwiththechargespaidbyBoiseCountytaxpayerstoCitizens/FrontierCommunicationsoverthepastfiveyears.This letter provides the results of our review
and requests that Citizens/Frontier Communications provide an irnmediate refund toBoiseCountyforanyandallover-and unauthorized charges.
Attachment 1 providesour summary of what Boise County actually paid and what we
should have paid based on the rate införmation provided on March 18,2002.This
summary shows that Boise County is due a refund of $44,997.22 for over-charges andunauthorizedchargesaccumulatedsinceJuly1997.
Attachment 2 is a copy of the March 24,1997 Boise County Commissioner's Minutes
showing that the Boise County Board of Commissioners did not authorize Sweet 911
calling to ldaho City.There are no subsequentminutes where the Board authorized the
Sweet 911.Therefore,any charges associated with Sweet 911 service to ldaho City
were un-authorized and repayment for those.un-authorized charges is included in the
$44,997.22.
Attachment 3 is a summary of attemptsby date that Boise County employeescontacted
Citizen/Frontier employeesto get accurate 911 rate information from Citizens/Frontier
Communications for the period 1997 to 1999.
We,the Board of Commissioners,find it absolutelyextraordinarythat the Boise County
Clerk had,after repeated attemptsby multi-tasked employees,to dedicate a full time
P (1 Box BC.Idaho Citv.Idaho 83631 Office (2083 392-6636 FAX [phone] 
employeefor 5 months just to get enough rate and billing information to cause
CitizendiFiorgërto riièetiivithus as mentioned above.Had responsiveand accurate
information bèert provieled when originally requested in 1997 and 1998,neither of us
would be~in this'Sitliäfior 16day.
The Boise County Clerk has informed us that Citizens/Frontier,on our billing dated April
18,2002,has credited the Boise County account for some of the overcharges
discussed at our meeting on March 18,2002.As we firmly stated at that time,Boise
County did not then,nor do we riow,accept or agree with the amounts mentioned by Mr.
Curtis.Additionally,we do not now accept the amount credited to our account,without
our agreementor concurrence,as the full amount of the refund due to the Boise CountytaxpayersbyCitizens/Frontier.
To settle this matter an expeditiouslyas possible,Boise County would agree to waive
any and all interest charges due for over-and unauthorized charges paid by Boise
County taxpayersif Citizens/Frontier Communications were to refund Boise County for
the $44,997.22 within 30 days.If Citizens/Frontier does not desire to settle this matter
expeditiously,then we will include interest from the date of our payment in all
subsequentadministrative and legal proceedings.
Questions or responses to this letter should be directed to Theresa Gardunia,Boise
County Prosecuting Attorney,at 392-4485.
Sincerely,
Board Of County Commissioners
J hn S.oard,Jr.,Dale Hanson Ro¶.Jack
hairman Commissioner Commissioner
Cc:File
PUC
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Citizen's 911 numbers and explanation
1/7/02 -Waiting for a response from Lucinda of Citizens on the 911 numbers and why
there are so many lines for these.
1/10/02 Talked to Paul Curtis at Citizens.He says the 911 billings are wrong and
he will have them fixed.He also said it would be better for the Boise County people
near Sweet to be connected to Emmett rather than Idaho City for their Boise County
service.He told me our Commissioners needed to formally contact Gem County
Commissioners in order to implementthis.
He could not explainwhy we have 5 bills.He is researching this and will get back to
me.
Third week of January talked to Paul Curtis he told me that we were being double billed
from what he could figure out for the 911 lines to HSB and GV.He asked that we give
him a "couple"of days to check it out.
Fourth week of January called and told Lucinda at Citizens that I was tired of trying to
get Paul to give me an answer could she help.She gave him a message.I told her I
wanted somethingin writing and gave her my email address.
February 12 called Lucinda at Citizens and asked for the name of someone over Paul
and in charge that could let us know what is happening here.She gave me Ralph
McKenzie,208-634-6110,he is the territorial manager for Citizens.Called Mr.
McKenzie left a message and had a return call from another gentleman.Explained the
situation to him.Explained to him that I was not getting a response from Paul Curtis.
He told me he would check into it and call me back.
Lucinda called me back and told me he had turned it over to her to fix.She had not
been able to find the file and Paul Curtis was in Sacramento.Mr.Curtis had the file with
him.She called Mr.Curtis in Sacramento and he said he was meeting with the person
who understands the circuits and would have an answer.
2/13/02 -Lucinda called and said Paul Curtis would be calling me on 2/14/02 PM and
giving me all the answers for our questions.
I plan on lettinghim know that he needs to be scheduled for one of the commissioners
meetingsin March and he can explain the circuits and whatever else to them.
Rora has asked that I now involve Wayne Hart of the PUC in this.Wayne Hart 334-
0354.
2/14/02 -Called Wayne Hart explainedthe situation to him.Scheduled a meeting with
him on 2/26/02 at 2:00 for Rora and I.
3
2/14/02 --Mr.Curtis called he told me they owed us a credit of what he figured to beabout$5000.00.He asked if we would take this as a credit I said no.Rora wants themoneyreturnedtothe911system.Also in reviewing what we have paid in to them,Ibelievetheyoweusalotmoremoney.He told me there was not hookup with Qwest for
the Sweet line.He didn't give me a date on this.I have a request into Quest to
research this and find out if there ever was a line for Sweet.I asked Mr.Curtis which
billings were correct for HSB and GV and he said none of them.Therefore it is hard tofigurethecorrectcredit.
Told Mr.Curtis I wanted him to come before the Commissioners and explainall of this
directly to them.He said he would do that.He said he would have everything in writing
also.
2/20/02 -Called Paul Curtis to set a time for him to come meet with the commissioners.
Left message on voice mail.
2/26/02 -Mr.Curtis has not returned my call.Called Lucinda at Citizens.She set a
time of 3/18/02 at 1:30 for Mr.Curtis to meet with the Commissioners.
2/26/02 -Rora and I met with Wayne Hart of the PUC.Explained the Citizens 911
situation to him.He looked over the information we gave him and said he would be at
the Commissioners Meeting on March 18.He suggestedwe have Trula Stone from
Qwest at the meeting.
3/5/02 --Called Trula Stone of Qwest.Dennis and she will be here on March 18,2002
for the commissioners meeting.She has been in contact with Paul Curtis of Citizens
trying to figure this out.She told me as far as she could figure,Sweet was connected to
HSB because they have never had a line to Sweet.Also Gem County is E911 and
therefore not compatiblewith Boise County who is only 911.E911 is enhanced 911
system.She was afraid that Sweet,(Boise County Residents)did not have 911 at all
since Emmett put in the E911 lines.She also told me that Qwest goes by prefix not by
county lines.Therefore accordingly,Sweet on Boise County side should be in Gem.
But since we are dealing with Citizens and not Qwest she didn't know where their 911
service came from.
3/6/02 -I asked Carrie,who works for the road dept.,to call the 911 number from her
home.She is lives on the Boise County side of Sweet.She has the Sweet prefix.She
called 911 from her home and was responded to by Gem County Sheriff..
3/13/02 --Mr.Curtis called asking what time the meeting was.He said he would be
here.
3/14/02 -talked to Kathy Brady,she told me that Executone set up the 911.
4
3/28/02 -Met with Rora on Wednesday the 27th
.Did a spread sheet showing the
breakdown of what we should have paid and what we paid.Asked Cambridge
Telephone,Citizens and Qwest for copies of a signed contract.There are none.
According to Paul Curtis at Citizens and Kristie Kanady at Cambridge the orders came
from Qwest.
Talked to Sharon the clerk of Gem County.She told me they do not receive a bill from
Citizens.They only receive money from Citizens.Their 911 charges come from Qwest.
She faxed me a copy of the revenue sheet for one month of revenue from Citizens.
5/3/02 --Rora noted speaking to Jim McKinnon of Frontier/Citizens in Arizona,he talked
to Gem County and all "we should never have received a bill for Gem".
5