20051025Petition for reconsideration.pdf

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Citizens Communications Company r ! 1 \~1" f~ ;- r. f'i r"1H lSSlOfc1; i \ ,-; ! t
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Triad Center, Suite1 60
Salt Lake City, UT84180
Phone: [phone]
Fax: [phone]
October 24, 2005
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, ill 83720
RE: Citizens Telecommunications Company of Idaho tariffID-05-, Case No.
CTC- T -05-
Dear Ms Jewell
Please find enclosed one original and seven copies of Citizens Telecommunications
/DBA Frontier Communications of Idaho s request for reconsideration of the
Commissions order No. 29893 in the above referenced tariff filing.
If you have any questions or concerns, please contact me at 801-924-6357 or 3 Triad
Center, Suite 160, Salt Lake City, UT 84180
Sincerely,
\ 'CE\VED
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSIONp;J\h1 Q: "J.l
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IN THE MATTER OF CITIZENS
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IGLiC
TELECOMMUNICATIONS COMPANY OF CASE NO. CTC-O5MdM\F
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IDAHO DBA FRONTIER COMMUNICATIONS
OF IDAHO'S TARIFF ADVICE NO.ID-O5-06 TO
IMPLEMENT ELECTRONIC BILLING AND
PAYMENT SERVICE FOR RESIDENTIAL CUSTOMERS
PETITION FOR
RECONSIDERATION OF
ORDER NO. 29893
Citizens Telecommunications Company of Idaho, DBA Frontier Communications of
Idaho ( Frontier) respectfully requests that the Idaho Public Utilities Commission
reconsider its order No. 29893 issued October 17, 2005 in the above referenced matter, to
the extent that the order requires Frontier to provide simultaneous electronic and paper
bills without charge.
Frontier filed this tariff in order to give customers the option of receiving bills
electronically rather than the current paper bills received in the mail. This new service is
intended to make the bill paying process easier and ultimately less expensive for both
customers and the Company. The Commission agreed that electronic billing was a
beneficial service, as it stated in its order
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The Commission compliments the Company
for proposing an on-line billing service. We find that electronic billing and payment
options expand customer convenience and may result in reduced costs and improved
efficiencies for the Company.
Customers are not charged if they choose to receive only a paper bill or only electronic
billing. The $2.00 charge is only imposed if a customer chooses to receive both. Under
the new tariff, a customer can try electronic billing while still receiving their paper bill
for a two month trial period. If after that time the customer determines the paper bill is
preferable the paper bill only can be restored at no charge. Additionally, most customers
that are capable of receiving an electronic bill should be able to print a copy of the bill on
their own equipment if they desire a paper copy.
Current rates include the cost of producing a paper bill only. Frontier invested substantial
amounts of money to develop and implement the electronic billing service on a
nationwide basis. The electronic billing option is less expensive on an incremental basis
for both the customer, who saves postage and any check charges, and the company, that
no longer needs to produce and mail a paper bill. The cost savings to the company will
eventually offset the costs of its investment in the new electronic billing system.
Customers who choose to continue with paper only bills will not cause any cost changes
one way or the other, for themselves or for the company. However, customers who
choose to receive both a paper and electronic bill will impose additional costs on Frontier
with no way to recover the additional costs of providing two bills let alone its investment
in the electronic billing system. In addition, the nominal charge of $2.00 should help
provide some incentive for customers to make a conscious decision as to which method
of billing is preferable, rather than request both electronic and paper bills by default.
Frontier developed its electronic billing system on a nationwide basis, not on a state
specific basis. This was done because the costs were far less for development as well as
maintenance and training. Because of the single nationwide design of the service the
company will have great difficulty providing the service in Idaho without the customer
charge. Frontier has filed this tariff, including the $2.00 charge for simultaneous billing
only, in all of the 23 states in which it operates. No other state has rejected the tariff with
this charge included (California is still reviewing the filing, but the company believes it
will be approved there as well). Substantial changes to the billing system will be needed
to prevent the system from adding the $2.00 charge to the bills of customers choosing to
receive both a paper and electronic bill for Idaho only. Advertising campaigns will have
to be modified to exempt only Idaho and Company web pages will need to be changed to
exempt Idaho customers from the charges. Employees will also need additional training
to specifically understand and explain to customers the unique circumstances in Idaho.
All of these Idaho specific accommodations will significantly increase the costs of the
offering to the company. Therefore, it may be necessary for the company to completely
withdraw the tariff and not offer the electronic billing service in Idaho at all.
For the reasons stated above, Frontier believes that the $2.00 charge to only those
customers who chose to receive both a paper and electronic bill is appropriate. The
Company therefore, requests that the Public Utilities Commission reconsider its order in
this matter and allow the company to implement the tariff as filed.
Respectfully submitted this ?.fi/day of October, 2005.
L~
Ingo tHennlngsen
Manager, Government and External Affairs
Frontier Communications of Idaho.