20080625Petition.pdf

frontier'
COMMUNICATIONS SOLUTIONS
2.: 09
P.O. Box 708970
Sand, UT 84070-8970
Phone: [phone]
Fax: [phone]
June 20, 2008
Mrs. Jean Jewell
Idaho Public Utilities Commission
472 West Washington Street
Boise,ID 83702
c Tc -( -013 -o:L
RE: The Petition of Citizens Telecommuncations of Idaho for a parial exemption from
Rule 31.41.01.201(02).
Mrs. Jewell,
Please find enclosed the original and 8 copies of the Petition of Citizens
Telecommunications of Idaho, dba, Frontier Communications of Idaho for a parial
waiver from Rule 31.41.01.201(02).
If you have any questions, please contact me.
Sincerely,
~~
Manager, Governent and Externl Afairs
BEFORE THE IDAHO PUBLIC SERVICE COMMISSIÖ~
PETITION OF CITIZENS )
TELECOMMUNCATIONS OF IDAHO FOR ) CASE NO.
A PARTIAL EXEMPTION FROM RULE )31.41.01.201(02) )
P,;t ?- t'tln &," u:;
etc ..-ò 8-0 L
PETITION FOR EXEMPTION
Citizens Telecommuncations of Idaho, dba, Frontier Communcations of Idaho
(Frontier) hereby submits a petition for parial exemption from Rule 31.41.01.201(02).
1) Pursuat to IDAP A 31.41.01.009 Frontier requests a permanent exemption from rue
31.41.01.201(02) (Rule 201.02) to the extent that long distace biling detail is
required for customers that do not pay for toll calls on a per call basis but instead pay
a flat rate for unimited Long distace calling.
2) Rule 201.02 requires that "bils for MTS service must itemize for all MTS calls the
number called and the date, time, duration, destination and charge for each call".
3) Frontier offers customers service options that include unimited long distace charges
at a flat rate. Customers who choose these options are not charged separately for each
call, but rather pay a single monthy charge for unimted long distace just as they do
for local service. Frontier wishes to discontinue providing the required long distace
detail in the bils of customers who subscribe to flat rate long distance service only.
Customers who do not subscribe to a flat rated toll plan and pay long distance charges
based on time and distace of individual calls will continue to receive details of each
long distace call being biled.
4) Providing individua details of each call adds signficant printing and postage charges
to the preparation and distribution of customer bils. In addition, the bils are often
significantly more cumbersome and provide information that most customers do not
need or want.
5) Frontier customers who wish to receive call detal for their unimited plan may do so
by requesting the information from Frontier's customer service centers.
6) In its order No. 30555 in Case No.QWE-T-08-02, the Commission granted Qwests
application for exemption from certin provisions of rue 201, including rule 201.02,
with the condition that customers have "access to a minimum of 12 consecutive
monthly biling statements at no charge". Frontier wil maintan records of call detail
of at least 12 months and make that information available to customers upon request
at no charge.
7) Under rule No. IDAPA 31.4.1.01.009 (rue 9) "If unusual or uneasonable hardships
result from the application of any of these rules, any telephone company or customer
may apply to the Commission for, or the Commission on its own motion may order, a
permanent or temporar exemption." Frontier believes that this request meets that
stadad.
8) Without the requested exemption, Frontier and its customers will be required to bear
the unecessar expense of preparg and mailing additional information that is not
necessar for customers to determe the accuracy of their bils and will stil be
available on line or upon customer request.
9) Granting this petition will allow Frontier and its customers to avoid unecessar bils
and will simplify bils received by customers while stil makng all of the data
required by rule 201.02 available to customers upon request. Denying the petition
will result in a hardship on Frontier, which is attempting to improve customer service
by reducing costs without the loss of any data that customers may require.
10) Frontier therefore, respectfully requests that the Commission consider ths petition
and expeditiously grant the relief requested.
Submitted this 20th day of June ,2008
Manager, Governent and External Affairs
Frontier Communcations
P.O. Box 708970
Sandy, Uta 84070-8970