20080730Comments.pdf

KRSTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
Sit
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
CITIZENS TELECOMMUNICATIONS OF
IDAHO FOR EXEMPTION FROM RULE
201(2), IDAPA 31.41.01.201.02.
)
) CASE NO. CTC- T -08-2
)
) COMMENTS OF THE
) COMMISSION STAFF
)
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
Attorney of record, Kristine A. Sasser, Deputy Attorney General, and in response to the Notice
of Petition and Notice of Modified Procedure issued in Order No. 30593 on July 9, 2008 in Case
No. CTC- T -08-2, submits the following comments.
BACKGROUND
On June 24, 2008, Citizens Telecommunications of Idaho dba Frontier Communications
of Idaho (Citizens) fied a request with the Commission, pursuant to ID AP A 31.41.01.009,
seeking a permanent exemption from a provision of the Commission's Telephone Customer
Relations Rule 201, IDAPA 31.41.01.201. Specifically, the Company seeks an exemption from
Rule 201.02 requiring itemization oflong-distace usage and charges.
The Company maintains that it offers service plans for unlimited long-distance calls at a
flat rate. The Company requests discontinuance of itemized biling for its flat rate long-distace
customers only. Customers who do not subscribe to a flat rate toll plan and pay for long-distace
STAFF COMMENTS 1 JUL Y 30, 2008
services based on time and distace of individual calls would continue to receive itemized biling
in accordance with Rule 201.02, IDAPA 31.41.01.201.02.
The Petition states that customers who wish to receive call detail for the unlimited plans
may do so by contacting the Company's customer service center. In addition, the Company
intends to make no less than 12 months of detailed biling statements available to its customers at
no charge.
The Company asserts that providing the details of each call adds significant printing and
postage charges, makes the bils more cumbersome, and provides information that most
customers do not need or want. Citizens contends that denying its Petition would result in
hardship to the Company, which is attempting to improve customer service by reducing costs
and simplifying biling. See IDAPA 31.41.01.009.
STAFF ANALYSIS
Staff supports Citizens' request for a permanent exemption from Rule 31.41.01.201.02 of
the Telephone Customer Relations Rules. The Company offers customers optional flat-rated,
unlimited usage toll callng plans. Offering a varety of biling options and callng plans to
customers is an essential component of good customer service. Staff believes it is importt that
customers for a reasonable period of time be able to obtain detailed biling information if
necessar. The Company indicates it wil provide call detail for at least twelve consecutive
months upon request by customers whose regular biling statements lack that information.
Staff determined that as of January 2008, the Company discontinued providing
information on individual toll calls as required by Rule 201. At some point prior to that date,
Citizens decided that it was unecessar to continue providing call detail to any of its customers
who subscribed to flat-rated, unlimited usage toll callng plans. When Staff became aware of
this change, it advised the Company of the rule violation and the need to seek a rule exemption if
it wished to continue this biling practice. Because the Company ceased to provide call detail on
January 1,2008, it informally requested that the approval date for the rule exemption be made
retroactive to that date.
Although Staff supports the Company's request for an exemption in this instance, it is
unfortunate that the Company undertook a significant change to its billng system, affecting
customers throughout its nationwide service territory, without questioning whether such a change
STAFF COMMENTS 2 mLY 30, 2008
was permissible in Idaho. Staff recognizes that on Januar 26, 2007, Citizens filed a Notice of
Election to be regulated under the terms of Idaho Code § 62- 604 and exempted from normal
price regulation under Title 61. However, the Commission retains authority over non-economic
regulatory requirements "including, but not limited to, such matters as service quality standards,
provision of access to carriers providing (long-distance) service, filing of price lists, customer
notice and customer relation rules, and bilings practices and procedures." Idaho Code § 62-
605(5)(b). Staff recommends that the Commission remind the Company of its continuing
obligation to comply with Commission rules and, if necessary, seek an exemption in advance of
changing long-standing policies and operating procedures.
RECOMMENDATIONS
Staff recommends that the Commission:
Grant Citizens a permanent exemption to Rule 201.02, IDAP A 31.41.01.201.02
with respect to customers who subscribe to flat-rated, unlimited toll callng plans with the
condition that, upon customer request, the Company make call detail available without charge
for a period covering a minimum of twelve consecutive months prior to receipt of the request;
Specify an effective date of January 1, 2008, for the exemption as requested
informally by the Company;
Remind the Company of its continuing obligation to comply with Commission
rules and, if necessar in the future, seek an exemption in advance of changing long-standing
policies and operating procedures.
Respectfully submitted this '3df day of July 2008.
~ -2 ,(,
Kristine A. Sasser
Deputy Attorney General
Technical Staff: Beverly Barker
i:umisc:commentslctcto8.2ksbab.doc
STAFF COMMENTS 3 mLY30,2008
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 30TH DAY OF mLY 2008,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. CTC-T-08-02, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
INGO HENNINGSEN MGR
GOVERNMENT & EXT AFFAIRS
CITIZENS TELECOMM OF ID
PO BOX 708970
SANDY UT 84070-8970
CERTIFICATE OF SERVICE