20131016Comments.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3283
Street Address for Express Mail:
472W WASHINGTON
BOrSE ID 83702-5918
Attorney for the Commission Staff
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF BLACKFOOT
TELECOMMUNICATIONS GROUP'S
APPLICATION TO MODIFY ITS NUMBER
RESERVE AND SEASONAL SERVICE
TARIFFS.
CASE NO. FRE.T.I3.OI
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through
its Attorney of record, Weldon B. Stutzman, Deputy Attorney General, and in response to the
Notice of Application and Notice of Modified Procedure issued in Order No. 32902 on October
2,2013, submits the following comments.
BACKGROUND AND STAFF ANALYSIS
Blackfoot Telecommunications Group ("BTG"), since acquiring Fremont Telcom
("Fremont") from FairPoint Communications, is updating its tariffs and billing systems while
transitioning customers to its upgraded services. The Company filed revised tariffs and seeks
Commission approval to eliminate Number Reserve service, clarify its current seasonal service
charges, and adjust the residential customer rate to comply with the FCC's rate floor guidelines
set forth in FCC 47 C.F.R. $ 54.318. The Company is also asking the Commission to approve a
$25.00 non-recurring charge for the second and subsequent activations of seasonal service. The
STAFF COMMENTS ocroBER t6,2013
purpose of this charge is to discourage customers from disconnecting and reconnecting service
numerous times throughout a calendar year.
Number Reserve
In 1998, Fremont began offering a service called Number Reserve. The rate for this
service was25Yo of the flat rate service charge or $6.44 for residential and $10.20 for business
customers. Number Reserve service reserved a customer's telephone number when the customer
left the service area for an extended period of time, and disconnected dial tone and all other
switch-based services associated with it. BTG discovered that in some instances the Number
Reserve service was incorrectly provisioned as seasonal or vacation service, improperly
enabling customers to receive calls and make outbound calls. The Company proposes to
discontinue the Number Reserve service and migrate those customers to its Seasonal Service,
preserving the customer's phone number and line. The Company is setting a monthly rate of
$14.00 and $21.00, for residential and business respectively. The previous Seasonal Service
residential rate was $12.90 per month. Staff contacted the Company to inquire about the
customer response to this transition. As reflected in the Company's cost analysis, some
customers are choosing to discontinue their service instead of migrating. Overall, the number of
disconnects have not had a significant impact on revenues.
Rate Change to Comply With the FCC
The proposed monthly increase in the residential Seasonal Service rate from $12.90 to
$14.00 is to comply with the FCC's Connect America Fund Order.l The monthly business rate
of $21.00 is in compliance with the FCC's Order and will not need to be adjusted. See FCC 47
CFR $ 54.318. The Company presented a cost analysis with its filing indicating the rate
adjustment will be revenue neutral. Although it is difficult to calculate the revenue impact on an
optional service for seasonal customers, Staff believes the submitted rate analysis is reasonable.
I See In the Matter of Connect America Fund; A National Broqdband Plqn for Our Future; Establishing Just and
Reasonable Rates for Local Exchange Caruiers; High-Cost Universal Service Support; Developing an Unified
Intercarrier Compensation Regime; Federal-Stqte Joint Board on Universal Serttice; Lifeline and Link-Up;
Universal Service Reform - Mobility Fund, llC Docket Nos. l0-92, 07-135, 05-337, 03-109, GN Docket No. 09-51,
CC Docket Nos. 0t-92, 86-45, WT Docket No. 10-208, Report and Order and Further Notice of Proposed Rule
Making, FCC 11-161, pp.234-241 (rel. Nov. 18,201l)
STAFF COMMENTS ocToBER 16,2013
The Company also provided Staff with a copy of the customer notices that were published in the
local newspaper on September 24 and27. Staff contacted the Company to determine if any
customers objected to the transition to Seasonal Service or the rate increase. The Company
indicated many customers are simply opting to disconnect their service instead of paying the
monthly rate increase. Again, this was reflected in the Company's cost analysis.
Non-Recurring Service Order Charge
Blackfoot proposes to implement a $25.00 service activation fee. Customers placing
their service on seasonal status will not be charged the $25.00 non-recurring fee for a one-time
activation in a l2-month period. However, the charge will be assessed each time Seasonal
Service is activated during a 12-month period following the initial activation/termination. This
fee is meant to deter repeated activations/terminations during a single year. This fee will be
waived if the customer chooses to sign up for the Company's regular local exchange service.
The proposal is reasonable and does reflect many service activation charges for the industry as a
whole.
STAFF RECOMMENDATION
Staff recommends that the Commission approve the Company's request to eliminate the
Number Reserve service, clarify terms and conditions for the Seasonal Service, implement the
$25.00 non-recurring charge as set forth above, and increase the monthly residential rate for its
Seasonal Service from $12.90 to $14.00 ($1.4Oimonth) so that the Company remains in
compliance with the FCC's $14.00 rate floor requirement. Staff believes the Company's
requested effective date of November 1,2013 is reasonable and recommends approval.
Respectfully submitted this ldl- day of october 2013.
Weldon B. Stutzman
Deputy Attorney General
Technical Staff: Carolee Hall
i:umisc:comments/fret I 3. I wsch comments
STAFF COMMENTS ocToBER 16,2013
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I6,H DAY oF OCTOBER 2013,
SERVED THE FOREGOING COMMENTS OF' THE COMMISSION STAFF, IN
CASE NO. FRE.T.13-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
MICHELLE NORBECK
FREMONT TELCOM CO
DBA FREMONT COMMUN
1221 N RUSSELL STREET
MISSOULA MT 59808
CERTIFICATE OF SERVICE