20050517Frontier comments.pdf

Citizens Communications Company Triad Center; Suite 2f)()
Salt Lake City, UT 84180
Phone: [phone]
Fax: [phone]
May 12, 2005
Ms. Jean Jewel!
Commission Secretary
IDAHO PUBLIC UTILITIES COMMISSION
472 West Washington Street
Boise, Idaho 83720
RE;Docket No. GNR- T -05-
Dear Ms. Jewell:
Enclosed please find the comments of Citizens Telecommunications Company of Idaho
d/b/a Frontier Communication of Idaho In The Matter of the Investigation of Intrastate
Presucscribed Interexchange Carrier (LPIC) Change Charges.
Should you have any questionsl please direct them to me at 924-63571 or at 4 Triad Center
Suite 200, Salt Lake City, UT 84180, email: Inao.Henninasen(OJczn.com
Sincerely~
f~enni sen~~;ger tate Government Affairs
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BEFORE THE IDAHO PUBLIC SERVICE COMMISSION
IN THE MATTER OF THE INVESTIGATION
OF INTRASTATE PRE SUBSCRIBED
INTEREXCHANGE CARRIER (LPIC) CHANGE CHARGES
CASE NO. GNR-OS..
COMMENTS & RESPONSE
TO INFORMATION
REQUEST OF CITIZENS
COMMUNICATIONS OF
IDAHO, dba FRONTIER
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COMMENTS
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Citizens Telecommunications Company of Idaho, dba Frontier CommunicationS;9f
Idaho (Frontier) believes that action by the Idaho PSC to determine newintrast~ ~::
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presubscribed interexchange carrier change charges (LPIC) to mirror interstate Rites is ; r"'l ('":"71unnecessary and should not be implemented. t" L,~.J l",~,
First, a pre-subscription rate determined by the PSC will not be applicable to Idaho
largest carrier, Qwest and will likely not long be applicable to other carriers. Qwest is
regulated under Title 62 of Idaho statutes, so its rates for LPIC are not subject to PSC
approval. It is very likely that Frontier and numerous other Idaho carriers will elect to
move to regulation under Title 62 when recently enacted changes to the statute become
effective in July. Therefore any changes implemented by this commission will not ~pply
to the vast majority of Idaho customers.
Furthermore, customers should not be confused by different charges for interstate and
intrastate carrier changes. The customer s bill will clearly indicate the separate charges
and identify them as being for change of their interstate and/or intrastate long distance
carrier. Many charges on the customer s bill are already different for intra and interstate
services. The Idaho PSC does not mirror the FCC on all charges on the customer s bill.
In many cases customers now pay a different rate for the very intrastate and interstate
long distance services that they will be asking to have changed to incur the PIC and LPIC
charges.
To mirror the Fed~ral charges, the PSC would have to reduce the LPIC charges currently
authorized. The amount of the LPIC charge is already very low and should not be a
burden to customers. In fact, in the great majority of instances the inter-exchange carrier
actually reimburses the customer for these charges, so the actual cost to the customer is
zero. On the other hand the LPIC charges do provide a source of revenue to the local
carrier Although admittedly not a large amount, the revenues from LPIC should at a
minimum recover the cost of implementing the carrier change. If there are any excess
revenues, which is not at all clear, they now contribute to covering the overall cost of
operations of the company. These lost revenues will have to be made up somewhere else
or the company s rate of return will be reduced without any showing, or even an
allegation, that current earnings are excessive. Because the amounts involved are low
companies covered by title 61 could not justify a rate proceeding before the Commission
that might be necessary to raise other rates to replace the lost revenues caused by
reducing the LPIC charges.
Finally, the FCC has now extended the implementation date of its new PIC change rates
to November 1 2005. Verizon, and Qwest have filed comments with the FCC
challenging at least some of the proposed rates. It is therefore, possible that the FCt' s
rates could change before the final implementation actually occurs. There is no ne~d for
this Commission to act now to change rates that may still not match FCC rates when
those rates become final.
F or all of the above reasons, Frontier recommends that the Idaho PSC not act to mak~.
any changes to LPIC rates at this time.
INFO~'I'ION QQtJEST
The Commission reques~ed that ILECs "provide their capabilities and actual usage levels
of electronic processing for PIC/LPIC changes.
Frontier is c~pable of electrQnically processing PIC and LPIC change-ref.iuest&.from
customer. However, for various reasons, the vast majority of reques~ ar,~ processed,
manually, as shown below
During J~nuary, 2005 F:rontier processed a total of636 PIC and lPiC changes. Of that
amount 12.1 were electronic. The remaining 515 were processed' manually.
Respectfully submitted this day of April, 2005
lng ennlngsen
M nager, State vernment Affairs
Citizens Communications of Idaho dba Frontier
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