2000719_ws2.doc

July 19, 2000

Conley Ward
Givens, Pursley LLP
277 N 6TH Street, Ste 200
PO Box 2720
Boise ID 83701-2720

Re: INL-T-99-02; Notice to the Public Regarding Proposed Rate Increase for Inland Telephone Company

Dear Conley:

While gathering information to prepare Staff testimony in Case No. INL-T-99-02, Inland Telephone Company’s case for rate rebalancing, Staff learned that the Company has not provided notice to its customers regarding its proposed rate increases. Idaho Code § 61-307 requires a public utility requesting an increase in its rates to provide at least 30 days’ notice to customers of the proposed increases. In addition, the Commission’s Telephone Customer Information Rules, IDAPA 31.41.02, set forth specific notice requirements when an increase in customer rates is proposed. Specifically, IDAPA 31.41.02.102.01 requires the public utilities to

give to each such customer a statement (customer notice) announcing the application. If the telephone company is requesting a rate increase, the customer notice shall include a brief explanation of the Company’s need for additional revenue and the dollar amount requested. The notice shall give the proposed overall percentage change from current revenue levels, and its proposed percentage increase in revenues from local rates and charges, as well as the proposed percentage increase in rates for the most commonly used residential and small business services. The customer notice shall make it clear that the application is a proposal, subject to public review and a commission decision. It shall also inform customers that a copy of the Company’s Application is available for public review at the offices of both the Commission and the Company.

Rule 102.02 requires that the notice be mailed to customers as bill stuffers, and paragraph 102.03 requires the Company to send a press release “to all newspapers and radio and television stations listed on the Commission’s news organization list for that Company.” A copy of the press release is required to be filed with the Company’s Application. Rule 102.05 states that a Company’s failure to comply with the notice requirements of paragraphs 01 through 03 can be grounds for returning an application for incompleteness.

At the least, Inland Telephone Company must comply with the notice requirements of the applicable statute and Commission Rules. As a result of the Company’s failure to comply with the notice requirements, Staff’s testimony will need to be supplemented once the notices have been provided to customers and the customers have had an opportunity to respond. If notices are sent promptly to customers, it may be possible to prevent a delay in scheduling a public hearing at a forum in Inland’s service territory.

Please contact me if you have any questions or comments.

Sincerely,

Weldon B. Stutzman
Deputy Attorney General

Vld/L:Ward_ws
Conley Ward
07/18/00
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