20030321Comments.pdf

Jean Jewell
/~IO)
From:
Sent:
To:
Subject:
Ed Howell
Friday, March 21 200312:33 PM
Jean Jewell; Ed Howell; Gene Fadness; Tanya Clark
Comment acknowledgement
WWW Form Submission:
Friday, March 21, 2003
12: 33: 16
Case: QWE-T-02-25
Name: Clyde Dailey
Street Address: 3080 Gentry Way, Suite 100
City: Meridian
State: ID
ZIP: 83642-3599
Home Telephone: [phone]E-Mail: cdailey0aarp. org
Company: Qwest
mailing list yes no: no
Comment = descriptIon:
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF QWEST CORPORATION FOR DEREGULATION OF BASIC LOCAL
EXCHANGE RATES IN ITS BOISE, NAMPA, CALDWELL, MERIDIAN, TWIN FALLS, IDAHO FALLS, AND
POCATELLO EXCHANGES.
Case No. QWE-T-02-
AARP Comments in Opposition to Qwest Application
INTRODUCTION
AARP files these comments pursuant to the Commission s Notice of Application and Notice of
Right to Intervene issued December 17, 2002. The Notice allows those who desire to
present their views without intervening in the proceeding the opportunity to "present
their comments without prior notification to the Commission or the parties.Thus, AARP
submits these comments in opposition to Qwest's Application to deregulate basic localtelephone rates.
AARP is the nation s leading organization for people age 50 and older. It serves their
needs and interests through information, education, advocacy, and community services,
which are provided by a network of local chapters and experienced volunteers throughoutthe country. The Association s membership has a vested interest in the
telecommunications services marketplace. AARP has over 145,000 members in Idaho,
virtually all of whom receive basic local telephone service and many of whom live in thepotentially affected exchanges. Basic local telephone service is essential for all
people, particularly older people, and consumers must be able to rely upon the
availability of affordable and high-quality telecommunications services. For these
reasons, we thank the Commission for giving the public an opportunity to comment on this
very important matter.
DISCUSSION
AARP urges the Commission to proceed cautiously and perform a rigorous review of the
Company s Application. The stakes in this proceeding are too high to do otherwise.
Absent true competition in the local telephone marketplace, approval of the companypeti tion would inevitably lead to higher rates for basic local phone service and allow
Qwest to secure a monopoly of the local telephone market. While Qwest states that
wireless phone service now provides sufficient competition to basic local exchange service
to warrant deregulation , AARP is concerned that a move to deregulation at this time wouldbe premature. Qwest' s Application places the availability and affordabili ty of this
essential service at significant risk. If granted, the Company would have the power to
raise basic local telephone rates at will.
Idaho Code ~61-602 (3) directs the Commission, in its deliberation of deregulation of an
incumbent telephone company, to "examine the impact such deregulation will have on the
public interest in accordance with the general grant of authority given to the Commissionby the legislature.In addition, in order to justify a request for deregulation, the
incumbent provider must also show that effective competition exists. Idaho Code ~62-622(3) (b) states that effective competition equates to the existence of functionally
equivalent, competitively priced local services reasonably available to both residential
and small business customers from a telephone corporation unaffiliated with the incumbenttelephone corporation.
However, Qwest's filing does not fully satisfy this test because it does not acknowledge
or address several key issues. The inability to take one s current wireless telephone
number to a new wireless carrier (number portability), high fees for breaking contracts,barriers to entry (such as limited spectrum bandwidth), different technology standards
(wireless service employs different technologies from the traditional local and longdistance phone networks), and the absence of consumer protection rules speci fic to
wireless service providers may prevent consumers from fully enj oying competition despite
the preliminary inroads the service has made into the marketplace. Also, the potential
for market share dominance by two or three top wireless carriers may eventually reduce the
total number of choices consumers have in the wireless market.
Moreover , findings from a recent national AARP survey of consumers ' experience with
wireless phone service suggest that reasons for subscribing to wireless phone services
tend to vary according to the consumer s age. While younger subscribers often report that
wireless is most valuable because of the convenience it affords them, older subscribers
are more likely to say they purchase it for security in case of an emergency. The cost
for wireless service can also vary significantly depending upon the calling plan selected,
with each plan including a variety of fees and charges. In addition, calling plans can
vary by quality of service, which is determined by a number of factors. These include the
network capacity, the type of network and technology used by the provider, and the number
and placement of wireless towers. Buildings and other structures, mountains and other
geography, and even inclement weather, which can all deflect or block radio signals, also
may cause poor reception for wireless users. One of the best ways to assess the quality
of service coverage in the mobile phone industry would be to review customer complaints.
However, no federal or state agency is currently required to undertake customer
satisfaction surveys with regard to mobile telephone service, and even the data that is
available from the Federal Communications Commission is not broken down by carrier.
Thus, AARP urges the Commission to take all of these issues into consideration in its
decision making process. The current state of the wireless industry does not make it a
true substitute for wireline telephone service. Contrary to the Qwest' s contentions,
competition from wireless service simply has not risen to the level necessitating the
total deregulation of basic local telephone rates at this time.
CONCLUSION
AARP appreciates this opportunity to comment on this critical issue. For the reasons
stated above, AARP opposes Qwest' s proposal to deregulate basic local telephone rates in
the seven Idaho exchanges presented in the Company s Application. Thus, we urge the
Commission to reject the Company s proposal because, above all else, it stands to
adversely impact the public interest.
Dated: March 21, 2003 Respectfully submitted,
Clyde Dailey
State Director
AARP Idaho
3080 Gentry Way
Suite 100
Jean Jewell
j~~O3
,if'
From:
Sent:
To:
Subject:
Ed Howell
Thursday, March 20, 2003 8:51 PM
Jean Jewell; Ed Howell; Gene Fadness; Tanya Clark
Comment acknowledgement
WWW Form Submission:
Thursday, March 20, 2003
8:50:48 PM
Case: QWE-T-02-
Name: Dale Wocicki
Street Address: 612 E Antigua Dr
City: Meridian
State: Id
ZIP: 83642
Home Telephone: [phone]
E-Mail: dwocic0qwest. net
Company: Qwest
mailing list yes no: no
Comment=descriptIon: I am a 30 year employee of Mt. Bell/US West/Qwest. I have seen to
business go from a true monopoly to many choices. As the telecommunications world haschanged so has the competi ti ve environment. From no competition to 7 or more choices for
local service. I feel with as many choices as consumers now have that it is only fair
Qwest be removed from local price regulation as none of the competitors as subj ected
the same regulation. The marketplace will decide a fair price for local service.
Regulating the prices of only one company very well may cost the company jobs as well. If
there are fewer customers there obviously will be fewer jobs. Thank you for yourconsideration
Transaction ID: 3202050.
Referred by: http: / /www.puc. state. id. us/ scripts/polyform. dll/ ipucUser Address: 63.227.246.User Hostname: 63.227.246.