20030605Comments by ICC.pdf

Idaho Citizens CoalitionO. Box 190514Boise, ID 83719Telephone: [phone] or [phone]E-mail: erfothergill~qwest.net or sharonu~cableone.netBEFORE THE IDAHO PUBLIC UTILITIES COMMISSIONIN THE MATTER OF THE APPLICATIONOF QWEST CORPORATION FOR PRICEDEREGULATION OF BASIC LOCALEXCHANGE SERVICES. CASE NO. QWE- T -02-COMMENTS OF THEIDAHO CITIZENSCOALITIONComes now the Idaho Citizens Coalition ("I CC") to strongly urge the IdahoPublic Utilities Commission (the "Commission ) to reject Qwest's applicationfor deregulation of local service in seven Idaho counties.
As the Commission is aware , the purpose of public utility regulation is to guard
against price gouging by companies that have a monopoly over the provision
necessary public utility services. Although ICC is willing to concede that there
are perhaps a small percentage of telephone users who have eliminated their
ground line telephone service and have replaced it with cell phone service
Qwest still has a monopoly on the provision of ground line service.
It is the belief of ICC that cell phones primarily supplement, rather than replace
ground line telephone service for most residential and small business users.
CC' s position is supported by data from the article
, "
Fast Facts on
Telecommunications In Tennessee " which can be found on the internet at
http://www. state. tn. us/tra/telecomfiles/tcfastfacts. p df. According to
information in this article
, "
97.0% of Tennessee households had telephone
service , (national average: 97., southern region: 96.7%).It goes on to say
that
, "
50% of Tennesseans have wireless (according to industry)/mobile phones
(June 30 , 2001 , 2.3 million Tennesseans)"The article does not specify the
date it was written; however, it is obviously very recent as data cited further on
in the report has a February 28 2003 date. Although these data provide
information on Tennesseans ' rather than Idahoans ' telephone usage , it is
reasonable to assume that data for Idahoans would be similar.
COMMENTS OF ICC
CC contends that cellular service is not replacing ground line telephoneservice for the vast majority of telephone users despite the fact that many havesupplemented that ground line service with one or more cell phones for useoutside the home and for long distance calling. Can you imagine trying to run atypical" household of two parents and three kids with no telephoneextensions" around the house and only cell phone service? These samearguments would hold true for small business customers as well.CC also contends that residential and small business use of the internet andfacsimile machines has increased over the last several years , which provides anopportunity for Qwest to actually IN CREASE the number of ground linetelephone connections it services since cell phones are not adapted to theseservIces.CC also has some serious concerns about how the quality of local ground linetelephone service might suffer under deregulation. According to UniversalService To Universal Access , cg 1995 - International Research Center, found athttp://www .researchedge. com/uss/ dereg.htmlAs Local Exchange Carriers (LECs) downsize staffing to prepare for
local telephone loop competition, service problems have seemingly
increased in areas such as delayed installations , missing repair
commitments and billing problems. Of 27 states reporting LEC staff
reductions , 24 indicated an increase in service quality complaints.
The same article goes on to state that the top three complaints include:
'" 800' calls where the initial free call' turned into a billable call
operator service company practices and rates , and unauthorized
switching of long distance service ('slamming
The State of Texas deregulated local phone service in 1996. Consumers Union
in their January 2001 report "Local Telephone Deregulation
" -
http://www. consumersunion. org/pdf/ swro/T elephone. p df - indicates that rates
have consistently increased for customers since that time. According to the
same Consumers Union article , the most active growing market is for pre-paid
local service. These services target low income residents with problem credit
or those without social security numbers.
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Consumers Union found that nearly three quarters of the companiesproviding residential service in six large Texas metropolitan areasprovide service to customers in this segment only. By acceptingcustomers rej ected from the monopoly phone company, these companiesare not actually competing on price.Another troubling concern to I CC is whether consumers who switched localproviders would be able to maintain their same telephone number. Thepossibility of losing a well-established telephone number is likely to causemany residential and business telephone customers not to switch to a companywith lower rates , which effectively ensures that Qwest's monopoly wouldremain in place.Based on the history of deregulation in local ground line telephone service andthe arguments set forth above , the Idaho Citizens Coalition strongly encouragesthe Commission to rej ect Qwest' s proposal for deregulation in seven Idahocounties.Dated: June 5 , 2003 Respectfully submitted via e-mailby Emilie Fothergilland Sharon Ullman
on behalf of the Idaho Citizens Coalition
COMMENTS OF ICC