20030312Application.pdf

nECEIVED f71L"..I
Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ID 83702
Telephone: [phone]
Facsimile: [phone]
msho bson~stoel.com
F!LED L".-
znn3r;,!;R ! 2 PH 5: 04
UTILITieS COt~jl"1!SSION
Adam L. Sherr (WSBA #25291)
Qwest
1600 7th Avenue - Room 3206
Seattle, W A 98191
Telephone: [phone]
Facsimile: [phone]
asherr~qwest.com
Attorneys for Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF QWEST
CORPORATION'S PROPOSAL TO PHASE
OUT BOISE AND POCATELLO CUSTOMER
PAYMENT CENTERS
Case. No. QWE-
APPLICATION OF QWEST CORPORATION
FOR AUTHORITY TO PHASE OUT BOISE
AND POCA TELLO CUSTOMER PAYMENT
CENTERS AND REQUEST FOR MODIFIED
PROCEDURE
Qwest Corporation ("Qwest" or the "Company ), by and through its undersigned
attorneys, requests authority from the Commission pursuant to IDAP 31.01.01.052 to phase out
its two remaining Customer Payment Centers ("CPCs ), located in Boise and Pocatello, Idaho.
Phasing out the CPCs would permit Qwest to operate more efficiently and cost-effectively and
would not adversely impact the public interest. Qwest requests that the Commission consider
this proposal on modified procedure pursuant to IDAP A 31.01.01.201-204.
APPLICATION OF QWEST CORPORATION - Page 1
Boise-154220.10029164-00012
INTRODUCTION
Qwest operates only two CPCs in its 14-state region. One is located at 999 Main
in Boise (the "Boise CPC"). The other is located at 455 W. Lewis in Pocatello (the "Pocatello
CPC"). Historically, Qwest's predecessors ran additional CPCs throughout their service
territory. While the Company phased out its other CPCs long ago, the Commission did not
permit the Company to close the Boise CPC and the Pocatello CPC when it attempted to do so
thirteen years ago.
In 1990, the Company, as part of a regionwide restructuring, filed a proposal with
the Commission to combine its residential marketing centers and its collection management
centers. 1 One component of this plan was to close the Boise and the Pocatello CPCs. This raised
concerns with the Commission. At the time, the Company s customers primarily had four
payment options: payment by mail; payment at a CPC; payment at an outside payment agent
location ("PAL"); or direct/automatic payment. In Order No. 23179, the Commission ordered
that the Company continue to operate the CPCs pending the creation of a record sufficient to
allow the Commission to determine whether PALs could provide service equal to that provided
by the CPCs. In September 1990, the Commission entered Order No. 23350, which approved an
agreement between the Company and Commission Staff for a comprehensive monitoring plan.
That plan required the Company to, on a daily basis, manually track the number of payments
processed by CPC tellers and PAL agents, the number of payments placed in external CPC drop
boxes, the number of payments placed in internal CPC drop boxes, the number of payments
delivered to CPC tellers by other company employees (e., service representatives and credit
managers), the types and numbers of customer questions, requests for telephone books, service-
In the Matter of the Investigation into Restructuring of Residence Service Centers Operated by Mountain
States Telephone and Telegraph Company d/b/a US WEST Communications, Inc.Case No. MTB- T -90-
APPLICATION OF QWEST CORPORATION - Page 2
Boise-154220.10029164-00012
related complaints and services for special needs customers. The daily tally sheets tracking all
the specified data were to be delivered to the Commission Staff each month. According to the
monitoring plan, after a three-month period of data collection was completed, a neutral third
party was to conduct a survey of customers using the CPCs and the PALs to assess the level of
customer satisfaction with each type of entity. Following completion of the survey, both the
Company and Commission Staff were to submit reports to the Commission to assess, among
other things, whether the CPCs could be closed.
The data tracking and reporting requirements proved to be extremely burdensome.
In early 1991 , just two months after the data monitoring plan had been implemented, the
Company requested permission from the Commission to stop tracking the required data on a
daily basis. The Company indicated it would continue to track and report the gross number of
payments made at the CPCs and PALs on a monthly basis. It also indicated that, if it in the
future sought to close the CPCs, it would provide six months of data consistent with its previous
obligations. The Commission agreed.2 In 1997, the Commission agreed that the Company could
stop tracking and reporting data on the CPCs altogether, but again indicated that if the Company
sought to close the CPCs, all previous requirements would be re-implemented.
Qwest acknowledges that it has not tracked the previously-required data of the
type or in the level of detail earlier required by the Commission. It submits that to do so would
be onerous. More importantly, doing so is unnecessary given the stark differences between 1990
and 2003 in terms of the many additional modes of payment available to Qwest customers and
the steep decline in the use of the CPCs by Qwest customers. Qwest asks that the Commission
waive its data collection mandates from the prior case, which took place in an entirely different
Order No. 23483 Case No. MTB-90-1 (January 1991).
APPLICATION OF QWEST CORPORATION - Page 3
Boise-154220.10029164-00012
era, under completely different circumstances, and permit Qwest the flexibility it needs to
operate its business in an efficient, cost-effective manner.
QWEST'PROPOSAL
Qwest proposes to phase out the CPCs over a 90-day period beginning May 1
2003. Qwest will distribute notices in the CPCs beginning May 1 2003 in the forms attached
hereto as Exhibit A (Boise) and Exhibit B (Pocatello). Qwest invites the Commission s input
into the form and contents of the proposed notices. The notices will advise customers that the
CPCs will be closing as ofthe end of July 2003 and will delineate each of Qwest's payment
options. They will also provide customers web site links and telephone numbers to assist CPC
users in learning about the many alternative payment options at their disposal. By providing
these notices, CPC customers will have at minimum two (and up to three) full billing cycles to
adjust how they tender their payments to Qwest.
FACTS SUPPORTING QWEST'PROPOSAL TO PHASE OUT THE CPCS
The CPCs are not cost-effective. Processing payments via the CPCs is grossly
inefficient, costing the Company over $211 000 per year.3 On a per-payment basis, the average
cost4 of processing a payment through the Pocatello CPC is $2.27 and through the Boise CPC is
$3.00. This is compared to only $0.11 for processing a payment made through the mail. In these
very difficult economic times, and given the multitude of payment options available to Qwest
customers, this disparate expense is not justified.
Use of the CPCs has declined sharply in recent years. Fewer and fewer customer
payments are processed by tellers through the CPCs. The number of payments processed by
This estimate is actually quite low, as it includes only labor and security costs for the two CPCs. It does
not include real property costs or the cost of utilities, equipment or supplies.4 Again, this includes only labor and security costs.
APPLICATION OF QWEST CORPORATION - Page 4
Boise-154220.10029164-00012
tellers has decreased by 38% since 1996, from a total of 112 820 in 1996 to 70 126 in 2002.5 By
comparison, use of the non-Qwest PALs has increased by 156%, from 91 369 in 1996 to 234 316
in 2002.6 Because the cost of operating the CPCs is largely fixed, this sharp decrease in usage
causes continued operation of the CPCs to be increasingly less cost-effective. Despite the high
cost of operating the CPCs, teller-processed payments constitute only 1.43% of the total number
of payments processed for Idaho customers in 2002 and less than .005% of the total number of
payments processed for Qwest customers regionwide in 2002.
Payment by mail and at PALs are still available and popular. As in 1990
payment by mail remains the most common method of customer payment, with 84% ofidaho
Qwest payments being made by mail. To a much greater degree than in 1990, PALs exist in
many Idaho locations. PALs are non-Qwest businesses that agree to receive Qwest payments
from Qwest costumers. There were only 11 PALs in Idaho in December 1990. Today, however
there are a total of 58 free PALs in Idaho , including 8 in Boise7 and 3 in Pocatello.8 These PALs
generally have longer customer hours than do the CPCs.9 Customers may find the nearest PAL
by simply entering the city, state or zip code on Qwest's website.10 Qwest customers using the
In late 1990, the CPC tellers processed an average of7 615 payments per month. If this average number is
annualized, it appears that in 1990, the CPC tellers processed approximately 91 380 payments, some 30% more than
were processed in 2002.
In late 1990, non-Qwest PALs averaged only 2 837 payments per month. If this average number is
annualized, it appears that in 1990, the PALs processed only about 34 000 payments, less than one-sixth of what
they processed in 2002.
The Boise PALs include All Makes Vacuums (615 N. Orchard), Boise Box Office (111 Broadway, Suite
133), Mr. Payroll (6350 Fairview), Ship N Check (8469 W. Franklin) and four locations of Singers Insta Cash (8411
Fairview; 6942 W. State; 111 Broadway, Suite 101; and 8618 West Overland). A ninth Boise location is currently
being negotiated.
The Pocatello PALs include R Place (245 Riverside Ct), Ridley s (911 N. Main) and Super Save Drug (701
East Center).
The Boise CPC is open Monday-Friday 8:30 to 5:00; the Pocatello CPC is open Monday-Friday 9:00-5:00.
Ten of the eleven PALs in Boise and Pocatello have weekend hours. Many take payments at night as well. The
hours of operation of the Boise and Pocatello PALs are provided in the flyers attached as Exhibits A and B to this
Application.10 The steps for getting from the qwestcom home page to the PAL query tool are described on the flyers
attached as Exhibits A and B to this Application.
APPLICATION OF QWEST CORPORATION - Page 5
Boise-154220.10029164-00012
Boise or Pocatello PALs identified in footnotes 7 and 8 pay no additional fees or charges than
they would had they made payment at a Cpc.
PALs offer customers more choices and functionality than they were able to in
1990. In 1990, payments made at PALs were simply aggregated and forwarded by mail to
Qwest's billing centers. Today, Qwest's PAL vendor electronically uploads payment
information from each of the PALs and transmits that information to Qwest four times each
business day. In the 1990 docket, the Commission indicated some concern that PALs alone were
insufficient since they did not possess direct access to Qwest's billing systems. As such , the
Commission indicated that customers facing disconnection due to late payment would not be
able to avoid disconnection by visiting a PAL to make payment. This is no longer the case, as
Qwest electronically receives notice ofF AL payments four times a day. Once record of a
customer payment is transmitted to Qwest, the customer s account is instantly noted to prevent
,disconnection. 11 In addition, unlike in 1990, there are a number of alternative methods now
available to Qwest customers that can be used to make instant payment to avoid service
interruption. These are discussed in paragraph 10 below. In the 1990 docket, the Commission
also raised as a concern that cash payments might not be allowed at PALs, while they were at the
CPCs. The Commission believed this difference unreasonably limited the choices available to
the Company s customers. This is no longer a concern, as the PALs now accept cash in addition
to other forms of payments.
10.Customers now have many additional methods of payment at their disposal.
Qwest's Idaho customers have a multitude of alternative payment options in addition to paying
by mail or at one of the 58 free PALs in the state. Customers, as they could in 1990, may
APPLICATION OF QWEST CORPORATION - Page 6
Boise-154220.10029164-00012
arrange with Qwest for direct/automatic withdrawal from their bank accounts.12 Customers may
provide a debit card, credit card or a check routing number to a Qwest billing representative over
the telephone. 13 They may also provide a check routing number or credit card number through
an automatic Interactive Voice Response Unit ("IVRU") system over the telephone. 14 Qwest
customers may also pay by debit card, credit card or check over the Internet.15 Each of these
methods provides the advantage of instant payment without the time associated with having to
visit a CPC or PAL. The payment methods available to Qwest customers are described on
Qwest's website.
11.Qwest offers assistance to customers with special needs. Another concern
expressed by Commission Staff and other intervenors in 1990 was the role CPCs could play in
assisting the Company s customers with special needs. Once again, Qwest is much better
situated today to deal with these issues and Qwest provides several products and services to
assist persons with disabilities with their telecommunications needs. Qwest operates a Special
Needs Center ("Center ) to assist persons with disabilities. The Center l7 responsibilities
include: (a) handling service and sales issues related to the disabled community; (b) applying
and following up on those accounts that are exempt from directory assistance charges because of
Additionally, if a Qwest customer is extremely concerned that his or her service may get disconnected, the
customer may immediately telephone Qwest with the receipt number provided by the PAL. This too will prevent
interruption of service.12 Approximately 700 000 Qwest customers regionwide use this automatic payment method.
This method of payment was fITSt available in 1997, the same year that Qwest switched to its current PAL
vendor. The increase in the number of customer payment options and the number of available PALs has no doubt
led to the decline in the use of the CPCs, as described in paragraph 7 above.14 Over one million IVRU payments were made by Qwest customers regionwide in 2002.
Qwest is working to expand the capabilities of its IVRU system and its Internet payment tool to pennit
payment at times when the Qwest business office is not operating. This advance will allow even greater flexibility
to customers.16 The steps for getting from the qwestcom home page to the payment options screen are described on the
flyers attached as Exhibits A and B to this Application.17 Voice and TDD calls to the Center can be made to 1-800-223-3131. Faxes to the Center can be sent to 1-
505-765-8203.
APPLICATION OF QWEST CORPORATION - Page 7
Boise-154220.10029164-00012
a verified disability; (c) applying and following up on those accounts that are TTY/TTD
discounted for intra-LATA calling; and (d) serving as a point of contact for customers using Text
Telephone Relay/Telecommunications Device for the Deaf. The Center can also, when
requested, provide bills in Braille, in large font, in audio format (recorded to a tape and mailed to
the customer) and via email (to be translated by a "talking modem
12.The Idaho telecommunications market has shifted from monopoly to competition
In 1990, when the Commission addressed the closure of the two CPCs in Idaho, Qwest's
predecessor was essentially the only provider of local exchange services for residence and small
business customers. Passage of the federal Telecommunications Act of 1996 was still years in
the future and the familiar methods of gaining competitive entry in the local markets (i., resale
interconnection, collocation, and the purchase of unbundled network elements) were virtually
unheard of. Deployment of cellular technology for voice communications was in its infancy. At
that time, both the Commission and the local exchange customers had a different relationship
with the company that is now Qwest.
13.The reality of 2003 is much different. The pervasive rate regulation of the
monopoly era has largely transitioned into a role of regulatory oversight focused largely on the
implementation of the 1996 Act. Recently, this Commission confirmed to the FCC that Qwest
had successfully opened its markets in Idaho as required under the 1996 Act.
The Idaho legislature has also recognized these changes in the environment and enacted a
number of statutory provisions including, in 1997, Idaho Code 9 62-622(5) which provides that
the Commission shall determine the "noneconomic regulatory requirements" for all telephone
corporations providing basic local exchange service. The Commission s 1990 decision to
require Qwest's predecessor to maintain the Boise and Pocatello CPCs has not been extended to
18 TTY ITID" is a telecommunications evice for the deaf over teletypewriter technology.
APPLICATION OF QWEST CORPORATION - Page 8
Boise-154220.10029164-00012
competitive providers or adopted as a rule of general applicability for local exchange companies
or companies designated as eligible telecommunications carriers under Idaho Code 9 62-610A
through F. Any continuing mandate by the Commission that Qwest operate the CPCs would
stand at odds with the statutory and market realities of the present day. Such a mandate would
also serve to put Qwest at the competitive disadvantage of continuing to incur the costs of
operating the CPCs when they are no longer necessary in Qwest's business judgment and are not
required of competing carriers.
REQUEST FOR MODIFIED PROCEDURE
14.Qwest respectfully requests that the Commission consider this application under
the modified procedure provisions (Rules 201 through 204) ofIDAPA 31.01.01. Qwest believes
that it has provided ample facts to support a preliminary finding under Rule 201 that the public
interest may not require a hearing to consider the issues presented in this application. Qwest
suggests that a three-week comment cycle would be appropriate and sufficient. Qwest will post
a copy of the Commission s notice regarding the modified procedure in the CPCs to facilitate
comments from users of the CPCs.
CONCLUSION AND PRAYER FOR RELIEF
15.Customer service is of central importance to Qwest, as is ensuring that Qwest's
customers are able to pay their bills and that Qwest is able to operate as cost-effectively as
possible. Unlike in 1990, Qwest customers now have at their disposal a myriad of payment
options other than remitting their payments by mail or visiting a CPC. Qwest offers customers a
variety of instant, economical alternatives, including payment by phone or over the Internet. For
those customers desiring to pay in cash or in person, 58 free PALs exist in the state as of the date
of this application. Others are likely to be added if the CPCs are closed. Qwest's proposal
APPLICATION OF QWEST CORPORATION - Page 9
Boise-154220.10029164-00012
would ensure a smooth transition for those Qwest customers still accustomed to visiting the
Boise or Pocatello CPCs to make payment. As such, the Commission should approve this
proposal expeditiously.
WHEREFORE, Qwest respectfully requests that this Commission enter an order, on
modified procedure, approving Qwest's proposal to phase out the Boise CPC and the Pocatello
CPC over a period of90 days after entry of the Commission s order.
Submitted this 12th day of March, 2003.
Qwest Corporation
vt~~Jf~
Mary S. bson
Stoel Rives LLP
Adam L. Sherr
Qwest
Attorneys for Qwest Corporation
APPLICATION OF QWEST CORPORA nON - Page 10
Boise-154220.10029164-00012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 1th day of March, 2003 , the foregoing
APPLICATION OF QWEST CORPORATION FOR AUTHORITY TO PHASE OUT BOISE
AND POCA TELLO CUSTOMER PAYMENT CENTERS AND REQUEST FOR MODIFIED
PROCEDURE was served upon the following parties:
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ill 83720-0074
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
~~~
Brandi L. Gearhart, PLS
Legal Secretary to Mary S. Hobson
Stoel Rives LLP
APPLICATION OF QWEST CORPORATION - Page 11
Boise-154220.10029164-00012
QWEST CUSTOMER NOTICE
PAYMENT CENTER CLOSURE
EFFECTIVE JUNE 30. 2003
THE BOISE PAYMENT CENTER WILL BE CLOSED
Qwest values our customers and wants you to know there
are many options available for making payments on your
Qwest account:
. Sign up for Automatic Payment
. Pay by Credit Card over the Internet or by telephone
(MasterCard, Visa or Discover)
. Pay by check over the nternet or by telephone
. Pay by mail
Visit a Walk-In Payment Location
(see reverse for payment locations in Boise)
Additional information on payment options can be found on our website:
www.qwestcom. Follow these steps:
RESIDENTIAL
. Click "Residential"
. Enter Area Code and Prefix
. Click "Continue
. Click "Manage Your Account"
SMALL BUSINESS
. Click "Small Business
. Select state (Idaho)
. Click "Manage Your Account"
Residential Billing Inquiries:
1 800 244 1111
Small Business Billing Inquiries:
1 800 603 6000
Qwest.
Spirit of Service
BOISE
WALK-IN PAYMENT LOCATIONS
ALL MAKES VACUUM
615 N Orchard
BOISE BOX OFFICE
111 Broadway
SINGERS INST A CASH #3
6942 State St
SINGERS INST A CASH #4
111 Broadway Ave Ste 101
F 9 am - 530 pm
SA 9 am - 4 pm
F 9 am - 6 pm
SA 10 am - 2 pm
F 10 am - 7 pm
SA 10 am - 5 pm
F 10 am - 6 pm
SA 10 am - 2 pm
F 10 am - 7 pm
SA 10 am - 3 pm
F 10 am - 6 pm
MR PAYROLL
6350 Fairview
SHIP N CHECK
8649 Franklin Rd 83709
SINGERS INST A CASH #2
8411 Fairview Ave
F 10 am - 7 pm
SA 10 am - 3 pm
SINGERS INST A CASH #8
8618 W Overland
F 10 am - 7 pm
SA 10 am - 3 pm
Additional walk-in payment locations can be found on our website:
www.qwestcom. Follow these steps:
RESIDENTIAL SMALL BUSINESS
. Click "Residential" . Click "Small Business
. Enter Area Code and Prefix . Select state (Idaho)
. Click "Continue . Click "Manage Your Account"
. Click "Manage Your Account" . Click "View Other Payment Options
. Click "View Other Payment Options . Click "Pay at a Walk-In Payment
. Click "Pay at a Walk-In Payment Location" then follow prompts
Location" then follow prompts
Residential Billing Inquiries:
1 800 244 1111
Small Business Billing Inquiries:
1 800 603 6000
Qwest.
Spirit of Service
QWEST CUSTOMER NOTICE
PAYMENT CENTER CLOSURE
EFFECTIVE JUNE 30. 2003 , THE POCATELLO
PAYMENT CENTER WILL BE CLOSED
Owest values our customers and wants you to know there
are many options available for making payments on your
Owest account:
. Sign up for Automatic Payment
. Pay by Credit Card over the Internet or by telephone
(MasterCard, Visa or Discover)
. Pay by check over the nternet or by telephone
. Pay by mail
Visit a Walk-In Payment Location
(see reverse for payment locations in Pocatello)
Additional information on payment options can be found on our website:
www.qwestcom. Follow these steps:
RESIDENTIAL
. Click "Residential"
. Enter Area Code and Prefix
. Click "Continue
. Click "Manage Your Account"
SMALL BUSINESS
. Click "Small Business
. Select state (Idaho)
. Click "Manage Your Account"
Residential Billing Inquiries:
1 800 244 1111
Small Business Billing Inquiries:
1 800 603 6000
Qwest.
Spirit of Service
POCA TELLO
WALK-IN PAYMENT LOCATIONS
R PLACE
245 Riverside Ct
RIDLEY'
911 N Main St
SUPER SAVE DRUG
701 E Center
HOURS
SU-TH 6 am - 10 pm
SA 7 am - 11 pm
DAILY 7 am -11 pm
F 9 am - 9
SA 9 am - 5 pm
SU 11 am - 5 pm
Additional walk-in payment locations can be found on our website:
www.qwest.com. Follow these steps:
RESIDENTIAL
. Click "Residential"
. Enter Area Code and Prefix
. Click "Continue
. Click "Manage Your Account"
. Click "View Other Payment Options
. Click "Pay at a Walk-In Payment
Location" then follow prompts
Residential Billing Inquiries:
1 800 244 1111
SMAll BUSINESS
. Click "Small Business
. Select state (Idaho)
. Click "Manage Your Account"
. Click "View Other Payment Options
. Click "Pay at a Walk-In Payment
Location" then follow prompts
Small Business Billing Inquiries:
1 800 603 6000
Qwest
Spirit of Service