20030409Order No 29218 Notice of Application.pdf

Office of the Secretary
Service Date
April 9, 2003
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
QWEST CORPORATION TO PHASE OUT AND)
CLOSE THE BOISE AND POCA TELLO
CUSTOMER PAYMENT CENTERS.
CASE NO. QWE-O3-
NOTICE OF APPLICATION
NOTICE OF MODIFIED
PROCED URE
ORDER NO. 29218
On March 12, 2003 , Qwest Corporation filed an Application to close its two
remaining customer payment centers (CPCs) located in Boise and Pocatello. Qwest maintains
that continued operation of these two payment centers is not cost-effective and the closures
would not adversely affect the public interest. The Company has requested that the Commission
process its Application via Modified Procedure.
BACKGROUND
As part of a region-wide restructuring, Qwest's predecessor (U S WEST
Communications) filed a proposal to consolidate several of its residential marketing and
collection centers. This plan included a proposal to close the Boise and Pocatello payment
centers. In Order No. 23179 issued in June 1990, the Commission ordered U S WEST to
continue operating the payment centers until the Commission could subsequently determine
whether the use of alternative payment agent locations (PALs) could provide service equivalent
to that provided by the CPCs. The Company now proposes to close these two CPCs.
NOTICE OF APPLICATION
YOU ARE HEREBY NOTIFIED that Qwest asserts that the only remaining payment
centers in its 14-state region are the Boise and Pocatello CPCs. Application at 2. Qwest
proposes to phase out the two remaining payment centers over "a 90-day period beginning
May 1 , 2003.Id. at 4. If the Commission approves the closure of the payment centers, then the
Company will post notices advising CPC customers that the centers "will be closing as of the end
NOTICE OF APPLICATION
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 29218
of July 2003.1 The Company also maintains that the notices will provide customers with
information about website links and telephone numbers so that payment center customers can
learn about the many alternative payment options at their disposal. Id. at 4. The Boise and
Pocatello notices also identify the eight Boise "walk-" payment agents and the three Pocatello
walk-" payment agents.
YOU ARE FURTHER NOTIFIED that Qwest lists three primary reasons why it
desires to close the two remaining payment centers. First, the Company insists that the payment
centers are "grossly inefficient, costing the Company over $211 000 per year.Id. at 4. This
figure does not include the cost of renting space and utilities. On a per payment basis, the
Company estimates that the average cost of processing a payment through the Pocatello and
Boise centers are $2.27 and $3., respectively. These costs compare to the cost of processing a
payment made through the mail at only $0.11. Id.
Second, the Company insists that usage of the payment centers has declined sharply
in recent years. "The number of payments processed by tellers has decreased by 38% since
1996, from a total of 112 820 in 1996 to 70 126 in 2002.Id. at 5 (footnotes omitted). By
comparison, the Company maintains that the use of its payment agent locations (PALs) has
increased by 156%, from 91 369 in 1996 to 234 316 in 2002. The Company maintains that the
two CPCs only process 1.43% of the total number of payments made by Idaho customers in
2002. Id.
Third, customers may still choose from an array of payment options. The Company
notes that the most common method of payment is by mail, which is used by 84% of Idaho
customers. In addition to mail payments, the Company maintains 58 PALs in Idaho including 8
in Boise and 3 in Pocatello. The Application states that information about the nearest PAL is
obtainable by entering the city, state or zip code on Qwest's website (www.qwest.com). There is
no fee or charge for using payment agents. In addition, Qwest's PAL vendors electronically
upload payment information four times each business day. Thus, the Company insists that
customer accounts are updated to avoid disconnection in those cases where disconnection
pending.
1 However, the proposed notices attached as Exhibits A and B to the Application state that the payment centers will
be closed effective June 30, 2003. In other words, the payment centers would be closed in 60 days after the notices
are distributed "beginning May 1 2003." Application at 4.
NOTICE OF APPLICATION
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 29218
YOU ARE FURTHER NOTIFIED that the Application maintains that customers may
also arrange with Qwest for direct/automatic withdrawals from their checking account or pay by
credit card, debit card or a check routing number when speaking to a Qwest billing
representative. In addition to communications with billing representatives, customers may also
use Qwest's "interactive voice response unit" to provide for automated payment via check
routing number or credit card. Finally, Qwest says that customers may pay via debit card, credit
card or check over the Internet.
YOU ARE FURTHER NOTIFIED that the Application also addresses customers
with special needs. Qwest operates a special needs call center to assist persons with disabilities
with their telecommunications needs. Id. at 7. The center handles:
Service and sales issues related to the disabled;
Follows up on those accounts that are exempt from directory assistance
charges because of a verified disability;
Follows up on those accounts that are TDY/TDD discounted for intra-
LATA calling, and;
Serves as a point of contact for customers USIng text telephone
relay/TDD apparatus.
The center also has the capability when requested to provide bills in brail, in large fonts, in audio
format, and via e-mail (to be translated by a "talking modem
YOU ARE FURTHER NOTIFIED that given the availability of competitive local
exchange companies, Qwest asserts in its Application that requiring Qwest to maintain its two
payment centers would place it at a competitive disadvantage when competitors are not required
to maintain payment centers.
WAIVER REQUEST
YOU ARE FURTHER NOTIFIED that for several years, Qwest tracked and reported
the monthly number of payments made at the two payment centers and PALs. As set out in its
Application, the Company discontinued collecting data in 1997 with the Commission s approval.
However, the Commission at that time required that if Qwest sought to close the payment
centers, then all previous tracking data requirements would be re-implemented. Order No 23596
at 3-4; Letter to Qwest Idaho Vice President (April 30, 1997). This data included: (1) the
NOTICE OF APPLICATION
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 29218
number of payments processed by payment center tellers and PAL agents; (2) the number of
payments placed in external drop boxes; (3) the number of payments placed in internal drop
boxes; (4) the number of payments received by other company employees and delivered to the
payment centers; (5) the type and scope of customer questions received at the CPCs; (6) the
number of requests for telephone books, service related complaints, and requests from special
need customers.
YOU ARE FURTHER NOTIFIED that despite the requirement to submit tracking
data with this Application to close the two remaining payment offices, Qwest acknowledges that
its Application does not contain the required tracking data. Application at 3. Qwest states that
requiring it to submit the data "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.!d. Accordingly, Qwest requested that the Commission "waive its data collection
mandates from the prior case.
NOTICE OF MODIFIED PROCEDURE
YOU ARE FURTHER NOTIFIED that the Commission has determined that the
public interest may not require a formal hearing in this matter and will proceed under Modified
Procedure pursuant to Rules 201 through 204 of the Idaho Public Utilities Commission s Rules
of Procedure, IDAPA 31.01.01.201 through-204.
YOU ARE FURTHER NOTIFIED that any person desiring to state a position on this
Application may file a written comment in support or opposition with the Commission within
twenty-eight (28) days from the service date of this Order. The comment must contain a
statement of reasons supporting the comment. Persons desiring a hearing must specifically
request a hearing in their written comments. Written comments concerning this application may
be mailed to the Commission and the Applicant at the addresses reflected below:
NOTICE OF APPLICATION
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 29218
COMMISSION SECRETARY
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
ADAM L. SHERR
QWEST CORPORATION
1600 7TH AVENUE, ROOM 3206
SEATTLE, WA 98191
E-mail: asheIT~qwest.com
Street Address for Express Mail:
472 WWASHINGTON ST
BOISE, ID 83702-5983
SUSAN MOHR
REGULATORY AFFAIRS MANAGER
QWEST CORPORATION
PO BOX 7888
BOISE, ID 83723-7888
E-mail: smohr~qwest.com
All comments should contain the case caption and case number shown on ~he first page of this
document.Persons desiring to submit comments via e-mail may do so by accessing the
Commission s home page located at www.puc.state.id.. Click the "Comments and Questions
icon, and complete the comment form, using the case number as it appears on the front of this
document. These comments must also be sent to the Applicant at the e-mail addressees) listed
above.
YOU ARE FURTHER NOTIFIED that the Application and exhibits can be reviewed
at the Commission office and may be viewed on the Commission s Web site at
www.puc.state.id.under the "File Room" icon.
YOU ARE FURTHER NOTIFIED that if no written comments or protests are
received within the time limit set, the Commission will consider this matter on its merits and
enter its Order without a formal hearing. If written comments are received within the time limit
set, the Commission will consider them and, in its discretion, may set the same for formal
hearing.
D ISCUSSI 0 N
As indicted above, prior Commission Orders reqUIre Qwest to submit certain
categories of data in any application to close the Boise and Pocatello payment centers. In
addition to the tracking data, U S WEST committed to provide a customer survey produced by
an independent third-party to obtain additional information from customers who actually used
the payment centers. Joint Staff and U S WEST Communications' proposal submitted in Case
No. MTB-90-1 at 5 (August 24, 1990). Rather than submit the data and survey, Qwest asked
the Commission to "waive" these requirements.
NOTICE OF APPLICATION
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 29218
For purposes of processing this case, the Commission finds it need not decide at this
time whether the waiver request should be granted. Interested persons may wish to comment on
this issue. In addition, it is our understanding that the Commission Staff has served a production
request on the Company that seeks data relevant to this Application.
Commission reserves judgment on the issue of granting the waiver request.
Consequently, the
ORDER
IT IS HEREBY ORDERED that this Application be processed under Modified
Procedure. Persons interested in submitting written comments regarding this Application should
do so within twenty-eight (28) days of the service date of this Order.
IT IS FURTHER ORDERED that Qwest conspicuously post a Notice of this
proceeding at its two payment centers advising customers of the Company s proposal to phase
out and close the centers. The Notice shall clearly state that the proposed closure is subject to
the Commission s approval.
IT IS FURTHER ORDERED that Qwest shall prepare a handout summarizing its
proposal to close the payment centers. The handout shall be distributed to customers using the
Boise and Pocatello CPCs. The handout should advise customers of the proposal to phase out
the CPCs and inform interested customers how they may file a comment with the Commission.
NOTICE OF APPLICATION
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 29218
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 8fL
day of April 2003.
ATTEST:
;/t.Co isslOn Secretary
vldJO:QWETO3 1 O
NOTICE OF APPLICATION
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 29218
&~~NT
MARSHA H. SMITH, COMMISSIONER
Commissioner Hansen Dissents Without Opinion
DENNIS S. HANSEN, COMMISSIONER