20030626Final Order No 29270.pdf

Office of the Secretary
Service Date
June 26, 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-03-
ORDER NO. 29270
On March 12, 2003 , Qwest Corporation filed an Application to close its two
remaining customer payment centers (CPCs) located in Boise and Pocatello. The Company
generally maintains the continued operation of these two payment centers is not cost effective
and closure would not adversely affect the public interest.
On April 9, 2003 , the Commission issued a Notice of Application and Notice of
Modified Procedure. The Commission requested that interested persons submit comment no
later than May 7, 2003. The Commission subsequently adopted a stipulation proposed by the
Commission Staff and Qwest to extend the comment period until May 16, 2003. The
Commission received comments from Qwest, Staff, and approximately 33 members of the
public. On May 21 , 2003, Qwest submitted Reply Comments.
THE APPLICATION
Qwest asserted that the only remaining payment centers in its 14-state region are the
Boise and Pocatello CPCs. Application at 2. Qwest proposed to phase out the two payment
centers over "a 90-day period beginning May 1 , 2003.Id. at 4. Ifthe Commission approves the
closure of the payment centers, then the Company will post notices advising CPC customers that
the centers will be closing. The Company also maintained that the notices will provide
customers with information about web site links and telephone numbers so that payment center
customers can learn about the many alternative payment options available. Id. at 4. The Boise
and Pocatello notices also identify the eight "walk-" payment agencies in Boise and the three
walk-" payment agencies in Pocatello.
Qwest advanced three primary reasons why it wanted to close the two CPCs. First
the Company insisted 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 estimated that the average costs of processing a
ORDER NO. 29270
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 stated that usage of the Company operated payment centers has
declined sharply in recent years. "The number of payments processed by (CPC) 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 maintained that the use of its local payment
agents has increased by 156%, from 91 369 in 1996 to 234 316 in 2002. The Company asserted
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
stated the most common method of payment, which is by mail, is used by 84% of Idaho
customers. In addition to mail payments, the Company has procured 58 payment agencies in
Idaho including 8 in Boise and 3 in Pocatello. The local payment agencies provide walk-
face-to- face service for customers desiring to pay their bills in person. Information about the
nearest agencies locations is available on Qwest's website (www.qwest.com). Most payment
agents do not charge a fee for using their service. Qwest's payment agents electronically upload
payment information four times each business day. Thus, the customer s account is timely
updated to avoid disconnection in those cases where disconnection is pending.
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, customers may pay via debit card
credit card or check over the Internet.
The Application also addressed 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;
Follow up on those accounts that are exempt from directory assistance
charges because of a verified disability;
ORDER NO. 29270
Follow up on those accounts that are TDY/TDD discounted for intra-
LATA calling, and;
Contacts with customers using text telephone relay/TDD apparatus.
The center has the capability when requested to provide bills in Braille, in large fonts, in audio
format, and via e-mail (to be translated by a "talking modem
PUBLIC COMMENTS
The Commission received approximately 33 public comments, five from Boise and
the balance from Pocatello. All the public comments except one1 urged the Commission to
require Qwest to retain the CPCs. All of the opposing comments expressed concern that closure
of the CPCs represents a decline in the level of customer service provided by Qwest. The five
Boise comments noted that the existing CPC on Main Street is conveniently located downtown
and they like the availability of a "courtesy" phone. Some of these customers expressed concern
that payment agencies would not accept partial payment for their bills.
Several Pocatello customers expressed concern about the loss and status of CPC
employees. They did not want the CPC tellers to lose their jobs. Some Pocatello comments
noted that closure of the CPC would disrupt their payment routine and that using the alternative
local payment agents would be inconvenient. One commenter noted that the CPC provides
important "face-to-face" contact versus the frustration in using complicated web or telephone
menus to resolve problems.
QWEST COMMENTS
In its comments, Qwest maintained that the public "has shown little interest in this
docket." Comments at 2. Despite being required to conspicuously post a notice of the
proceeding and distribute a handout to customers using the CPCs, Qwest insisted that the
Commission only received about 31 written comments.Id.F or the most part, Qwest's
comments respond to the points addressed by many ofthe public commenters.
Qwest urged the Commission to discount the relevance of several letters based upon
the commenters ' alleged "misunderstanding of the Company s proposal." More specifically,
several commenters urged the Commission to preserve the CPCs so that customers may continue
1 Initially, the Mayor of Pocatello filed comments strongly opposing Qwest's Application. In a subsequent letter
the Mayor retracted his statement and encouraged the Commission "to approve Qwest's request" to close the two
CPCs.
ORDER NO. 29270
to transact business with an actual Company employee. The Company responded that the local
payment agencies are intended to replace the two CPCs. The Company maintains that there are
11 outside payment agencies located in Boise and Pocatello that allow customers to transact
business with a "live person." Comments at 3. Four commenters also mentioned the Qwest
employees that would lose their jobs following closure ofthe CPCs. The Company noted that all
three employees in Pocatello will be eligible for a transfer to the Pocatello Customer Solution
Center and that the two Boise employees will have similar opportunities.
Qwest argued that its local payment agencies constitute a sufficient and reasonable
substitute to the two CPC locations. Qwest noted that local agencies accept cash for making
payments; the 11 payment agencies located in Boise and Pocatello do not charge a fee for use of
their services; and payments made at local agencies are downloaded and applied to customer
accounts 4 times daily. Comments at 4-
Given the wide variety of options for customers to pay their bills, Qwest maintained
that fewer customers are using the CPC this year than in the previous year. Comparing January
through April 2002 with the same 4 months of 2003, Qwest stated that payments made at the
CPCs have declined by 24% in Boise and by 18% at Pocatello. The Company asserted that these
declines demonstrate that "customers are aware and availing themselves of alternative, equally-
convenient (if not more convenient) payment methods.Id. at 6.
The Company also inferred that requiring it to retain the two CPCs is discriminatory.
Qwest maintained that no other Idaho utility is required to maintain a CPC. Id. at 6. Qwest
noted that United Water in Boise has two payment agencies; Intermountain Gas customers may
make payments at either the Boise or Pocatello office; and Idaho Power does not have a
Company-operated payment office anywhere in Idaho.
Although there is no downtown payment agent in Boise, Qwest observed that there is
a payment agent located on Broadway A venue (near St. Lukes RMC) and another one located in
the Albertsons Market Place at ih and State Streets.
2 In fact, payments made at the CPCs result in a "notation" being made on the customer s record. Payments are then
applied to customer s account balances after the payments are delivered overnight to the processing service center in
Denver.
ORDER NO. 29270
STAFF COMMENT
Staff noted that Idaho Code ~ 61-302 requires every public utility to furnish and
provide such service "as shall promote the safety, health, comfort and convenience of its patrons
. . . and the public, and shall be in all respects adequate, efficient, just and reasonable.Staff
calculated that if the CPCs were closed, an average of nearly 6 400 payments per month would
have to be made at some other location or in some other manner. Staff Comments at 6. Staff
observed that the use of the payment agencies has increased in recent years. Based upon the use
and availability of the 58 local payment agencies, Staff did not oppose closure of the CPCs.
However, Staff recommended that the following six conditions be imposed as
conditions for closure ofthe CPCs:
1. If there is a convenience fee or service charge for using payment options
this fee should be clearly posted so that customers are notified in advance
of the charge.
2. Agencies should list the types of payment options available. Payment
agents should accept cash, make change, accept partial payment, accept
payment without bills or notices, accept checks and money orders, accept
deposits as well as paYment on bills, post payments within a reasonable
amount of time, and provide receipts.
3. Maintain drop boxes at the closed CPCs for 12 months.
4. Require a downtown Boise payment agency (within five blocks of the
existing CPC).
5. All payment agencies should be accessible to customers with physical
disabilities.
6. Modify Qwest's website to make it easier to find the location of payment
agencIes.
QWEST'S REPLY
Qwest submitted Reply Comments addressing some of Staff s recommended
conditions. These comments are set out in greater detail below.
1. Drop Boxes. Qwest believes that requiring it to maintain drop boxes at the two
CPCs "could be counter-productive." Reply Comments at 2. The Company expressed concern
that the use of drop boxes does not provide the advantages of dealing with a payment agent, i.
dealing with a live person, having payments immediately posted to accounts, or producing a
ORDER NO. 29270
payment receipt. The Company also expressed concern with the efforts necessary to service the
box and maintain the suggested signs at the box due to inclement weather and potential
vandalism. Id.
2. Downtown Boise Payment Agent.Despite Qwest's efforts, the Company stated
that it was unlikely that "Qwest can meet this requirement if it is imposed.Id. at 3. Qwest
notes that it has not been able to find a suitable (agent) location downtown." Qwest states there
are other payment locations which are conducive to customers traveling to payment locations
via the bus or automobile. Qwest also noted that the other Boise payment agencies tend to have
longer hours than the Boise CPC.
3. Handicap Accessibility and Web site Changes. Although "Qwest does not wish to
suggest that Staff s suggestions (in this area are not meritorious)", these suggestions may exceed
the appropriate scope of this docket. Reply Comments at 4. Qwest is not unique in dealing with
customers who are elderly, handicapped, or experiencing financial difficulties.If the
Commission decides that it must impose requirements on the facilities used by Qwest's pay
agents or on Qwest's web site design, (the Commission) should be prepared to impose similar
requirements on all Idaho telephone corporations and other utilities.Id.
DISCUSSION AND FINDINGS
As the Company noted in its Application, these Idaho centers are the only remaining
CPCs in Qwest's 14-state region. At one time nearly all utilities and railroads, including
Qwest's predecessors, had local offices in many of the communities they served. These local
offices provided many services for customers in their respective communities including: ordering
utility service, paying bills, answering inquiries and complaints. In addition, these offices were
used by the utilities to maintain a local presence, house service technicians and employees, and
conduct local operations. Over time, these local offices and their functions were consolidated
into regional offices. Eventually utilities and railroads further consolidated the regional offices
to a centralized or single office serving multiple states.
After reviewing the Application and the written comments filed in this matter, we
find it reasonable for Qwest to close its Boise and Pocatello customer payment centers. We find
that closing two payment centers will save the Company more than $200 000 for a year. The
number of payments processed at these two payment centers has declined substantially in recent
ORDER NO. 29270
years, and there are many alternatives now available for customers to pay their Qwest bills
including 58 local payment agencies in Idaho.
The majority of the public comments urged the Commission to keep the payment
centers open. These public comments expressed concern that closure of the CPCs represents a
decline in customer service. It is true that closure of the customer payment centers may disrupt
the routine of customers utilizing these centers and it does eliminate the last places in the State to
speak with a Qwest representative in person. However, there are alternative ways for customers
to pay their Qwest bills including the numerous local payment agencies. For example, Boise has
eight payment agent locations and Pocatello has three locations. These payment agencies usually
are open for longer hours than the Company payment centers. In addition, they offer one
significant advantage over the existing CPCs - these local agents electronically upload payment
information four times each day. CPCs did not do this.
We next address the Staffs six recommended conditions for allowing Qwest to close
the CPCs. Staff recommended that the payment agencies clearly post whether there is a fee or
service charge for use of their services and list the type of payment options available. Staff also
recommended that the Commission should require the payment agents to accept cash, make
change, accept partial payments, accept payments without bills or notices, accept checks and
money orders, accept deposits, provide receipts, and post payments within a reasonable amount
of time. It appears that most of these recommendations are already in use by the local payment
agencies and if they are not, they should be. Consequently, we find that it is reasonable to adopt
these recommendations. We believe it is appropriate that customers be apprised whether a fee or
charge is imposed for paying their Qwest bills. Moreover, the agencies should list the types of
payment options available.
The Staff also recommended that drop boxes be kept at the current CPC locations for
one year after closure and that the Company obtain a local payment agency within five blocks of
the Boise CPC. The Company objected to both conditions. We find that the use of drop boxes
could be cumbersome and possibly counter-productive. Drop boxes have to be serviced and
maintained. Use of the payment agencies offers the advantages of transacting business at a local
payment office, provides face-to-face interaction, provides a receipt, and updates payment
transactions four times daily. Although Qwest indicates that it has attempted to find a suitable
payment location in downtown Boise, it has been unable to do so. While we believe that a
ORDER NO. 29270
downtown payment agency is desirable, we will not condition closure of the CPCs on this
recommendation.Nevertheless, we encourage the Company to continue searching for an
appropriate payment location downtown.
Staff also recommended that those payment agencies closest to the CPCs be handicap
accessible. In addition, Staffrecommended that Qwest's web site (www.qwest.com) be modified
so that customers can find the location of payment agents more readily. Qwest objected to both
of these recommendations.Qwest asserted that these recommendations may exceed "the
appropriate scope of this docket." Reply Comments at 4. The Company insisted that if the
Commission were to impose these requirements on the Company, "it should be prepared to
impose similar requirements on all Idaho telephone corporations and utilities.Id.
We find Qwest's Reply Comments offthe mark. Qwest is correct that it is not unique
in having customers who are elderly or physically handicapped. However, we expect that
Qwest's payment agencies are already handicap accessible. We find that the provisions of the
Americans with Disabilities Act (ADA, 42 u.S.C. ~ 12101 et seq.adequately address the Staffs
concerns. Title III of the ADA covers public accommodations and services operated by private
entities. Under the ADA people with disabilities are afforded equal access to a wide variety of
public accommodations " including a "service establishment.42 U.C. ~ 12182(a) and
~ 12181(7). Thus, there is no need for the Commission to address the accessibility of the
payment agencies because this issue is adequately covered by the ADA.
Turning next to Staffs recommendation about Qwest's web site, we find that Staffs
observations have merit.Although Qwest's Home Page lists "Customer Service" and
Residential" headings, trying to find a "Payment Location" under either heading is a 9 or 10-
step process. We find that the list of local payment agencies may be made easier. Consequently,
we direct the Company to work with our Consumer Assistance Staff to determine how
information about the actual locations of payment agencies may be made more readily available
to customers.
In its Application, Qwest proposed that the two CPCs be permanently closed effective
July 31 , 2003. Qwest had previously posted a notice in its CPCs regarding this case. This notice
advised customers of the Company s proposal to close the CPCs "as of the end of July 2003.
We find that it is reasonable to allow the Company to close the CPCs at the end of normal office
hours on July 31 2003.
ORDER NO. 29270
ORDER
IT IS HEREBY ORDERED that Qwest Corporation s Application to close its two
remaining service centers is granted as conditioned above.
IT IS FURTHER ORDERED that Qwest clearly post notices at the two CPCs
advising customers that these payment centers will be closed at the end of normal office hours on
July 31 2003.
IT IS FURTHER ORDERED that Qwest work with Staff to determine how to make
information regarding payment locations more readily accessible on Qwest's Home Page.
THIS IS A FINAL ORDER. Any person interested in this Order (or in issues finally
decided by this Order) may petition for reconsideration within twenty-one (21) days of the
service date of this Order with regard to any matter decided in this Order. Within seven (7) days
after any person has petitioned for reconsideration, any other person may cross-petition for
reconsideration. See Idaho Code ~ 61-626.
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this e2.~ fI-.
day of June 2003.
OkR
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DENNIS S. HANSEN, COMMISSIONER
ATTEST:
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Commission Secretary
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ORDER NO. 29270