HomeMy WebLinkAbout20030516Comments.pdfDONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-0312
IDAHO BAR NO. 3366
HECEIVED FiLED
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UTIUTIES- COril'ilSSIOH
Street Address for Express Mail:
472 WWASHINGTON
BOISE ID 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
QWEST CORPORATION TO PHASE OUT AND )CLOSE THE BOISE AND POCATELLO
CUSTOMER PAYMENT CENTERS.
CASE NO. QWE-O3-
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
attorney of record, Donald L. Howell, II, Deputy Attorney General, and submits the following
comments in response to the Notice of Application, Notice of Modified Procedure and Order No.
29218 issued on April 9, 2003.
THE APPLICATION
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.
Qwest proposes to close the two remaining Customer Payment Centers (CPCs) in its 14-
state region; one located in Pocatello, Idaho and the other in Boise, Idaho. A similar proposal was
filed with the Commission in 1990 in Case No. MTB-90-1. Those proceedings were stayed and
STAFF COMMENTS MAY 16 20031
the CPCs remained open. A monitoring plan was established to track customer payment
information in an attempt to create a record sufficient to allow the Commission to determine
whether non-Company owned payment agents could provide service equal to that provided by the
CPCs. In 1997 the Commission allowed the Company to discontinue the tracking and reporting of
data until such time as the Company sought to close the CPCs (Order No. 23596).
CPC OPERATIONS
The CPCs continue to be used by many Qwest customers. There were 63 211 payments
made and processed by the tellers of the Qwest Pocatello and Boise CPCs in 2002 (37 567 in
Pocatello and 25 644 in Boise).! Another 13 177 payments were received in the drop boxes at
those locations (6,495 in Pocatello and 6 682 in Boise). Another 933 payments were mailed to a
CPC (699 in Pocatello and 234 in Boise). For some reason, customers who mailed payments to
the CPC did not use the self-addressed envelope provided with the bill.
The reasons vary as to why customers continue to pay their telephone bill in person.
Some customers may simply find it convenient because the payment center is near where they
live, shop or work. Others may just like the idea of saving money, and although the $.37 for a
stamp isn t a large amount, some people like the idea of saving $4.44 a year. Others like the
satisfaction of dropping that payment off personally, because they have face-to-face personal
contact with the representative of the telephone company, or it has become part of the normal
routine to personally pay their bills. Some customers believe (erroneously) that when payments
are made in person, there is a speedier posting to their account, especially in instances of a
pending disconnection.
While CPCs provide personal contact with a telephone company representative, they do
not provide customers an opportunity to resolve all customer-related issues. The tellers at the
CPCs can pull up a customer s account to verify an amount owing or to confirm if a payment has
posted, but the teller is not empowered to negotiate payment arrangements, answer billing
questions, take orders for new service, or resolve disputes. Returned telephone equipment
cannot be dropped off at either CPC. Customers wanting to change or add services, disconnect
service or question a long distance charge are provided the appropriate Qwest telephone number
and instructed to call the Company for specialized assistance.
1 In its response to Staff's Production Request , Qwest revised the numbers given in its Application.
STAFF COMMENTS MAY 16 20032
Both CPCs are physically accessible to customers with disabilities and can accept cash
payments and make change for payments made in excess of the exact amount. The CPCs accept
payments even without the bill or disconnection notice and payment may be made by personal
check, cashier check or money order. CPCs also accept payments for deposits and provide
receipts for all transactions. The CPCs have drop boxes for customers who simply want to make
the payment, but do not require a receipt.
Customers in need of a local or out-of-area telephone directory cannot pick one up at
either CPC. Boise customers are advised to go to the QwestDex Boise location and all other
customers are instructed to call 1-800-422-8793 to receive a directory.
ALTERNATIVE LOCAL PAYMENT AGENTS
One of the alternatives available to customers wanting to continue to pay in person would
be to use one of the 11 Qwest payments agents. There are eight payment agents in the Boise area
and three in Pocatello. (See Attachments A and B -- Maps of current CPC and payment agent
locations.) In Pocatello there is a payment agent, the Super Save Drug, approximately three
blocks away from the CPC. The closest payment agent to the Boise CPC is nearly a mile away.
These agents are businesses engaged in other commercial activities such as vacuum sales, check
cashing and payday loan service, or grocery and drug stores. In addition to their primary
businesses, these companies accept payments on behalf of Qwest. Customers can pay their
telephone bill and an employee of that business processes the payment electronically and hands
the customer a receipt.
Qwest states that the eleven payment agents in Pocatello and Boise provide all the same
services as the CPCs. Attachment C is a chart showing a comparison of services provided by the
CPCs and by the payment agents. The tellers at the CPCs can pull up a customer s record and
provide limited information, where the payment agents cannot, and CPCs provide drop boxes for
payments not requiring receipts. Other than that, payment agents perform similar functions as
the CPCs. That has not always been the case. There was a large disparity between functions of
the CPCs and the payments agents as noted in Case No. MTB-90-, where Staff witness
Stokes testified that "Agents may not even be able to accept partial payment of bills, cash
payments or payment of deposits." (p. II , lines 16-18.
STAFF COMMENTS MAY 16 20033
There are a total of 58 payment agents across southern Idaho. In 2002, those payment
agents processed 234 316 customer payments. Qwest has a contract with First Data Corporation
to manage the business relationship with the payment agents. All First Data Corporation
payment agents in Idaho currently allow customers to pay Qwest bills without charge for their
service. Qwest pays First Data Corporation a fixed-unit rate for each walk-in payment. In
addition, Qwest has an Independent Agency Agreement with ACE Cash Express businesses.
The agreement allows the retail chain to accept Qwest payments from customers for a $1
convenience fee. The $1 fee is assessed and retained by ACE Cash Express. There are two ACE
payment locations, one in Nampa and the other in Mountain Home. The ACE locations transmit
payments via an electronic file in the same manner as the other payment agents. None of the
payment agents have drop boxes available for the use of Qwest customers. Qwest did not verify
that all the payment agents were accessible to customers with disabilities, since accessibility was
not a requirement to becoming a First Data Corporation agent.
Using a payment agent has some advantages over using the CPCs, such as the extended
hours of operation. Two payment agents in Pocatello accept and process payments 7 days a
week and all but one payment agent in Boise are open Monday through Saturday. In contrast
the hours of operation for the CPC in Boise are from 8:30 a.m. to 5:00 p.m. Monday through
Friday and Pocatello from 9:00 a.m. to 5 :00 p.m. Monday through Friday. Payments received by
an agent are electronically transmitted four times daily to Qwest, and information is recorded on
the customer s record that a payment was made; however, actual posting to the customer
account may take up to 48 hours.
Customers in imminent danger of being disconnected who use a payment agent or CPC
must call the Company and provide the receipt number as proof of payment. The payment
agents provide a receipt with a payment tracking code that is familiar throughout the Company
as a proof of payment. This tracking code is then noted on the customer s account by a Qwest
consultant, which stops the pending disconnection. Customers who make a payment at the
Qwest CPCs receive a basic payment receipt containing no tracking code, which may create an
additional challenge if customers contact a Qwest representative. Since the two CPCs in Idaho
are the only Company-owned payment centers within Qwest's 14-state region , Qwest
representatives are not as familiar with CPC operations or even aware of their existence.
Therefore, they may be hesitant to accept the customer s claim that a payment has been made.
STAFF COMMENTS MAY 16, 20034
Payments made at a CPC are noted on the customer s account by a Qwest teller and
billing receipts are sent via overnight mail to the processing center in Denver. Payments made
either at a CPC or a payment agent should post within a 48-hour period of time; however, it is
more likely that payments taken at a CPC actually take longer to post than ifpaid at one of the
payment agents since the receipts are mailed to another location for posting. Neither of the
CPCs have the capability of processing electronic checks, yet some of the payment agents do.
Qwest did not provide information regarding which agents have the electronic check capability;
however, Staff notes that this information is provided on Qwest's website.
OTHER PAYMENT 0 PTI 0 NS
Other options are available for customers to pay their telephone bill besides paying by
mail or personally making a payment at a CPC or payment agent. Customers can have
direct/automatic payments withdrawn from checking accounts. Options available today, but
unavailable in 1990 include payment by debit card, credit card or a check routing number over
the telephone. Customers can also connect to the Qwest automatic Interactive Voice Response
Unit and pay by using a check routing number or credit card. Customers with access to
computers have several payment options using Internet transactions including debit card, credit
card or check. For customers who do not have access to computers, the options include debit
card, credit card or check by phone. These optional payment choices may have fees attached
depending on the vendor used. Customers can make a calculated decision to use a fee-based
service or use an alternate method of payment.
Staff notes that customers searching Qwest's Web site may find it cumbersome to locate
the walk-in payment locations. The Home Page does not make it obvious where the payment
agent information may be found. The Attachments to the Application in this case indicate
customers can click on "Residential" then enter their area code and phone number, and then click
four other times then follow the prompts that ask for the city or ZIP code. The typical rule of
thumb for Internet use is that three clicks of the mouse should take you where you want to go. It
would be much more user-friendly to add a link to payment agent information on the Home
Page.
As for Web site contents, Staff notes that clear disclosure is provided if personal checks
are accepted, or the location is an electronic check site. The website also lists the address and
STAFF COMMENTS MAY 16, 20035
hours of operation as well as other details about payment agent functions. However, Staff notes
that the language "QWEST PRINTED MEDIA REQUIRED TO PAY" may be confusing to
customers and suggests that specific reference be made to Qwest bills or notices rather than
printed media
Face to face contact between customers and utility representatives has been on the
decline in Idaho and throughout the country over the past several years. Utilities have steadily
been replacing local offices in favor of centralizing functions. The increased efficiency and
reduced costs of central processing has made satellite offices uneconomical. The two Qwest
CPCs in Idaho are the only Company-owned centers operating in its 14-state region. According
to Qwest, the costs of operating these two facilities is over $211 000 per year, yet the number of
payments processed by Qwest tellers constitute only 1.43% of the total number of payments
processed for Idaho customers in 2002. Staff has verified that the cost per transaction using a
payment agent is less than the cost per transaction at the Cpc.
STAFF OBSERVATIONS
The focus of the Commission is to satisfy the requirements contained in Idaho Code
961-302
, "
Every public utility shall furnish, provide and maintain such service
instrumentalities, equipment and facilities as shall promote the safety, health, comfort and
convenience of its patrons, employees and the public, and as shall be in all respects adequate
efficient, just and reasonable." Even though the Commission s Telephone Customer Relations
Rules do not require face-to-face contact, the expectation is that companies will generally be
responsive to the needs of its customers. Consumer complaints, orders for connection and
disconnection, and changes in services can all be handled by Qwest even though the Company
does not have a place for people to go to meet personally with a Company representative.
Currently the tellers at CPCs do little more than take and process payments. To the extent that
Qwest can sufficiently meet the needs of its customers without having a local office for
customers to pay the bills, Staff does not oppose closure of the CPCs.
If the CPCs are closed, an average of nearly 6400 payments per month will have to be
made in some other manner. If the payment agents can provide equivalent service to effectively
meet the needs of Qwest customers, the changes customers will have to make will be minimal.
A variety of alternative methods are available for these same patrons.
STAFF COMMENTS MAY 16 20036
Staff recognizes that the Commission has not imposed standards for payment agents used
by any utility under its jurisdiction. However, Staff maintains that certain requirements are both
reasonable and necessary in light of the increasing frequency of utility office closures. These
include:
(1)All payment agents should be physically accessible to customers with
disabilities. Customers paying in person should not be turned away due to
(2)
inaccessibility.
That the customers be clearly notified if there is a convenience fee or service
charge for using the payment options ava.ilable (e., electronic checks, check
by phone, Internet, credit card, debit card).
(3)For the convenience of the customers, those agents that do not have the ability
to process electronic checks have signs posted informing customers of that
(4)
fact.
That payment agents accept cash, make change, accept partial payments
accept payments 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.
With the exception of handicap accessibility at some sites, Staff believes that the existing
Qwest payment agents in Boise and Pocatello meet all the requirements.
PUBLIC COMMENTS
The Commission received a total of 33 comments from customers and employees of
Qwest. All comments originally were against closing the CPCs. The Mayor ofPocatello, Roger
W. Chase, originally submitted comments against the closure of the Pocatello CPC , but has since
retracted his original letter and submitted a letter in support of Qwest' s business decision to close
the Pocatello CPC as long as Qwest continues to provide a variety of convenient options for
customers to pay their telephone bills.
All the customers opposing closure were genuinely concerned that the closure of the
CPCs represents a decline in the level of customer services provided by the Company. There
were no public comments received requesting a public hearing. There were five comments
received from the Boise area stating that the CPC on Main Street was convenient, and they liked
STAFF COMMENTS MAY 16 20037
the availability of the courtesy phone. Some customers believed that the exact amount would be
necessary if payment was made anywhere except the CPC, and another customer thought that by
making a payment at the CPC was the fastest way to pay the telephone bill.
Convenience and friendly customer service was mentioned in many of the 28 comments
from the Pocatello area. Customers feel the employees of Qwest are part of the community and
they don t want the tellers to lose their jobs. Some customers have a routine of paying the bills
in person because they like the face-to-face contact. Other customers stated it would be a hassle
to pay the bill elsewhere because they have had to stand in line when using a payment agent.
Another customer asked if the savings involved would be significant enough that the rates would
be lowered. One employee of Qwest noted how important the human contact is for the elderly,
since they can become very frustrated with the complicated menu when trying to reach the
company by phone to resolve a problem.
Staff notes that there are some misconceptions as to what the payment agents offer and
what functions they are capable of providing. The savings in closing the CPCs could offset the
upward pressure on rates, since any reduction in costs benefits all customers. However, a
monetary value cannot be placed on how the customer feels having face-to-face contact with
Company personnel. There are so few customers using the CPCs related to the total number of
Qwest customers, that to keep the CPCs open is not a cost-effective way of providing a payment
service. In this instance, Staff maintains that preserving the convenience and inherent value of
face-to- face contact with Qwest for those customers who patronize the CPCs is not sufficient
reason for prohibiting closure of the CPCs.
STAFF RECOMMENDATIONS
Staff recommends that Qwest be allowed to close the Boise and Pocatello CPCs if a
payment agent is secured in the near proximity to where the existing CPCs are currently located
prior to closure. In Pocatello the Super Saver Drug store located approximately three blocks
away would be adequate. In Boise, however, the closest payment agent is nearly a mile away.
Staff recommends that a payment agent be secured in the downtown Boise area, within five
blocks of the Boise CPC.
Staff also recommends that those payment agents closest to the CPCs be handicapped
accessible so that there is no loss of functionality in the transition between the CPCs and
STAFF COMMENTS MAY 16 20038
payment agents. Qwest should verify that the Super Saver Drug in Pocatello is handicapped
accessible. The downtown Boise payment agent should also be handicapped accessible.
Staff also recommends that drop boxes be kept at the current locations for at least one
year after closure of the CPC to help customers with the transition of the CPC closure. If Qwest
chooses to discontinue the use of drop boxes after a year s time, a sign should be put on the drop
box advising of the pending closure 60 days prior to actual closure. If the payments received in
the drop box will not be processed immediately, a sign should be posted alerting customers of
the timeframe involved for payments to post as well as the availability of other payment options
including the location of the nearest payment agent.
Staff also recommends that Qwest verify that the payment agents located in Boise and
Pocatello are accessible to the handicapped prior to closure of the CPCs and meet all the criteria
specified on page? of Staffs comments.
Staff also recommends that Qwest's Web site be modified to more clearly advise
customers of what they need to bring with them when using a payment agent. Staff also
recommends that a link be added to Qwest's Home Page for payment agent information. Finally,
Staff recommends that Qwest make provisions to expeditiously handle payments that are mailed
to the CPC locations.
Respectfully submitted this M,ikday of May 2003.
Donald L. Ho ll, II
Deputy Attorney General
Technical Staff: Carol Cooper
i:umisc:comments/qwetO3.!Odhcj
STAFF COMMENTS MAY 16 20039
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COMP ARISON OF SERVICES
Customer Payment
Centers
Pocatello and Boise
Payment Agents
Pocatello and Boise
All Other Southern
Idaho Payment Agents
Accept cash and make change Yes Yes Yes
Accept payment for less than Yes Yes Yes
full amounts due.
Accept payment if customer Yes Yes Yes
does not have copy of bill or
notice.
Accept payment if customer Yes
does not have the payment
stub.
Accept personal checks or Yes Yes Yes
Money Orders
Process electronic checks Some, but not all.Some, but not all.
Accept payments for Deposits Yes Yes Some, but not all.
as well as bills.
Provide Receipts for payments Yes Yes Yes
Drop Box Available Yes
Evening and Weekend Hours Yes Yes
Pick up Directories
Charge Fee for Payment Some, but not all.
Make Payment Arrangements
Timely Post Payments Yes Yes Yes
Handicapped Accessible Yes Maybe Maybe
Attachment C
Case No. QWE-03-
Staff Comments
C. Cooper, Staff
05/16/03
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 16TH DAY OF MAY 2003
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF IN CASE
NO. QWE-03-, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
MARY S HOBSON
STOEL RIVES LLP
SUITE 1900
101 S CAPITOL BLVD
BOISE ID 83702-5958
ADAM L SHERR
QWEST
1600 7TH AVE ROOM 3206
SEATTLE WA 98191
F:~
SECRETARY
CERTIFICATE OF SERVICE