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Home My WebLink About20080523Reply Comments.pdfMar S. Hobson Attorney & Counselor 999 Main, Suite 1103 Boise, il 83702 208-385-8666 Rt:,.,.. ..- '-' f"1 i i ~D.... \Ie 2008HAY 22 PH 1,: 5/ UTld¥í~~"~¡~~ J JUe UM!H/SSION May 22, 2008 VIA HAND DELIVERY Jean D. Jewell, Secretar Idaho Public Utilities Commission 472 West Washington Boise, ID 83702-5983 RE: Docket No. QWE-T-08-oa Dear Ms. Jewell: Enclosed for filing with this Commission are an original and seven (7) copies of QWEST CORPORATION'S REPLY TO THE COMMENTS OF THE COMMISSION STAFF. If you have any questions, please contact me. Than you for your cooperation in this matter. Ver trly yours, i;~f!~ Enclosures Mar S. Hobson (ISB. No. 2142) 999 Main, Suite 1103 Boise, ID 83702 Tel: 208-385-8666 mary.hobsonifqwest.com RECEiVED inua HAY 22 PM 4:51 FU2,LlC ON COMìvilSSi .. Adam L. Sher Corporate Counsel, Qwest 1600 7th Avenue, Room 3206 Seattle, W A 98191 Tel: (206) 398-2507 adam. sherrinqwest. com Attorneys for Qwest Corporation BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION PETITION OF QWEST CORPORATION FOR EXEMPTION FROM CERTAIN PROVISIONS OF RULE 31.41.01.201 Case No. QWE-T-08-2 QWEST CORPORATION'S REPLY TO COMMENTS OF COMMISSION STAFF Qwest Corporation (Qwest), by and through its undersigned attorneys, fies this Reply to the Comments of the Commission Staff (Comments) fied on Mayl4, 2008 in response to Qwest Corporation's Petition for Exemption. In those comments Staff recommends that Qwest be granted cerain specific exemptions to the provisions of Rule 31.41.01.201 (Rule 201) rather than "a general exemption to the entire rule." QWEST REPLY COMMENTS - 1 - Comments, p. 3. The specific provisions Staff singles out for exemption are sections 201.01.j and 201.01.k. Staff is correct in noting that Qwest does not seek exemption from "the entire rule," i.e., ever provision of Rule 201 and its varous subpars. Rather, Qwests Petition clearly states that the Company is seeking an exemption to perit it to offer a Sumar Statement as an option to its customers. A copy of the form of Qwests Summary Statement was attached as Exhibit 1 to Qwests Petition. It is Qwests intention to offer this statement to customers who affrmatively choose it under the conditions spelled out in Qwests Petition including that "any ofthe more detailed information that is required under Rule 201 that is not provided on the Summary Statement can be readily obtained online, or by callng Qwests customer serice representatives.." Qwest Petition, ir 7. Among the detailed information that is required by Rule 201, but not provided on the Sumar Statement, is itemization of all MTS calls including the number called and the date, time, duration, destination and charge for each calL. Nor does the Summar Statement itemize the origin of the call for collect and third-pary calls. Rule 31.41.01.201.02. In its Comments Staff did not suggest that MTS biling detail as contemplated by ths subsection of Rule 201 must be retained even when customers choose the Summar Statement. Nor did Staff raise any objection to the form of the Sumar Statement. Indeed Staff notes, "Offerng a varety of biling options to customers is an essential component of good customer serice." Comments, p. 3. Qwest requests, therefore, that the Commission grant an exemption to the provisions of Rule 201 including, but not limited to, subsection 201.02, such that Qwest may offer the Sumar Statement in the form depicted on Exhibit 1 to its Petition. QWEST REPLY COMMENTS - 2 - Submitted this 22ud day of May, 2008. Respectfully submitted, Mar Sf obson (ISB. No. 2142) 999 Main. Suite 1103 Boise, ID 83702 Adam L. Sher Corporate Counsel, Qwest 1600 7th Avenue, Room 3206 Seattle, WA 98191 Attorneys for Qwest Corporation QWEST REPLY COMMENTS - 3 ~ CERTIFICATE OF SERVICE I do hereby cerify that a tre and correct copy of the foregoing QWEST CORPRATION'S ~'. TO COMMENT OF THE.COMMISSIN STAFF was served on the ~day of 2008 on the followig individuals: Jean D. Jewell i Hand DeliveryIdaho Public Utilties Commssion U. S. Mail 472 West Washigton Street Overnght DeliveryP.O. Box 83720 FacsimileBoise, il 83702 Email Telephone (208) 334-0300 Facsimile: (208) 334-3762 jjewellêJuc.state.id.us obson for Qwest Corporation