20080514Comments.pdf

KRSTIE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
RECEIVED
i it Al1
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF )
QWEST CORPORATION FOR EXEMPTION )
FROM CERTAIN PROVISIONS OF RULE 201, )IDAPA 31.41.01.201. )
)
)
CASE NO. QWE-T-08-2
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilties Commission, by and through its
Attorney of record, Kristine A. Sasser, Deputy Attorney General, and in response to the Notice of
Petition and Notice of Modified Procedure issued in Order No. 30539 on April 23, 2008 in Case
No. QWE- T -08-2, submits the following comments.
BACKGROUND
On April 2, 2008, Qwest Corporation fied a Petition with the Commission, pursuant to
IDAP A 31.41.01.009, seeking a permanent exemption from certain provisions of the
Commission's Telephone Customer Relations Rule 201, IDAPA 31.41.01.201. In paricular,
Rule 201 pertins to the itemized content of telephone bils for residential and small business
customers. Qwest wishes to offer its customers a "Summar Statement" in lieu of the detailed
information contained in the Company's curent bil.
STAFF COMMENTS 1 MAY 14,2008
The Company contends the Sumar Statement option was created in response to
customer demand for simplified biling. In order to receive a Summar Statement, a customer
must affrmatively select the change to their biling statement. Customers who do not
affirmatively request a Sumar Statement will continue to receive the standard bil, which
complies with the detailed requirements set forth in Rule 201, IDAPA 31.41.01.201.
The Company asserts that customers who choose to receive a Summar Statement may
switch back to standard biling at any time, without charge or penalty. In addition, customers who
have chosen a Sumar Statement may stil review the standard detailed biling information for
their account on the Company's website at any time.
Telephone Customer Relations Rule 201 requires bils to include: Biling date; due date;
time period covered by the bil; total amount due; past due amounts; toll-free telephone number
for billng inquiries; an itemization of all non-recurring charges; and an itemization of recurng
charges such as monthly exchange service, equipment leases, taxes, surcharges, fees, and custom
callng features. IDAPA 31.41.01.201.
The Company claims that its proposed Summar Statement provides the most importt
biling information that customers are looking for, i.e., biling date, due date, total amount due,
past due amounts (if any), payments received since the prior biling, biling totals for each class of
service, summar of information about taes and surcharges, and information about service
provided by third paries, including contact information for questions regarding third-pary
biling.
The Petition states that the Company's objective is to provide customers with more
options and to respond to customer demand for simplified biling information. The Company
asserts that strict adherence to the detailed requirements of Rule 201 would prohibit Qwest from
making an option available to customers that would reduce the volume and complexity of their
bils, thereby working a hardship on the Company and its customers. See IDAPA 31.41.01.009.
STAFF ANALYSIS
Staff supports the Company's request for permanent exemption from certain provisions of
Rule 31.41.01.201 (Rule 201) with certin conditions. Rules 201.0 I.j and 201.0 I.k require
detailed itemization of all non-recuring and most recuring charges on bils for residential and
small business local exchange service. These provisions restrict the Company's ability to offer
STAFF COMMENTS 2 MAY 14,2008
customers the option of a simplified biling statement that does not contain the amount of detail
curently required. Staff recommends that Qwest be granted an exemption to these specific
provisions rather than a general exemption to the entire rule.
Offering a varety of biling options to customers is an essential component of good
customer service. Qwest states that it intends to offer the Summar Statement to customers as an
alternative to the standard biling format, which contains the detailed information required by
Rule 201. Customers who choose the Sumar Statement wil stil be able to obtain recent
detailed information from Qwest on the Company's website, by telephone inquiry and by paper
copy upon request. Curently, customers are charged for paper copies of bils that are older than
six months. Customers who have an online account have access to twelve months of biling detail
online, and are charged for paper copies of bils older than twelve months. Staff recommends that
the permanent exemption be granted with the condition that the biling detail required by Rule
201 continue to be available to customers without charge on Qwests website or by telephone
inquiry for a period covering a minimum of twelve consecutive monthly biling statements. Staff
believes it is importt that customers for a reasonable period of time be able to obtain detailed
biling information if necessar. Granting an exemption with this condition will not place any
additional burdens on the Company and wil assure customers that the opportunity to obtain
important information will be preserved.
RECOMMENDATIONS
Staff recommends that Qwest be granted a permanent exemption to Rules 201.0 l.j and
201.01.k with the condition that the Company continue to make biling detail available to
customers without charge on Qwest s website or by telephone inquiry for a period covering a
minimum of twelve consecutive monthly biling statements.
Respectfully submitted this 14~ day of May 2008.
'y-
Ll,,I)~
Krstine A. Sasser
Deputy Attorney General
Technical Staff: Beverly Barker
i: umisc: commentsqwet08.2ksbab
STAFF COMMENTS 3 MAY 14,2008
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 14TH DAY OF MAY 2008,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. QWE-T-08-2, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
MARY S HOBSON
QWEST CORPORATION
999 MAIN ST, SUITE 1103
BOISE ID 83702
ADAM LSHERR
CORPORATE COUNSEL
QWEST CORPORATION
1600 7TH AVE, ROOM 3206
SEATTLE WA 98191
~~.\(Ot,
CERTIFICATE OF SERVICE