20091027Frontier Comments.pdf

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4064 Lisa Dr.
Salt Lak City, UT 84124
Phone: [phone]
Fax: [phone]
2009 OCT 27 PM 2: 07
IDAHO PUBLiC
UTILITIES COMr,MSS¡ON
October 23, 2009
Mr. Jean Jewell
Idaho Public Utilities Commssion
472 West Washington Street
Boise,ID 83702
I
RE: Case No. RUL-T-09-0l, In the matter of the Commssion's Review of
Telecommuncations Customer Relations Rules
Mrs. Jewell,
Please fid enclosed the original and 4 copies of the comments of Citizens
Telecommunications of Idao, dba, Frontier Communcations of Idaho.
If you have any questions, please contact me.
Sincerely,
&~"Ingo Hennngsen
Manager, Governent and External Affairs
RECEIVED
October 22, 2009 2009 OCT 27 PH 2: 07
IDAHO PUBliCBEFORE THE IDAHO PUBLIC UTILITIES COMJISSON)MMiSSION
IN THE MATTER OF THE COMMISSION'S
REVIEW OF TELEPHONE CUSTOMER
RELATIONS RULES.
) I
) CASE NO. RUL-T-09-o1
)
) FRONTIER COMMUNICATIONS
) OF IDAHO COMMENTS
)
)
)
COMMENTS
Citizens Telecommunications Company of Idaho, dba Frontier Communications of Idaho,
(Frontier) respectfully submits the following comments regarding the proposed changes to
telephone customer relations rules that were published in the Idaho Administrative Bulletin on
October 7,2009.
Generally, Frontier does not oppose the proposed rule changes. However, there are specific
items discussed below that the Commission should consider.
The single issue of greatest concern to Frontier is found in rule 604, "Public Notice" regarding
public notice of rate changes. This new section states:
"Telephone companies must give "public notice" of all proposed changes in rates as required by Section 62-606,
Idaho Code. Public notice must be ft~asonably designed to call affected customers' attention to the proposed changes
in rates. Legal advertisements alone wil not be considered adequate public notice. Individual notice to all customers
affected wil always constitute public notice. Notices must be provided to individual customers at least thirt
(30) days before change is effective." (emphasis added).
Frontier believes that the thirty-day notice period should only apply to rate increases. The
current wording would require that companies also provide the thirty-day notice for rate
decreases. Section 62-606 specifically excludes rate reductions. It states" ... changes that result
in price reductions, shall be effective immediately upon filing with the commission and no other
public notice shall be required". Therefore, a requirement for advance customer notice of rate
reductions is contrary to the wording in the statute. There is no need to delay rate decreases to
provide customer notice. Customers would benefit from the rate reduction so there is no
protection provided by prior notice and the related delay that would occur. A delay could also
impair a regulated providers abilty to rapidly respond to changes in the marketplace created by
providers that are not subject to Commission regulation. Frontier therefore, recommends that the
Commission modify rule 604 to apply only to rate increases. Additionally, the language in
Section 607-02, Changes to Price Lists or Tariffs, should be modified to allow rate reductions to
become effective upon fiing with the Commission.
Frontier also has some concerns regarding rule 309 "Restriction on Termination of Local
Exchange Service - Opportity to Avoid Termination of Local Exchange Service."
Section 309-02( c) expands the time period when termination of service may be accomplished at
premises that are unoccupied and service has been abandoned, to include Fridays. Frontier does
not support the need for any restrction on termination of service to an unoccupied premise. This
restrction can only lead to additional cost and confusion for service providers. Frontier
recommends that there be no time or day restrctions for the disconnection of service to
unoccupied premises.
Section 309-2(d) allows for the termination of service to be extended to 9 pm "if the company is
unable to gain access to equipment during normal business hours or for ilegal use of service".
Frontier does not believe that there should be any restrictions on the time or day for
disconnection of service for ilegal use of service. If a service is being used ilegally, the user
has no right to the service and should have no protections regarding disconnection. Frontier
therefore, recommends that the rule be modifed to allow disconnection of ilegal use of service
at any time.
Respectfully submitted,,./ ~;te:Z
Manager, Government and External Affairs
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