950901.docx

WELDON STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE,  IDAHO  83720-0074
[phone]
ATTORNEY FOR THE COMMISSION STAFF
BEFORE  THE  IDAHO  PUBLIC  UTILITIES  COMMISSION

IN THE MATTER OF THE PETITION FOR)
REOPENING OF THE TROY, IDAHO)CASE  NO.  TRO-T-95-1
BUSINESS OFFICE OF TROY TELEPHONE)
)COMMENTS OF                                   )THE COMMISSION
)STAFF
____________________________________________)
COMES  NOW  the Staff of the Idaho Public Utilities Commission, by and through its Attorney of record, Weldon Stutzman, Deputy Attorney General, and submits these comments as provided for in the Commissions' Notice of Petition and Notice of Modified Procedure issued in this case on August 16, 1995.  These comments are filed in response to a petition by customers of Troy Telephone to have the former telephone business office reopened.
BACKGROUND
On May 18, 1995, the Commission received a petition signed by 300 people in Troy requesting the reopening of the Troy Telephone business office.  The petition states that it is "very inconvenient for quick response for maintenance men, the inconvenience for new telephone services, on a less personal level and losing another business on main street."
Staff has investigated the petition and makes the following observations.  Both Troy Telephone and Potlatch Telephone are owned by TDS Telecom (TDS).  On January 20, 1995, TDS sent a letter to the Commission stating that it was closing the Troy office.  A copy of the letter is included as Attachment A.  In the letter, the Company states its intention to close the Troy business office and its plans for serving customers subsequent to the closing.
Business office functions for TDS are now handled out of the Company’s location in Kendrick, approximately 12 miles from Troy.  This office is open Monday through Friday, from 8:00 AM to 5:00 PM.  In addition, TDS has established a payment center at the Farmer's Mutual Fire Insurance Company across the street from the former Troy business office.  Since the time of the closure, TDS has also made arrangements with Key Bank in Troy to act as a payment agent for the Company.
In checking into the number of consumer complaints filed with the Commission since the first of the year, Staff finds that there have been six complaints on Troy Telephone, all of them related to the desire for extended area service.  Inquiries made to Doug Paynter, the manager for TDS in the area, also show that there are no held orders in Troy at this time.
Attachment B is a summary of the smaller local exchange companies in the state and their present and anticipated business office operations.  For these companies, multiple business office locations is the exception.  Currently, none of the companies have more than one location in Idaho.  Also of relevant interest is that on February 15, 1995, in Case No. GEM-T-94-1, Order No. 25895, the Commission approved the closure of Gem State Utilities' (PTI) business office in Grandview, which had served 1721 customers in the Grandview area.
On July 26, 1995, Staff Attorney Don Howell met with five of the petitioners in Troy.  TDS Manager, Doug Paynter, and the resident maintenance technician were also present.  The attendees did not voice any complaints about the quality of service or about the availability of payment agents (although some did not "like" Key Bank).  During the meeting, Doug Paynter indicated that the Company does have a repair technician residing in Troy and anticipates stationing such an employee in Troy in the future.  The Company can also dispatch three other technicians from the Kendrick office.
Mr. Paynter indicated that no jobs were eliminated by the office closure but were merely transferred to the Kendrick office, indicating the closure did not reduce personnel costs.  However, the Company desires to lease the Troy office to two business occupants and rent out a third space as an apartment.  Until the Petition is resolved, the Company feels it cannot move forward with its plans to lease the former Troy office.  The petitioners generally indicated that the Company should have an office in Troy because Troy is a growing community.  In particular, there are two subdivisions currently being planned for approximately 40 and 75 lots each.
COMMENTS
The closure of the Troy business office follows an ever increasing trend in the telephone business of reducing expenses.  The latest evidence of that is the closing of the Grandview business office by PTI.  These closings, while regrettable, are inevitable in light of increasing uncertainty in the industry concerning continued federal subsidies and concern about the eventual effects of competition.  These cost cutting efforts must be weighed against their effect on customer service.
In the case of the Troy business office, it appears that customer service is not being harmed.  There have been no service related complaints, there are no held orders, there is a installation/repairman living in the community, and there are two payment agents and a toll-free number for customer assistance.  In addition, for customers who need to talk directly to a service representative, the Kendrick office is twelve miles away.
Currently, there are no small local exchange companies in the state with more than one business office.  Century, at approximately twice the size of TDS, has one in Salmon and PTI, approximately the same size as TDS, has none.
Although Staff sympathizes with customers in Troy, reopening the business office would place TDS in a position apart from any other small LEC in the state.  There is also no reason to believe that doing so would significantly increase the quality of service which customers are currently receiving.  The facts in this case convince Staff to recommend that the petition of the Troy customers to reopen the business office should be denied.
   DATED  at Boise, Idaho, this            day of September, 1995.
______________________________________
Weldon Stutzman
Deputy Attorney General
umisc/comments/trot951