28857.doc

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

in the matter of THE PETITION OF VERIZON NORTHWEST, INC. FOR A WAIVER FROM THE COMMISSION’S TELEPHONE CUSTOMER RELATIONS RULES REGARDING PARTIAL PAYMENT APPLICATION. )
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CASE NO. VZN-T-01-8

ORDER NO. 28857

On June 21, 2001, Verizon Northwest, Inc. filed a Petition requesting that the Commission grant it exemptions from Rules 306.06 and 312.03 of the Telephone Customer Relations Rules. IDAPA 31.41.01. On July 31, 2001, the Commission issued a Notice of Application and Notice of Modified Procedure. Order No. 28794. The Commission established a written comment deadline for interested persons and parties. The Commission Staff and Verizon filed written comments. The Commission in this Order approves Verizon’s Petition as presented.
VERIZON’S PETITION
Verizon states that its billing system does not have the capability to accommodate customers’ requests to manually dictate partial payment allocations. Accordingly, the Company states that its system does not technically comply with Rules 306.06 and 312.03. The Company alleges that it has investigated the cost to upgrade its billing system to allow for strict compliance with the manual allocation provisions of Rule 306.06 and 312.03 and estimates that its costs would be approximately $51 million. Verizon states this huge investment would create a substantial hardship for it.
Verizon also states that its inability to comply with these Rules has not resulted in a large number of customer complaints that have come to the Commission, and it is aware of only two that mention the limitations of its billing system.
The Company is requesting a waiver from compliance from these Rules for a period of two years. Verizon states that with Commission authorization it will continue to allocate customers’ partial payments in the manner within the current capabilities of its billing system. At the close of the two-year period, Verizon proposes that it provide the Commission with a status report on the ability of its billing systems to comply to the letter of these payment allocation rules.
Verizon’s written comments filed on August 17, 2001 restated the positions taken in its Petition. Furthermore, the Company filed reply comments disagreeing with certain recommendations contained in Staff comments.
STAFF ANALYSIS AND RECOMMENDATION
Staff recommended that the Commission grant the Company a two-year, temporary exemption from these Rules contingent upon its continued compliance with the remaining Telephone Customer Relations Rules. Staff also recommended that at the end of two years Verizon be required to comply in full with the Commission’s Rules or demonstrate that it is in the process of complying with the Rules. Finally, although the Company has technically been in non-compliance with these Rules Staff did not recommend fining/penalizing the Company as it has been working diligently with the Commission Staff to reach a solution to this situation.
COMMISSION FINDINGS
After reviewing the record in this matter the Commission finds it appropriate to grant the Company’s Petition as presented. Although the Commission recognizes the Staff’s concerns, Verizon has had very few complaints regarding its inability to comply with these rules and has sufficiently addressed those that have arisen. Furthermore, because of the GTE-Bell Atlantic merger, Verizon is reviewing Company systems to determine which will remain, be modified or replaced. The Commission finds that the Company has shown that it would suffer a substantial financial hardship if it were forced to comply with these Rules. Staff has acknowledged this in its written comments. Therefore, Verizon’s request for exemptions from Telephone Customer Relations Rules 306.06 and 312.03 is granted for a two-year period as requested in its Petition. The Commission also requires Verizon on or before two years from the date of this Order to advise the Commission on its progress towards meeting the requirements of these Rules.
O R D E R
IT IS HEREBY ORDERED that Verizon Northwest, Inc.’s Petition for exemptions from the Commission’s Telephone Customer Relations Rules 306.06 and 312.03 is granted for a two-year period as requested by the Company.

IT IS FURTHER ORDERED that on or before two years from the issuance of this Order Verizon shall advise the Commission on its progress towards meeting the requirements of these rules.
THIS IS A FINAL ORDER. Any person interested in this Order or in interlocutory Orders previously issued in this Case No. VZN-T-01-8 may petition for reconsideration within twenty-one (21) days of the service date of this Order with regard to any matter decided in this Order or in interlocutory Orders previously issued in this Case No. VZN-T-01-8. Within seven (7) days after any person has petitioned for reconsideration, any other person may cross-petition for reconsideration. See Idaho Code § 61626.
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this
day of September 2001.

PAUL KJELLANDER, PRESIDENT

MARSHA H. SMITH, COMMISSIONER

DENNIS S. HANSEN, COMMISSIONER

ATTEST:

Jean D. Jewell
Commission Secretary

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ORDER NO. 28857 1

Office of the Secretary
Service Date
September 19, 2001