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Home My WebLink About200304021st Pro Request of Staff to Qwest.pdf~,?I..( DONALD L. HOWELL, II DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0312 IDAHO BAR NO. 3366 RECEIVED mFILED 2003 APR -I PH~: 23 WAhU PUBliC UTILITIES COMMISSION Street Address for Express Mail: 472 W W ASHIN GTON BOISE ID 83702-5983 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF QWEST CORPORATION TO PHASE OUT AND )CLOSE THE BOISE AND POCATELLO CUSTOMER PAYMENT CENTERS. CASE NO. QWE-03- FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO QWEST CORPORATION The Staff of the Idaho Public Utilities Commission by and through its attorneyofrecord Donald L. Howell, II, Deputy Attorney General, requests Qwest Corporation (Qwest) provide the following documents and infonnation, pursuant to Commission Rule of Procedure 225 , IDAP A 31.01.01.225 , on or before MONDAY, APRIL 14 2003. The Company is reminded that responses pursuant to Commission Rules of Procedure must include the name and phone number of the person preparing the document, and the name location and phone number of the record holder. Reference IDAP A 31.01.01.228. This Production Request is to be considered as continuing, and Qwest is requested to provide, by way of supplementary responses, additional documents that it or any person acting on its behalf may later obtain that will augment the documents produced. FIRST PRODUCTION REQUEST TO QWEST APRIL 1 , 2003 Please provide answers to each question; supporting workpapers that provide detail or are the source ofinfonnation used in calculations; the name and telephone number of the person preparing the documents; and the name, location and telephone number of the record holder. For each item, please indicate the name of the person(s) preparing the answers, along with the job title of such person(s) and the witness who can sponsor the answer at hearing. Request No.1: Please provide a map marking the current physical locations of the customer payment centers (CPCs) and the current payment agent locations for both Pocatello and Boise. Request No.2: Please provide a list of the payment agents in southern Idaho other than those located in Boise and Pocatello. Request No.3: Please provide the current total number of Qwest access lines in southern Idaho? How many of these access lines are for residential service? Request No.4: Does Qwest compensate its payment agents for accepting payments on behalfofQwest? Ifso, please explain the tenns of its compensation agreement(s) and the degree to which such agreements may vary from agent to agent. Request No.5: Are both of Qwest's CPC's in Boise and Pocatello: (a) physically accessible to customers with disabilities; (b) able to accept cash and make change for amounts paid in excess of the amount the customer wishes to pay; ( c) able to accept payment for less than the full amount due Qwest; (d) able to accept payment if the customer does not provide a copy of the bill or notice; (e) able to accept personal checks or money orders; (f) able to process electronic checks; (g) able to accept payment for both deposits and phone bills; and (h) able to provide payment receipts. If the answer is ", please explain why the CPC is not accessible or unable to provide the service in question. FIRST PRODUCTION REQUEST TO QWEST APRIL 1 , 2003 Request No.6: Are all of Qwest's payment agents in Boise and Pocatello: (a) physically accessible to customers with disabilities; (b) able to accept cash and make change for amounts paid in excess of the amount the customer wishes to pay; (c) able to accept payment for less than the full amount due Qwest; (d) able to accept payment if the customer does not provide a copy of the bill or notice; (e) able to accept personal checks or money orders; (f) able to process electronic checks; (g) able to accept payment for both deposits and phone bills; and (h) able to provide payment receipts. If the answer is ", please explain why the payment agent is not accessible or unable to provide the service in question. Request No.7: Are all of Qwest's payment agents in southern Idaho locations other than Boise and Pocatello: (a) physically accessible to customers with disabilities; (b) able to accept cash and make change for amounts paid in excess of the amount the customer wishes to pay; (c) able to accept payment for less than the full amount due Qwest; (d) able to accept payment if the customer does not provide a copy of the bill or notice; (e) able to accept personal checks or money orders; (f) able to process electronic checks; (g) able to accept payment for both deposits and phone bills; and (h) able to provide payment receipts. If the answer is ", please explain why the payment agent is not accessible or unable to provide the service in question. Request No.8: Are there any services currently being provided by the Boise and Pocatello CPCs that are not currently provided by payment agents in Boise and Pocatello? Request No.9: Do any of Qwest's payment agents in Boise or Pocatello charge customers a fee for processing payments? If so, please explain the amount of the charge and the reason why such a fee is charged. Request No. 10: Do any of Qwest's payment agents in southern Idaho locations other than Boise or Pocatello charge customers a fee for processing payments? If so, please explain the amount of the charge and the reason why such a fee is charged. Request No. 11: Do payment agents keep payment receipt records? If so, for what length of time are those receipts retained? FIRST PRODUCTION REQUEST TO QWEST APRIL 1 , 2003 Request No. 12: If a customer for whom disconnection of service is imminent pays at a payment agent, what steps must the customer take to avoid being disconnected? Do the steps necessary to avoid disconnection differ if the customer pays at the Pocatello or Boise CPC versus a payment agent? Request No. 13: Are customers able to pick up Qwest telephone directories at the Pocatello or Boise CPC? If so, are customers charged for each requested directory? If so, what is the charge? Are out-of-area Qwest telephone directories available at the Pocatello or Boise CPC? Request No. 14: For CY 2002, how many customers paid either in person or by using the on site drop box at the Pocatello CPC? Please provide a breakdown between residential and business class of service. Of the total number of customers, how many paid a deposit only? How many paid a bill on or before its due date? How many customers paid a bill after its due date? How many payments were made by customers using the on-site drop box? How many payments were made in cash? Request No. 15: For CY 2002, how many customers paid either in person or by using the on site drop box at the Boise CPC? Please provide a breakdown between residential and business class of service. Of the total number of customers, how many paid a deposit only? How many paid a bill on or before its due date? How many customers paid a bill after its due date? How many payments were made by customers using the on-site drop box? How many payments were made in cash? Request No. 16: If a customer makes a payment using the drop boxes at the Boise or Pocatello CPCs, how often are the drop boxes emptied and the payment recorded? Request No. 17: Do any payment agents have drop boxes available for the use of Qwest customers? FIRST PRODUCTION REQUEST TO QWEST APRIL 1 , 2003 Request No. 18: After the Pocatello or Boise CPC accepts a customer s payment, how long does it take for a customer s payment to be posted to the customer s account? Does the customer s account reflect the actual date payment was made at the CPC or the date payment was posted, if those dates are different? Request No. 19: After a payment agent accepts a customer s payment, how long does it take for a customer s payment to be posted to the customer s account? Does the customer account reflect the actual date payment was made to the payment agent or the date payment was posted by Qwest, if those dates are different? Request No. 20: If the CPCs are closed, how will Qwest comply with Rule 401 ofthe Commission s Utility Customer Relation Rules (IDAPA 31.21.01.401)? Specifically, how will Qwest accommodate customer requests for face-to-face meetings with Qwest representatives? Request No. 21: Will Qwest continue to keep drop boxes at the sites where the CPCs are located now if the CPCs are closed? Request No. 22: Please provide the hours of operation for the Pocatello and Boise CPCs. DATED at Boise, Idaho, this ,Jr-day of April 2003. \l~.G-r Donald L. Howell, II Deputy Attorney General Technical Staff: Carol Cooper Joe Cusick i:umisc/prdreglqwetO3. 1 Odhcjjwc FIRST PRODUCTION REQUEST TO QWEST APRIL 1 , 2003 CERTIFICATE OF SERVICE HEREBY CERTIFY THAT I HAVE THIS 1ST DAY OF APRIL 2003 SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO QWEST CORPORATION IN CASE NO. QWE-03- BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING: MARY S HOBSON STOEL RIVES LLP SUITE 1900 101 S CAPITOL BLVD BOISE ID 83702-5958 ADAM L SHERR QWEST 1600 7TH AVE ROOM 3206 SEATTLE WA 98191 CERTIFICATE OF SERVICE