20030424Supplemental 1st Response of Qwest.pdf

Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoel.com
RECEIVED 0F"lLED 0
2003 APR 24 PM ~: 15
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UTILITIES COt1i"1ISSIOH
Adam L. Sherr (WSBA #25291)
Qwest
1600 7th Avenue - Room 3206
Seattle, WA 98191
Telephone: [phone]
Facsimile: [phone]
asherr~qwest.com
Attorneys for Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF QWEST
CORPORATION'S PROPOSAL TO PHASE
OUT BOISE AND POCATELLO CUSTOMER
PAYMENT CENTERS
Case. No. QWE-O3-
QWEST'S SUPPLEMENTAL RESPONSE TO
FffiST PRODUCTION REQUEST OF THE
COMMISSION STAFF
Qwest Corporation, through its undersigned attorneys, hereby files the attached
supplemental response to the First Production Request of the Commission Staff.
Respectfully submitted this 24th day of April, 2003.
Qwest Corporation
L---.
Adam L. Sherr
Qwest Corporation
Attorneys for Qwest Corporation
QWEST'S SUPPLEMENTAL RESPONSE TO FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - Page 1
Boise-1561 13.1 0029164-00012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 24th day of April, 2003 , the foregoing QWEST'
SUPPLEMENTAL RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF was served upon the following parties:
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
o. Box 83720
Boise, ill 83720-0074
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Donald L. Howell, II
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ill 83720-0074
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
tYcana ~duMad
Brandi L. Gearhart, PLS
Legal Secretary to Mary S. Hobson
Stoel Rives LLP
QWEST'S SUPPLEMENTAL RESPONSE TO FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - Page 2
Boise-1561 13.1 0029164-00012
Idaho
Case No. QWE-03-
STF 01-010Sl
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:010Sl
Do any of Qwest I 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.
RESPONSE:
, all First Data Corporation payment agents in Idaho are free at this time.
However , two ACE locations (one in Nampa and one in Mt. Home), which do not
have payment agent contracts with Qwest, do also collect Qwest payments, and
do charge a one dollar fee to customers at this time.
Respondent:Beth Jordan
Sue Lanker
SUPPLEMENTAL RESPONSE dated 4/24/03:
On 4/23/03, Staff asked the following follow-up question:
In regard to Answer to Production Request No 10.
If Qwest has no contract with the ACE locations, how is it they are
authorized to take payments on behalf of Qwest? How is it they are
authorized to accept $1 fee from customers for taking those payments?
Are these businesses processing payments in the same manner as the other
payments agents? Are payments posted as often and in the same manner as
the other payment agents under First Data Corporation?"
Response:
Qwest has a contract with First Data Corporation (FDC) to provide an
outside walk-in payment agent network for Qwest. In addition to the FDC
contract , Qwest has an Independent Agency Agreement with ACE Cash Express
(ACE), which is a non-monetary, business agreement which allows ACE retail
chain to accept Qwest payments from our mutual customers for a $1
convenience fee. Ace is a convenience, non-contracted agent. The
is assessed and retained by ACE. As stated in response to Staff I s
for Production No. 10, the only ACE locations in Idaho that accept
payments are in Mt. Home and in Nampa; there are no ACE locations
accepting Qwest payments in either Boise or Pocatello.
$1 fee
Request
Qwest
ACE transmits payment notification via an electronic file that notes
payment on the customer account in the same manner as FDC. Like FDC, ACE
transmits a memo post four times daily.
Respondent:Beth Jordan