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Home My WebLink About20030512Supp. Response of Qwest.pdf'107 STOEL ~~, HECEIVEO :: n r- 1\ : ,,- '-. ' !Xl ATTORNEYS AT lAW 2GOH11\~ \2 PM 5: 02 UT\lY:hESJ CO-iYi ~S\ON 101 S, Capitol Boulevard. Suite 1900 Boise. Idaho 83702 main 208.389.9000 fax 208.389.9040 www.stoeLcom May 12 2003 MARYS. HOBSON Direct (208) 387-4277 mshobson(iYstoel.com VIA HAND DELIVERY Jean D. Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Boise, ill 83702-5983 RE:Docket No. QWE-O3- Dear Ms. Jewell: Enclosed for filing with this Commission is an original and three (3) copies of QWEST' SUPPLEMENTAL RESPONSE TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF. Copies of Confidential Attachments A and B to Response No.4 are provided under separate cover. If you have any questions, please contact me. Thank you for your cooperation in this matter. Very truly yours It VV f!g~ Mary S. &r~bson :blg Enclosurescc: Service List Oregon Washington California U I a h Boise-156786.10029164-00012 idaho TO E L ~~, RECEIVED F!LED IX"' ,~.(-' '-_o 101 S. Capitol Boulevard. Suite 1900 Boise. Idaho 83702 main 208.389.9000 fax 208.389.90402003 MAY! 2 PM 5: 03 www.stoeLcom ATTORNEYS AT lAW lit)'i" ; f':;;:j; IC UTILiYH~S' CO:i1t1iSS!ON May 12, 2003 MARY S. HOBSON Direct (208) 387-4277 mshobson(iYstoe1.com VIA HAND DELIVERY PROPRIETARY AND CONFIDENTIAL Jean Jewell Deputy Attorney General Idaho Public Utilities Commission 472 West Washington Boise, ill 83702-5983 RE:Docket No. QWE-O3- Dear Ms. Jewell: Enclosed for filing with this Commission are an original and three (3) copies of Confidential Attachments A and B to Response No.4 to QWEST'S SUPPLEMENTAL RESPONSE TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF in the above-referenced matter. Also enclosed is an Attorney Certificate in support of this confidential filing. Thank you for your cooperation in this matter. Very truly yours~tvn~~~ Mary s. adbson :blg Enclosures Oregon Washington California Utah Boise-156788.10029164-00012 Idaho RECEIVED Mary S. Hobson (ISB #2142) Stoel Rives LLP 101 South Capitol Boulevard - Suite 1900 Boise, ill 83702 Telephone: (208) 389-9000 Facsimile: (208) 389-9040 mshobson0Moel.com FILED 2003 f~f\Y 12 PM 5: 02 Ie_I; ..; ;. 0HLIC UTILITIES COt1MISSION Adam L. Sherr (WSBA #25291) Qwest 1600 7th Avenue - Room 3206 Seattle, W A 98191 Telephone: (206) 398-2507 Facsimile: (206) 343-4040 asherr(q),qwestcom Attorneys for Qwest Corporation BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF QWEST CORPORATION'S PROPOSAL TO PHASE OUT BOISE AND POCA TELLO CUSTOMER pAYMENT CENTERS Case. No. QWE-O3- QWEST'S SUPPLEMENTAL RESPONSE TO FIRST 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 lih day of May, 2003. Qwest Corporation fJ::lie Stoel Rives LLP Adam L. Sherr Qwest Corporation Attorneys for Qwest Corporation QWEST'S SUPPLEMENTAL RESPONSE TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - Page 1 Boise-156787.10029164-00012 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 12th day of May, 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 .x.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 .x.Hand Delivery U. S. Mail Overnight Delivery Facsimile A?~# 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-156787.1 0029164-00012 Idaho Case No. QWE-03- STF Supp. 01-004S INTERVENOR:Staff of the Idaho Public Utilities Commission REQUEST NO:004S Supplemental Staff Request in regard to Qwest I s Response to Staff Request No. What is the fixed unit rate paid by Qwest for each walk-in payment processed? Please provide a copy of the contract with First Data Corporation. RESPONSE: Please see Confidential Attachment A for a copy of the contract with First Data Corporation. Please see Confidential Attachment B for the fixed unit rate paid by Qwest for each walk- in payment processed. Respondent:Sue Lanker Beth Jordan Idaho Case No. QWE-03- STF Supp. 01-014S INTERVENOR:Staff of the Idaho Public Utilities Commission REQUEST NO:014S Supplemental Staff Request in regard to Qwest I s Response to Staff Request No. 14. 1. Please explain what is meant by the term "processed" in regard to the 37,567 payments processed by the tellers at the pocatello CPC. 2. Please explain what happens with the payments received in the drop box (6,495 for 2002). Do the tellers at the CPC open these envelopes and make notes on customer accounts? Are the payments received in the drop box treated differently than those taken personally by the tellers? How long does it take for a payment to post that was placed in the drop box at the Pocatello CPU 3. Of the 37 567 payments processed by the tellers in the Pocatello CPC, are the 6 495 payments received in the drop box or the 699 payments handed to tellers included in that number. 4. Please explain the 699 payments that were handed to the tellers to be dropped in the mail. Did these payments come through the mail? Were the payments made in person? Were they addressed to the Pocatello address of the CPC? What happens to those payments? Were any of the 699 payments processed at the CPC? Were the 699 payments mailed somewhere else for processing? If , where were they mailed and how long would it take for a payment received in that manner to post to a customer s account? RESPONSE: 1. The teller will accept a payment from the customer , make a notation on the customer s account relative to the amount paid, and provide the customer areceipt. (As discussed in Response No., this is not the same receipt customers receive when making a payment with a payment agent. ). The payments are deposited locally in Pocatello while copies of billing receipts are sent via overnight mail to the Remittance Processing Services (RPS) Center in Denver. The customer payment amount is applied to the customer account by the RPS center typically within two business days. 2. As previously stated in Qwest' s response to Request No. 16, the drop boxes are emptied and payments are recorded daily by the tellers. The process is the same as described in the response to Supplemental Request No. 14. 3. The Pocatello CPC received and processed 37 567 payments directly from Qwest customers. In addition 6,495 payments were received in the drop box and 699 payments were mailed directly to the Pocatello CPC address at 455 Lewis. 4. Qwest' s response to Request No. 14 indicated that 699 payments are "given to the tellers to be dropped in the mail"After further investigation , it was discovered that the 699 payments were actually mailed directly to Pocatello CPC at 455 W. Lewis. These 699 payments were not made in person at the pocatello CPC. Payments that are mailed directly to the pocatello CPC are processed in accordance with Qwest's Qwest's Supplemental Response No. 14 subset number one. Respondent:Beth Jordan Larry Walters Susan Mohr Idaho Case No. QWE-03- STF Supp. 01- 015S INTERVENOR:Staff of the Idaho Public Utilities Commission REQUEST NO:015S Supplemental Staff Request in regard to Qwest' s Response to Staff Request No. 15. Please explain what is meant by the term "processed" in regard to the 644 payments processed by the tellers at the Boise CPC. Please explain what happens with the payments received in the drop box (6,682 for 2002). Do the tellers at the CPC open these envelopes and make notes on customer accounts? Are the payments received in the drop box treated differently than those taken personally by the tellers? How long does it take for a payment to post that was placed in the drop box at the Boise CPC? Of the 25,644 payments processed by the tellers in the Boise CPC, are the 682 payments received in the drop box or the 234 payments handed to tellers included in that number? Please explain the 234 payments that were handed to the tellers to be dropped in the mail. Did these payments come through the mail? Were the payments made in person? Were they addressed to the Boise address of the CPC? What happens to those payments? Were any of the 234 payments processed at the Boise CPC? Were the 234 payments mailed somewhere else for processing? If so, where were they mailed and how long would it take for a payment received in that manner to post to a customer's account? RESPONSE:1. The teller will accept a payment from the customer , make a notation on the customer s account relative to the amount paid, and provide the customer areceipt. (As discussed in Response No.5, this is not the same receipt customers receive when making a payment with a payment agent. ). The payments are deposited locally in Boise while copies of billing receipts are sent via overnight mail to the Remittance Processing Services (RPS) Center in Denver. The customer payment amount is applied to the customer account by the RPS center typically within two business days. As previously stated in Response No. 16 , the drop boxes are emptied and payments are recorded daily by the tellers. The process is the same as described in the response to Supplemental Request No. 14.3. The Boise CPC received and processed 25,644 payments directly from Qwest customers. In addition 6 682 payments were received in the drop box and 234 payments were mailed directly to the Boise CPC address at 999 Main Street.4. Qwest' s response to Request No - 14 indicated that 234 payments are given to the tellers to be dropped in the mail"After further investigation , it was discovered that the 234 payments were actually mailed directly to the Boise CPC at 999 Main St. These 234 payments were not made in person at the Boise CPC. Payments that are mailed directly to the Boise CPC are processed in accordance with Qwest' s Supplemental Response No - 14 subset number one. Respondent:Beth Jordan Larry Wal ters Susan Mohr Idaho Case No. QWE-03- STF Supp. 01-016S INTERVENOR:Staff of the Idaho Public Utilities Commission REQUEST NO:016S Supplemental Staff Request in regard to Qwest I s Response to Staff Request No. 16. Please explain what it means when "payments are recorded daily". How does that differ from "noted on the account"? If payments are placed in a drop box , are the payments opened at the CPCs and the customer s account updated to reflect that payment was made? Does that update consist of a written note on the customer s account or is the payment actually recorded in the Company s billing records for the customer? RESPONSE: Payments received in the drop box are recorded daily by placing a notation on the account recording the payment. These two phrases are synonymous in thisinstance. Payments placed in a drop box are processed on a daily basis as described in response to Supplemental No. 14. The notation placed on the account by the teller at the CPC does not impact the billing record for thecustomer. The impact on the billing record occurs once the payment is posted at the RPS center. Respondent:Beth Jordan Larry Wal ters Susan Mohr