20130610_4075.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KJELLANDER
COMMISSIONER REDFORD
COMMISSIONER SMITH
COMMISSION SECRETARY
LEGAL
WORKING FILE
FROM:CAROLEE HALL
DATE:JUNE 7,2013
RE:FREMONT TELECOM’S TARIFF ADVICE NO.13-03 REQUESTING
COMMISSION APPROVAL TO CORRECT BILLING DISCREPANCIES
BETWEEN NUMBER RESERVE AND SEASONAL/VACATION
SERVICE OFFERINGS.ALSO REQUESTING TO ELIMINATE
NUMBER RESERVE SERVICE.THE COMPANY REQUESTS A JULY 1,
2013 EFFECTIVE DATE.
BACKGROUND AND DISCUSSION
Blackfoot Telecommunications Group (“BTG”)recently acquired Fremont from
FairPoint Communications.See Case No.FRE-T-12-01.As a result of the acquisition,BTG is
actively working toward a conversion in billing and other systems from FairPoint to Blackfoot.
In this process,Blackfoot has identified a number of billing problems.One such problem
identified with this filing is that of Number Reserve and Seasonal/Vacation Service.
Currently Fremont offers a Number Reserve service at a monthly rate of $6.44 for
residential and $10.20 for businesses.As tariffed.Number Reserve is a product that was to
reserve a customer’s telephone number for future use when the customer was away from their
vacation home.This product was not to have any dial tone or call features associated with it.
Unfortunately,this service was confused with seasonal/vacation service and some of the
customer accounts were provisioned incorrectly.Seasonal/Vacation service,as tariffed,is
offered at a 50%discount on the customer’s flat monthly local service rate.The discounted rate
is currently SI 2.90 and $21.00 for residential and business,respectively.
With this filing,the Company is attempting to correct the provisioning problems and to
migrate the Fremont customers over to the Blackfoot Telecommunication’s billing network.As
part of the migration,the Company is seeking Commission approval to eliminate the number
DECISION MEMORANDUM JUNE 7,2013
reserve service.This is due in part with the Numbering Orders at the FCC that do not allow for
reserving numbers for extended periods of time.Therefore,the Company proposes that at the
end of this vacation season all customers will be migrated to Seasonal/Vacation service.
As part of the migration the monthly local residential rate must increase to $14.00 and the
monthly business rates will remain at $21.00.This increase in the residential rate is necessary in
order for the Company to comply with the FCC’s floor rates as prescribed in 47 CFR §54.318.
Moreover,the residential rate will now comport with the NECA and USAC requirements thereby
eliminating any penalties the company would have been subject to.
The Company provided Staff with detailed cost studies for the proposed transitions.As
proposed,the revenue impact for the Company will be de mizitnus.Moreover,the Company will
avoid imputation costs now that it is in compliance with the FCC’s price floor requirement.
STAFF RECOMMENDATION
Staff has reviewed this filing and finds the proposal offered by the Company to eliminate
Number Reserve and transfer customers over to Vacation Service is a reasonable solution to the
mis-provisioned and questionable business practices of Number Reserve.
Staff understands that the small residential rate increase is needed to comply with the
FCC’s rate flooring as well as NECA and USAC guidelines.This small rate increase ‘viii only
affect a small number of seasonal vacation customer’s in the Island Park area.
Staff appreciates the Companies efforts to minimize the transition effects on the Fremont
customers and recommends approval of this filing with an effective date of July 1,2013.
Does the Commission agree?
U :4
aroke Hall
i:udmemos/Frcmont Telecom 13-03
DECISION MEMORANDUM JUNE 7,2013