fiontier~ RE: Case No. 09- BY FACSIMILE AND U.S. MAIL (304) March 3 1, 2009

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1 fiontier~ 3 Legal Department 180 South Clinton Ave. Rochester, NY 'rei: Fax: gregg.sayre@front~ercorp.com BY FACSIMILE AND U.S. MAIL (304) March 3 1, 2009 Ms. Sandra Squire Executive Secretary West Virginia Public Service Commission 201 Brooks Street Charleston, WV ow RE: Case No. 09- Dear Ms. Squire: -T-PC -Citizens Telecommunications Company of West - - Virginia, dba Frontier Communications of West Virginia; Petition for Approval of a New Billing Format Attached for filing please find the original and 12 copies of Frontier's Petition for Approval of a New Billing Format. This Petition is filed pursuant to the Commission Order adopted on April 24,2007 in Case No T-PC, which directed Frontier to file a new case regarding this matter on or before January 5,2009. Frontier apologizes to the Commission for the late filing, and respectfully requests the Commission to follow the process established in the April 24, 2007 Order for the consideration of this Petition. Veryjruly yours, firegg. Sa Assiktant Secretary GCS : hmj Enc. (original + 12) cc: See enclosed certificate of service

2 STATE OF WEST VIRGINIA PUBLIC SERVICE COMMISSION CHARLESTON Case No. 09- O WT-PC CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA, dba FRONTIER COMMUNICATIONS OF WEST VIRGINIA, a public utility, Bluefield, Mercer County. Petition for approval of a new billing format. PETITION OF FRONTIER COMMUNICATIONS OF WEST VIRGINIA FOR APPROVAL OF A NEW BILING FORMAT Citizens Telecommunications Company of West Virginia doing business as Frontier Communications of West Virginia ("Frontier") respectfilly petitions the Commission for approval of a new billing format, and respectfully states as follows: 1. On April 24,2007 the Commission issued an Order in Case No T-PC that among other things established a test period between April 24,2007 and November 1,2008 to determine whether Frontier's customers benefited from the additional information regarding bundled services that the Commission allowed Frontier to provide on its bills, and in particular, the total bundle price. The Commission also directed Frontier to file a new case on or before January 5,2009 and provided a one-month period after Frontier's filing for Staff, CAD or other interested parties to respond to Frontier's petition. Frontier apologizes to the Commission for not making this filing at the time directed by the Commission, and requests the Commission to accept the filing of this Petition at this time. Frontier respectfully requests the Commission to allow the same one-month period for responses to this Petition and otherwise to follow the process for consideration set forth on the April 24, 2007 Commission Order,

3 2 2. During the test period, Frontier s bills reflected the total bundle price as a line item for Frontier s bundled services. In this period of time Frontier received more than 350 complaints of all kinds. Not one of these complaints was related to understanding the bill or to the bundle on the bill. Frontier submits that this lack of complaints is strong evidence that consumers expect to be billed for bundles the way Frontier advertises them - as a single package with a single price. 3. In light ofthe Commission s April 24,2007 Order, the Commission s Rules and the results of the test period, Frontier hereby offers for Commission approval a new billing format, as set forth in Exhibit 1. The following are the salient features of Exhibit 1 : (a) The most critical details of Exhibit 1 are on page 3, where the charges are presented, The left hand column on page 3 shows the bundle with a single line-item price, with the components of the bundle listed below. (b) The right hand column on page 3 presents a breakdown of the total costs of each category of service, or bucket, for the current month s charges with a sub-breakdown of the elements of the Basic Charges bucket. The amounts in the Basic Charges bucket include the line charge and applicable State and Federal taxes and surcharges including the WV Telecom Relay Service Charge. Any abbreviations in the right hand column are spelled out in full in the presentation of the charges in the left hand column. (c) The explanation above the buckets in the right hand column tells the customer precisely what amount must be paid in order to prevent the loss of basic local service. The referenced amount is Previous Basic Charges, which is the past due amount (if any) for basic local service. (d) The DirectoryiNon-Reg bucket includes items associated with directory listings, directory advertising and applicable State and Federal taxes. (e) The Toll bucket includes items associated with long distance charges

4 3 including long distance plans, directory assistance, operator services, and applicable State and Federal taxes and surcharges. (0 The Optional Services bucket includes items associated with features, inside wire maintenance, E-91 1 surcharge, and applicable State and Federal taxes. (g) The 900 Pay-Per-Call bucket includes items associated with placing calls to a 900 number along with applicable State and Federal taxes. (h) (i) Dish Network is for satellite television Frontier will show only the buckets applicable to the particular customer in the breakdown in the right hand column. The customer on Exhibit 1 only has charges for Basic, Directory / Non-Reg, and Toll so these are the only buckets that appear on the invoice. 4. Attached as Exhibit 2, is a breakdown ofhow the current charges on the sample bill in Exhibit 1 are allocated into the various buckets. 5. Frontier submits that Commission approval of the attached bill format is in the public interest. It reflects the results of the test period by continuing to show the price of a bundled service as a line item, which Frontier submits is the way that customers expect to be billed. It provides a detailed and monthly breakdown of what is included in the bundle. Finally it provides a breakdown by bucket of all charges, and makes it much more clear what amount must be paid to retain basic local service only. Frontier submits that the proposed billing format is both clearer and more useful to the consumer than Frontier s past or existing billing statements. 6. Attached as Exhibit 3 is a proposed Notice to be published one time statewide, advising of the purposes of the case, the ability to participate, and the deadline for responses to Frontier s Petition. WHEREFORE, Frontier respectfully requests the Commission:

5 4 (1) to accept this Petition for filing; (2) to initiate a new case and provide for a 30 day period for Staff, CAD or other interested parties to file responses or comments; and (3) to approve the proposed new billing format. Respectfully Submitted, CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA 180 South Clinton Avenue Rochester, NY tel fax March 31,2009 Citizens Telecommunications Company of West Virginia

6 _ -- - Page 1 of 4 d Welcome to the New Frontier j I - Account Summary -_._- Check out for great products, special offers and complete customer service information. I I I f... Date Due 2112/09 Billing Date 1119/09._.... Contacting Us Your - Personal identification - Number is ~ ~ Billing Questions Residential HARD DRIVE BACKUP Afraid of losing your precious photos and documents? Backup your digital photos, documents, music and E.maii. UNLIMITED PC TECH SUPPORT Frustrated by computer issuos and have nowhere to turn? Add Unlimited PC Tech Support and Frontier will solve your problems for you. Protection is simple with Frontier Peace of Mind. Call us today at or log in at WerPeaceofMinf = 'This price requires a one.year agreement and subscription to Frontier High-speed Internet. Limit 5 PC's per agreement. Other plans available for both Frontier and nonjrontier customers, Residential customers only. Other restrictions may apply. Applicable taxes and surcharges apply. Unlimited PC tech support is as described at rm.frontlrrhrlp.com/aboutpom,cfm PAYMENT STUB fr c - ont-rer. Welcome to the New Fron+aer 1398 S. WOODLAND BLVD., DEIAND, FL _-_._ manifest line Total Amount Due $ Date Due 2/1 2/ Account ----_- 3c4- Please do not send comrpondencs with your payment. Make checks peyrme lo Frontlor. Amount Enclosed f! _ T Check here for changing your billing address (see page 2) L_i Number FRONTIER PO BOX ROCHESTER NY l~~~i'"i'~"i~'"ii~~'ii'''~iii~ii'iii~iii~

7 fi%n+ierd Welcome to the New Frontier Date of Bill Account Number # Page 2 of 4 1 I1 9/09 tiow TO PAY YOZJFt UI LL Please mail your payment using the retum envelope provided. Sending a check to pay your account authorizes us to use your check to initiate an ACH (Automated Clearing House) debit in the amount of your check, from the account on which your check is written. A debit could be transacted as early as the day your check is received. Include the payment stub to ensure proper credit. If, you pay in person, bring your entire bill, including the payment stub, to an authorized payment location. Be sure to write your account number on your check. QUESTIONS AUOUT YOUR BILL If you have any questions, please call the billing inquiry number that appears on the front of your bill. For written inquiries, always include your account number, then mail your correspondence to the following address: Frontier 1398 S. Woodland Blvd Deland, FL I PREVIOUS PAYMENTS You may have sent a payment that was not processed in time to reflect on this billing statement. If so, just deduct that amount defo# sending your current payment. PAST DUE BALANCE Any past due amount should be paid immediately. The Amount of Current Billing Due By date printed on your bill indicates when we expect to receive payment for your current charges only. LATE PAYMENT FEES A late payment fee of 1.O%, calculated monthly, may be assessed if your payment is not received by the date shown on the first page of this bill and the unpaid balance is $50 or more. TREAI MENT CHARGES A Treatment Charge may be assessed if your account is delinquent for 3 consecutive months and the balance is greater than $99. SUSPENSION FOR NON-PAYMENT As a customer, you are responsible for all legitimate charges on your telephone biil. Non-payment of basic local service charges can result in disconnection of your basic local service and/or collection action. Frontier Choices Tier bundles may include basic local services and non-basic services. Non-payment of basic local service charges within the bundle may result in disconnection of your basic local services. Non-payment of charges for any other services on your bill such as 900 charges, long distance charges, custom calling features, caller ID, voice mail, inside wire maintenance, and internet may result in termination of those services. You may request blocking of 900 and long distance service. Frontier and other carriers providing your service have a toll-free number on the summary portion of your bill for inquiries about changes or to dispute charges. If you have any questions about your charges, call the number listed on the summary page of your bill for the carrier providing the service. Eased on state regulatory and notice requirements, once your bill is past due some or all of your service may be suspended. Charges may apply to reconnect service that has been interrupted. In addition, a deposit may be required in order to reestablilsh your credit RETURNED CHECKS In some states, a fee may apply to a check returned by the bank for any reason. ADDITIONAL INFORMATION Please consult your local Frontier Directory for additional billing and service information, CR indicates the amount shown is a credit. Name: Address: _I._ Account Number Changing your billing address Use this space or login to My Account at to change the mailing address where we send your bill. Allow 2 billing cycles for the address change to take effect. W00A City: StateZiD: Home Phone: Business Phone: Address:

8 - d Welcome to the New Frontier Monthly Service from 1/19/09 to Pty Dewription 304 Charge Frontier Dioital Phone Service ies 1.Pty Premium Calling Unlimited US Features Unlimited US Inside Wire Maintenance Res Bus/Res Non Published Number Total Monthly Service Charges One Tlme Charges and Credits Frontier -Detailed Below Total One Time Charger and Credits oo 1.oo Page 3 of 4 1 I1 9/09 Account Number 3 o n CUSTOMER TALK If your bill shows a Previous amount, Current Charges remain due by the Date Due shown. All of your bill charges must be paid each month to keep your account current and avoid collection activities, including a notice of possible disconnection of service. To avoid disconnection of local sewice, the Previous Basic Charges should be paid immediately. Taxes and Other Charges Federal Charges Frontier Federal Tax - Federal Subscriber Line Charge Federal USF Recovery Charge Svc Provider Num Port Frontier Corn of America FCA Long Distance - Federal USF Surcharge Total Federal Charges State and Other Charges Frontier WV State Sales Tax WV Telecornm Relay Svc Sur WV Webster Cnty E911 Char Total State and Other Charges Total Taxer and Other Charges Subtotal I TOTAL Detail of Frontier Long Distance Calls Toll charged to 30 Ref X Date -in *Type Place and Number Called Charge 1 DEC 20 7:43P 1 DN NATL D.A. WV (865) oo Legend Call Types: DN. Night - Description Basic Charges Primary Fed Sub L Res 1-Pty Premiu Svc Provider Num WV Telecornm Re1 Directoty/Non-Reg Optional Services Toll Total Current $36.81 $7.33 $29.00 $0.38 $0.10 $1.60 $8.88 $33.85 $81.14 Previous $42.68 $ $0.00 $0.00 $0.00 $3.20 $ $44.56 $ "IMPORTANT MESSAGE ABOUT YOUR AREA CODE" West Virginia will exhaust all available phone numbers under the 304 area code by the end of 2008 requiring the addition of a new Area Code. The West Virginia Public Service Commission has established the Overlay method for implementing the new Area Code of 681. In the Overlay methodology, all existing telephone numbers in the state remain unchanged, some new telephone numbers in the state will be assigned a new area code, and all in-state telephone calls, including local calls, will require the caller to use ten-digit dialing. The term ten-digit dialing is used to describe the overlay requirement that a user dial the 304 or 681 area code and the seven-digit telephone number for local calls. Your current local calling areas will not change. Any calls that did not incur a toll charge prior to the areas code changes will continue to be Inclusive in your current plan. Frontier offers bundled local and unlimited long distance packages starting at $39.99 (plus tax and applicable surcharges). Watch for additional information in your local Frontier Phone Directory or call the Customer Service Rep at for residential questions and for business questions. You can also find information on our website at You will need to enter your phone number then select "New WV Area Code Information" from the red box on the left side of the screen. - - "'IMPORTANT CUSTOMER INFORMATION"'

9 ct/ Welcome to the New Frontier Account Number Page 4 of 4 1 I1 9/09 Effective January 1,2009, the Federal USF Recovery Charge is decreasing from 11.4% to 9.5% of interstate retail revenues. The Federal Universal Service Fund (USF) helps many of our customers nationwide through support of investments in high-cost areas that keeps service affordable in Frontier's rural markets, and by providing discounts on communications services purchased by schools, libraries and rural health care providers. The money Frontier receives from the Fund allows us to continue to invest in bringing advanced services to all ot our customers. If you have Frontier as your long distance carrier, the Long Distance USF Recovery Charge is 9.5%. **IMPORTANT CUSTOMER INFORMATION*' After February 17, 2009, a television receiver with only an analog broadcast tuner will require a converter box to receive full power over-the-air broadcasts with an antenna because of the Nation's transition to digital broadcasting. Analog-only TVs should continue to work as before with satellite and cable TV services, low-power N stations, gaming consoles, VCRs, DVD players, and similar products. Information about the DTV transition is available from or Frontier at and and from or DTV-2009 for information about subsidized coupons for digital-to-analog converter boxes. Frontier will help you with the solution you may need. Call us today at

10 Exhibit 2 Citizens Telecommunications Company of West Virginia dba Frontier Communications of West Virginia Breakdown of Buckets under CUSTOMER TALK Basic Charges Primary Fed Sub. L SLC 9.5% USF Surcharge 3% Fed Tax on SLC and USF Sur Res 1 -Pty Premiu Svc Provider Num Svc Provider Num Prt 9.5% USF Surcharge 3% Fed Tax on LNP and USF Sur WV Telecomm Re1 Directory/Non-Reg Bus/Res Non Published Number 3% Fed Tax Optional Services Inside Wire Maintenance Res Unlimited US Features WV Webster Cnty E91 1 Char 6% State Sales Tax on IWM Toll Unlimited US Features National DA 9.5% USF Surcharge on LD $ 6.50 $ 0.62 $ 0.21 $ 0.34 $ 0.03 $ 0.01 $ 1.55 $ 0.05 $ 4.99 $ 0.99 $ 2.60 $ 0.30 $ $ 1.00 $ 2.85 Current $ $ 7.33 $ $ 0.38 $ 0.10 $ 1.60 $ 8.88 $ $ 81.14

11 Exhibit 3 NOTICE The purpose of this notice is to advise the public that Citizens Telecommunications Company of West Virginia, doing business as Frontier Communications of West Virginia, has petitioned the West Virginia Public Service Commission to modify its billing format to include bundles shown at the bundle rate, listing the components of the bundle. This petition asks for approval of the new bill format that includes a breakdown of the charges by category, showing the amount a customer must pay to prevent loss of basic local phone service, with detail added to the Basic Charges category. Any persons interested in commenting upon the petition for approval of the new bill format must file their comments, supported by facts and arguments, with the West Virginia Public Service Commission within thirty (30) days of the publication of this notice. All comments must be sent to: Executive Secretary, Public Service Commission, 201 Brooks Street, Charleston, WV

12 Case No T-PC CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA, dba FRONTIER COMMUNICATIONS OF WEST VIRGINIA, a public utility, Bluefield, Mercer County. Petition for Approval of a New Billing Format CERTIFICATE OF SERVICE I, Gregg C. Sayre, Assistant Secretary of Citizens Telecommunications Company of West Virginia, hereby certify that I have served a copy of the foregoing Petition of Frontier Communications for Approval of a New Billing Format, upon the potentially interested parties listed below, by First Class United States Mail, postage prepaid this 3 1 st day of March, 2009: Patrick W. Pearlman, Esq. Consumer Advocate Division 700 Union Building 723 Kanawha Boulevard, East Charleston, WV Robert R. Rodecker, Esq. Counsel, AT&T Communications of WV PO Box 3713 Charleston, WV James V. Kelsh, Esq. Counsel, NTELOS of West Virginia, Inc. PO Box Charleston, WV Blaine A. Braithwaite, Executive Director South Bluefield Neighborhood Association 663 Rockbridge Street Bluefield, WV Barbara J. Direnzo Armstrong Telephone Company One Armstrong Place Butler, PA Norman Googel Rob Bastress Office of the Attorney General PO Box 1789 Charleston, WV Ohia Wein, Esq. National Consumer Law Center, Inc Connecticut Avenue, NW, Suite 510 Washington, DC Frank Bellinetti, State Director AARP West Virginia 300 Summers Street, Suite 400 Charleston, WV Heather E. W. Walsh Mountain State Justice, Inc. 922 Quarrier Street, Suite 525 Charleston, WV Ted Boettner West Virginia Citizen Action Group 1500 Dixie Street Charleston, WV Joseph J. Starsick, Jr., Esq. Counsel, Verizon West Virginia hc. Goodwin & Goodwin PO Box 2107 Charleston, WV Assistant Secretary

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