19990822Comments.doc

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3283

Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983

Attorney for the Commission Staff

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION OF AVISTA COMMUNICATIONS OF IDAHO, INC. FOR APPROVAL OF ITS TOLL DIALING PARITY IMPLEMENTATION PLAN. )
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CASE NO. AVC-T-99-2

STAFF COMMENTS

COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Weldon B. Stutzman, Deputy Attorney General, and in response to the Notice of Application and Notice of Modified Procedure issued on August 16, 1999, submits the following comments.

BACKGROUND
On August 5, 1999, AVISTA Communications of Idaho Inc. (AVISTA) filed its Application for approval of an intrastate, intraLATA toll dialing parity plan. AVISTA filed its Implementation Plan in compliance with the Telecommunications Act of 1996 (the Act), Section 251 which states:

(b) OBLIGATIONS OF ALL LOCAL EXCHANGE CARRIERS.-Each local exchange carrier has the following duties (emphasis added):

DIALING PARITY.-The duty to provide dialing parity to competing providers of telephone exchange service and telephone toll service, and the duty to permit all such providers to have nondiscriminatory access to telephone numbers, operator services, directory assistance, and directory listing, with no unreasonable dialing delays.

Avista is a competitive local exchange carrier (CLEC) and is filing its plan to comply with the FCC order for areas of the state in which the Company is certified to provide local exchange service.

SUMMARY OF PLAN
AVISTA anticipates it will fully implement the 2-PIC methodology by August 30, 1999. On December 4, 1998, AVISTA obtained its certification to provide local service in all U S WEST territories. Recently, the Company filed an Application to extend its certificated area to include the GTE service area in northern Idaho. Coincident with the certification(s), AVISTA is implementing full 2-PIC (intraLATA toll and interLATA) dialing parity, allowing its customers to pre-subscribe to one carrier for all interLATA calls and to the same or another carrier for all intraLATA toll calls.
Staff believes the 2-PIC implementation plan submitted by AVISTA satisfies the guidelines of the FCC.

Customer Notification
With its implementation of services in the state of Idaho, AVISTA employees who communicate with the public accepting orders and serve in customer service, explain to customers the availability of 2-PIC equal access. The employees then assist customers in making an initial PIC choice and in changing a PIC choice for intraLATA and interLATA calls. Staff believes that this practice comports with the Federal guidelines and is fair and reasonable.

IntraLATA Carrier for New Customers
AVISTA will inform new customers that they may choose both an interLATA and intraLATA toll carrier when taking the customers order. If the new customer does not affirmatively choose an intraLATA toll carrier they must then dial an access code to route intraLATA toll calls until they select a presubscribed intraLATA toll carrier.
Staff believes this practice is reasonable and comports with other plans filed with the Commission.

PIC Changes and Charge
AVISTA will charge $5.00 for each PIC change. If a customer requests a simultaneous intraLATA and interLATA PIC change, then that customer is assessed $5.00 for the combined change charge.

Cost Recovery
AVISTA did not request any cost recovery methodology in its plan.

Proposed Implementation Schedule
AVISTA anticipates having the methodology for dialing parity implemented by August 30, 1999 in conjunction with its offering of local exchange service.

Staff Recommendation
Staff recommends that the Commission approve AVISTA’s intraLATA toll dialing parity practices as presented in its plan.

Respectfully submitted this day of August 1999

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Weldon Stutzman

Technical Staff: Carolee Hall

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STAFF COMMENTS 3 AUGUST 23, 1999