20130725Frontier Comments in Support.pdf

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July 23,2013
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472W. Washington
Boise, ID 83720
RE: Comments in Support of CenturyLink's Request for Partial Waiver of the
Requirements of IPUC Order No. 29841 - Case Nos. QWE-T-13-03, CEN-T-13-03,
CGS-T-13-03
Dear Ms Jewell,
Please find enclosed the original and seven copies of comments on behalf of Frontier
Communications Northwest lnc. and Citizens Telecommunications Company of Oregon
(collectively, "Frontier Communications") in support of the above mentioned
CenturyLink petition.
Sincerely,
Wh d,jvn
Renee Willer
Regulatory Manager
Frontier Communications Northwest Inc.
20575 NW Von Neumann Drive
Beaverton, OR 97006
s03.645.7909
[e-mail]
Enclosures
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
i, lr,
IN THE MATTER OF THE REQUEST FOR)
PARTIAL WAIVER OF THE
REQUIREMENTS OF IPUC ORDER
NO.29841
) QWE-r-13-03) CEN-T-13-03
) CGS-T-13-03
)) COMMENTS OF
) FRONTIER COMMLINICATONS
Frontier Communications submits the following comments in response to the Notice
of Application and Notice of Modified Procedure in Case Nos. QWE-T-13-03, CEN-T-
13-03 and CGS-T-13-03 issued by the Commission on July 3,2013. Frontier
Communications Northwest Inc. and Citizen's Telecommunications Company of Idaho
(Collectively Frontier Communications) are designated Eligible Telecommunications
Carriers ("ETC") in Idaho and are interested in the outcome of this proceeding.
On June 7,2013 the collective CenturyLink Companies filed a Petition for Partial
Waiver of the ETC reporting requirements set forth in IPUC Order 20841, specifically
the requirement to file a two-year network improvement plan. The Commission
subsequently issued Order No. 32844, Notice of Application and Notice of Modified
Procedure and invited comments from interested parties as to whether or not the waiver
request, if approved, should apply to all ETCs in addition to the Petitioner CenturyLink.
ln its Petition, CenturyLink noted that the FCC issued an order waiving the five-year
plan requirement for 2013, noting that the agency has not completed all the steps
necessary to provide a final form for use by ETCs and is still in the process of
formulating their new reporting requirements. In light of this action, it does not make
prudent sense to prepare and submit a two-year network improvement plan for Idaho
that is not in conformance with the 2013 FCC requirements.
Frontier Communications supports the Petition for Partial Waiver submitted by the
CenturyLink companies and requests that the Commission grant the Partial Waiver and
have it apply to all Idaho Eligible Telecommunications Carriers in the state of Idaho.
Respectfully submitted this 23'd day of July, 2013.
Wh d,i/,r
Renee M. Willer
Authorized Representative
Frontier Communications
20575 NW VonNeumann Drive
Beaverton, OR 97006
CERTIFICATE OF SERVICE
I certiff that on the23rd day of July 2013,1served the foregoing Comments of Frontier
Communications by electronic mail to the following individuals
Jean Jewell
Idaho Public Utilities Commission
472 W. Washington Street
Boise,lD 83702
Jean [e-mail]. gov
Mary S.Hobson
Attorney for CenturyLink
999 Main, Suite 1103
Boise, Idaho 83702
[e-mail]
Weldon Stutzman
Deputy Attorney General
Idaho Public Utilities Commission
472 W . Washington Street
Boise,ID 83702
Weldon.stutzman@puc. idaho.gov
Cynthia A. Melillo
Attorney for Idaho Telecom Alliance
8385 W. Emerald Street
Boise,ID 83704
[e-mail]
Dated this 23rd day of July, 2013
W?n aiar
Renee Willer
State Regulatory Manager - Frontier Communications