20180223Comments.pdf

SEAN COSTELLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 W . WASHTNGTON STREET (83702)
PO BOX 83720
BOISE, IDAHO 83720.0074
Tel: [phone]
Fax: [phone]
Idaho Bar No. 8743
RECEIVED
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Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. CPI.T.18-02
COMMENTS OF THE
COMMISSION STAFF
STAFF OF the Idaho Public Utilities Commission, by and through its Attorney of
record, Sean Costello, Deputy Attorney General, submits the following comments.
BACKGBOUND
On January 19,2018, Comcast Phone of Idaho, LLC ("Comcast Phone") filed an
Application with the Commission, pursuant to Procedural Order No.32217 and IDAPA
3 I .0 I .0 I . I 14, for registration as a wholesale provider of telecommunications service in Idaho.
Application at l.
STAFF ANALYSIS
Comcast Phone is a limited liability company organized in the State of Delaware and lists
its principal place of business as Philadelphia, Pennsylvania. Id. InMay 2016,Idaho's
Secretary of State certified that Comcast Phone is authorized to transact business in Idaho as of
May 24,2016. Id.;Exhibit A. Comcast Phone lists CT Corporation Services, 921 S. Orchard
St., Suite G, Boise, Idaho 83705, as its registered agent in Idaho. Id. at2.
ISTAFF COMMENTS FEBRUARY 23,2018
IN THE MATTER OF THE APPLICATION OF
COMCAST PHONE OF IDAHO, LLC FOR
REGISTRATION AS A WHOLESALE
TELECOMMUNICATIONS PROVIDER IN
IDAHO.
Comcast Phone is seeking authority to provide wholesale local telecommunications
services within the State of Idaho. Id. at l. Comcast Phone states that it has already negotiated
an interconnection agreement with Qwest Corp. d/b/a CenturyLink, which was filed with this
Commission on August 10,2017, and approved on August 24,2017. See Order No. 33855; Case
No. QWE-T-L7-02.
Comcast Phone states that it will comply with all applicable Idaho laws and Commission
Rules applicable to competitive wholesale providers of local telecommunication services and, if
it obtains numbering resources in Idaho, will be subject to all applicable numbering conservation
measures. Id. at3.
STAFF RECOMMENDATION
Staff has reviewed the Application by Comcast Phone for compliance with applicable
legal requirements to be registered as a wholesale provider of telecommunications services in
Idaho and believes the Company understands and agrees to comply with Commission Rules of
Procedure I 14 and Commission Order No.32277. Staff believes that the Company possesses the
requisite financial, managerial, and technical qualifications necessary to operate as a provider of
telecommunications services. Staff, therefore, recommends the Commission approve Comcast
Phone as a registered wholesale communications provider subject to the following conditions:
l. Comcast Phone shall comply with number pooling and reporting requirements of the
North American Numbering Plan Administrator, as set forth in Commission Order
No.30425;
2. Comcast Phone shall provide necessary reports and contribute as appropriate to the
Idaho Universal Service Fund, Idaho Telecommunications Relay System, Idaho
Telecommunications Service Assistance Pro gram; and
3. Comcast Phone shall comply with all future reporting requirements deemed
appropriate by the Commission for competitive telecommunications providers.
2STAFF COMMENTS FEBRUARY 23,2018
Respectfully submitted this z,"day of February 2018.
L
Sean Costello
Deputy Attorney General
Technical Staff: Daniel Klein
i :umisc:comments/cpit I 8.2scdk comments
JSTAFF COMMENTS FEBRUARY 23,2018
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 23'd DAY OFFEBRUARY2OI8,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. CPI-T-18-02, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
MICHAEL C SLOAN
DAVIS WRIGHT TREMAINE
STE 8OO
1919 PENNSYLVANIA AVE NW
WASHINGTON DC 20006
E-MAIL: rnichaelsloan(idrvt.corn
BETH O'DONNELL
DIR REGULATORY AFFAIRS
COMCAST PHONE OF IDAHO
1701 JFK BLVD 55TH FLOOR
PHILADELPHIA PA 19103
E-MAIL: beth-odonnell(0corncast.com
CERTIFICATE OF SERVICE