20201215Comments.pdf

MATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.10655
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF CLEAR RATE )COMMUNICATIONS,INC.'S APPLICATION )CASE NO.CRC-T-20-01FORACERTIFICATEOFPUBLIC)CONVENIENCE AND NECESSITY TO )PROVIDE RESOLD AND NON-FACILITIES )COMMENTS OF THE
BASED LOCAL EXCHANGE SERVICES )COMMISSION STAFF
THROUGHOUT IDAHO )
STAFF OF the Idaho Public Utilities Commission,by and through its Attorneyof
record,Matt Hunter,Deputy Attorney General,submits the followingcomments.
BACKGROUND
On October 14,2020,Clear Rate Communications,Inc.("CRC"or "Company")applied
for a Certificate of Public Convenience and Necessity ("CPCN")to provide resold basic local
exchange telecommunication services in Idaho pursuant to procedural Rule l14 (IDAPA
31.01.01.114)and Order No.26665.
STAFF ANALYSIS
CRC is incorporated in the State of Michigan and is authorized to do business in Idaho.
Its main corporate address is 2600 W.Big Beaver Rd.,Suite 450,Troy,MI 48084.It is
registered with the Idaho Secretary of State as a foreign business corporation.Application,
Exhibit 2.CRC plans to offer service statewide.
STAFF COMMENTS 1 DECEMBER 15,2020
CRC provided the names and addresses of its officers and owners,as well as relevant
corporate financial information.CRC asserts it has reviewed the Commission's applicable rules
and agrees to provide service in accordance with those rules.
STAFF RECOMMENDATION
Staff has reviewed CRC's Application and believes CRC understands the Commission's
rules and requirements related to the provision of telecommunication services in Idaho.Staff
believes CRC's Application fulfills the requirements of the procedural Rule l14 and Order No.
26665.Staff also believes CRC possesses the requisite financial,managerial,and technical
qualifications necessary to operate as a provider of telecommunications services.
Therefore,Staff recommends approval of CRC's Application for a CPCN,subject to the
followingconditions:
1.CRC complies with number pooling and reporting requirements of the North
American Numbering Plan Administrator,as set forth in Commission Order No.30425;
2.CRC provides necessary reports and contributions as appropriateto the Idaho
Universal Service Fund,Idaho Telecommunications Relay Services,Idaho Telecommunications
Service Assistance Program,and complies with all future reporting requirements deemed
appropriateby the Commission for competitive telecommunications providers;
3.Prior to issuance of the CPCN,CRC files a final price list outliningall its rates,
terms,and conditions with the Commission;and
4.CRC provides three reports to the Commission indicating the number of basic local
exchange customers it has and the services being offered.Those reports will be due as follows:
a.April 10,2021
b.August 16,2021
c.December 13,2021
If the Company fails to provide the three reports,CRC shall relinquish its CPCN and all
telephone numbers it has been assigned or the Commission will by its own order revoke the
Company's CPCN.
5.If CRC is not providing basic local exchange service by the time the third report is
due,the Commission by its own order will revoke the Company's CPCN.
STAFF COMMENTS 2 DECEMBER 15,2020
Respectfully submitted this 15th day of December 2020.
Matt Hunter
Deputy AttorneyGeneral
Technical Staff:Daniel Klein
i:umisc/comments/crct20.lmhdkcomments
STAFF COMMENTS 3 DECEMBER 15,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 157"DAY OF DECEMBER 2020,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF,IN
CASE NO.CRC-T-20-01,BY E-MAILING A COPY THEREOF,TO THE
FOLLOWING:
MARK LAMMERT
COMPLIANCE SOLUTIONS INC
242 RANGELINE RD
LONGWOOD FL 32750
E-MAIL:regulatory esilonewood.com
SECRETARY
CERTIFICATE OF SERVICE