20000830Comments.doc

JOHN R. HAMMOND
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5470

Street Address for Express Mail:
472 W WASHINGTON
BOISE ID 83702-5983

Attorney for the Commission Staff

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE JOINT APPLICATION
OF CITIZENS TELECOMMUNICATIONS COMPANY OF IDAHO AND COMMSOUTH COMPANIES, INC. FOR APPROVAL OF AN INTERCONNECTION AGREEMENT PURSUANT TO 47 U.S.C. § 252(e). )
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CASE NO. CTC-T-00-1

COMMENTS OF THE
COMMISSION STAFF

COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its Attorney of record, John R. Hammond, Deputy Attorney General, in response to Order No. 28467,
the Notice of Joint Application and Notice of Modified Procedure in Case No. CTC-T-00-1 issued on August 9, 2000, submits the following comments.
On July 17, 2000, Citizens Telecommunications Company of Idaho and CommSouth Companies, Inc. filed a Joint Application requesting approval of an interconnection agreement. The Joint Application states that the agreement was reached through voluntary negotiations without resort to mediation or arbitration and is submitted for approval pursuant to Section 252(e) of the Telecommunications Act of 1996.

STAFF ANALYSIS
Staff reviewed the terms and conditions of the Agreement and does not find any of the terms or conditions to be discriminatory. This Agreement is the first resale agreement submitted by Citizens. As the terms of this Agreement would be available to all competitors seeking to resell Citizens’ service if the Commission approves it, Staff does not find these terms to be discriminatory. Finally, as the Agreement increases the likelihood that competitors will decide to provide competition in Citizens’ service area, Staff concurs with the companies claim that the Agreement is consistent with the pro-competitive policies of the Commission, the Idaho Legislature, and the Telecommunications Act of 1996. Accordingly it is consistent with the public interest.

STAFF RECOMMENDATION
Staff recommends the Commission approve this Interconnection Agreement as filed.

DATED at Boise, Idaho, this day of August 2000.

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John R. Hammond
Deputy Attorney General

Technical Staff: Wayne Hart

WH:JH:gdk:i:umisc/comments/ctct001.jhwh
STAFF COMMENTS 1 AUGUST 30, 2000