19980915Parties Letter.doc

September 15, 1998

Mary S. Hobson
Stoel Rives LLP
101 S. Capitol Blvd, Suite 1900
Boise, ID 83702-5958

M. W. Richards
Moffatt, Thomas, Barrett, et al
PO Box 829
Boise, ID 83701-0829

Barbara L. Snider
Jacqueline R. Kinney
Citizens Telecommunications Co of Idaho
7901 Freeport Blvd., Suite 100
Sacramento, CA 95832

Michael Creamer
Conley Ward
Givens Pursley LLP
277 N. 6th Street, Suite 200
PO Box 2720
Boise, ID 83701

Peter Butler
U S WEST Communications
1600 7th Avenue, Suite 3206
Seattle, WA 98191

Maria Arias-Chapleau
Margaret Beth Graham
AT&T Communications
1875 Lawrence Street, Suite 1575
Denver, CO 80202

Aloa J. Stevens
Citizens Telecommunications Co of Idaho
9672 S. 700 E., Suite 101
Sandy, UT 84070-3555

Dean J. Miller
Chas. F. McDevitt
PO Box 2564
Boise, ID 83701

Ray Hendershot
GVNW Inc./Management
PO Box 25969
Colorado Springs, CO 80936

Dear Parties,

After reflecting on the discussions during the settlement conference held on September 10, 1998, Staff believes that it should make clear its position on several of the issues raised during that conference -- the effect of adopting Citizens optional calling plans, the real threat of arbitrage, the distinctions between mandatory EAS and optional calling plans, and two-way versus one-way EAS.

Staff takes the position that Citizens optional calling plans, if approved by the Commission, terminate into the specific exchanges enumerated in Citizens supporting documents. For example, if the Commission were to approve the Proposed Optional Regional Calling Plan for the Marsing exchange customers, labeled USW-3, customers paying for that plan would only be able to call toll-free into the Boise, Caldwell, Emmett, Idaho City, Kuna, Melba, Meridian, Middleton, Nampa and Star exchanges. To the extent that the Commission has previously approved EAS from various independent exchanges into Boise, for example, by approving Citizens optional plans, Staff does not support extending toll-free calling to Citizens customers who opt for USW-3.

Staff likewise takes the position that to the extent parties believe that arbitrage may occur if the Commission approves the implementation of Citizens proposed optional calling plans, those concerns should be addressed on a case by case basis after an appropriate complaint is made. See Idaho Local Exchange Companies v. Upper Valley Communications, Inc., Order No. 25885 (Case No. GNRT941).

Staff also believes that mandatory EAS and optional calling plans are significantly different and require a different analysis.

Finally, Staff believes that while the Commission has previously ordered two-way EAS, it is not always required to adopt two-way EAS.

Sincerely,

Cheri C. Copsey
Deputy Attorney General

L:ctct983.cc3
Parties of Record
September 15, 1998
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