20061213Comments.pdf

CECELIA A. GASSNER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 6977
FIVED
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
CACTUS INTERNATIONAL, INC. FOR
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY TO PROVIDE LOCAL
EXCHANGE SERVICES WITHIN THE STATEOF IDAHO
CASE NO. CZ8-O6-
COMMENTS OF THE
COMMISSION STAFF
The Staff of the Idaho Public Utilities Commission (Commission), by and through its
Attorney of record, Cecelia A. Gassner, Deputy Attorney General, in response to the Notice of
Application and Notice of Modified Procedure in Order No. 30184 issued on November 22
2006, submits the following comments.
BACKGROUND
On November 7, 2006, Cactus International, Inc. ("Cactus ) filed an Application for a
Certificate of Public Convenience and Necessity (CPCN) to provide telephone service to
customers who collocate equipment in its facility, such as Direct Inward Dialed telephone lines
to Internet Service Providers. The Application states that it will provide these services through
interconnection agreements with Verizon Northwest Inc. and it intends to be able to start
providing such services beginning January 1 , 2007. Its Application states that it intends to
provide Voice over Internet Protocol (VoIP) services at some point in the future.
STAFF COMMENTS DECEMBER 13, 2006
Cactus has a Certificate of Incorporation showing it has been an Idaho corporation since
March 12, 1990. Its principal place of business is in Moscow, Idaho. The Company has
provided financial information and the appropriate contact information for its registered agent for
service of process within Idaho. The Company also filed a revised illustrative tariff on
November 15, 2006. Its proposed service territory will coincide with Verizon s Moscow, Idaho
market area.
STAFF ANALYSIS
Staff has reviewed the information provided by Cactus in its Application and believes
it satisfies the requirements of the Commission s Rule of Procedure 111 IDAPA 31.01.01.111
and Procedural Order No. 26665 issued November 7, 1996, which sets out the necessary
information to be included with an application for a certificate. Cactus s Application includes all
of the required information.
The Application stated Cactus will offer telecommunications servIces using its own
network in the Moscow area currently served by Verizon. The Company will initially provide
phone service to customer s equipment that is collocated at their facility, especially Direct
Inward Dialed lines to internet service providers or call centers. The Company also expects to
expand to voice over internet protocol (VoIP) services.The Company entered into an
interconnection agreement with Verizon, which was approved by this Commission in Order No.
29882 on October 4, 2005.
The Application included unaudited financial information for 2005 and up-to-date
information for 2006. Staff is satisfied that the Company has the technical, managerial and
financial strength to provide the services identified in the Application.
Cactus specifically stated in its Application it will comply with all Commission rules.
It has provided an illustrative tariff with its Application that demonstrates an understanding of
tariff requirements and processes. The Company will not require advance deposits by its
customers and therefore did not submit an executed copy of an escrow account.
ST AFF RECOMMENDATION
Staff recommends that a Certificate of Public Convenience and Necessity to provide
competitive local exchange service in Idaho be granted to Cactus International, Inc.
STAFF COMMENTS DECEMBER 13, 2006
I ,,
Respectfully submitted this \:J day of December 2006.
Cecelia A. Q sner
Deputy Attorney General
Technical Staff: Wayne Hart
i:umisc:comments/cz8tO6, 1 cgwh
STAFF COMMENTS DECEMBER 13, 2006
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 13TH DAY OF DECEMBER 2006
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. CZ8-06-, BY MAILING A COpy THEREOF, POSTAGE PREPAID
TO THE FOLLOWING:
CRAIG A RA Y
PRESIDENT
CACTUS INTERNATIONAL INC
211 S MAIN ST
MOSCOW ID 83843
Jg (J~SECRETAR~
CERTIFICATE OF SERVICE