20130102Comments.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 6864
RECE'
2013 JAN-2 PM 2: 13
ID1HO
U-1 ILIT111--s MMb.i I
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
EDNETICS, INC. FOR A CERTIFICATE OF ) CASE NO. EDN-T-12-01
PUBLIC CONVENIENCE AND NECESSITY. )
)
) COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
attorney of record, Neil Price, Deputy Attorney General, and in response to the Notice of
Application and Notice of Modified Procedure issued in Order No. 32693 on December 11, 2012,
in Case No. EDN-T-12-01, submits the following comments.
BACKGROUND
On September 10, 2012, Ednetics, Inc. ("Ednetics" or "Company") filed an Application,
pursuant to Idaho Code §§ 61-526 through 528 and IDAPA 31.01.01.111 (Rules 111 and 112) as
clarified in Procedural Order No. 26665 in Case No. GNR-T-96-4, seeking a Certificate of Public
Convenience and Necessity ("CPCN") to provide local exchange telecommunications services
and interexchange telecommunications services in Idaho.
Ednetics will provide services by establishing interconnection and resale agreements with
incumbent and rural telephone companies throughout Idaho. Application at 1-2. The Company
STAFF COMMENTS 1 JANUARY 2, 2013
will act as both a reseller of third-party services and as a facilities-based provider purchasing
loops and transport. Id. at 2. The Company will also "acquire and/or build its own facilities
where necessary and when it makes financial sense to do so." Id. Ednetics intends to provide
integrated voice services over advanced IP networks primarily to schools and libraries. Id.
STAFF ANALYSIS
Ednetics is an Idaho corporation and lists its principal place of business as Post Falls,
Idaho. Id. The Company states that it has operated in Idaho, Oregon, and Washington for over
15 years. Id. at 1. Ednetics explains that it uses an IP data network to deliver integrated data
services, bell control, paging, video distribution, video surveillance, and emergency alert services.
The Company wishes to introduce voice services using a platform that will allow integration with
their existing services. Id.
Ednetics believes that it is likely to compete with CenturyLink, Frontier Communications,
other incumbent local exchange carriers ("ILECs"), and other competitive local exchange carriers
("CLECs") as well as some Internet service providers ("ISPs"). Id. at 4. Currently, the
Company's equipment consists of Network Equipment Building System (NEBS) 3 compliant
telecommunications termination, transport, remote management, and support hardware and
software.
With its Application, Ednetics submitted financial information that included income
statements for December 2011 and July 2012. Id. Exh. C. The Company also included an
illustrative tariff with its Application. Id. Exh. D. Ednetics states it has "reviewed all of the
Commission rules and agrees to comply with them." Id. at 5.
STAFF RECOMMENDATION
Staff has reviewed the Application submitted by Ednetics and believes the Company
understands and agrees to comply with the Commission rules and requirements. Based on this
review, the Company's filing fulfills the requirements of the Commission Rules and Procedural
Order No. 26665. Staff believes that Ednetics possesses the requisite financial, managerial, and
technical qualifications necessary to operates as a provider of telecommunications services. Staff,
therefore, recommends approval of the Application for a Certificate of Public Convenience and
Necessity subject to the following conditions:
STAFF COMMENTS 2 JANUARY 2, 2013
1.The Company complies with number pooling and reporting requirements of the North
American Numbering Plan Administrator, as set forth in Commission Order No. 30425;
2.Ednetics provides necessary reports and contributes as appropriate to the Idaho Universal
Service Fund (USF), Idaho Telecommunications Relay System (TRS), Idaho
Telecommunications Service Assistance Program (ITSAP), and complies with all future
reporting requirements deemed appropriate by the Commission for competitive
telecommunications providers;
3.Prior to issuance of the Certificate, Ednetics files a final price list with all rates, terms, and
conditions with the Commission; and,
4.Ednetics will relinquish its Certificate and all telephone numbers if, within one year of
issuance of a CPCN, the Company is not providing local exchange telecommunications
services in Idaho as defined by Idaho Code § 6203(l).1
Respectfully submitted this day of January 2013.
Neil Price
Deputy Attorney General
Technical Staff: Grace Seaman
i:umisc:comments/ednt12. lnpgs comments
"Basic local exchange service" means the provision of access lines to residential and small business customers with
the associated transmission of two-way interactive switched voice communications within a local exchange calling
area.
STAFF COMMENTS 3 JANUARY 2, 2013
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2 " DAY OF JANUARY 2013,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. EDN-T-12-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
SHAWN SWANBY PRES! DIR
EDNETICS INC
971 CLEARWATER LOOP
STE 1000
POST FALLS ID 83854
SECRETARY
CERTIFICATE OF SERVICE