20160728Comments.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 7956
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
IN THE MATTER OF THE APPLICATION OF
EXTENET SYSTEMS, INC. FOR
REGISTRATION AS A WHOLESALE
TELECOMMUNICATIONS PROVIDER IN
IDAHO
RE C E IVED
?t16,llii- ?B AI',t 10' 06
. t,; I II-
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. ENS.T.16-01
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
attorney of record, Brandon Karpen, Deputy Attorney General, submits the following comments.
BACKGROUND
On June 18,2016, ExteNet Systems, Inc. filed an Application with the Commission for a
Certificate of Public Convenience and Necessity for registratiorVcertification as a wholesale
provider of telecommunications service in Idaho. Application at l.
STAFF ANALYSIS
ExteNet is a wholesale provider of telecommunications services incorporated in the State
of Delaware, listing its principal place of business as Lisle, Illinois. Id. The Company is a
wholly-owned subsidiary of Odyssey Acquisition LLC. Id. at2. In March 20l6,Idaho's
Secretary of State certified that ExteNet is authorizedto transact business in Idaho. 1d., Exh B.
ExteNet claims in its Application that the Company plans to provide facilities-based local
STAFF COMMENTS JULY 28,2016
exchange and interexchange services in Idaho. Id. at3-4. ExteNet states it "primarily installs its
own facilities," or where not feasible, will negotiate interconnection agreements with incumbent
local exchange carriers. Id. ExteNet does not maintain a place of business in Idaho and lists
Corporation Services Company as its registered agent in Idaho. Id. at2.
ExteNet provided a sworn verification that it will "comply with all Idaho laws and
Commission rules and regulations, including rules regarding the conservation of telephone
numbers." Id.,Exh.B
RECOMMENDATION
Staff has reviewed ExteNet's Application for compliance with applicable legal
requirements for registration as a wholesale provider of telecommunications services in Idaho.
The Company states that it understands and agrees to comply with the Commission Rule 114,
and Commission Order No.32277. Staff believes ExteNet possesses the requisite financial,
managerial, and technical qualifications necessary to operate as a provider of
telecommunications services and is in compliance with applicable legal requirements. Staff,
therefore, recommends that the Commission approve the Application, and accept ExteNet as a
registered wholesale communications provider subject to the following conditions:
l. ExteNet comply with number pooling and reporting requirements of the North
American Numbering Plan Administrator, as set forth in Commission Order No. 30425;
2. ExteNet provide necessary reports, and contributions as appropriate to the Idaho
Universal Service Fund (USF), Idaho Telecommunications Relay System (TRS), Idaho
Telecommunications Service Assistance Program (ITSAP); and
3. ExteNet comply with all future reporting requirements deemed appropriate by the
Commission for competitive telecommunications providers.
Respectfully submitted this
Technical Staff: Grace Seaman
i:umisc:comments/enstl6.lbkgs comments
STAFF COMMENTS
Ld2 day of July 2016.
JULY 28,2016
CERTIFICATE OF SERYICE
I HEREBY CERTIFY THAT I HAVE THIS 28TH DAY OF ruLY 2016,
SERVED THE FOREGOTNG COMMENTS OF TrrE COMMTSSION STAFF, IN
CASE NO. ENS.T.I6.OI, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
ANITA TAFF-RICE
COLTNSEL FOR EXTENET
ICOMMLAW
1547 PALOS VERDES #298
WALNUT CREEK CA94597
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE