19980806PUC Comments.doc

BEFORE THE FEDERAL COMMUNICATIONS COMMISSION
WASHINGTON, DC 20554

IN THE MATTER OF

GVNW REQUEST FOR CLARIFICATION OF
CERTAIN RULES IN PARTS 32, 36, 54, AND 69, CC DOCKET NO. 96-45, DA 98-1421.

[FEDERAL-STATE JOINT BOARD ON UNIVERSAL SERVICE] )
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CC DOCKET NO. 9645

DA 98-1421

COMMENTS OF THE IDAHO PUBLIC UTILITIES COMMISSION

INTRODUCTION
The Idaho Public Utilities Commission (IPUC) submits these comments in response to the Federal Communication Commissions Public Notice dated July 16, 1998 in the matter of GVNW Request for Clarification of Certain Rules in Parts 32,36,54, and 69, CC Docket No. 96-45, DA 98-1421.
The IPUC supports the principal behind the GVNW letter dated June 16, 1998 requesting clarification and modification of FCC rules and believes that special attention should be paid to the following Part 36 calculation recommendations.
Part 36 - Calculation of Weighted DEM

There are two parts for developing the Central Office Equipment (COE) Category 3 allocation factor: 1) starting in 1998 the current year DEM factor, plus 2) the 1996 weighted DEM factor minus the 1996 interstate DEM factor. The COE Category 3 allocation factor is then developed by taking the lessor of the combination described above or 85%. GVNW states that the weighted DEM factor, part of number 2 above, should be calculated utilizing the 1996 COE Category 3 allocation factor, not the 1996 interstate weighted DEM factor. The IPUC agrees with GVNW.
Part 36 - Change in Access Line Count
There are no provisions in the Part 36 rules similar to the Part 54 rules related to the shifting of costs from the interstate jurisdiction to the State jurisdiction because of access line growth. The growth in access lines causes a company to cross a threshold thus causing a large shift in costs. The Commissions rules adopted for the Universal Service in effect froze the access line influence on the calculation at the 1996 level until the FCC can address universal service support for rural companies on a permanent basis. GVNW asks the Commission to retain the rule as written to assist those few companies that will be crossing a threshold after 1996. The IPUC agrees with GVNW.
Respectfully submitted this 6th day of August 1998.

/s/
Weldon B. Stutzman
Deputy Attorney General
Idaho Public Utilities Commission
PO Box 83720
Boise, ID 837200074
[phone]

Express Mail:

472 W. Washington St.
Boise, ID 837025983

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IPUC COMMENTS
CC 96-45 2