20050214Comments.pdf

KIRA DALE PFISTERER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 6571
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, ID 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
FRANCE TELECOM CORPORATE
SOLUTIONS L.C. FOR A CERTIFICATE OF
PUBLIC CONVENIENCE AND NECESSITY TO
PROVIDE RESOLD LOCAL EXCHANGE AND
INTEREXCHANGE SERVICES.
CASE NO. FRN-O4-
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
Attorney of record, Kira Dale Pfisterer, Deputy Attorney General, in response to Order No. 29693
the Notice of Application and Notice of Modified Procedure in Case No. FRN- T -04-1 issued on
January 24 2005 , and submits the following comments.
BACKGROUND
On December 23 2004, France Telecom Corporate Solutions L.C. (FTCS; Company)
filed an Application for a Certificate of Public Convenience and Necessity with the Commission
to provide local exchange and toll services throughout the State of Idaho. FTCS is a Delaware
limited liability company with a corporate office in Herndon, Virginia. FTCS is majority-owned
and controlled by France Telecom S., a publicly traded company on both the Paris Stock
Exchange and the New York Stock Exchange. FTCS has a Certificate of Good Standing issued by
STAFF COMMENTS FEBRUARY 14, 2005
the Idaho Secretary of State on September 16, 2004 and although the Company does not maintain
an office in Idaho , it does have a registered in-state agent.
ST AFF ANALYSIS
In the Application, FTCS proposes to provide all forms of resold local exchange and
interexchange telecommunications services within the State of Idaho. Additionally, the Company
intends to provide resold commercial mobile radio services. Applicant does not intend to own
operate, or construct any telecommunications facilities, but plans to enter into resale agreements
with Qwest and Verizon within the next two years.
The Application also states that FTCS is a newly formed Company and does not have any
audited financial statements. Demonstration of financial capabilities has been provided by two
letters of credit by the parent company, France Telecom, SA. The Company has also provided
France Telecom s financial filings with the Securities and Exchange Commission for the years
1999-2003.
STAFF RECOMMENDATION
Staff has reviewed the Application submitted by FTCS. Based on this review, Staff finds
the Company s filing complies with the requirements of the Commission. See Procedural Order
No. 26665; IDAP 31.01.01.111. Staff believes that the Company understands and agrees to
comply with the Commission rules and requirements. Staff further believes that the Company
possesses the requisite financial, managerial, and technical qualifications necessary to operate as a
provider of telecommunications services. Therefore, Commission Staff recommends approval of
the Application for a Certificate of Public Convenience and Necessity.
Respectfully submitted this /j'f/-7 day of February 2005.
~tPF-
Kira Dale Pfiste r
Deputy Attorney General
Technical Staff: Grace Seaman
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STAFF COMMENTS FEBRUARY 14, 2005
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 14TH DAY OF FEBRUARY 2005
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. FRN-04-, BY MAILING A COpy THEREOF POSTAGE PREPAID, TO
THE FOLLOWING:
WILLIAM K COULTER
COUD ER T BROTHERS LLP
1627 "I" STREET NW
WASHINGTON DC 20006-4007
SECRET
CERTIFICATE OF SERVICE