LECS.docx

MEMORANDUM
TO:COMMISSIONER HANSEN
COMMISSIONER SMITH
COMMISSIONER KJELLANDER
FROM:WELDON STUTZMAN
DATE:APRIL 8, 1999
RE:PROCESSING APPROVAL OF TOLL DIALING PARITY PLANS
The recent order issued by the Federal Communications Commission requiring local exchange carriers (LECs) to file toll dialing parity plans with state commissions by April 22, 1999, establishes a short time-period for state commissions to review and approve the plans.  After filing with the state commissions by April 22, the FCC order requires a LEC to file its implementation plan with the FCC on June 22, 1999, “if a state commission has not yet acted on a LEC’s intraLATA toll dialing parity implementation plan”.  The FCC thus allows a mere 60 days for state commissions to review the implementation plans and approve (or deny) them.  Given the short time frame, the Commission should be prepared to proceed expeditiously after April 22 when the implementation plans are filed.  This memorandum proposes a procedural method and schedule to complete the review process.
U S WEST can file its implementation plan in the existing dialing parity docket, Case No. GNR-T-94-5.  If the Commission approves this process, the Commission can issue a Notice of Modified Procedure and Notice of Plan Filing upon the filing of U S WEST’s implementation plan.  See Rules of Procedure 201-204; IDAPA 31.01.01.201-04.  Staff recommends that the comment period be 25 days, and that a settlement conference be scheduled for the end of the comment period to iron out any issues presented by interested parties.
Each of the other implementation plans filed by LECs should have its own docket number and case caption, but the cases probably can be consolidated procedurally to simplify the process.  A single Notice of Modified Procedure and Notice of Filing can be prepared for all of the LECs to minimize the mailings required to complete the process.  As with U S WEST, the independent LECs  should be invited to a settlement conference to resolve any remaining issues.
To complete this procedural process, Staff therefore makes the following specific recommendations:
1.  U S WEST should file its implementation plan within the already existing U S WEST toll dialing parity docket, Case No. GNR-T-94-5.
2.  A case number and caption should be assigned for each of the independent company LECs when it files its implementation plan.
3.  All of the cases should be consolidated to simplify the procedural process and enhance the ability of the Commission to complete the review and approval process by June 22, 1999.  A single Notice of Modified Procedure and Notice of Plan Filing can be issued to establish a 25-day comment period.  The Notice should also contain a Notice of Settlement Conference scheduled for the week of May 24-28, 1999.
If the Commission agrees with this approach to process approval of the toll dialing parity implementation plans, it will be possible to begin the process immediately after April 22, 1999, when the implementation plans are filed.
Weldon Stutzman
cc:
Don Howell
Cheri Copsey
Joe Cusick