19971205Comments.doc

BRAD PURDY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]

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 GROUP LONG DISTANCE, INC. FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY TO OPERATE AS A LOCAL EXCHANGE CARRIER WITHIN THE STATE OF IDAHO.
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CASE NO. GLD-T-97-1

COMMENTS OF THE
COMMISSION STAFF

COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Brad Purdy, Deputy Attorney General, and in response to the Notice of Application and Notice of Modified Procedure issued on November 14, 1997, submits the following comments.
Group Long Distance has provided all the information required to comply with Order No. 26665 from Case No. GNR-T-96-4, the Commission order that sets out the filing and procedural requirements for approval of certificates of public convenience and necessity for telecommunications providers desiring to provide local service in Idaho. Group Long Distance already has on file with the Commission a price list for interexchange services that was accepted for filing on October 13, 1996.

Group Long Distance has been cooperative with Staff in correcting its original application where necessary. The proposed initial tariff filing was deficient in a small number of respects and failed to conform fully to IPUC requirements. Staff has detailed in writing several substantive and editorial concerns about the proposed tariff and expects to receive from Group Long Distance prompt and satisfactory answers. Group Long Distances existing tariff, for instance, has already added the Commission-required language to its exculpatory liability section.
Final resale agreements with USW and GTE are not yet available, but filings with the Commission are expected within a short time. Group Long Distance understands that it must provide such agreements for Commission approval and make additions to its proposed tariff before formally commencing service as allowed under the proposed certificate. The proposed tariff, for example, has left zeros in the rate section for now, pending completion of its interconnection and service resale agreements with the two major Idaho LECs.
Staff recommends approval of the Group Long Distance application for a certificate to provide competitive local exchange service.

Respectfully submitted this day of December 1997.

_______________________________
Brad Purdy
Deputy Attorney General

Technical Staff: Bill Eastlake

BP:BE/gdk/umisc\comments\gldt971.bpb

STAFF COMMENTS 1 DECEMBER 5, 1997