gnrt0034.dhwh.doc

DONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3366

Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983

Attorney for the Commission Staff

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION OF PREMIERE NETWORK SERVICES, INC. FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY TO PROVIDE LOCAL EXCHANGE AND LONG-DISTANCE (TOLL) SERVICES WITH IN THE STATE OF IDAHO.
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COMMENTS OF THE
COMMISSION STAFF

COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Donald L. Howell, II, Deputy Attorney General, and submits the following comments in response to Order No. 28774 issued on July 9, 2001. Staff recommends that the Commission grant the requested certificate.
In October 2000, Premiere Network Services, Inc. (Premiere) filed an Application seeking a Certificate of Public Convenience and Necessity. Premiere intends to offer telecommunication services to both residential and business customers. The Company requests authority to resell and provide facilities-based local and toll services statewide. However, Premiere does not intend to operate in areas served by incumbent local exchange carriers that are eligible for a small or rural carrier exemption pursuant to Section 251 of the federal Telecommunications Act of 1996. Premier primarily intends to offer services in the areas of the state currently served by Qwest Corporation.
STAFF ANALYSIS:
Staff reviewed the Application submitted by Premier and found that it included all of the items identified by the Commission in its procedural Order No. 26665. Premier is primarily a management consultancy, providing clients with solutions to telecommunications needs. It has been in existence since 1986, but has only recently expanded its geographic scope.
The Application indicated the Company intended to provide a full range of telecommunications services to both residential and business customers. Telecommunications services include local exchange service, long distance services, vertical features and a wide range of data and advanced services. Services would primarily be provided through resale and purchasing and combining unbundled network elements of the incumbent's facilities.
The Application included internal financial statements from the Company. Although the financial information supplied by the Applicant does not demonstrate as stable a financial position as may be desired, the financial information appeared to be typical for an existing and stable company undergoing an expansion. In addition, the Applicant operates in a significantly different mode than typical competitive local exchange carriers. The Company designs and engineers custom solutions for its customers, and does not typically build or acquire facilities to implement the custom solution until after the customer has contracted for the designed solution. Financing for each project is then obtained from traditional sources. Therefore, Staff finds the financial position of the Company to be sufficient for the intended operation strategy, and no further financial security should be necessary.
The Company provided brief summaries of the technical qualifications of its management team. The team has extensive experience in both telecommunications and business management. Staff believes this expertise to be sufficient for the range and type of services the Company proposes to offer.

STAFF RECOMMENDATION
Staff recommends the Commission approve the Application of Premier for a Certificate of Public Convenience and Necessity.

Respectfully submitted this day of July 2001.

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Donald L. Howell, II
Deputy Attorney General

Technical Staff: Wayne Hart

DH:WH:umisc/comments/gnrt0034.dhwh
STAFF COMMENTS 3 JULY 23, 2001