20020709Comments.pdf

WELDON B.STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION 2 2 JUL -9 PN 12·05
PO BOX 83720
BOISE,IDAHO 83720-0074 LifÍLiiiES CÜiviiiiSSIOil
[phone]
IDAHO BAR NO.3283
Street Address for Express Mail:
472 W WASHINGTON
BOISE ID 83702-5983
Attorney for the Conamission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
THE LOCAL CONNECTION TELEPHONE )CASE NO.GNR-T-02-9
COMPANY FOR A CERTIFICATE OF PUBLIC )CONVENIENCE AND NECESSITY TO )
PROVIDE LOCAL EXCHANGE )COMMENTS OF THETELECOMMUNICATIONSSERVICES.)COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission,by and through its
Attorneyof record,Weldon B.Stutzman,Deputy AttorneyGeneral,and in response to the
Notice of Application and Notice of Modified Procedure issued in Order No.29054 on
June 18,2002,submits the followingcomments.
On June 7,2002,The Local Connection Telephone Company (LCTC)filed an
Application for a Certificate of Public Convenience and Necessity to provide basic local
exchange service within the service areas in Idaho of Qwest,Citizens Communications and
Verizon.The Local Connection is a subsidiary of V &V Inc.,a Nevada corporation with
headquarters in Elko,Nevada.On April 15,2002,the Idaho Secretary of State issued a
Certificate of Authority to V &V Inc.
STAFF COMMENTS 1 JULY 9,2002
STAFF FINDINGS
Staff has reviewed the information provided by LCTC in its Application and the
additional material provided to support that Application and believes it satisfies the requirements
of the Commission's Rule of Procedure 111,IDAPA 31.01.01.111,and Procedural Order No.
26665 issued November 7,1996,which sets out the necessary information to be included with an
Application for a certificate.
The Application indicated LCTC would be providing resold services.The Company
provides similar services in Nevada,and the Application included a copy of the bond the
Company obtained for its Nevada operation.The Company does not intend to require deposits.
The parent company operates a post-dated check loan service,Check For a Check,in Elko.The
Application did not include financial information because this is a new business.
The Company's intended mode of operation requires minimal capital investment and
relativelyminimal technical expertise.As the Company provides similar service in Nevada,the
Company appears to have adequate technical skills to provide the services identified in the
Application.While the financial capabilities of such a new company are unknown,the risk to -
any individual customer is minimal,and Staff believes the benefits of a bond or other financial
security instrument would be outweighed by the cost of distributing the proceeds and other
administrative functions.Therefore,Staff does not recommend imposing a financial security
requirement.
LCTC specifically indicated in its Application it will comply with all Commission rules.
It has provided an illustrative tariff with its Application that demonstrates an understandingof
tariffmgrequirements and processes.
STAFF RECOMMENDATION
Although Staff has concerns about companies like LCTC that target high-riskcustomers,
LCTC appears to meet the minimum requirements and Staff fmds no reason for the Commission
to reject this Application.Therefore,Staff recommends that a Certificate of Public Convenience
and Necessity to provide competitive local exchange service in the service areas of Qwest,
Citizens Communications and Verizon be provided to The Local Connection Telephone
Company.
STAFF COMMENTS 2 JULY 9,2002
Respectively submitted this day of July 2002.
Weldon B.Stutzman
Deputy Attorney General
Technical Staff:Wayne Hart
WS:i:umisc/comments/gnrt02.9wswh
STAFF COMMENTS 3 JULY 9,2002
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 9TH DAY OF JULY 2002,SERVED
THE FOREGOING COMMENTS OF THE COMMISSION STAFF,IN CASE
NO.GNR-T-02-9,BY MAILING A COPY THEREOF,POSTAGE PREPAID,TO THE
FOLLOWING:
JOEVELASQUEZ
LOCAL CONNECTION TELE.CO.
1003 IDAHO ST,SUITE 5
ELKO NV 89801
SECRETARY
CERTIFICATE OF SERVICE