The URL can be used to link to this page

Home My WebLink About20020822Time Warner Comments.pdfBrian Thomas 2002 22 PM 3:06 TIME WARNER TELECOM 520 SW Sixth Avenue,Suite 300 LIC Portland,OR 97204 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION ) OF CENTURYTEL OF THE GEM STATE,INC.)AND CENTURYTEL OF IDAHO,INC.FOR )APPROVAL OF A TARIFF ADVICE )Case No.GNR-T-02-Oll CONTAINING DEPOSIT REQUIREMENTS BY )INCUMBENT LOCAL EXCHANGE CARRIERS )FOR INTEREXCHANGE CARRIERS.) COMMENTS OF TIME WARNER TELECOMMUNICATIONS On July 12,2002,CenturyTelof Idaho Inc.("Century")issued Advice No.2002- 10,to alter its existing deposit conditions in Idaho PUC-12,its intrastate access service tariff for the State of Idaho.Time Warner Telecom of Idaho,LLC.("TWTC")submits the followingcomments on Century's filing. TWTC does not carry any significant amount of access traffic over Century Tel facilities and does not therefore have a strong business reason to directly oppose Century's filing.TWTC is,however,concerned with any precedent it may establish for carrier-to-carrier deposit arrangements in the State of Idaho.As many recognize,the telecommunications industryhas recently experienced significant financial turmoil that is causing many carriers to examine closely the deposit policies to be applied to other carriers.Indeed,TWTC itself has been prudentlyreviewing its deposit requirements to COMMENTS OF TIME WARNER 1 reduce or avoid further negative financial impacts associate with other carrier financial distress. Nevertheless,the Centuryfiling is the first in this state to address directly the rapid decline of the telecommunications sector.As such,Century's filing should not be viewed by this Commission as a mere change to the deposit requirements of a rural carrier.Rather,the filing raises the entire issue of what are appropriate carrier-to-carrier deposit requirements in the State of Idaho,an issue that TWTC believes should be addressed on a generic rulemakingbasis,rather than piecemeal throughindividual company tariff or price list revisions. In its August7,2002 Notice of Application and Notice of Modified Procedure the Commission correctlyidentifies many of the legal and policyissues relating to deposit requirements.TWTC is concerned,however,that these issues may not be amenable to thoughtfulresolutionin a single round of original and replywritten comments.TWTC recommends,therefore,that this case be converted to a generic proceeding with opportunity for industry participation throughworkshops or other appropriate meatis that would permit a full explorationof the issues.TWTC notes,in this regard,that on August 20,2002 the Oregon Public Utilities Commission suspended a similar Century filing pending full investigation.In the interest of comity however,and because TWTC is not a sigmficant customer of Century,TWTC does not oppose the filing as long as Commission approval is conditioned on Century's commitment to bring its deposit requirements into line with any future carrier-to-carrier deposit regulations adopted by the Commission. COMMENTS OF TIME WARNER 2 DATED this 7 day of August,2002. RESPECTFULLY SUBMITTED Time Warner Telecom Brian Thomas Vice-President,Regulatory COMMENTS OF TIME WARNER 3 CERTIFICATE OF SERVICE I hereby certify that on the 22nd day of August,2002,true and correct copies of the foregoing COMMENTS OF TIME WARNER TELECOMMUNICATIONS were forwarded by U.S.Mail,postage prepaid to the following: Brian Thomas TIME WARNER TELECOMMUNICATIONS 520 SW Sixth Avenue,Suite 300 Portland,OR 97204 Brian Thomas