20110411AT&T Communications Reply Comments.pdf

Molly O'Leary
Richardson & O'Lear, PLLC
515 N 27th Street (83702)
P.O. Box 7218
Boise, Idaho 83707
Telephone: [phone]
Fax: (208) -38-7904
RECENEO
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Attorneys for AT&T Communications of the Mountain States, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AN INVESTIGATION)
OF AN APPROPRITE CERTIFICATION )
PROCESS FOR TELECOMMUNICATIONS )
COMPANIES THAT DO NOT PROVIDE )
BASIC LOCAL EXCHANGE SERVICE )
)
CASE NO. GNR- T-ll-Ol
REPLY COMMENTS OF AT&T
COMMUNICATIONS OF THE
MOUNTAIN STATES, INC.
AT&T Communcations of the Mountain States, Inc., on behalf of itself and its affiliates,
("AT&T") hereby fies its reply comments in the above-captioned proceeding before the Idaho
Public Utilities Commission ("Commission"). AT&T appreciates the Commission's willngness
to underte this investigation and to address the appropriate process for companies that do not
provide basic local exchange service.
AT&T is sympathetic to the concerns raised by Time Warer Cable Information Services (Idaho),
LLC ("TWCIS") regarding the practical difficulties encountered by a non-basic local exchange service
provider in Idaho; specifically, obtaining numbering resources and interconnection agreements without a
Certificate of Public Convenience and Necessity ("CPCN"). Further, AT&T agrees with TWCIS that the
Commission should have a mechanism in place to faciltate the practical "abilty of such providers to
enter the Idaho market."!
i Comments of Time Warer Cable Information Services (Idaho), LLC, page 6.
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Indeed, at a high level, most commenters seem to agree that the Commission should have a
process in place to provide written documentation demonstrating that a provider that does not
offer basic local exchange service is neverteless "authorized" to enter the local market in Idaho
as this would allow the provider to more easily obtain access to numbering resources2 and
interconnection agreements. Commenters, however, have varous suggestions on what the
wrtten documentation from the Commission should entail, including an Order in Lieu of a
Certificate3 or some other form of CPCN for providers of non-basic local exchange service.4 In its
opening comments, AT&T suggested that a non-basic local exchange service provider register
with the Commission and receive a registration number.5 The registration number would demonstrate
that the non-basic local exchange service provider is authorized to offer service in the state. This process
would also be consistent with the intent of the legislature to remove needlessly burdensome CPCN
requirements from certain providers, while at the same time faciltating the practical diffculties these
non-basic local exchange providers face in obtaining numbering resources and interconnection agreement.
If the Commission determines that the registration process outlned by AT&T is not sufficient,
AT&T does not oppose the use of an Order in Lieu of Certificate for providers of non-basic local
exchange service. However, to be consistent with the intent ofthe legislature to remove needlessly
burdensome CPCN requirements, providers of non-basic local exchange service that seek an Order in
Lieu of Certificate should not have to provide as detailed of information as those providers that require a
CPCN. Further, the Commission should specify in advance the precise information that is required for an
247 C.F.R. §52.l5(g)(2) requires that applications for initial number resources include, among other things,
evidence that the "applicant is authorized to provide service in the area for which numbering resources are being
requested."
3 See Comments of
Staff, Comments of 360Neworks (USA) Inc., page 2-3, and Comments of Time Warner Cable
Information Services (Idaho), LLC, page 7.
4 The concerns raised by Qwest Communications Company LLC ("QCC") seem to mostly involve an issue of timing
(when basic local exchange service wil be provided); as such, AT&T has not attempted to address QQC's concerns.
5 See Comments of AT&T, page 1.
2
Order in Lieu of Certificate so providers know in advance what information must be provided and the
Order in Lieu of Certificate can be granted expeditiously.
LLC
3