20001020_ws.doc

October 20, 2000

Re: Staff’s Proposal for a High Cost Fund Methodology, Case Nos. GNR-T-97-22 and GNR-T-00-02

Dear Parties of Records:

Consistent with the Commission’s directive “to help us devise a simple, practical, understandable scheme for Idaho’s non-rural USF using readily available data and information so that we can quickly resolve these issues and complete this process”, Tr. p. 22, Staff has prepared a proposal for an alternative methodology for establishing the high-cost fund. Staff’s proposal is similar to the one filed prior to the last workshop, but contains some modifications as a result of the discussions during the workshop.

Given the Commission’s clear dissatisfaction with the high-cost fund models, and its desire to devise a simple, workable high-cost fund that is readily understood, Staff believes its proposal comports with the Commission’s goal. Staff is also optimistic, given the discussion with various parties, that at least a framework for establishing the fund can be agreed upon by the parties to present to the Commission. It is in that spirit of cooperation that Staff presents its proposal to the parties in this case.

Please review the enclosed proposal and indicate in a response whether you can support the proposal, either in whole or in part. Please be specific about any areas or issues on which you disagree, and provide an alternative to Staff’s proposal in those areas where you disagree. Please provide your written response to the Staff no later than October 31, 2000.

The Commission Staff appreciates your efforts to assist the Commission in establishing high-cost Universal Service Fund pursuant to Idaho Code § 62-610F. Please do not hesitate to contact me if you have any questions or concerns regarding Staff’s proposal.

Sincerely,

Weldon Stutzman
Deputy Attorney General

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