981123.docx

BRAD PURDY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO  83720-0074
[phone]
Street Address for Express Mail:
472 W WASHINGTON
BOISE ID  83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF LEVEL 3 COMMUNICATIONS, LLC FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY TO PROVIDE TELECOMMUNICA-TIONS SERVICES IN IDAHO.

)
)
)
)
)
)
)
CASE NO. GNR-T-98-13
COMMENTS OF THE
COMMISSION STAFF
COMES  NOW  the Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Brad Purdy, Deputy Attorney General, and in response to the Notice of Application and Notice of Modified Procedure issued on November 4, 1998, submits the following comments.
BACKGROUND
On October 6, 1998, Level 3 Communications, LLC (“Level 3") filed and Application for a Certificate of Public Convenience and Necessity (CPCN) in compliance with Commission Rules of Procedures, IDAPA 31.01.01.111 and Procedural Order No. 26665.  Level 3 is seeking authorization to provide all forms of facilities-based and resold local exchange services pursuant
to Title 61 of Idaho Code within the U S WEST (North and South) and GTE service areas in Idaho.  In addition, Level 3 seeks authorization to provide switched access service pursuant to Title 62 of Idaho Code to interexchange carriers within these areas of Idaho.
DISCUSSION
Staff has reviewed the Application submitted by Level 3 and believes the Company understands the Commission’s rules and requirements.  Level 3 is owned and operated by its parent company, PKS Information Services, Inc., which is in turn wholly owned by Level 3 Communications, Inc.  As a start-up limited liability company, Level 3 does not own any subsidiaries and will rely upon its parent company for financing and capital.
Based on Staff’s review of Level 3's Application and financial situation, Staff believes that Level 3's filing meets the requirements of the Commission’s Rules and Procedural Order No. 26665 and should be granted a CPCN.
Respectfully submitted this                        day of November 1998.
_______________________________
Brad Purdy
Deputy Attorney General
Technical Staff:  Doug Cooley
BP:DC:jo\umisc\comments\gnrt9813.bp