990113.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 HIGHSPEED.COM, LLC FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY TO PROVIDE INTERLATA AND INTRALATA INTEREXCHANGE SERVICES AND COMPETI­TIVE LOCAL EXCHANGE SERVICES AS A FACILITIES-BASED CARRIER AND RESELLER.
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CASE NO. GNR-T-98-19
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 December 23, 1998, submits the following comments.
BACKGROUND
On November 9, 1998, HighSpeed.Com of Idaho, L.L.C. filed an 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.  As described in a subsequent letter of clarification, HighSpeed.Com of Idaho is seeking authorization to provide all forms of facilities-based and resold local exchange services pursuant to Title 61 of the Idaho Code within the U S WEST (North and South) and GTE service areas in Idaho.  In addition, HighSpeed.Com of Idaho seeks statewide authorization to provide interexchange services pursuant to Title 62 of the Idaho Code.  These services will be provided by way of Local Multipoint Distribution Services (LMDS) microwave radio technology as licensed by the FCC in combination with facilities furnished by other authorized carriers.  At present, HighSpeed.Com has not obtained an interconnection agreement with U S WEST or GTE.
DISCUSSION
Staff has reviewed the Application submitted by HighSpeed.Com of Idaho and believes the Company understands and agrees to comply with the Commission’s rules and requirements.  HighSpeed.Com of Idaho is a wholly owned subsidiary of HighSpeed.Com, L.L.C.  Based on the financial information presented with the Application and the lack of business history in Idaho, Staff has required and received evidence of a $50,000 performance bond for HighSpeed.Com.  
STAFF RECOMMENDATION
Based on Staff’s review of HighSpeed.Com of Idaho's Application, Staff believes that HighSpeed.Com's filing meets the requirements of the Commission’s Rules and Procedural Order No. 26665.  Therefore, Staff recommends approval of the Application for Certificate of Public Convenience and Necessity.
Respectfully submitted this                        day of January 1999.
_______________________________
Brad Purdy
Deputy Attorney General
Technical Staff:Doug Cooley
BP:DC:jo\umisc\comments\gnrt9819.bp