20030702Qwest Petition to Intervene.pdf

Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
msho bsonCfj),stoel. com
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UTILITIES COMi'1iSSION
Adam L. SheIT (WSBA #25291)
Qwest
1600 ih Avenue - Room 3206
Seattle, W A 98191
Telephone: [phone]
Facsimile: [phone]
asheITCfj),qwestcom
Attorneys for Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IPUC RESPONSE TO
FCC ORDER ON REVIEW OF SECTION 251
UNBUNDLING OBLIGATIONS OF
INCUMBENT LOCAL EXCHANGE
CARRIERS (CC DOCKET NO. 01-338)
Case. No. GNR-03-
QWEST CORPORATION'S PETITION
TO INTERVENE
90-DAY REVIEW ON SWITCHI8NG ON
HIGH CAPACITY LOOPS
Qwest Corporation ("Qwest"), by and through its attorneys of record, respectfully
petitions the Idaho Public Utilities Commission ("Commission ) for leave to intervene in the
above captioned proceeding pursuant to the Commission s Rules of Practice and Procedure for
the following reasons:
Qwest is a corporation authorized to do and doing business in the state of Idaho
with its principal Idaho business office located at 999 Main Street, Boise, Idaho, 83702. Qwest
is a corporation organized under the laws of the state of Colorado and is authorized to engage in
QWEST CORPORATION'S PETITION TO INTERVENE - Page
Boise-I 58946,1 0029164-00012
the furnishing of general telephone service in the north central and southern portions of Idaho
and elsewhere in the western United States.
Qwest has a direct and substantial interest in the above entitled proceedings
because, as an incumbent local exchange carrier it is required to provide "non-discriminatory
access to network elements on an unbundled basis at any technically feasible point on rates
terms and conditions that are just reasonable and non-discriminatory." 47 USe. 251(c)(3)
This case potentially impacts Qwest's obligations to provide unbundled network elements.
Qwest does not expect that its intervention will broaden the issues in this case or prejudice any
party.
Qwest desires to intervene in order that it might receive documents and if its
interests require, comment, cross-examine witnesses and present evidence in this case. At this
point, Qwest cannot inform the Commission or other parties how involved its individual
participation in this proceeding will be because the positions of the other parties and the
Commission s Staff are not yet fully known. Therefore, Qwest cannot presently inform the
Commission as to the type of evidence it will present if any, or the length of time necessary for
such presentation.
Qwest recognizes that this Petition is being filed after the Commission s June 27
deadline. However, the Commission has not yet undertaken any review of the case and the
Federal Communications Commission has not yet released its order, which is expected to
provide guidance on the topics addressed in this docket. Qwest believes, therefore, that no party
will be prejudiced and that the Commission s consideration of this case will not be delayed by
this Petition.
5. It is respectfully requested that all pleadings, testimony, exhibits, orders of the
Commission and any other documents relating to this proceeding be served upon the Qwest and
its attorneys, to wit:
Mary S. Hobson
Stoel Rives LLP
101 S. Capitol Blvd., Suite 1900
Boise, ID 83702-5958
Adam L. SheIT
Qwest
1600 ih Avenue - Room 3206
Seattle, W A 98191
QWEST CORPORATION'S PETITION TO INTERVENE - Page 2
Boise-I 58946.1 0029164-00012
Respectfully submitted this 1 st day of July, 2003.
Qwest Corporation
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Stoel Rives LLP
Adam L. SheIT
Qwest
1600 ih Avenue - Room 3206
Seattle, WA 98191
Attorneys for Qwest Corporation
QWEST CORPORATION'S PETITION TO INTERVENE - Page 3
Boise-158946.10029164-00012
CERTIFICATE OF SERVICE
I hereby certify that on this 1st day of July, 2003 , I served QWEST CORPORATION'
PETITION TO INTERVENE as follows:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ill 83720-0074
Phone: [phone]
Fax: [phone]
i i ewell((j),puc. state.id. us
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Brandi L. arhart, PLS
Legal Secretary to Mary S. Hobson
Stoel Rives LLP
QWEST CORPORATION'S PETITION TO INTERVENE - Page 4
Boise-158946.10029164-00012