20030623ATT Petition to Intervene.pdf

Mary B. Tribby
Letty S.D. Friesen
AT&T Communications of the
Mountain States, Inc.
1875 Lawrence Street, Suite 1575
Denver, Colorado 80202
[phone] (Phone)
[phone] (Fax)
Attorneys for AT&T
RECEIVED
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UTILIT IES COI'H1ISSIOH
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
NINE-MONTH REVIEW ON ECONOMIC
AND OPERATIONAL IMPAIRMENT
REGARDING ACCESS TO SPECIFIC UNES
CASE NO. GNR- T -03-
AT&T COMMUNICATIONS OF THE
MOUNTAIN STATES, INC.S PETITION TO INTERVENE
In accordance with IPUC 072 and the Idaho Public Utilities Commission
Commission) Notice of State Proceeding and Notice of Right to Intervene dated June 17
2003 , AT&T Communications of the Mountain States, Inc. ("AT&T") files this petition to
intervene and, in support of its petition, states as follows:
AT&T is a telecommunications carrier authorized to provide various
telecommunications services in Idaho.
The Commission has opened this proceeding to address the Federal
Communications Commission s ("FCC") Triennial Review Order relating to new rules
regarding the availability of unbundled network elements and competitive local exchange
carriers' economic or operational impairment issues related to the same.
As a prospective purchaser of unbundled network elements and a duly
authorized competitive local exchange carrier ("CLEC"), AT&T has a direct interest in any
proceeding addressing these issues.
AT&T requests that all pleadings, notices, and other filings be sent to:
Mary B. Tribby
Letty S.D. Friesen
AT&T Communication of the Mountain States, Inc.
1875 Lawrence Street, Suite 1575
Denver, Colorado 80202
[phone] (Phone)
[phone] (Fax)
(lsfriesen~att.com)
Robert M. Pomeroy, Jr.
Holland & Hart
8390 East Crescent Parkway
Suite 400
Greenwood Village, Colorado 80111
[phone] (Phone)
[phone] (Fax)
(bpomeroy~hollandhart. com)
AT&T's intervention will not unduly broaden the issues in this proceeding;
rather, AT&T's participation will enhance and further inform the existing issues and record in
this proceeding.
Accordingly, AT&T requests the Commission grant its intervention in this case
with full rights of participation as a party.
Respectfully submitted this 20th day of June 2003.
AT&T COMMUNICATIONS OF THE
MOUNTAIN STATES, INC.
By:
Mary B. T .
Letty S. . Fr' senAT&T unications of the
Mountain States, Inc.
1875 Lawrence Street, Room 1575
Denver, Colorado 80202
[phone]
CERTIFICATE OF SERVICE
I certify that the original and seven copies of AT &T Communications of the Mountain States
Inc.s Petition to Intervene in Docket No. GNR-03-23 were sent by overnight delivery on June
2003 to:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, ID 83702-5983
and a true and correct copy was sent by U. S. Mail, postage prepaid, on June 20 2003 to:
Robert M. Pomeroy, Jr.
Holland & Hart
8390 E. Crescent Parkway, Suite 400
Greenwood Village, CO 80111
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