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Home My WebLink About20030702Qwest Petition to Intervene.pdf:) I: I' C" I \.l ",-v l_.:.:JMary S. Hobson (ISB #2142) Stoel Rives LLP 101 South Capitol Boulevard - Suite 1900 Boise, ill 83702 Telephone: (208) 389-9000 Facsimile: (208) 389-9040 mshobson~stoel.com J"'J i t. 2003 JUL - I PN ~: 52 iUj,~;ii.)~'LiL UTILITIES COr1t'iISSION Adam L. Sherr (WSBA #25291) Qwest 1600 7th Avenue - Room 3206 Seattle, WA 98191 Telephone: (206) 398-2507 Facsimile: (206) 343-4040 asherr~qwest.com 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 NINE-MONTH REVIEW OF ECONOMIC AND OPERATIONAL IMPAIRMENT REGARDING ACCESS TO SPECIFIC UNES 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 QWEST CORPORATION'S PETITION TO INTERVENE - Page Boise-158963.10029164-00012 is a corporation organized under the laws of the state of Colorado and is authorized to engage in 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. 9251(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 necess3;ry 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 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. 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, ill 83702-5958 Adam L. Sherr Qwest 1600 ih Avenue - Room 3206 Seattle, W A 98191 QWEST CORPORATION'S PETITION TO INTERVENE - Page 2 Boise-158963.10029164-00012 Respectfully submitted this 1st day of July, 2003. Qwest CorporationAi Mary s7w~ Stoel Rives LLP Adam L. Sherr Qwest 1600 ih Avenue - Room 3206 Seattle, WA 98191 Attorneys for Qwest Corporation QWEST CORPORATION'S PETITION TO INTERVENE - Page 3 Boise-158963.10029164-00012 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: (208) 334-0300 Fax: (208) 334-3762 i i ewell~puc.state.id. us Hand Delivery U. S, Mail Overnight Delivery Facsimile Email &d4d Brandi L. Gearhart, PLS Legal Secretary to Mary S. Hobson Stoel Rives LLP QWEST CORPORATION'S PETITION TO INTERVENE - Page 4 Boise-158963.1 0029164-00012