20031114Comments of Verizon.pdf

11/14/03 08: 32 GTE NW EXTERNAL AFFA I RS OR/ I D ~ IDAHO PUC
November 14,2003
Mr. WeldoR StUtzman
Deputy Attorney General
Idaho Public Utilities Commission
PO Box 83720
Boise, IO 83720-0074
Dear Mr. Stutzman:
NO.090 P002/002
0/JI? 1- 02
verimn
17933 N,W. EV1iIf9fesn Pkwy
O, Bo.z 1 HXI~Qn , OR 97076
This letter confirms that Venzon Northwest Inc. (Verizon) will not challenge at this time
the FCC's presumption of impairment for unbundled mass market switching, dedicated
transport, or unbundled enterprise market loops. 'Accordingly, Voizon witl not
participate as a formal party in this docket, and me Commi &sion need not conduct
discovery ofVerizon or approve a batch hot cut process for Verizon as pan of this
proceeding,
Venzon believes that the unbundling standards set forth by the Federa1 Communications
Commission ("FCC") are improperly restrictive, and Verizon is currently challenging
these standards in proceedings before the United States Coun of Appeals for the District
of Columbia Circuit. In the event that the FCC's cwrent unbundling roles are upheld by
the courts, Verizon reserves the right in a subsequent proceeding to demonstrate that
CLECs are in fact not impaired without access to these netWork elements - an approach
contemplated by the FCC. See. e., Triennial Review Order 1 526 ('.We emphasize h~re
that the framework set folu'1 here contemplates ongoing state r~vit:W of the starus of
unbundled switching,
Thank you for your attention to this mauer.
Sincerely,
/ A."7 AI
Ian Thoms
Vice President - Public Policy and External Affairs