20000210Comments.doc

DONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3366

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 JOINT APPLICATION OF GTE NORTHWEST INCORPORATED AND COMM SOUTH COMPANIES, INC. FOR APPROVAL OF AN AMENDMENT TO A PREVIOUSLY APPROVED RESALE AGREEMENT PURSUANT TO 47 U.S.C. § 252(e).
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CASE NO. GTE-T-00-3

COMMENTS OF THE
COMMISSION STAFF

COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its Attorney of record, Donald L. Howell, II, Deputy Attorney General, and in response to the Notice of Joint Petition for Approval of Interconnection Agreement and Notice of Modified Procedure issued in Order No.28270 on January 27, 2000, submits the following comments.

On January 14, 2000, GTE Northwest Incorporated (GTE) and Comm South Companies Inc. (Comm South), a competitive provider of telecommunication services, submitted a Joint Application for approval of an amendment to their resale Interconnection Agreement in accordance with Section 252(e)(1) and (2)(A) of the federal Telecommunications Act of 1996. The companies indicated the amendment had been reached through voluntary negotiations, and claimed the amendment was not discriminatory against any other company, and that it is consistent with the public interest, convenience and necessity. They requested the Commission approve the amendment without a hearing or intervention by other parties.
Staff reviewed the language of this amendment and did not find any terms or conditions that Staff would consider discriminatory. The amendment merely corrects typographical errors contained in one paragraph of the underlying agreement, which was approved by the Commission on December 17, 1999 in Order No. 28236. Staff concurs with the companies’ claim that the amendment is consistent with the pro-competitive policies of the Commission, the Idaho Legislature, and the Telecommunications Act of 1996, and therefore is consistent with the public interest.

STAFF RECOMMENDATION
Staff recommends the Commission approve the amendment to this Interconnection Agreement as filed.

DATED at Boise, Idaho, this 10th day of February 2000.

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DONALD L. HOWELL, II
Deputy Attorney General

Technical Staff: Wayne Hart

DH:WH:gdk:i/umisc/comments/gtet003.dhw

STAFF COMMENTS 1 FEBRUARY 10, 2000