20000814Comments.doc

JOHN R. HAMMOND
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5470

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 APPLICATON CERTIFICATE OF PUBLIC CONVENIENCE AND NEW EDGE NETWORK, INC. DBA NEW EDGE NETWORKS FOR APPROVAL OF AN
INTERCONNECTION AGREEMENT PURSUANT
TO 47 U.S.C. § 252(e). )
)
)
)
)
)
)
)
CASE NO. GTE-T-00-6

COMMENTS OF THE
COMMISSION STAFF

COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its Attorney of record, John R. Hammond, Deputy Attorney General, in response to Order No. 28455,
the Notice of Amendment to Existing Interconnection Agreement and Notice of Modified Procedure in Case No. GTE-T-00-6 issued on July 24, 2000, submits the following comments.
On June 30, 2000, GTE Northwest Incorporated submitted an Amendment to an existing interconnection agreement between itself and New Edge Network, Inc. dba New Edge Networks for review and approval. The Joint Application states that the Amendment was reached through voluntary negotiations without resort to mediation or arbitration and is submitted for the Commission’s approval pursuant to Section 252(e) of the federal Telecommunications Act of 1996.

The Commission approved New Edge’s underlying interconnection agreement on
May 9, 2000 in Order No. 28373. The companies indicated the Amendment to the Agreement had been reached through voluntary negotiations, and claimed the Agreement 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 Agreement without a hearing or intervention by other parties.
Staff reviewed the language of this Amendment which adds terms and conditions for line sharing. As these terms and conditions will be available to other competitors, and increase the options available to all competitors, Staff does not find them to be discriminatory. Staff also concurs with the companies claim that the Agreement is consistent with the pro-competitive policies of the Commission, the Idaho Legislature, and the Telecommunications Act of 1996. Accordingly, the Amendment is consistent with the public interest.

STAFF RECOMMENDATION
Staff recommends the Commission approve the Agreement as filed.

DATED at Boise, Idaho, this day of August 2000.

________________________
John Hammond
Deputy Attorney General

Technical Staff: Wayne Hart

WH:JH:gdk:i:umisc/comments/gtet006.wh
STAFF COMMENTS 1 AUGUST 14, 2000