20100422Comments.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 6618
C,.:'; "f....!-' ,~
ZOW APR 22 fìM 9: 10
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
INTELEPEER, INC. FOR A CERTIFICATE OF )
PUBLIC CONVENIENCE AND NECESSITY TO )PROVIDE LOCAL EXCHANGE )
TELECOMMUNICATIONS SERVICES. )
)
CASE NO. IPI-T-09-01
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilties Commission, by and through its
Attorney of record, Kristine A. Sasser, Deputy Attorney General, and in response to the Notice of
Application and Notice of Modified Procedure issued in Order NO.3 1035 on April 2, 2010, in
Case No. IPI-T-09-01, submits the following comments.
BACKGROUND
On December 17,2009, IntelePeer, Inc. filed an Application for a Certificate of Public
Convenience and Necessity (CPCN) to provide facilities-based and resold local exchange and
access telecommunications services in the State of Idaho. The Application states that the
Company intends to provide basic local exchange services, custom callng features, and
interexchange toll services (including toll-free services) to business and residential customers.
The Company intends to offer service in the areas served by Qwest and does not plan to
provide service in areas of any small or rural local exchange carriers. IntelePeer's Application
STAFF COMMENTS 1 APRIL 22, 2010
states that the Company initially intends to provide toll services through the Company's
underlying long-distance carier. However, the Company seeks authority to provide the full range
of resold and facilities-based local exchange and interexchange services so that it retains
flexibility in providing its services in the future.
Although the Company has not yet initiated interconnection negotiations, it anticipates
entering into interconnection and service arangements with Qwest Corporation as soon as the
Commission authorizes it to begin providing service.
The Company asserts that its expertise in telecommunications wil permit it to select the
most economical and effcient services, thereby providing customers with an excellent
combination of price, quality, and customer service. The Company states that it possesses the
requisite financial, managerial, and technical capacities to provide the proposed services.
IntelePeer is a corporation organized under the laws of Delaware and authorized to transact
business as a foreign corporation in Idaho.
STAFF ANALYSIS
Staff and the Company have been working closely to complete the Company's
Application. On three occasions Staff sent corrections to the Company and all responses were
timely. Staff also contacted a neighboring state Commission where the Company is certificated to
provide local service and was told that the Company is in good standing. Staff believes that the
Company's Application merits Commission approvaL.
STAFF RECOMMENDATIONS
Staff recommends that IntelePeer, Inc. be granted a CPCN subject to the following
conditions:
a) The Company agrees to comply with the Number Pool Administrator and Idaho
Commission Order No. 30425, which requires NRUF and Utilization reporting.
b) As a provider of intrastate regulated local exchange services and in accordance with
the Commission's Rules of Procedure, IntelePeer wil be required to report and
contribute, as appropriate, to the Idaho Universal Service Fund, Idaho
Telecommunications Relay System, ITSAP and any requisite anual reporting that
may be deemed appropriate in the future for competitive telecommunication providers.
STAFF COMMENTS 2 APRIL 22, 2010
c) Prior to issuance of the Certificate, IntelePeer shall file a completed and final price list
with all its rates, terms and conditions to have on fie with the Commission.
d) The Company wil relinquish its Certificate and any telephone numbers if, within one
year of the issuance of a CPCN, the Company is not offering local exchange
telecommunications services in Idaho.
~
Respectfully submitted this i~ day of April 2010.
l(.,. · fl. ~Kri tine A. Sasser
Deputy Attorney General
Technical Staff: Carolee Hall
i :umisc: commentsipit09. i ksch comments
STAFF COMMENTS 3 APRIL 22, 2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF APRIL 2010,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. IPI-T-09-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
RONALD W DEL SESTO JR
NGUYENTVU
BINGHAM McCUTCHEN
2020KSTNW
WASHINGTON DC 20006
E-MAIL: r.delsesto(fbingham.com
nguyen. vu(fbingham.com
, r;'0 . ~erSECRETARt -
CERTIFICATE OF SERVICE