20060901Petition to intervene.pdf

o~ih P. O. Box 708970
Sandy, UT 84070-8970
2006 SEP = I AM 9: 2&zone: [phone]
COMMUNICATIONS SOLUTlq~~o
PUBLiC
Fax: [phone]
UTILITIES COiv1MISSION
RECEIVED
August 31 , 2006
Mrs. Jean Jewell
Idaho Public Utilities Commission
472 West Washington Street
Boise, ID 83702
RE: Case No. INC-06-
Mrs. Jewell
Please find enclosed the original and 8 copies of Frontier Communications of Idaho
petition to intervene in the above referenced docket. Also enclosed is the certificate of
servIce.
If you have any questions, please contact me.
Sincerely,
,,(
-;t1
. I 0 Henni~gyn
anager, Government and External Affairs
Ingo Henningsen
Manager, Government & External Affairs
Citizens Telecommunications Company of Idaho, Inc.
dba Frontier Communications of Idaho
O. Box 708970
Sandy, Utah 84070-8970
Telephone: [phone]
Facsimile: [phone]
E-mail: ingo.henningsen~czn.com
RECEIVED
2006 SfP
AM 9: 29
IDAHOP('R/I'"\UTILITIES COA1PJitSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION
OF INLAND CELLULAR
FOR DESIGNATION AS AN ELIGIBLE
TELECOMMUNICATIONS CARRIER
UNDER 47 U.g 214(E)(2)
) Case No: INC- T -06-
PETITION TO INTERVENE OF
) CITIZENS TELECOMMUNI-
CATIONS COMPANY
) OF IDAHO
Pursuant to Rules 71 through 75 of the Commission s Rules, Citizens
Telecommunications Company of Idaho, Inc. dba Frontier Communications of Idaho
(Frontier) respectfully petitions the Commission for an order allowing Frontier to
intervene and become a party in the above captioned docket. Frontier has a direct and
substantial interest in the Proceeding for the following reasons:
1. On June 27, 2006 Inland Cellular filed a petition to be designated as an
Eligible Telecommunications Carrier (ETC) with the Idaho Public Utilities
Commission.
2. The petition filed by Inland Cellular requests ETC designation in portions of
Frontier s Elk City and White Bird wire centers. Both of these wire centers
are within the certificated territory of Frontier.
Frontier is an incumbent local exchange carrier certified by the Commission
to provide telecommunications in Idaho. This Proceeding could have an
impact on Frontier and its customers.
4. By virtue of Frontier s status as an incumbent local exchange carrier in Idaho
it will be able to advise the Commission on the potential impacts of the
Proceeding on telecommunications customers and other telecommunications
companies in Idaho.
5. Although Frontier is uncertain about the extent of its participation at this early
stage of the Proceeding, Frontier s participation will not unduly broaden the
issues or delay the adjudication process.
6. If Frontier is not allowed to intervene in the Proceeding, it will not be able to
protect the interests of its customers or the company.
Copies of all filings, discovery and correspondence should be served on:
Ingo Henningsen
Manager, Government & External Affairs
Frontier Communications
Box 708970
Sandy, UT 84070-8970
Facsimile: [phone]
E-mail: ingo.henningsen~czn.com
With a copy to:
Kevin Saville
Associate General Counsel
Frontier Communications
2378 Wilshire Blvd.
Mound, MN 55364
E-mail: ksaville~czn.com
Based upon the foregoing Petition, Frontier respectfully requests the Commission
issue an order granting Frontier s Petition to intervene.
Respectfully submitted this 31 st day of August, 2006.
By: Ingo He
Manager, Government & External AffaIrs
Citizens Telecommunications of Idaho, Inc.
dba Frontier Communications of Idaho
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION
OF INLAND CELLULAR
FOR DESIGNATION AS AN ELIGIBLE
TELECOMMUNICATIONS CARRIER
UNDER 47 U.g 214(E)(2)
) Case No. INC-06-
) PETITION TO INTERVENE
) CITIZENS TELECOMMUNI-
CATIONS COMPANY
) OF IDAHO
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of this filing dated August 31
2006 by Citizens Telecommunications Company of Idaho, dba Frontier
Communications of Idaho , was this day mailed by USPS to the following (next
day air to PUC Executive Secretary):
Ms. Jean Jewel
Executive Secretary
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise , 10 83720
Conley E. Ward
Givens Pursley LLP
601 West Bannock Street
Box 2720
Boise , Idaho 83701-2720
Nez Perce Tribal Executive Committee
Rebecca Miles , Chairman
O. Box 305
Lapwai lD 83540
James Brooks
Inland Cellular
103 S. 2nd Street
O. Box 688
Roslyn, WA 98941
The Coeur d'Alene Tribe
Chief James Allen , Tribal Chairman
850 A Street
O. Box 408
Plummer, 1083851
Inland Telephone Company
Douglas Weis, President
O. Box 171
Roslyn , WA 98941
Potlatch Telephone Company, Inc.
TDS Telecom
Gail Long, Regulatory Contact
O. Box 1566
Oregon City, OR 97045
Qwest Corporation
Theresa Jensen , Director-Regulatory
1600-71st Ave. Room 1806
Seattle , WA 98191
Verizon Northwest, Inc.
David Valdez, Vice President
1800 41 st Street
O. Box 1003
Everett, WA 98206
DATED this 31st Day of August, 2006
Citizens Communications Company