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Home My WebLink About20060912Petition to intervene.pdf~Guillory~H rt P.L.LC.Advisors to the Rural Communimtions Industry Barry L. Hjort O. Box 15855 . Washington D.C. 20003-0855 . Ph: (303) 550-4772 . Email: roUsroyal~aol.com September 11 , 2006 r-.) :j g C7""=is - -- rrtm~ CI:' C) --, N0'- Via Federal Express Overnight Delivery Ms. Jean Jewel, Executive Secretary Idaho Public Utilities Commission 472 W. Washington St. PO Box 83720 Boise, ill 83720-0074 ;po::x ():. n 5 0~- Re: Case No. INC-06- Dear Ms. Jewel: Enclosed please find the original and seven copies of the Petition to Intervene of the Potlatch Telephone Company, Inc. in the referenced matter as well as an original and seven copies of a Motion for Admission Pro Hac Vice in the same docket. If you have questions concerning these filings, please contact me at (303) 550-4772. Thank you. Very truly yours ~)q~ /' ~Umory 2111 West Boulevard Rapid City, SD 57701 :::0 Morgan W. Richards, Jr. BarNo. 1913 Richards Law Firm 804 East Pennsylvania Lane Boise, Idaho 83706 208-345-8371 Email: mwrlaw~cableone.net BECE\\JfJ) lUUo St.? \ 2 M-\ \O~ Q9 !' "'\~F1\ IC Di\hU ~\SS\ .\~~ C \'/II~\\j1\l \ \...'"" Barry L. Hjort Colorado BarNo. 19551 Guillory & Hjort 2111 West Boulevard Rapid City, South Dakota 57701 303-550-4772 Email: rollsroyal(illaol.com BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF IDAHO IN THE MATTER OF THE PETITION OF INLAND CELLULAR FOR DESIGNATION AS ELIGIBLE TELECOMMUNICATIONS CARRIERS UNDER 47 U.C. SECTION 214(e)(2) Case No. INC-06- PETITION TO INTERVENE OF THE POTLATCH TELEPHONE COMPANY, INC. Potlatch Telephone Company Inc., through its undersigned counsel, pursuant to Idaho Public Utility Commission (IPUC) Rule of Procedure 72 et seq., submits its Petition to Intervene in this matter and in support thereof states as follows: 1. Potlatch Telephone Company, Inc. ("Potlatch") is a certified provider oflocal exchange telephone service in the State of Idaho with its address for regulatory contact purposes as follows: Gail Long, Manager, External Relations, TDS Telecom PO Box 1566, Oregon City, OR 97045. 2. Potlatch has a direct and substantial interest in this proceeding. It is and has been certified by the IPUC as an Eligible Telecommunications Carrier (ETC) in its designated service area for the purpose of providing supported local exchange telecommunications service and receiving Federal Universal Service support. Potlatch is a "rural telecommunications carrier" as defined by the Federal Telecommunications Act of 1996. As such, it is a co-called "rural LEC. 3. The Application oflnland Cellular Telephone Company ("Inland Cellular ) for designation as an ETC, filed on June 26, 2006 identifies Potlatch as an affected "rural LEc." As is noted in paragraph 9 of the Application: "Inland Cellular s service area encompasses the entire study areas of the rural LECs listed in Exhibit Coo.." Exhibit C to the Application identifies Potlatch as one of the rural LECs affected by the Application and lists the Potlatch wire centers of Juliaetta, Kendrick and Troy as being affected by the Inland Application. 4. Potlatch seeks intervention in this matter to advocate the application by the IPUC of those applicable provisions of federal law and this Commission s IPUC's rules concerning applications for designation as an ETC, and specifically those provisions relating to the public interest and the competitive entry by a Competitive Eligible Telecommunications Carrier (CETC) into the study areas of rural local exchange providers for the purpose of providing competitive and supported ETC services. Approval of its intervention will not unduly delay the proceeding. 5. Potlatch will be directly and substantially affected by this Commission s decision in this case. It seeks intervention in order to fully participate in the proceeding to protect the interest of itself and its customers and to ensure the continuing protection of the public interest. Potlatch requests that pleadings, notices and other filings be provided to its undersigned counsel in this docket. It additionally requests that such filings also be provided to: Gail Long, Manager, External Relations TDS Telecom PO Box 1566 Oregon City, OR 97045 WHEREFORE, Potlatch respectfully requests that the Commission approve its Petition to Intervene in this Docket. J'/11 DATED this /.-:------ day of September, 2006. "d~ o. Applying Co Barry L. Hjort Guillory & Hjort 2111 West Boulevard Rapid City, SD 57701 303-550-4772 Local Counsel Morgan W. Richards, Jr. Richards Law Firm 804 East Pennsylvania Lane Boise, Idaho 83706 208-345-8371 CERTIFICATE OF SERVICE , Barry L. Hjort, hereby certify that I have, on this ~daY of September, 2006 served the foregoing PETITION TO INTERVENE OF THE POTLATCH TELEPHONE COMPANY, INc. upon all parties listed in the Certificate provided with the Inland Cellular Application. A copy ofthe foregoing PETITION TO INTERVENE OF THE POTLATCH TELEPHONE COMPANY, INc. filed today was placed in the United States mail, first class postage pre-paid, addressed to the following: James K. Brooks, Treasurer/Controller Inland Cellular Telephone Company 103 S. 2nd St., PO Box 688 Roslyn, W A 98941 Ms. Jean Jewel, Executive Secretary Idaho Public Utilities Commission 472 W. Washington St. PO Box 83720 Boise, ID 83720-0074 Nez Perce Tribal Executive Committee Rebecca Miles, Chairman P. O. Box 305 Lapwai, ID 83540 Citizens Telecommunications DBA Frontier Communications of Ingo Henningson, Manager 4 Triad Center, Suite 200 Salt Lake City, UT 84180 Conley Ward, Esq. Givens Pursley LLP P. O. Box 2720 Boise, ID 83701 Qwest Corporation Theresa Jensen, Director-Regulatory 1600 71st Avenue, Room 1806 Seattle, W A 98191 The Coeur d' Alene Tribe Chief James Allen, Tribal Chairman 850 A Street PO Box 408 Plummer, ID 83851 Verizon Northwest, Inc. David Valdez, Vice President 1800 41 st Street O. Box 1003 Everett, W A 98206 Inland Telephone Company Douglas Weis, President O. Box 171 Roslyn, W A 98941 Gail Long, Manager External Affairs TDS Telecom PO Box 1566 Oregon City, OR 97045