20130213Motion for Extension.pdf

RECE!VED
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSiONJj..ç N 56
iAl1 ' mLlT' coM'rss
In the Matter of the Application of Nexus
Communications, Inc. for Designation as an Case No. NCI-T-1 1-01
Eligible Telecommunications Carrier for Low
Income Support Only
MOTION TO EXTEND COMMENT PERIOD
Nexus Communications, Inc. ("Nexus") respectfully submits this motion to extend the
comment period in Case No. NCI-T- 11-01, Nexus's application for designation as an eligible
telecommunications carrier, filed on April 5, 2011. Per conversations with Commission staff and
in order to allow time to respond to their inquiries, Nexus moves that the comment period be
extended by an additional 30 days.
Dated this 12th day of February, 2013
Respectfully submitted,
Nexus Communications, Inc.
BcDJfTN
Danielle Frappier
Adam Shoemaker
Davis Wright Tremaine LLP
1919 Pennsylvania Avenue, NW, Suite 800
Washington, DC 20006
[phone]
Attorneys for Nexus Communications, Inc.
DWT 21153838y1 00922I0-00000
D. NEIL PRICE (ISB# 6864)
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P.O. BOX 83720
BOISE, IDAHO 83720-0074
[phone]
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
2013FEB 12 P11 4: Of
DAH•U Fi;•c IITtLITlES COMM1S3k
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF NEXUS COMMUNICATIONS, INC. ) CASE NO. NCI-T-11-01
FOR DESIGNATION AS AN ELIGIBLE )
TELECOMMUNICATIONS CARRIER IN )
IDAHO ) MOTION FOR EXTENSION
) OF COMMENT PERIOD
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
Attorney of Record, D. Neil Price, Deputy Attorney General, to submit the foregoing Motion for
Extension of Comment Period.
XC[tIIIJP1J
On April 6, 2011, Nexus Communications, Inc. ("Nexus" or "Company"), filed an
Application, pursuant to 47 U.S.C. § 214(e)(6) of the Communications Act of 1934 ("the Act"),
47 C.F.R. § 54.201 et seq., and Order No. 29841, seeking designation as an eligible
telecommunications carrier ("ETC") in the State of Idaho for the sole purpose of receiving
Lifeline/Link-up ("Low-Income") support. Application at 1. On September 27, 2012, the
Company filed amendments to its original Application describing how Nexus will comply with
the new requirements in the Federal Communication Commission's ("FCC") rules for the
Lifeline Universal Service program instituted by the FCC's November 18, 2011 ("Connect
America Fund Order") and February 6, 2012 ("Lifeline Reform Order") Orders.
On January 22, 2013, the Commission issued a Notice of Application and Modified
Procedure with a 21-day comment period.
MOTION FOR EXTENSION
OF COMMENT PERIOD
MOTION FOR EXTENSION OF COMMENT PERIOD
Staff requests a 30-day extension from the end of the comment period for Nexus'
ETC Application. Recent discussions between Staff and representatives of Nexus revealed that
the Company intends to file an amendment to its Application in an attempt to bring the Company
into full compliance with the Commission's ETC requirements regarding the remittance of
applicable Idaho Telephone Service Assistance Program ("ITSAP") and E-911 fees.
Respectfully submitted this 12th day of February 2013.
, 9A1
D. eil Price
Deputy Attorney General
N:NCI-T- 11-01_np_Motion
MOTION FOR EXTENSION
OF COMMENT PERIOD 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 12TH DAY OF FEBRUARY 2013,
SERVED THE FOREGOING MOTION FOR EXTENSION OF COMMENT PERIOD,
IN CASE NO. NCI-T-11-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
DANIELLE FRAPPIER
BRIAN A NIXON
DAVIS WRIGHT TREMAINE
1919 PENNSYLVANIA AVE NW
STE 800
WASHINGTON DC 20006
E-MAIL: [e-mail]
[e-mail]
STEVEN FENKER, PRESIDENT
NEXUS COMMUNICATIONS INC
3629 CLEVELAND AVE
STEC
COLUMBUS OH 43224
E-MAIL: [e-mail]
-I a
CERTIFICATE OF SERVICE