20220330Comments.pdf

RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03r8
IDAHO BAR NO. II2O2
Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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IN THE MATTER OF OREGON TELEPHONE
CORPORATION'S AMENDED
APPLICATION FOR A CERTIFICATE OF
PUBLIC CONVENIENCE AND NECESSITY
TO PROVIDE LOCAL EXCHANGE
SERVICES WITHIN THE STATE OF IDAHO
CASE NO. ORT.T.22-OI
COMMENTS OF THE
COMMISSION STAFF
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STAFF OF the Idaho Public Utilities Commission, by and through its Attorney of
record, Riley Newton, Deputy Attomey General, submits the following comments.
BACKGROUND
On January 18,2022, Oregon Telephone Corporation ("Company" or "OTC") applied for
a Certificate of Public Convenience and Necessity ("CPCN") to provide wholesale transport,
retail broadband, Voice over Internet Protocol ("VoIP") service in Idaho.
On February 17,2022, the Company filed an Amended Application for a CPCN to
correct deficiencies in its initial application.
The Company is an Oregon corporation authorized to do business in Idaho as a foreign
corporation.
The Company plans to "provide wholesale transport along with retail broadband and
local exchange services" statewide. Application at 1-3.
ISTAFF COMMENTS MARCH 30,2022
The Company asserts it will file a proposed price list, but that broadband services and
VoIP services will be provided on a de-tariffed basis with rates, terms and conditions posted on
its website (otcconnections.net). Id. at3.
The Application includes a customer contact for complaints and inquiries. The Company
also filed confidential financial statements. The Company asserts it will comply with
Commission rules.
STAFF REVIEW
Staff examined the Company's Application and the accompanied exhibits. Staff verified
that the name, address, and the form of business presented in the Application are correct;
confirmed that the Certificates of lncorporation and Authority to transact business in ldaho are
valid; and confirmed the financial viability of the Company by reviewing the financial
statements (consolidated income and balance sheet statements) the Company submitted.
Staff believes the Company understands the Commission's rules and requirements
pertaining to the provision of telecommunication services in Idaho. Staff believes the Company
possesses the requisite financial, managerial, and technical qualifications necessary to operate as
a provider of telecommunications services. Staff believes the Company's Application fulfills the
requirements of procedural Rule 114 and Order No. 26665.
STAFF RECOMMENDATIONS
After its review, Staff recommends approval of the Company's Application for a CPCN
subject to the following conditions:
1. OTC complies with number pooling and reporting requirements of the North
American Numbering Plan Administrator, as set forth in Commission Order
No.30425;
2. OTC provides necessary reports and contributions appropriate to the Idaho
Universal Service Fund, Idaho Telecommunications Relay Services, Idaho
Telecommunications Service Assistance Program, and complies with all future
reporting requirements deemed appropriate by the Commission for competitive
telecommunications providers ;
2STAFF COMMENTS MARCH 30,2022
3. Prior to issuance of the CPCN, OTC files a final price list outlining all its rates,
terms, and conditions with the Commission;
4. OTC provides three reports to the Commission indicating the number of basic
local exchange customers it has and the services being offered. These reports will
be due as follows:
a. August I,2022
b. December 1,2022
c. Aplill,2023
If the Company fails to timely provide any of the three reports, OTC shall
relinquish its CPCN and all telephone numbers it has been assigned or the
Commission will by its own order revoke the Company's CPCN; and
5. If OTC is not providing basic local exchange service by the time the third report
is due, the Commission by its own order will revoke the Company's CPCN.
Respectfully submitted this SOIP day of March 30, 2022.
Riley N
Deputy General
Technical Staff: Johan Kalala-Kasanda
i:umisc/commens/ortt22. I mjk comments
JSTAFF COMMENTS MARCH 30,2022
CERTIFICATE OF SERVICE
r HEREBy cERTIFy rHAT r HAVE THIS 30n ply oF MARCH2Izz,
SERVED THE FOREGOING COMMENTS OF TIIE COMMISSION STAFF, IN
CASE NO. ORT-T-2}-OI, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
MARCUS BOTT
OREGON TELEPHONE CORP
PO BOX 609
I TELEPHONE DRIVE
MT VERNON OR 97865
E-MAIL : [e-mail]
DELINDA KLUSER
OREGON TELEPHONE CORP
PO BOX 609
1 TELEPHONE DRIVE
MT VERNON OR 97865
E-MAIL : [e-mail]
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SECRETARY '/
CERTIFICATE OF SERVICE