20180403Comments.pdf

SEAN COSTELLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8743
IN THE MATTER OF THE APPLICATION OF )
PEERLESS NETWORK OF IDAHO, LLC FOR A )
R[CE IVED
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Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIBS COMMISSION
CASE NO. PEN.T.17-01
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY COMMENTS OF THE
COMMISSION STAFF
STAFF OF the Idaho Public Utilities Commission, by and through its Attorney of
record, Sean Costello, Deputy Attorney General, submits the following comments.
BACKGROUND
On August 29,2017, Peerless Network of Idaho, LLC ("Peerless") applied to the
Commission for a Certificate of Public Convenience and Necessity (Application)(CPCN)
authorizing it to provide local exchange and interexchange telecommunications services in
Idaho.
Peerless is an Idaho Limited Liability Company, headquartered at 222 S. Riverside Plaza,
Suite 2730, Chicago, IL 60606. It is registered with the Idaho Secretary of State and its
Certificate of Organization and Certificate of Existence is attached as Exhibit A to its
Application.
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ISTAFF COMMENTS APRIL 3,2018
STAFF ANALYSIS
On February 21,2018, Peerless filed a revision to its original filing. This filing was to
address some changes that Staff identified and were made to comply with the filing requirements
set out in Rule 1 14, IDAPA 31.01.01.1 14.
Peerless proposes, and requests authority, to offer local exchange and interexchange
telecommunications services statewide within the State of Idaho. Application at 1. Peerless
intends to provide facilities-based and resold local exchange and interexchange
telecommunications services. Peerless intends to provide telecommunications services to large
business/enterprise customers, and wholesale facilities-based services to other competitive local
exchange carriers ("CLECs"), Voice over Internet Protocol ("VolP") providers, and wireless
providers. Id. at3. Peerless intends to focus its service offerings in the territories of
Centurylink and Frontier, and, if certified, pursue interconnection agreements with those
providers. 1d.
Peerless provided its names and addresses of Officers and Directors, as well as financial
information, which it asserts is exempt from public disclosure pursuant to Rule 67 . See Exhibit
D; IDAPA 31.01.01.067.
Peerless agrees to comply with all Commission rules. Id. at 5. Peerless asserts that it
possesses the experience and financial ability to provide local and interexchange services in
Idaho. The Company maintains that granting the Application will serve the public interest,
convenience and necessity by promoting customer choice, competition and innovation in local
and interexchange telecommunications markets.
Peerless acknowledges that it is subject to numbering conservation measures including
mandatory thousand block pooling. The Company also acknowledges its obligations to monitor
number utilization rates and file appropriate utilization reports.
RECOMMENDATION
Staff has reviewed Peerless's Application and believes the Company understands the
Commission's rules and requirements related to the provision of telecommunication services in
Idaho. The Company asserts it will comply with all applicable rules, requirements and Orders.
Rule I 14.07 ,IDAPA 3l .01.01 .114.07 . Based on this review, Staff also believes that Peerless
possesses the requisite financial, managerial, and technical qualifications necessary to provide
2STAFF COMMENTS APRIL 3,2018
telecommunications services. Therefore, Staff recommends that the Commission issue a CPCN
to Peerless, subject to the following conditions:
l. The Company must comply with all number pooling and reporting requirements of the
North American Number Plan Administrator. See Commission Order No. 30425 and
Rule 114.08;
2. The Company must comply with all reporting and contribution requirements as
prescribed by the Idaho Universal Service Fund, Idaho Telecommunications Relay
System, ldaho Telecommunications Service Assistance Program; and
3. The Company must comply with all future reporting requirements deemed appropriate by
the Commission for competitive telecommunications providers.
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Respectfully submitted this ) day of April2018.
Sean Costello
Deputy Attorney General
Technical Staff: Carolee Hall
i:umisc/comments/pent 17. I scch comme nts
JSTAFF COMMENTS APRIL 3,2018
I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3'd DAY OF APRIL 2018, SERVED
THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. PEN-T-I7-OI, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
JULIE OOST A/P REG AFF
PEERLESS NETWORK INC
222 S RIVERSIDE PLAZA
STE 2730
CHICAGO IL 60606
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE