20040507Letter.pdf

May 6, 2004
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Joe Cusick
Telecom Supervisor
Idaho Public Utilities Commission
O. Box 83720
Boise, Idaho 83720-0074
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Qwest.
Spirit of Service
RE: QCC CLEC APPLICATION --QCC-O4-
Dear Joe
In our conversation on May 4th I committed to provide additional information regarding QCC'
CLEC application in Idaho. QCC is seeking a CLEC certificate because, in part, it is possible to
read the statutes and orders in this area as requiring a CLEC certificate for provision of "local
exchange service" as well as the more narrowly defined category, "basic local exchange
service." Furthermore, as will be explained below, even if this interpretation is overly cautious
(meaning a certificate is not required ifQCC's services do not include basic local exchange
service) it is prudent for QCC to obtain a certificate at this time.
QCC's 's answers to Staff discovery indicate that QCC's focus initially will be on the provision
of local exchange service to Title 62 business customers, i.e. those who subscribe to six or more
lines billed to a single billing location. Nevertheless, QCC is concerned with having the
flexibility to manage its business into the future.
First, in responding to RFPs for business customers seeking service on a multi-location basis
QCC would like to avoid missing out on the opportunity to serve. Should even one of the
customers' billing locations require five or fewer lines , a CLEC certificate would technically be
required for QCC to serve that location. While under such circumstances provision of service to
a single location with five or fewer lines would fall within the "basic local exchange" definition
it would nonetheless be consistent with the overall thrust ofQCC's business plans as described
in its responses to Staff's discovery requests.
Second, the public interest is served by granting QCC permission without restrictions to compete
as a CLEC, because QCC will gain the ability its competitors like Sprint, MCI, AT&T, and
regionally-based CLEC's already have: the ability to provide both local and nation"wide services
through a single, simple, unconfusing entity.
Adding QCC to the competitive marketplace for both local and interexchange
telecommunications services with the structural advantages other CLECs enjoy benefits
consumers and serves the public interest by stimulating more competition in the market for
telecommunications, which generally results in better service, lower prices, greater availability,and improved innovation.
I hope this sheds additional light on the QCC CLEC Application before you. The Company
looks forward to moving the Application forward and, ultimately, providing service to Idaho
customers. Should you have additional questions, please feel free to contact me on 208-385-
8666.
smee
John Souba
Director Regulatory Affairs