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Home My WebLink About20040526Comments of ITA.pdfConley E. Ward (ISB #1683) Michael C. Creamer (ISB #4030) GIVENS PURSLEY LLP 601 West Bannock Street O. Box 2720 Boise, Idaho 83701-2720 Telephone: 208-388-1200 Facsimile: 208-388-1300 ('.I , \ In... I 'i fl rn r I !'~ L ill lOOl, rlAY 2' fM 3:1.t1 HI F'UBLiC . -::- .-.,., .. .. . c: ...\1i n"1 t -t- ~ . . . ' In.,J 1.Vli_JI-- S:\CLIENTS\1233\183\Comments on Qwest Application.DOC Attorneys for Idaho Telephone Association BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION FOR CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY AND TITLE 62 NOTICE OF QWEST COMMUNICATIONS CORPORATION Case No: QCC- T -04- COMMENTS OF IDAHO TELEPHONE ASSOCIATION Idaho Telephone Association ("ITA"), through its attorneys Givens Pursley LLP, on behalf of its member independent local exchange carriers, and pursuant to IDAP A 31.01.01.203 and Commission Order 29496, hereby submits Comments on the above-captioned Application of Qwest Communications Corporation. ("QCC" COMMENTS The independent local exchange carries on whose behalf ITA submits these Comments currently are the exclusive providers of basic local exchange service within their respective service areas pursuant to Certificates of Public Convenience and Necessity issued by the Idaho Public Utilities Commission ("Commission QCC's Application seeks to amend its Certificate of Public Convenience and Necessity to enable it to provide local services throughout the State of Idaho. QCC requests this COMMENTS OF IDAHO TELEPHONE ASSOCIATION - 1 amendment to provide local exchange service and vertical features to business and residential customers throughout the State of Idaho. QCC intends to provide local services using a combination of its own facilities and resold services and/or unbundled network elements. Each of ITA's member local exchange carriers meet the definitions of a Common Carrier " " Telecommunications Carrier" and "Rural Telephone Carrier" under the Federal Telecommunications Act of 1996 ("1996 Act" QCC has not made a bona fide request to ITA's members for interconnection services or network elements. Any grant of certificate authority to QCC should be made expressly subject to the exemption of ITA members from the obligations of incumbent local exchange carriers under section 251 (c) of the 1996 Act, until such time as the requirements for lifting such exemption contained in section 251(f) of the 1996 Act have been met. Respectfully submitted this ay ofMay2004. ~~:7 Conley E. Ward Michael C. Creamer Attorneys for Idaho Telephone Association COMMENTS OF IDAHO TELEPHONE ASSOCIATION - 2 CERTIFICATE OF SERVICE I hereby certify that on this ~ay of May 2004, I caused to be served a true and correct copy of the foregoing by the method indicated below, and addressed to the following: Commission Secretary Idaho Public Utilities Commission 472 W. Washington Street Boise, ID 83720-5983 S. Mail Facsimile and Delivery Overnight Mail ~. Mail~F acsimile Hand Delivery Overnight Mail Mary S. Hobson Stoel Rives LLP 101 S. Capitol Blvd., Suite 1900 Boise, ID 83702-5958 Adam L. Sherr Qwest 1600 ih Avenue-Rom 3206 Seattle, W A 98191 ---u:-8. Mail Facsimile Hand Delivery Overnight Mail Ptl Michael C. Creamer COMMENTS OF IDAHO TELEPHONE ASSOCIATION - 3