20001025Comments.doc

JOHN R. HAMMOND
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5470

Street Address for Express Mail:
472 W. WASHINGTON
BOISE, ID 83702-5983

Attorney for the Commission Staff

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE JOINT APPLICATION
OF QWEST CORPORATION AND CONTINENTAL F.S. COMMUNICATIONS, INC. FOR APPROVAL OF A RESALE INTERCONNECTION AGREEMENT PURSUANT TO 47 U.S.C. § 252(e).
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CASE NO. QWE-T-00-12

COMMENTS OF THE
COMMISSION STAFF

COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its Attorney of record, John R. Hammond, Deputy Attorney General, in response to Order No. 28530
the Notice of Joint Application and Notice of Modified Procedure in Case No. QWE-T-00-12 issued on October 4, 2000, submits the following comments.
On September 19, 2000, Qwest Corporation and Continental F.S. Communications, Inc. filed a Joint Application requesting approval of a resale interconnection agreement. The Joint Application states that the Agreement was reached through voluntary negotiations without resort to mediation or arbitration and is submitted for approval pursuant to Section 252(e) of the Telecommunications Act of 1996.

STAFF ANALYSIS
Staff reviewed the language of this Agreement and did not find any terms or conditions that Staff would consider discriminatory. The rates and terms are very similar to those contained in other resale agreements submitted by U S WEST, now Qwest, and previously approved by this Commission. Staff concurs with the companies claim that the Agreement is consistent with the pro-competitive policies of the Commission, the Idaho Legislature, and the Telecommunications Act of 1996. Accordingly it is consistent with the public interest.
STAFF RECOMMENDATION
Staff recommends the Commission approve the Interconnection Agreement as filed.

DATED at Boise, Idaho, this day of October 2000.

________________________
John R. Hammond
Deputy Attorney General

Technical Staff: Wayne Hart

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STAFF COMMENTS 1 OCTOBER 25, 2000