20010118Application.pdf

10 S ST0EL RIVES UP
MATTORNEY LED

101 SOUTH CAPITOL BOULEVARD
2CI JAN 8 : 55 SUITE 1900

BOISE, IDAHO 83702-5958
jJjJ PUBLIC Phone [phone] Fax [phone]
U Ti Liii ES C OMMI S S IOU
January 17, 2001
MARY S. HOBSON
Direct Dial
[phone]
email [e-mail]
Ms. Jean Jewell, Secretary
Idaho Public Utilities Commission
472 W. Washington Street
Boise, Idaho 83720-0074
Re: Case No.
Joint Application of Qwest Corporation and Washington RSA No. 8
Limited Partnership for Approval of a Type 2 Wireless
Interconnection Agreement for the State of Idaho pursuant to 47
U.S.C. 252(e)
Dear Ms. Jewell:
Enclosed for filing with this Commission on behalf of Qwest Corporation and Washington RSA
No. 8 Limited Partnership is an original and seven (7) copies of the parties' Joint Application seeking
approval of a Type 2 Wireless Interconnection Agreement for the State of Idaho. The parties
respectfully request that this matter be placed on the Commission Decision Meeting Agenda for
expedited approval.
Please contact me if you have any questions concerning the enclosed. Thank you for your
assistance in this matter.
Sincerely,

"&a - --
Mary S/jlobson
Enclosures
cc: Luba Hromyk do Denise Boucher (with pleading, with agreement)
John Coonan (with pleading, with agreement)
BOISE-119791.1 0029164-00016
SEATTLE PORTLAND VANCOUVER, WA BOISE SALT LAKE CITY WASHINGTON, D.C.
. .
Mary S. Hobson, ISB# 2142
Stoel Rives LLP
101 S. Capital Blvd., Suite 1900
Boise, ID 83702
Tele: [phone]
John Coonan
Washington RSA No. 8 Limited Partnership
103 South Second Street
P0 Box 688
Roslyn, WA 98941
Tele: [phone]
FAX: [phone]
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
JOINT APPLICATION OF QWEST )
CORPORATION AND WASHINGTON RSA )
NO. 8 LIMITED PARTNERSHIP FOR )
APPROVAL OF A TYPE 2 WIRELESS )
INTERCONNECTION AGREEMENT for the )
State of Idaho PURSUANT TO 47 U.S.C. )
§252(e) )
CASE No.
Qwest Corporation ("Qwest"), formerly U S WEST Communications, Inc., and
Washington RSA No. 8 Limited Partnership ("Washington RSA") hereby jointly file this
Application for Approval of a Type 2 Wireless Interconnection Agreement for the State of
Idaho, dated November 13, 2000 (the "Agreement"). A copy of the Agreement is submitted
herewith.
Application for Approval of a Type 2 Wireless Interconnection Agreement for the State of Idaho between Qwest and Washington RSA - 1
BOISE-119793.1 0029164-00016
S .
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 Communications
Act of 1934, as amended by the Telecommunications Act of 1996 (the "Act").
Section 252(e)(2) of the Act directs that a state Commission may reject an agreement
reached through voluntary negotiations only if the Commission finds that: the agreement (or
portion thereof) discriminates against a telecommunications carrier not a party to this
agreement; or the implementation of such an agreement or portion is not consistent with the
public interest, convenience and necessity.
Washington RSA and Qwest respectfully submit that the Agreement provides no basis
for either of these findings, and, therefore jointly request that the Commission approve the
Agreement expeditiously. The Agreement is consistent with the public interest as identified in
the pro-competitive policies of the State of Idaho, the Commission, the United States Congress,
and the Federal Communications Commission. Expeditious approval of the Agreement will
enable Washington RSA to interconnect with Qwest facilities and to provide customers with
increased choices among local telecommunications services.
Washington RSA and Qwest further request that the Commission approve this
Agreement without a hearing. Because this Agreement was reached through voluntary
negotiations, it does not raise issues requiring a hearing and does not concern other parties not
a party to the negotiations. Expeditious approval would further the public interest.
Application for Approval of a Type 2 Wireless Interconnection Agreement for the State of Idaho between Qwest and Washington RSA - 2
BOISE-119793.1 0029164-00016
. .
Respectfully submitted this lay of January, 2001.
Qwest Corporation
Mary S. Wilson
Stoel Rives
and
John Coonan
Washington RSA No. 8 Limited Partnership
Application for Approval of a Type 2 Wireless Interconnection Agreement for the State of Idaho between Qwest and Washington RSA - 3
BOISE-119793.1 0029164-00016
.

.
CERTIFICATE OF SERVICE
I hereby certify that on this day of January, 2001, I served the foregoing JOINT
APPLICATION OF QWEST CORPORATION and WASHINGTON RSA NO. 8 LIMITED
PARTNERSHIP FOR APPROVAL OF A TYPE 2 WIRELESS INTERCONNECTION
AGREEMENT FOR THE STATE OF IDAHO PURSUANT TO 47 U.S.C. §252(e) upon all
parties of record in this matter by mailing a copy thereof properly addressed, with postage
prepaid as follows:
Ms. Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83720-0074
John Coonan
Washington RSA No. 8 Limited Partnership
103 South Second Street
P0 Box 688
Roslyn, WA 98941
Mary S. "son
Stoel Riv6d LLP
Application for Approval of a Type 2 Wireless Interconnection Agreement for the State of Idaho between Qwest and Washington RSA - 4
BOISE-119793.1 0029164-00016