JointMotion-Draft.doc

Mary S. Hobson (ISB#: 2142)
Curtis D. McKenzie (ISB#: 5591)
Stoel Rives LLP
101 S. Capitol Blvd., Suite 1900
Boise, ID 83702-5958
Telephone: [phone]
Facsimile: [phone]

Attorneys for Qwest Corporation

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE TARIFF ADVICE )
SUBMITTED BY QWEST COMMUNICATIONS ) CASE NO.
TO REVISE ITS PERCENT INTERSTATE USAGE ) QWE-T-01-16
(PIU) REPORTING METHODOLOGY FOR )
ACCESS SERVICES IN ITS NORTHERN IDAHO )
SERVICE AREA. ) ________________________________________________)

JOINT MOTION OF STAFF and QWEST CORPORATION

On May 30, 2001 Qwest Corporation (Qwest) filed Tariff Advice No. 01-03-N that proposed revisions to Qwest’s Northern Idaho Access Tariff. When effective, the revised tariff language would make certain changes regarding the use and methods of reporting percent of interstate use (PIU). Qwest requested an effective date of July 1, 2001.
By Order No. 28768, served June 29, 2001, the Commission suspended Qwest’s tariff advice for a period not to exceed 60 days from July 1, 2001. The Commission Staff had recommended the suspension on the basis that it needed additional time to gather information and to give affected carriers the opportunity to file comment. The Commission directed interested persons to file comments no later than August 2, 2001. Order No. 28768 at 3, 4.
By this motion, the Commission Staff joins Qwest in seeking this Commission’s order allowing Tariff Advice No. 01-03-N to go into effect on its effective date pending completion of the Staff’s investigation and the receipt of public comment, if any. This motion is based on the fact that Qwest is seeking to simultaneously implement this change across its fourteen state service territory and for the interstate jurisdiction. Suspension of the tariff for northern Idaho will frustrate this effort. Qwest states that this tariff change has not been controversial and has been approved in every other jurisdiction.
The concerns expressed by the Commission in its Order No. 28768 can be accommodated by allowing the Tariff Advice to go into effect and receiving public comment as planned. Should the Commission ultimately decide that the Tariff Advice should be rejected, Qwest will make the necessary changes to return to operation under the tariff that is now in effect.
RESPECTFULLY SUBMITTED This ___day of July, 2001.

________________________
Donald L. Howell, II
Deputy Attorney General
Idaho Public Utilities Commission

Attorney Representing
Idaho Public Utilities Commission Staff

_________________________
Mary S. Hobson
Stoel Rives, LLP

Attorneys Representing
Qwest Corporation

MOTION OF QWEST CORPORATION - 1
Boise-127356.1 0029164-00075