20020830Application.pdf

Mary S.Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard -Suite 1900
Boise,ID 83702 UilLi,¡LS COkiSli0N
Telephone:[phone]
Scott Seab
NOW Communications,Inc.NEW CASE711SouthTejonStreet-Suite 201
Colorado Springs,CO 80903
Telephone:[phone]
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
JOINT APPLICATION OF QWEST )Case No.:¿Ÿ 'y
CORPORATION AND NOW )
COMMUNICATIONS,INC.FOR APPROVAL )
OF THE AGREEMENT FOR TERMS AND )
CONDITIONS FOR INTERCONNECTION,)
UNBUNDLED NETWORK ELEMENTS,)
ANCILLARY SERVICES,AND RESALE OF )
TELECOMMUNICATION SERVICES FOR )
THE STATE OF IDAHO PURSUANT TO 47 )
U.S.C.§252(E))
Qwest Corporation ("Qwest")and NOW Communications,Inc.("NOW")hereby
jointly file their Application for Approval of the Agreement for Terms and Conditions for
Interconnection,Unbundled Network Elements,Ancillary Services,and Resale of
Telecommunication Services (the "Agreement")for the State of Idaho.A copy of the
Agreement dated December 10,2001,is submitted herewith.
This 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").
JOINT APPLICATION FOR APPROVAL OF THE AGREEMENT FOR TERMS AND CONDITIONS
FOR INTERCONNECTION,UNBUNDLED NETWORK ELEMENTS,ANCILLARY SERVICES,AND
RESALE OF TELECOMMUNICATION SERVICES FOR THE STATE OF IDAHO -1
Boise-142649.1 0029164-00016
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 the
agreement;or the implementation of such an agreement or portion is not consistent with the
public interest,convenience and necessity.
ICG and Qwest respectfully submit that this 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 will enable NOW to
interconnect with Qwest facilities and to provide customers with increased choices among local
telecommunications services.
NOW and Qwest further request that the Commission approve this Agreement without
a hearing.Because the 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.
Respectfully submitted this 266 day of August,2002.
Qwest Corporation
Mary S 'obson
Stoel es
and
Scott Seab
NOW Communications,Inc.
JOINT APPLICATION FOR APPROVAL OF THE AGREEMENT FOR TERMS AND CONDITIONS
FOR INTERCONNECTION,UNBUNDLED NETWORK ELEMENTS,ANCILLARY SERVICES,AND
RESALE OF TELECOMMUNICATION SERVICES FOR THE STATE OF IDAHO -2
Boise-142649.1 0029164-00016
CERTIFICATE OF SERVICE
I hereby certify that on this 26th day of August,2002,I served the foregoing JOINT
APPLICATION OF QWEST CORPORATION AND NOW COMMUNICATIONS,INC.
FOR APPROVAL OF THE AGREEMENT FOR TERMS AND CONDITIONS FOR
INTERCONNECTION,UNBUNDLED NETWORK ELEMENTS,ANCILLARY
SERVICES,AND RESALE OF TELECOMMUNICATION SERVICES 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
Mr.Scott Seab
NOW Communications,Inc.
711 South Tejon Street -Suite 201
Colorado Springs,CO 80903
Qwest Corporation
Director Interconnection Compliance
1801 California -Room 2410
Denver,CO 80202
Qwest Corporation
Law Department
ATTN:Corporate Counsel,Interconnection
1801 California Street --496 Floor
Denver,CO 80202
Brandi L.Gearhart,PLS
Legal Secretary to Mary S.Hobson
JOINT APPLICATION FOR APPROVAL OF THE AGREEMENT FOR TERMS AND CONDITIONS
FOR INTERCONNECTION,UNBUNDLED NETWORK ELEMENTS,ANCILLARY SERVICES,AND
RESALE OF TELECOMMUNICATION SERVICES FOR THE STATE OF IDAHO -3
Boise-142649.1 0029164-00016