20030213Comments.pdf

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ATTORNEYS AT lAW in.!'."
UTIL((its cor'n'fisSION
'0'MARY S. HOBSON
Direct [phone]
mshobson(fjJstoel.com
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February 13 , 2003
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, ill 83702-5983
RE:Docket No. QWE-O3-
Dear Ms. Jewell:
Enclosed for filing with this Commission is an original and eight (8) copies of the COMMENTS
OF Q'VEST CORPORATION.
If you have any questions, please contact me. Thank you for your cooperation in this matter.
Mary S. Hobson
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Enclosures
Oregon
Washington
California
Boise-153184.10029164-00012
Utah
Idaho
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F!LED
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Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ID 83702
Telephone: [phone]
Facsimile: [phone]
Email: mshobsonCfYstoel.com
2003 FEB /3 Pr'1 4:
ID /\ f~ 'c --; C
UTIL iT IES COiffi"'iISSION
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Adam L. Sherr (WSBA #25291)
Qwest
1600 7th Avenue - Room 3206
Seattle, W A 98191
Telephone: [phone]
Facsimile: [phone]
Email: asherrCfYqwestcom
Attorneys for Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF QWEST'
PROPOSAL TO USE REVENUE SHARING
FUNDS TO MAKE NETWORK
IMPROVEMENTS IN ITS SOUTHERN
IDAHO SERVICE AREA
Case. No. QWE-O3-
COMMENTS OF QWEST CORPORATION
On January 24, 2003, the Idaho Public Utilities Commission (the "Commission ) served a
Notice of Proposal- Notice of Modified Procedure (the "Notice ) in Case No. QWE-03-4. The
Notice requested public comment on Qwest's Tech III proposal within twenty-one days. The Tech
III proposal concerns the suggested disposition of funds generated by U S WEST's Revenue Sharing
Plan. Qwest requests the Commission take notice and incorporate herein its previously filed
December 31 , 2002 Proposal and its January 17 , 2003 Supplemental Comments. The Company
previously filed Proposal and Supplemental Comments detail Qwest's proposal and the public
benefits Qwest believes will be derived from the Tech III project
COMMENTS OF QWEST CORPORA nON -
Boise-153180.10029164-00012
Qwest asks the Commission to approve its Tech III proposal, which will provide improved
service reliability and improved functionality to Qwest Title 61 customers at a time of severe
constraints on Company resources for new capital investment The Company finds the Tech III
project will protect jobs, will benefit both retail and wholesale customers (by improving the
underlying network) and will continue a longstanding partnership between the IPUC and Qwest in
maintaining a superior telecommunications infrastructure in Idaho. Qwest believes Tech III provides
the best use of residual Revenue Sharing funds in a competitively neutral application of service
improvements that benefit all users ofthe common telephone network in Idaho. In addition, the
Company strongly feels the Tech III proposal offers vastly superior long term benefits than would a
small, one-time customer credit provided to each current Title 61 access line. Such a credit would
provide no lasting benefit to Title 61 customers, whereas Qwest's proposal would improve the
reliability and functionality of the local network, to the benefit of Idaho residents and to anyone
terminating calls to Idaho citizens and businesses utilizing facilities improved through the Tech III
investments.
Qwest is committed to providing the Commission quarterly and annual reports for its review
of all Tech III expenditures. The Company is poised to begin the work identified for the first 90 days
of the program upon receipt of Commission approval and transfer to the Company of the Revenue
Sharing Funds associated with this work. For all these reasons, the Company requests Commission
approval of the Tech III project, as proposed, as expeditiously as possible.
Submitted this 13th day of February, 2003.
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Mary S. Hobson
Stoel Rives LLP
Adam L. Sherr
Qwest
Attorneys for Qwest Corporation
COMMENTS OF QWEST CORPORATION - 2
Boise-153180.10029164-00012
CERTIFICATE OF SERVICE
I hereby certify that on this 13th day of February, 2003, I served the foregoing COMMENTS
OF QWEST CORPORATION upon all parties of record in this matter as follows:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, Idaho 83720-0074
ij ewell~puc . state. id. us
-L Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
John Souba
Regulatory Affairs Manager
Qwest Corporation
999 Main Street - 11
th Floor
Boise, ill 83702
i souba(fYqwest com
-L Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Conley Ward
Givens Pursley LLP
277 North 6th Street - Suite 200
O. Box 2720
Boise, ill 83701
Telephone: [phone]
Facsimile: [phone]
cew((i),gi venspurs lev. com
Attorney for ITA
-L Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
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Brandi L. Gearhart, PLS
Legal Secretary to Mary S. Hobson
Stoel Rives LLP
COMMENTS OF QWEST CORPORATION - 3
Boise-153180.10029164-00012