20070815Motion to extend comment deadline.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3283
RECEIVED
laBl AUG ! 5 2: 02
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF QWEST
CORPORATION'S REVISIONS TO THE
IDAHO QWEST PERFORMANCE
ASSURANCE PLAN (QPAP)
) CASE NO. QWE- T -03-
MOTION TO EXTEND TIME FOR
) FILING COMMENTS
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through
its Attorney of record, Weldon B. Stutzman, Deputy Attorney General, and files this Motion to
Extend Time for Filing Comments. The Commission issued a Notice of Application and Notice
of Modified Procedure in Case No. QWE-03-23 on July 27, 2007, setting August 17 2007 as
the deadline for filing written comments.
On June 26, 2007, Qwest filed a Notice of Stipulation regarding certain performance
indicator definitions (PIDs) and Qwest's Performance Assurance Plan (QPAP) provisions. The
rIDs and QPAP are part of Qwest's Statement of Generally Available Terms and Conditions that
provides terms for competitive local exchange carriers to interconnect with Qwest's local service
facilities. The filing also includes a Motion by Qwest, on its own behalf and by three
competitive local exchange companies (CLECs), for approval of the proposed changes to the
QPAP. Qwest, Eschelon Telecom, Inc., DIECA Communications Inc. dba Covad
Communications Company, and McLeodUSA Telecommunications Services, Inc. agreed to the
changes to the rIDs and the QPAP in meetings held between May 23 2006 and May 17,2007.
Qwest requested that the Commission accept the Stipulation describing the proposed changes
MOTION TO EXTEND
TIME FOR FILING COMMENTS
and apply the changes to any interconnection agreements containing the Performance Assurance
Plan, and also to allow the PID changes to go into effect no later than 60 days in accordance with
47 US.C. ~ 252(t)(3).
The Stipulation was filed in all 14 Qwest states and is currently being discussed as a
multi-state matter by the Regional Oversight Committee (ROC) staff. Only three CLECs are
parties to the Stipulation and the proposed alterations to the rIDS and QP AP may affect other
CLECs that are not a party to the Stipulation. Staff believes Qwest's filing should be carefully
reviewed and that more time is needed to evaluate the impact the proposed Tier 1 and Tier 2
penalty payments have on other CLECs and states. The ROC staff has informally requested that
Qwest provide revenue impact analysis using the last two years of actual Tier 1 and Tier 2
payments to CLECs and states, and to provide projected revenue payments using the proposed
revisions in the Stipulation.
On August 6 2007, the chairman of the ROC delivered a letter to Qwest asking for an
extension of time, until September 28 2007, to allow states time to determine the revenue impact
to other CLECs or State Commissions. In a letter to Staff dated August 14 2007, Qwest stated it
will not oppose an extended review through September 28 2007.
Staff requests that the Commission issue an Order extending the time foro filing
written comments in this case until September 28, 2007. The additional time will allow Staff and
interested parties the opportunity to obtain additional information from Qwest and to evaluate the
affect of the changes on CLECs and on Tier 1 and Tier 2 payments.
Respectfully submitted this
;~
day of August 2007.
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Weldon B. Stutzman
Deputy Attorney General
bls/N:QWETO323- ws Motion
MOTION TO EXTEND
TIME FOR FILING COMMENTS
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 15th DAY OF AUGUST 2007
SERVED THE FOREGOING MOTION TO EXTEND TIME FOR FILING COMMENTS,
IN CASE NO. QWE-03-, BY MAILING A COpy THEREOF, POSTAGE
PREPAID, TO THE FOLLOWING:
MARY S HOBSON
999 MAIN STE 1103
BOISE ID 83702
ADAM L SHERR
CORPORATE COUNSEL
1600 7TH AVE RM 3206
SEATTLE WA 98191
ESCHELON TELECOM INC
730 SECOND AVE S STE 1200
MINNEAPOLIS MN 55402
DIECA COMMUNICATIONS INC
DBA COVAD COMMUNICATIONS COMPANY
110 RIO ROBLOS
SAN JOSE CA 95134-1813
McLEODUSA TELECOMMUNICATIONS
SERVICES INC
PO BOX 3177
CEDAR RAPIDS IA 52406-3177
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SECRET AR Y
CERTIFICATE OF SERVICE