20040527Application.pdf

Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
msho bson~stoel. com
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UTiLITIES COt'"lr1ISSION
Adam L. Sherr (WSBA #25291)
Qwest
1600 7th Avenue - Room 3206
Seattle, W A 98191
Telephone: [phone]
Facsimile: [phone]
adam.sherr~qwest.com
Attorneys for Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE FURTHER
CONSOLIDATION OF RATE CENTERS
FOR QWEST CORPORATION IN
SOUTHERN IDAHO
CASE NO. r?Jt/lf, I- /JL/~/I
PETITION OF QWEST CORPORATION
Qwest Corporation (Qwest), pursuant to Rule 53 of the Commission s Rules of Practice
and Procedure IDAPA 31.01.01. 053 requests that the Commission modify its Order No. 28943
that consolidated certain rate centers in Qwest's southern Idaho territory. Specifically Qwest
requests that the Rigby and Roberts exchanges be included in the consolidated group that is
comprised of the Rexburg, Ririe, Shelley, and Idaho Falls exchanges. This Petition is based on
the following:
BACKGROUND
On its own Motion in September 1999, the Commission initiated an investigation
to examine various actions that had the potential to delay the need for additional telephone area
PETITION OF QWEST CORPORATION - Page
Boise-171183.1 0029164-00105
codes in Idaho. Rate center consolidation was one of the options considered because it reduces
the number of rate centers in a local calling area and, consequently, conserves NXX prefixes.
After exploring other options for sustaining the 208 area code, and after allowing
interested parties to offer comment, on February 1 , 2001, the Commission entered Order No.
28943, which created a consolidated group, designated "Qwest Group No." consisting of the
Idaho Falls, Rexburg, Ririe, Shelley (including Firth) exchanges. Order No. 28943 also adopted
Staffs recommendation that Rigby and Roberts be removed from the proposed list for Qwest
Group No.6 and that the two exchanges be consolidated into a separate group.
Staffs Comments in the rate consolidation docket explained that the
recommendation to exclude Rigby and Roberts from Qwest Group No.6 was based on a concern
that consolidating rate centers could impact the Commission s ability to implement EAS in the
future. However, since Order No. 28943 was entered, there has been no EAS activity relating to
Rigby and Roberts, nor does it appear that such activity is pending or expected.
REQUESTED MODIFICATION
Qwest now asks that the Commission revisit the decision to exclude Rigby and
Roberts from the larger consolidated group. These exchanges meet all of the criteria for
consolidation with Qwest Group No.6. In addition, the countervailing EAS concerns that
prevented their inclusion in Qwest Group No.6 have not materialized.
Customers located in the Rigby and Roberts exchanges have requested certain
advanced services from Qwest that it cannot provide using the switches that are serving that rate
center group. Further, Qwest cannot offer an alternative for the provision of such services that
would preserve the customers' existing telephone numbers.
PETITION OF QWEST CORPORATION - Page 2
Boise-171183.1 0029164-00105
If the Rigby and Roberts exchanges ar~ included in the same consolidated group
as the Idaho Falls exchange, Qwest will be able to offer certain advanced services to customers
in these locations by using the capabilities of the Idaho Falls switch, while preserving the
customers' existing telephone numbers.
Qwest is not requesting compensation for the implementation of the requested
rate center consolidation in this proceeding. Costs to implement the consolidation would be
limited to reprogramming Qwest's billing system and would not require network changes.
WHEREFORE, Qwest respectfully requests that:
The Commission modify its Order No. 28943 to include the Rigby and Roberts
exchanges in the consolidated rate group designated "Qwest Group No." which now consists
of the Idaho Falls, Rexburg, Ririe, Shelley (including Firth) exchanges.
The Commission find this issue does not require industry review, is not
contentious, and does not justify opening contested docket prior to decision.
The Commission determine at its next available decision meeting to that the
requested modified order may be entered.
Submitted this 26th day of May, 2004.
Qwest Corporation
f!:;d: Mary S. obson
Stoel Rives LLP
Adam L. Sherr
Qwest
Attorneys for Qwest Corporation
PETITION OF QWEST CORPORATION - Page 3
Boise-171183.10029164-00105
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 26th day of May, 2004, a true and correct copy of the
foregoing PETITION OF QWEST CORPORATION was served upon the following:
Jean D. Jewell, Commission Secretary Hand DeliveryIdaho Public Utilities Commission U.S. Mail, postage prepaid472 West Washington Street FacsimilePO Box 83720 Overnight Delivery
Boise, ill 83720-0074
Telephone: [phone]
Facsimile: [phone]
iiewell~puc.state.id.
~/fl ~ r;;;/
Brandi L. Gearhart, PLS
Legal Assistant to Mary S. Hobson
Stoel Rives LLP
PETITION OF QWEST CORPORATION - Page 4
Boise-171183.1 0029164-00105