20050429Petition.pdf

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".",wi'.Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoe1. com
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Adam L. Sherr (WSBA #25291)
Qwest
1600 7th Avenue - Room 3206
Seattle, W A 98191
Telephone: [phone]
Facsimile: [phone]
adam. sherr~qwest. com
IN THE MATTER OF THE FURTHER
CONSOLIDATION OF RATE
CENTERS FOR QWEST
CORPORATION IN SOUTHERN
IDAHO
BEFORE THE PUBLIC UTILITIES COMMISSION OF IDAHO
Case No. wE -
- /
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 that Commission modify its Order No. 28943
which consolidated certain rate centers in Qwest's southern Idaho territory. Specifically Qwest
requests that the consolidated rate center containing the Boise and Idaho City exchanges be
consolidated with the rate center containing the Kuna, Meridian, Middleton and Star 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-183533.1 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 certain consolidated rate centers. One such center, designated "Boise
consisted of the Boise and Idaho City exchanges; another, designated "Meridian " consisted of
the Kuna, Meridian, Middleton and Star exchanges.
Since the entry of Order No. 28943, commercial activity in the Treasure Valley,
and particularly in Ada County, has increased. Some of Qwest's larger customers have business
operations located in both the Boise and Meridian rate centers. Qwest finds that it cannot meet
all of customers' needs to integrate the operations of these business customers without the ability
to port local numbers between the Meridian and Boise consolidated rate centers.
Pursuant to federal regulation, numbers cannot be ported between rate centers.
II.REQUESTED MODIFICATION
Qwest asks that the Commission consolidate the Meridian and Boise rate centers.
Because these two rate centers presently have slightly different local calling areas, Qwest also
asks that the Commission modify the local calling area for the Qwest customers in the
consolidated Meridian rate center to facilitate this consolidation request. Qwest does not request
compensation for the implementation of the requested consolidation or for changes to the local
calling area.
See 47 CFR ~ 52.26 (a), adopting the report of the North American Numbering Council Working Group,
dated April 25, 1998. That report states at Section 7.3, titled "LNP Portability Boundary,
" "
. . . location portability
is technically limited to rate center/rate district boundaries of the incumbent LEC due to rating/routing concerns.
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Boise-183533.10029164-00105
One of the criteria used by the Commission in determining how rate centers
should be consolidated is whether the exchanges that are candidates for consolidation have
identical local calling areas. Over the past several years, this Commission has created very large
local calling areas in southern Idaho by granting extended area service (BAS) between the
exchanges operated by Qwest and, in some cases, those of other Idaho telecommunications
corporations. These BAS regions have accorded customers toll-free access to business and
residents throughout the Treasure Valley and surrounding communities.
The six exchanges affected by this Petition, i., Boise, Idaho City, Kuna
Meridian, Middleton and Star, do not have identical BAS calling areas. Boise and Idaho City
have BAS to the Lowman exchange, which is operated by Cambridge Telephone Company
(Cambridge), while the exchanges in the consolidated Meridian rate center do not have toll-free
calling to Lowman.
To facilitate further rate center consolidation and provide the customer benefits
including the ability to port local numbers between exchanges, Qwest requests that the
Commission expand the local calling area of its Kuna, Meridian, Middleton and Star exchanges
to include Lowman.
Qwest proposes that it implement the BAS routes to provide one-way local calling
to Lowman from its Kuna, Meridian, Middleton and Star exchanges at its own expense.
10.Should Cambridge decide to expand its Lowman customers' local calling area to
include Kuna, Meridian, Middleton and Star, Qwest also agrees to implement that expansion
without requesting compensation for Qwest's lost access and toll revenues or for any additional
implementation expense to accommodate a proposed two-way BAS.
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Boise-183533.1 0029164-00105
11.Qwest acknowledges that the volume of calling and the customer demand for
expansion of BAS between the consolidated Meridian rate center and Lowman do not rise to the
levels that justified BAS expansion under the Commission s public interest standard. In contrast
to typical BAS requests, in this case calling volumes are low2 and the requested BAS expansion
has little or no impact economic impact on either of the companies.3 The customers in the
affected exchanges, however, can only benefit by expanded BAS.
12.Rather than meeting a customer demand for a larger local calling area, this BAS
expansion is driven by the need to consolidate rate centers to facilitate other customer needs
including the ability to port numbers within the large commercial center located in the Treasure
Valley.
13.In its initial order on rate center consolidation4 the Commission stated
, "
we find
that consolidation will conserve the assignment of and promote greater efficiency in the use of
NXX codes. This, in turn may extend the life of Idaho s area code." Bringing the Kuna
Meridian, Middleton and Star exchanges into the same consolidated rate center as Boise and
Idaho City will advance these goals of efficient use and conservation ofNXX codes and will
serve to extend the life of Idaho s area code.
III.CONCLUSION
Granting this request for consolidation of the Meridian and Boise rate centers yields the
benefits of conserving NXX codes and extending the life of the Idaho area code, as well as
For the period August-October, 2004 calls originating in the Qwest exchanges ofKuna, Meridian
Middleton and Star and terminating in Lowman totaled 102, producing an average 34 per month.
3 Qwest, for example, estimates that it wi11lose substantially less than $2000.00 per year in toll and
originating access revenue should these four EAS routes be converted to EAS. Under the Qwest proposal for one-
way EAS, Cambridge would retain its toll and originating access revenues.
Order No. 28943 In the Matter of the Investigation into Rate Center Consolidation for Qwest Corporation
in Southern Idaho to Conserve Available NXX Codes Case No. USW-99-21 (Feb. 1 2002.
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Boise-183533.1 0029164-00105
allowing Qwest to meet customers' needs to port numbers within the Treasure Valley. Creation
ofEAS between the Qwest exchanges ofKuna, Meridian, Middleton and Star and the Cambridge
exchange of Lowman will have little or no impact on the companies and can only benefit the
customers located in the affected exchanges.
WHEREFORE, Qwest respectfully requests that:
The Commission modify its Order No. 28943 to consolidate the Boise rate center
(consisting of the Boise and Idaho City exchanges) and the Meridian rate center (consisting of
the Kuna, Meridian, Middleton and Star exchanges);
To affect the requested rate center consolidation, the Commission grant one-way
EAS between the Qwest exchanges of Kuna, Meridian, Middleton and Star to the Cambridge
exchange of Lowman;
The Commission find, pursuant to IPUC Rule of Procedure 201 , that the public
interest does not require a hearing to consider the issues presented and that the proceeding may
be processed under modified procedure.
Respectfully submitted this 29th day of April, 2005.
Adam L. Sherr
QWEST CORPORATION
Attorneys for Qwest Corporation
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Boise-183533.1 0029164-00105
CERTIFICATE OF SERVICE
I hereby certify that on this 29th day of April, 2005, I served the foregoing PETITION
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
llewell~puc.state.id.
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Weldon Stutzman
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, Idaho 83720-0074
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Ron Wiggins
Cambridge Telephone
rwiggins~CTCW eb.net
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Brandi L. Gearhart, PLS
Legal Secretary to Mary S. Hobson
Stoel Rives LLP
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