20081126Motion for Extension, Revise Schedule.pdf

Mar S. Hobson
Attorney & Counselor
999 Main, Suite 1103
Boise, il 83702
208-385-8666
RECEIVED
lODD NOV 26 PH~: 25
IDAHO PUB.~\(~ 'I
UTILITIES COf.MTH:.SIO¡\í
November 26,2008
VIA HAND DELIVERY
Jean D. Jewell, Secretar
Idaho Public Utilities Commission
472 West Washington
Boise, ID 83702-5983
RE: Docket No. QWE- T -08-04
Dear Ms. Jewell:
Enclosedfor filing with this Commission are an original and seven (7) copies ofQWEST
CORPORATION'S MOTION FOR EXTENSION OF COMMENT DEADLINE
AND REVISED PROCEDUR SCHEDULE. If you have any questions, please
contact me. Than you for your cooperation in this matter.
Ver trly yours,
ßLfiii'b !-~
Mar S. ,'boon
Enclosures
cc Serice List
Mar S. Hobson (ISB. No. 2142)
999 Main, Suite 1103
Boise, ID 83702
Tel: [phone]
mar.hobsonßYqwest.com
RECE\VEO
tOnS NOV 26 PM~: 25
\OAHO PU9JJC~ "I '!
UTIUTIES CO~Ii(~t\SSION
Adam L. Sherr
Corporate Counsel, Qwest
1600 7th Avenue, Room 3206
Seattle, W A 98191
Tel: [phone]
adam.sherßYqwest.com
Attorneys for Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
In Re WITHDRAWAL of QWEST
COPORATION'S STATEMENT OF
GENERAL y AVAILABLE TERMS AND
CONDITIONS
Case No. QWE-T-08- 04
Qwest Corporation's Motion for Extension
of Comment Deadlie and Revised
Procedural Schedule .
On September 4,2008, the Commission issued a Notice of Procedural Schedule
which, among other dates, set a deadline for Staff and Intervenors to file comments or
briefs concering Qwests Petition and supporting filings for October 31,2008.
Thereafter, on October 23,2008, Staff filed a Motion to Extend Deadline for Comments
and Vacate Hearng Date. By Order No. 30662, the Commission granted Staffs motion
and extended the deadline for Staff and Intervenors to file comments or briefs to
December 1,2008. The Commission also vacated the hearng date for oral arguent.
As indicated in Staffs October motion, Qwest is in the process of developing an
alterative approach to some of the issues raised in its Petition. On November 25,2008,
Qwest distrbuted a draft proposal to Staff and Interenors that is aimed at addressing
Qwest Motion for Extension of
Comment Deadlie and Revised
Procedural Schedule - 1 -
concerns about Qwests petition to withdraw its Performance Assurance Plan ("QP AP").
The paries are scheduled to hold a conference call on December 3,2008 to review and
discuss this draft proposaL. In light of these developments, Qwest believes that it is
appropriate for the Commission to again extend the deadline for Intervenor and Staff
input. The undersigned counsel for Qwest has reviewed this proposal with
representatives ofthe Intervenors and Staff. The representatives ofIntegra Telecom and
360Networks (USA) Inc. stated they have no objection. Staff s attorney of record
advised that he had also discussed the schedule change with Interenors and that no party
objected to the vacation of the December 1, 2008 deadline.
Following the above-described conference call of December 3,2008, Qwest
intends to develop a final version of its alterative proposal for filing in the record of this
docket. Thereafter Qwest suggests the following procedural schedule:
. Thirty (30) days following serice of Qwest s alterative filing: Staff and
Intervenor comments or briefs wil be filed and served;
. Fourteen (14) days following service of Staff and Intervenor comments,
Qwest wil fie responsive comments, if any.
At present Qwest does not believe that it wil be necessar for the Commission to set a
date for oral arguent.
Based on the foregoing Qwest requests that the Commission vacate the comment
deadline presently set for December 1, 2008 and adopt the schedule presented above.
Respectfully submitted this 26th day of November, 2008.
_,l¿tiii ~' tL L-
Mar S. Hob on (ISB. No. 2142)
999 Main. uite 11 03
Boise, ID 83702
Adam L. Sherr
Corporate Counsel, Qwest
1600 7th Avenue, Room 3206
Seattle, W A 98191
Attorneys for Qwest Corporation
Qwest Motion for Extension of
Comment Deadle and Revised
Procedural Schedule - 2 -
CERTIFICATE OF SERVICE
I do hereby cerify that a tre and correct copy of the foregoing Qwest Motion for
Extension of Comment Deadlie and Revised Procedural Schedule was served on the
26th day of November, 2008 on the following individuals:
Jean D. Jewell
Weldon B. Stutzmn
Idao Public Utilties Commssion
472 West Washington Street
P.O. Box 83720
Boise, il 83702
j j ewellú!uc.statejd. us
i Hand Delivery
U. S. Mail
Overnght Delivery
Facsimile
Email
Douglas K, Denney
Integra Telecom
730 Second Avenue S., Suite 900
Mineapolis, MN 55402
dkdenneyCiintegratelecom.com
Hand Delivery
U. S. Mail
Overnght Delivery
Facsimile
i Email
Michel Singer Nelson
Associate General Counsel
360networks (USA) Inc.
867 Coal Creek Circle, Suite 160
Louisville, CO 80027
mne1sonCi360 .net
Hand Delivery
U. S. Mail
Overnght Delivery
Facsimle
i Email
Gregory L. Rogers
Senior Corporate Counsel
Level 3 Communcations LLC
1025 Eldorado Boulevard
Broomfeld, CO 80021
greg.rogersCi1eve13 .com
Hand Delivery
U. S. Mail
Overnght Delivery
Facsimle
-- Email
,/ltiilAf S ~
Mar S. Hob on
Attorney:6 Qwest Corporation
Qwest Motion for Extension of
Comment Deadlie and Revised
Procedural Schedule - 3 -