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Home My WebLink About20090206Motion.pdfMary S. Hobson Attorney & Counselor 999 Main, Suite 1103 Boise, il 83702 208-385-8666 RECE 2089 FEB -6 PH~: 29 IDAHO PUB1. .ì(~UTILITIES COMi\1iŠSION 1"..1\.,,,..," Februar 6, 2009 VIA HAND DELIVRY Jean D. Jewell, Secretar Idaho Public Utilities Commission 472 West Washington Boise, ID 83702-5983 RE: Docket No. QWE-T-08-07 Dear Ms. Jewell: Enclosed for filing with this Commission are an original and seven (7) copies of the MOTION of QWEST CORPORATION FOR INFORML PREHEARNG CONFERENCE. If you have any questions, please contact me. Than you for your cooperation in this matter. Very truly yours, ~~:~ Enclosures Mary S. Hobson (ISB. No. 2142) 999 Main, Suite 1103 Boise, ID 83702 Tel: 208-385-8666 mary.hobson(fg west. com RECE!VED 2Ð09 FEB -6 PH~: 29 Adam L. Sherr Corporate Counsel, Qwest 1600 7th Avenue, Room 3206 Seattle, WA 98191 Tel: (206) 398-2507 adam.sher~qwest.com Attorneys for Qwest Corporation BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF QWEST CORPORATION'S PETITION FOR APPROVAL OF NON-IMPAIRED WIRE CENTER LISTS PURSUANT TO THE TRIENNIAL REVIEW REMAD ORDER Case No. QWE- T -08-07 Motion of Qwest Corporation for Informal Prehearing Conference Qwest Corporation (Qwest), by and through its undersigned attorneys, moves this Commission for an order setting the above-referenced matter for an informal prehearing conference for the purpose of establishing a procedural schedule for resolving the remaining issues in this case, if any. Procedural Background Qwest filed its Petition for Commission Approval of Non-Impaired Wire Center Lists Pursuant to the Triennial Review Remand Order ("Petition '') on June 20, 2008, asking that the Commission open an investigation to develop a Commission-approved initial list of non-impaired wire centers as contemplated in the Federal Communcations Motion of Qwest Corporation for Informal Prehearing Conference 1 Commission's Triennial Review Remand Order, ("TRRO ,').1 The purose ofthis docket is to identify the Idaho wire centers that meet the non-impairment critera outlined by the FCC in the TRRO and to establish processes and procedures for handling these issues in future years. On June 27,2008, Qwest supplemented its Petition with the affidavits of Rober Brigham and Rachel Torrence. Attached to Mr. Brigham's affidavit were "Highly Confidential Attachments A, B, C and D" containing Idaho business line data. These data were prepared in compliance with the TRRO to satisfy one of the two crtera to be used in determining whether the Idaho wire centers are non-impaired. Similarly, Highly Confidential Attachments A-D to the affidavit of Ms. Torrence provide data relating to the second non-impairment critera, i.e., the number of fiber-based collocators in the subject Qwest wire centers. The Commission issued its Notice of Petition, Notice of Intervention Deadline and Order No.30592, setting the deadline for interention in this docket for July 30, 2008. 360networks (USA), inc. ("360networks") and a group of companies collectively refered to as "Integra"i were granted interention on August 13,2008. Accompanying its Petition, Qwest offered a proposed Protective Agreement to spell out procedures for the protection of any confidential information produced in this docket. The Protective Agreement was pattered after protective orders entered in other jurisdictions that were acceptable to competitive local exchange carers who were similarly situated to the Intervenors in this case. Representatives of the Commission Staff signed the Protective Agreement on July 21,2008. Integra's representative executed the Agreement on September 23,2009, and 360networks' counsel signed January 6,2009. Each of the parties received the Highly Confidential attachments to the Brigham and Torrence affidavits shortly after signng. Most recently the information was shipped to 360networks' representative onJanuar 8, 2009. i Order on Remand, In the Matter of Review of Unbundled Access to Network Elements, Review of Section 251 Unbundling Obligations of Incumbent Local Exchange Carriers, CC Docket No. 01-338, WC Docket No. 313 (FCC reI. Februar 4 2005) (hereinafter "TRRO'). 2 The group of companes seekig intervention included Integra Telecom ofIdaho Inc.; Electrc Lightwave, LLC, dba Integra Telecom; and Eschelon Telecom Inc., dba Integra. Motion of Qwest Corporation for Informal Prehearing Conference 2 Requested Relief The paries having received the data upon which Qwest bases its claim of non- impairment, Qwest now respectfully requests that the Commission promptly schedule an informal prehearng conference and establish an expedited process and schedule for addressing the remaining issues in this case, if any. Respectfully submitted this 6th day of Februar, 2009. ~lIb~ Mar S. H son (ISB. No. 2142) 999 Main. Suite 1103 Boise, ID 83702 Adam L. Sher Corporate Counsel, Qwest 1600 7th Avenue, Room 3206 Seattle, WA 98191 Attorneys for Qwest Corporation Motion of Qwest Corporation for Informal Prehearing Conference 3 CERTIFICATE OF SERVICE I do hereby certify that a tre and correct copy of the foregoing Motion of Qwest Corporation for Procedural Order was served on the 6th day of Febru, 2009 on the following individuals: Jean D. Jewell Weldon B. Stutzman Idaho Public Utilties Commssion 472 West Washington Street P.O. Box 83720 Boise, il 83702 j i ewel1(ilpuc.state.id. us i Hand Delivery U. S. Mail Overnght Delivery Facsimile Email Douglas K, Denney Integra Telecom 730 Second Avenue S., Suite 900 Minneapolis, MN 55402 dkdenney(iintegratelecom.com Hand Delivery i U.S.Mail Overnght Delivery Facsimle i Email Michel Singer Nelson Associate General Counsel 360networks (USA) Inc. 867 Coal Creek Circle, Suite 160 Louisville, CO 80027 mnelson(g360 .net Hand Delivery i U.S.Mail Overnght Delivery Facsimle i Email !:s~;fl- Attorney for Qwest Corporation Motion of Qwest Corporation for Informal Prehearing Conference 4