20150715Comments.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 7956
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702.5918
Attorney for the Commission Staff
IN THE MATTER OF THE APPLICATION OF
RCLEC, INC. FOR REGISTRATION AS A
WHOLESALE TELECOMMUNICATIONS
PROVIDER IN IDAHO.
,r i- [" .
.rnlf rrr( , !-'1'l\ ttrr 1,.rrr.__ i Lr Er{l!.n(l:;l {;'aJ
- tl: i 'l:, .l'.;, i :lri:L "- t.-.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. RCL.T.15-01
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
Attorney of record, Brandon Karpen, Deputy Attorney General, and in response to the Notice of
Application and Notice Modified Procedure issued in Order No. 33329 on June 24,2015,in
Case No. RCL-T-I5-01, submits the following comments.
BACKGROUND
On February 12,2015, RCLEC, Inc. ("RCLEC" or "Company") filed an Application with
the Commission for a Certificate of Public Convenience and Necessity. On April 27 , 2015,
RCLEC filed a revised Application per Procedural Order No. 32277 and IDAPA 3 1 .0 1 .0 1 .114, for
registration as a wholesale provider of telecommunications services in the State of Idaho. Revised
Application at l.
STAFF REVIEW
RCLEC is a wholesale provider of telecommunications services incorporated in the
State of Delaware, listing its principal place of business as Belmont, California. Id. In September
STAFF COMMENTS JULY 15,2OI5
2014,Idaho's Secretary of State certified that RCLEC is authorizedto transact business in Idaho.
Id. at l. RCLEC does not maintain a place of business in Idaho, but lists Incorp Services, Inc.,
1524 Vista Avenue, Suite 12, Boise, Idaho 83705, as its registered agent in Idaho. Id. at2.
RCLEC states that it will provide facilities-based/unbundled network element local
exchange and interexchange services and resold local exchange and interexchange services on a
wholesale basis to other retail providers in ldaho. Id. at 4. RCLEC confirms that it will comply
with all Idaho laws and Commission Rules. 1d.
STAFF RE,COMMENDATIONS
Staff has reviewed RCLEC's Application for registration as a wholesale provider of
telecommunications services in Idaho for compliance with applicable legal requirements and
believes the Company is in compliance with Commission Rule of Procedure 114 and Commission
Order No.32277. Staff further believes that RCLEC possesses the requisite financial, managerial,
and technical qualifications necessary to operate as a provider of telecommunications services.
Therefore, Staff recommends that the Commission approve RCLEC as a registered wholesale
telecommunications service provider subject to the following conditions:
1. RCLEC shall comply with number pooling and requirements of the North American
Numbering Plan Administrator, as set forth in Commission Order No. 30425;
2. RCLEC shall provide necessary reports, and contribute as appropriate to the Idaho
Universal Service Fund, Idaho Telecommunications Relay System, and Idaho
Telecommunications Service Assistance Program; and
3. RCLEC shall comply with all future reporting requirements deemed appropriate by the
Commission for competitive telecommunications providers.
Respecttully submitted this gly day of July 2015.
Technical Staff: Grace Seaman
i:umisc/comments/rcltl5. lbkgs comments
STAFF COMMENTS JULY 15,2OI5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 15TH DAY oF ruLY 2015,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. RCL.T.15-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
ANITA TAFF-RICE
ICOMMLAW
1547 PALOS VERDES,#298
WALNUT CREEK, CA94597
E-mail: [e-mail]
CERTIFICATE OF SERVICE