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Home My WebLink About20030214Citizens Comments.pdf7~ 7 Boise Idaho Falls Pocatello ffitt Thomas MOFFATT THOMAS BARRETT ROCK & FIELDS, CHTD. Eugene C. Thomas John W. Barrerr R. B. Rock Richard C. Fields Robert E. Bakes John S. Simko John C. WardD. James Manning Gary T. Dance Larry C. Hunter Morgan W. Richards Mark A. Ellison Randall A. Peterman Mark S. Prusynski Stephen R. Thomas Glenna M. Christensen Gerald T. Husch Scott 1. Campbell Michael G. McPeek Kirk R. Helvie Robert B. Burns James C. Dale Michael E. Thomas Patricia M. Olsson James C. deGleeBradley J Williams Lee Radford Michael O. Roe David S. Jensen James 1. Martin C. Clayton Gill David P. Gardner Casey C. Robertson Julian E. GabiolaAngela Schaer Kaufmann Benjamin H. Schwartz Bradley J. Dixon Keasa 1. Hollister Mark C. Peterson Andrew J. Waldera Shawn C. Nunley Willis C. Moffatt 1907-1980 US Bank Plaza Building 101 S Capitol Blvd 10th PO Box 829 Boise Idaho 83701 0829 February 14, 2003 via Hand Delivery 208 345 2000 800 422 2889 208 385 5384 Fax www.moffattcom 1"'.,,;) (...'-'I 4"1 ;-;';::i ;:::: 1'1 fTJoQ'1 -0:;: f"TI Ms. Jean Jewell Idaho Public Utilities Commission 472 West Washington Post Office Box 83720 Boise, Idaho 83720-0074 Re: Case No. QWE-O3- MTBR&F File No. 15-881 Dear Ms. Jewell: ",.(j;' ("-:;:::.. ::!t ;;:- :2: iu,::' (j) ,(:)+'" CT\ 1"'"-' \;;1 J t,;;:S Enclosed for filing in the above-referenced case are the original and seven copies of Citizens dba Frontier s Response Comments. Thank you for your assistance. Very truly yours~J~ Administrative Assistant to Morgan W. Richards, Jr. /jrt Enclosures BOI MT2:501390. Morgan W. Richards, ISB No. 1913 MOFFATT, THOMAS, BARRETT, ROCK & FIELDS, CHARTERED 101 S. Capitol Boulevard, 10th Floor Post Office Box 829 Boise, Idaho 83701 Telephone: (208) 345-2000 Facsimile: (208) 385-5384 mwr(fYmoffattcom 15-881 E\LG " ' ""- '.- ITJ ,-, 2003 FE8 14 Af'ill: 46 " ,- ,' '" ':""" i L IL~ CUrd';) , i Attorneys for Citizens Telecommunications Company ofldaho dba Frontier Communications BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF QWEST'S PROPOSAL TO USE REVENUE SHARING FUNDS TO MAKE NETWORK IMPROVEMENTS IN ITS SOUTHERN IDAHO SERVICE AREA. Case No. QWE-03- RESPONSE COMMENTS COMES NOW Citizens Telecommunications Company ofldaho doing business as Frontier Communications ("Frontier ) and files these comments in response to the proposed filing by Qwest Corporation ("Qwest") to use revenue sharing funds to make network improvements in its southern Idaho service area. A Notice of Modified Procedure was issued by the Idaho Public Utilities Commission ("Commission ) and these comments are filed pursuant to that notice. Qwest proposes to use $4 million in revenue sharing funds, plus $4 million of its own funds, to make improvements in the following system components: 1) replacement of lead sheath cabling in the local exchange network and selected wire centers; 2) replacement or rehabilitation of air core cabling in the local exchange network in selected wire centers; RESPONSE COMMENTS - 1 BOI MT2:501346. 3) replacement of control points/access points (i., terminal boxes or enclosures) in selected wire centers; and 4) replacement of Anaconda analog carrier systems across Idaho. Frontier believes the proposal made by Qwest is an inappropriate use of revenue sharing funds. The proposal is comprised of projects most, ifnot all, other companies in Idaho have completed without the benefit of special funding. As an alternative, Frontier proposes the fund be used to build a north - south fiber route. In Case No. GNR-00-, the Commission approved the construction of a fiber optic route between Riggins and Grangeville using funds made available from the sale of exchanges approved in Case No. USW-99-25/CTC-99-2. Subsequent to the Commission approval, the sale of exchange transaction between Frontier and Qwest was cancelled. One the consequences of the cancelled transaction between the two companies was the elimination of the proposed funding source for the fiber route. Although the funding source was eliminated, the need for the fiber route was not. The Commission s conclusions discussed in Case No. GNR-00-40 regarding the need for a communications infrastructure connecting southern and northern Idaho are just as valid today as they were in April of 2001. The record reflects almost unanimous support for the project, including dozens of written comments from the public extolling the benefits ofthe proposed facility. Long-term benefits of a direct fiber connection between Southern and Northern Idaho will be shared by customers on both sides of the present gap. As Staff noted in its report to the Commission , " (CJonstruction of this route will close the longest and costliest gap in a future continuous fiber route connecting the southern and northern part of our state." Immediate benefits from the construction of this project include a continuous fiber route from Lewiston to RESPONSE COMMENTS - 2 BOI MT2:501346. Horseshoe Bend providing increased capacity and reliability; improved emergency services for Riggins and Whitebird; and, provisioning of the long standing request for extended area service from Riggins and Whitebird to Grangeville. The Commission has already decided there is a need for the fiber route and that the local exchange companies serving the exchanges on both sides of the gap are in the best position to construct and operate the new facility. If funding is approved as outlined herein Frontier is prepared to perform the construction from Riggins all the way to the Grangeville central office, if necessary. In addition, Frontier is willing to accept all applicable provisions of Order No. 28690, including the preparation of detailed cost estimates, reporting of actual costs regulatory accounting, and access by competitor telecommunication providers on a non-discriminatory, competitively neutral basis. The Commission had the foresight to recognize the necessity of the fiber route two years ago. The necessity still exists today. Rather than appropriating revenue sharing funds for basic maintenance and network improvements that should rightfully be funded 100% by Qwest in the normal course of business, these revenue sharing funds could be better utilized for the construction of a north - south fiber route. The existing facility gap between the North and South is not likely to be bridged without special funding. Respectfully submitted this day of February, 2003. MOFFATT, THOMAS, BARRETT, ROCK & FIELDS , CHARTERED By I-\ Morgan W. Ri ards - Of the FIrm Attorneys for Citizens Telecommunications Company ofldaho dba Frontier Communications RESPONSE COMMENTS - 3 BOI MT2:501346. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the lll~day of February, 2003, I caused a true and correct copy of the foregoing RESPONSE COMMENTS to be served by the method indicated below, and addressed to the following: Commission Secretary IDAHO PUBLIC UTILITIES COMMISSION 472 West Washington Street Post Office Box 83720 Boise, Idaho 83720-0074 John Souba Regulatory Affairs Manager QWEST CORPORATION 999 Main Street, 11 th Floor Boise, Idaho 83702 Lance A. Tade, Manager State Government Affairs CITIZENS TELECOMMUNICATIONS OF IDAHO 4 Triad Center, Suite 200 Salt Lake City, Utah 84180 Mary S. Hobson STOEL RIvES LLP 101 S. Capitol Blvd., Suite 1900 Boise, Idaho 83702-5958 RESPONSE COMMENTS - 4 ( ) U~. Mail, Postage Prepaid ( --rHand Delivered ( ) Overnight Mail ( ) Facsimile ~S. Mail, Postage Prepaid ( ) Hand Delivered ( ) Overnight Mail ( ) Facsimile ~S. Mail, Postage Prepaid ( ) Hand Delivered ( ) Overnight Mail ( ) Facsimile )~. Mail, Postage Prepaid (0'Hand Delivered ( ) Overnight Mail ( ) Facsimile Morgan W. Rich ds BOI MT2:501346.