20080627Petition to Intervene.pdf

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June 26, 2008
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, 10 83702-5983
Re: Docket No. QWE- T -08-04
Dear Ms. Jewell:
Enclosed for filing with this Commission are an original and seven (7) copies of
360networks (USA) inco's Petition for Intervention. If you have any questions,
please contact me at 303-854-5513 or via email atmnelson(§360.net.
Enclosures
cc: Service List
Mary S. Hobson (ISB. No. 2142)
999 Main, Suite 1103
Boise, 10 83702
Tel: [phone]
mary. hobson(§gwest. com
Adam L Sherr
Corporate Counsel, Qwest
1600 th Avenue, Room 3206
Seattle, WA 98191
Tel: [phone]
Adam.sherr(§gwest.com
Michel Singer-Nelson (CSB. No. 19779)
867 Coal Creek Circle
Suite 160
Louisvile, CO 80027
Tel: [phone]
Fax: [phone]
mnelsonßì360.net
Attorney for 360networks (USA) inc.
Before the Idaho Public Utilties Commission
In re Withdrawal of Qwest
Corporation's Statement of
Generally Available Terms
and Conditions
Case No. QWE- T -08-04
Petition of Qwest Corporation
360networks (USA) inco's Petition for Intervention
360networks (USA) inc. ("360networks") petitions this Commission for leave to intervene in
the above-entitled proceeding pursuant to Rules 72 and 73 of the Commission's Rules of Procedure.
In support of this Petition, 360networks states as follows:
1. In this docket, Qwest asks the Commission to authorize it to withdraw its Statement of
Generally Available Terms and Conditions ("SGAT") relating to the services it provides to its
wholesale local exchange customers in Idaho. Qwest also asks to modify the service quality
standards that apply to the services it provides to its wholesale local exchange customers in
Idaho. 360networks is a competitive local exchange carrier ("CLEC") and wholesale local
exchange customer of Qwest in Idaho. Therefore, 360networks would be affected directly by
the Commission's granting of Qwests requests.
2. The granting of this Petition for Intervention would serve the purposes of intervention as
described by Rule 74 of the Rules of Practice and Procedure.
3. 360networks wil be represented in this proceeding by:
Michel Singer Nelson
Associate General Counsel
360networks (USA) inc.
867 Coal Creek Circle, Suite 160
Louisvile, CO 80027
3038545513 (voice)
3038545100 (fax)
mnelsonßì360. net
4. This Petition is timely filed and will not unduly broaden the issues or otherwise delay these
proceedings.
WHEREFORE, 360networks respectfully requests that the Commission grant this Petition to
Intervene and authorize 360networks to participate in the above-entitled proceeding with full rights as
a formal party.
360networks (USA) inc.'s Petition for Intervention 2
..
/)i~/Dated this 1t day of June, 2008
Certificate of Service
I do hereby certify that a true and correct copy of the foregoing 360networks (USA) inco's
Petition for Intervention was served on the _ day of June, 2008 on the following individuals:
VIA OVERNIGHT MAIL
Jean D. Jewell
Idaho Public Utilties Commission
472 West Washington Street
P.O. Box 83720
Boise, 10 83702
Tel: [phone]
Fax: [phone]
VIA OVERNIGHT MAIL
Mary S. Hobson (ISB. No. 2142)
999 Main, Suite 1103
Boise, 10 83702
Tel: [phone]
mary. hobson(§gwest.com
VIA OVERNIGHT MAIL
Adam L. Sherr
Corporate Counsel, Qwest
1600 th Avenue, Room 3206
Seattle, WA 98191
Tel: [phone]
adam.sherr(§gwest.com
360networks (USA) inc.'s Petition for Intervention 3