The URL can be used to link to this page

Home My WebLink About20080707Intervention and Request for Time.pdftiegra- TELECOM \i ~ \ \3 Integra Telecom 730 Second Avenue South, Suite 900 Minneapolis, MN 55402 ww.integratelecom.com " "(- July 3,2008 Via Email: jeanJewell(lpuc.idaho.gov, and Via Overnight 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: Enclosed for filing are an original and seven copies of Integra's Petition to Interene and Request for Extension of Time. Please feel free to contact me should you have any questions. Sincerely,7M~ Tobe L. Goldberg Legal & Regulatory Administrator Integra Telecom 612.436.6084 (Direct) 612.436.6816 (Dept. Fax) tlgoldberg(lintegratelecom.com Enclosures cc: See Attached Cerificates of Serice Douglas K. Deney 730 Second Avenue S. Suite 900 Minneapolis, MN 55402 612.436.1606 (Direct) 612.436.6816 (Fax) Ii: 18 Company Representative, Integra Telecom Before the Idaho Public Utiities Commssion In re Withdrawal of Qwest Corporation's Statement of Generally Available Terms and Conditions ) ) ) ) Case No. QWE-T-08-04 Petition of Qwest Corporation Integra's Petition to Intervene Integra Telecom of Idaho, Inc.; Electrc Lightwave, LLC dba Integra Telecom; and Eschelon Telecom, Inc. dba Integra (collectively referred to as "Integra") petition 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, Integra 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. Integra is a competitive local exchange carer ("CLEC") and wholesale local exchange customer of Qwest in Idaho. In interconnection agreement negotiations, Integra has depended upon Qwest s SGAT as a key source to help frame its negotiation positions, which may substantially reduce the number of issues for arbitration. Regarding serice quality standards, elimination or modification of the standards would directly affect Integra and service quality payments available to Integra. Therefore, Integra would be affected directly by the Commission's granting of Qwest s 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. Integra wil be represented in this proceeding by counsel as needed. The contact information for the company representative for Integra in this proceeding is: Douglas K. Denney Director, Costs & Policy Integra Telecom 730 Second Avenue South, Suite 900 Minneapolis, MN 55402 612.436.1606 (voice) 612.436.6816 (fax) dkdenney(lintegratelecom.com 4. This Petition is timely fied and wil not unduly broaden the issues or otherwise delay these proceedings. WHEREFORE, Integra respectfully requests that the Commission grant this Petition to Intervene and authorize Integra to paricipate in the above-entitled proceeding with full rights as a formal party. Dated this 3rd day of July, 2008. Respectfully submitted, ~k~ Dou as K. Denney Director, Costs & Policy 730 Second Avenue S., Suite 900 Minneapolis, MN 55402 612.436.1606 (Direct) 612.436.6816 (Fax) Company Representative, Integra 2 Cerificate of Service I do hereby certify that a tre and correct copy of the foregoing Integra Telecom of Idaho, Inc., Electric Lightwave, LLC dba Integra Telecom, and Eschelon Telecom, Inc. dba Integra Telecom ("Integra") Petition to Intervene was served on the following: VIA OVERNIGHT MAIL: Jean D. Jewell Idaho PUC 472 West Washington Street P.O. Box 83720 Boise,ID 83702 Telephone: 208.334.0300 Fax: 208.334.3762 Mar S. Hobson 999 Main, Suite 1103 Boise,ID 83702 Telephone: 208.385.8666 Mary.hobson(lqwest.com Adam L. Sherr Corporate Counsel Qwest Corporation 1600 7th Avenue, Room 3206 Seattle, WA 98191 Adam.sherr(lqwest.com Michel Singer-Nelson Associate General Counsel 360networks 867 Coal Creek Circle, Suite 160 Louisvile, CO 80027 mnelson(f360.net Greg Rogers Level 3 1025 Eldorado Boulevard Broomfield, CO 80021 3 Douglas K. Denney 730 Second Avenue S. Suite 900 Minneapolis, MN 55402 612.436.1606 (Direct) 612.436.6816 (Fax) I ¡ :18 Company Representative, Integra Telecom Before the Idaho Public Utilties Commssion In re Withdrawal of Qwest Corporation's Statement of Generally Available Terms and Conditions ) ) ) ) Case No. QWE-T-08-04 Petition of Qwest Corporation Integra's Request for Extension of Time Integra Telecom of Idaho, Inc.; Electrc Lightwave, LLC dba Integra Telecom; and Eschelon Telecom, Inc. dba Integra (collectively refered to as "Integra") ask this Commission for an extension of time to file Comments in this matter. In the Commission's Notice of Modified Procedure (Order No. 30552), the Commission established a deadline of Monday, July 7,2008, to file wrtten comments or protests in this matter. Integra requests leave for the paries to file wrtten comments or protests by Wednesday, July 9, 2008. Given the 4th of July holiday and deadlines in other matters, Integra would appreciate this short extension of time. Integra has consulted Qwest, 36Onetworks, and Level 3, and there are no objections to Integra's request for an extension of time until July 9,2008. Dated this 3rd day of July, 2008. Respectfully submitted, Douglas . Denney Director, Costs & Policy 730 Second Avenue S., Suite 900 Minneapolis, MN 55402 612.436.1606 (Direct) 612.436.6816 (Fax) Company Representative, Integra 2 Certificate of Service I do hereby certify that a tre and correct copy ofthe foregoing Integra Telecom of Idaho, Inc., Electric Lightwave, LLC dba Integra Telecom, and Eschelon Telecom, Inc. dba Integra Telecom ("Integra") Request for Extension of Time was served on the following: VIA OVERNIGHT MAIL: Jean D. Jewell Idaho PUC 472 West Washington Street P.O. Box 83720 Boise, ID 83702 Telephone: 208.334.0300 Fax: 208.334.3762 Mar S. Hobson 999 Main, Suite 1103 Boise, ID 83702 Telephone: 208.385.8666 Mary.hobson(lqwest.com Adam L. Sherr Corporate Counsel Qwest Corporation 1600 ih Avenue, Room 3206 Seattle, W A 98191 Adam.sherr(lqwest.com Michel Singer-Nelson Associate General Counsel 360networks 867 Coal Creek Circle, Suite 160 Louisvile, CO 80027 mnelsonCf360.net Greg Rogers Level 3 1025 Eldorado Boulevard Broomfield, CO 80021 3