20080730Petition to Intervene.pdf

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networks
July 28, 2008
Jean D. Jewell, Secretary
Idaho Public Utilties Commission
472 West Washington
Boise,ID 83702-5983
Re: Docket No. QWE- T -08-07
Dear Ms. Jewell:
360networks
867 Coal Creek Circle
Suite 160
Louisville, Colorado
80027
(t) 303.854.5000
(f) 303.854.5100
www.360.net
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 atmnelsoncæ360.net.
Enclosures
cc: Service List
Mary S. Hobson (ISB. No. 2142)
999 Main, Suite 1103
Boise, ID 83702
Tel: [phone]
mary. hobsoncægwest.com
Adam L Sherr
Corporate Counsel, Qwest
1600 ih Avenue, Room 3206
Seattle, WA 98191
Tel: [phone]
Adam.sherrcægwest.com
Michel Singer Nelson (CSB. No. 19779)
867 Coal Creek Circle
Suite 160
Louisvile, CO 80027
Tel: [phone]
Fax: [phone]
mnelsoncæ360.net
Attorney for 360networks (USA) inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN RE QWEST CORPORATION'S )
PETITION FOR COMMISSION )
APPROVAL OF NON-IMPAIRED )
WIRE CENTER LISTS PURSUANT TO )
THE TRIENNIAL REVIEW REMAND )
CASE NO. QWE- T -08-07
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 petitions the Commission to open an investigation to develop a
Commission-approved initial list of non-impaired wire centers as they relate to the unbundling
of network elements, pursuant to the Federal Communications Commission's ("FCC's")
Triennial Review Remand Order ("TRRO"), after party review and discussion of relevant data,
and to implement a process of updating and approving the lists. Qwest submits that the
primary purpose of the docket should be to review the number of business lines and fiber-
based collocators in certain Idaho wire centers that meet the non-impairment criteria outlined
by the FCC in its TRRO. 360networks is a competitive local exchange carrier ("CLEC") and
wholesale local exchange customer of Qwest in Idaho. Therefore, 360networks may be
directly impacted in this proceeding.
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
303-854-5513 (voice)
303-854-5100 (fax)
mnelson~360.net
4. This Petition is timely filed and wil not unduly broaden the issues or otherwise delay these
proceedings.
360networks (USA) inc.'s Petition for Intervention 2
.. ,
WHEREFORE, 360networks respectfully requests that the Commission grant this Petition to
Intervene and authorize 360networks to participate in the above-entitled proceedings with full rights
as a formal p~.
Dated this~ay of July, 2008
Certificate of Service
i do hereby certify that a true and corre~t fgy of the foregoing 360networks (USA) inco's
Petition for Intervention was served on the~ of July, 2008 on the following individuals:
VIA OVERNIGHT MAIL
Jean D. Jewell
Idaho Public Utilties Commission
472 West Washington Street
P.O. Box 83720
Boise,lD 83702
Tel: [phone]
Fax: [phone]
VIA OVERNIGHT MAIL
Mary S. Hobson (ISB. No. 2142)
999 Main, Suite 1103
Boise,ID 83702
Tel: [phone]
mary. hobsoncægwest.com
VIA OVERNIGHT MAIL
Adam L. Sherr
Corporate Counsel, Qwest
1600 7th Avenue, Room 3206
Seattle, WA 98191
Tel: [phone]
adam. sherrcægwest.com
cL-?-
360networks (USA) inc.'s Petition for Intervention 3