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Home My WebLink About20080730Petition to Intervene.pdfriegra TELECOM Integra Telecom 730 Second Avenue South, Suite 900 Minneapolis, MN 55402 ww.integratelecom.com July 29,2008 Via Email: jeanjewell(gpuc.idaho.gov and Via Overnight Delivery Jean D. Jewell, Secretar Idaho Public Utilties Commission 472 West Washington Boise, ID 83702-5983 RE: Docket No. QWE-T-08-07 Dear Ms. Jewell: Enclosed for filing are an original and seven copies of Integra's Petition to Intervene. Please feel free to contact me should you have any questions. Sincerely, me Tobe L. Goldberg Legal & Regulatory Administrator Integra Telecom 612.436.6084 (Direct) 612.436.6816 (Dept. Fax) tlgoldbergØ)integratelecom.com Enclosures cc: See Attached Cerificate of Servce Douglas K. Denney 730 Second Avenue S. Suite 900 Minneapolis, MN 55402 612.436.1606 (Direct) 612.436.6816 (Fax) Company Representative, Integra Telecom Before the Idaho Public Utilties Commission In the Matter of the Petition of ) Qwest Corporation for Approval ) Of Non-Impaired Wire Center ) Lists Pursuant to the Triennial ) Review Remand Order ) Case No. QWE- T -08-07 Integra's Petition to Intervene 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 ths 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 serices 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 SGA T as a key source to help frame its negotiation positions, which may substantially reduce the number of issues for arbitration. Regarding service 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 interention 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) dkdenneyØ)integratelecom.com 4. This Petition is timely filed 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 pary. Dated ths Æ day of July, 2008. Respectfuly submitted, Douglas K. enney 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 true 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 on July 29, 2008: 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 VIA U.S. MAIL: Mar S. Hobson 999 Main, Suite 1103 Boise,ID 83702 Telephone: 208.385.8666 Mar.hobsonØ)qwest.com Adam L. Sherr Corporate Counsel Qwest Corporation 1600 7th Avenue, Room 3206 Seattle, W A 98191 Adam.sherrØ)qwest.com Michel Singer-Nelson Associate General Counsel 36Onetworks 867 Coal Creek Circle, Suite 160 Louisvile, CO 80027 mnelsonØ)360.net Greg Rogers Level 3 1025 Eldorado Boulevard Broomfield, CO 80021 3