19990331Comments.doc

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]

Street Address for Express Mail:
472 W WASHINGTON
BOISE ID 83702-5983

Attorney for the Commission Staff

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION OF )
RURAL NETWORK SERVICES FOR A ) CASE  NO.  RNS-T-99-1
CERTIFICATE OF PUBLIC CONVENIENCE )
AND NECESSITY TO PROVIDE LOCAL ) COMMENTS OF THE
EXCHANGE TELECOMMUNICATIONS ) COMMISSION STAFF
SERVICES. )
_______________________________________________ )

COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its Attorney of record, Weldon B. Stutzman, Deputy Attorney General, and submits the following comments for the Commissions consideration in Case No. RNS-T-99-1.

BACKGROUND

On February 1, 1999, the Commission received an Application from Rural Network Services, Inc. (RNS) for a Certificate of Public Convenience and Necessity (CPCN) to provide local exchange telecommunications services within Idaho. RNSs Application stated that it desired to provide service in the areas currently served by U S WEST South. Service will be provided through facilities owned by RNS. RNS indicated in its Application it would provide a full range of telecommunications services to both residential and business customers. RNS indicated it was currently negotiating an interconnection agreement with U S WEST.

STAFF FINDINGS
Staff has reviewed the information provided by RNS in its Application and believes it satisfies the requirements of the Commissions Rule of Procedure 111, IDAPA 31.01.01.111, and Procedural Order No. 26665 issued November 7, 1996, which sets out the necessary information to be included with an Application for a certificate.
RNS is an Idaho corporation, originally organized to provide Internet and MTS service in the states of Idaho and Arizona. The officers of the Company include Lane and Stuart Williams, who are also the officers of Midvale Telephone Exchange. Staff is satisfied the Company has the technical expertise required to provide the services for which this Certificate is requested.
The Application indicates the Company currently has over two thousand customers and is currently operating at a profit. A copy of RNSs current balance sheet and profit and loss statements were attached to the Application. Although it is currently operating at a profit, the Company is quite young. In response to concerns expressed by Staff regarding its financial capability to provide the broad range of services identified in its Application, the Company provided confidential information to Staff which more clearly identified the Companys intentions. Staff is satisfied the Company has the financial capability to provide the more limited services identified in this confidential material.
RNS specifically indicated in its Application it will comply with all Commission rules. It has provided an illustrative tariff with its Application that demonstrates an understanding of tariffing requirements and processes.

STAFF RECOMMENDATION
Staff recommends that Rural Network Services, Inc. be granted a Certificate of Public Convenience and Necessity to provide local exchange telecommunications services within the Southern Idaho service territory of U S WEST.

DATED at Boise, Idaho, this day of March 1999. ____________________________
Weldon B. Stutzman
Deputy Attorney General
Technical Staff: Wayne Hart

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STAFF COMMENTS 2 MARCH 31, 1999