20120209Comments.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6864
RECEIVED
2BI7 FEB,-9 AHIO=51
IDAHO PUBLiC. ..
UTILITIES COMMISSIQN
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
TC SYSTEMS, INC. TO REGISTER AS A ) CASE NO. TCS-T-ll-Ol
WHOLESALE TELECOMMUNICATIONS )PROVIDER IN IDAHO )
) COMMENTS OF THE
) COMMISSION STAFF
)
)
COMES NOW the Staff of the Idaho Public Utilties Commission, by and through its
attorney of record, Neil Price, Deputy Attorney General, and in response to the Notice of
Application and Notice of Modified Procedure issued in Order No. 32442 on January 19,2012, in
Case No. TCS-T-II-0l, submits the following comments.
BACKGROUND
On November 22,2011, TC Systems, Inc. ("TCS" or "Company") fied an Application
with the Commission, pursuant to Commission Rule 114, IDAPA 31.01.01.114 and Procedural
Order No. 32277 (Case No. GNR-T-II-0l), to register as a wholesale provider of
telecommunications services within the State of Idaho.
STAFF COMMENTS 1 FEBRUARY 9, 2012
TCS is a competitive telecommunications company that intends to offer wholesale
transport service to one of its affiiates in the state of Idaho. TCS is a Delaware corporation and
lists its principal place of business as Bedminster, NJ.
STAFF ANALYSIS
TCS is a wholly-owned subsidiar of TCG New York, Inc., which is in tum wholly owned
by Teleport Communications Group Inc. ("Teleport"). Teleport is a wholly-owned subsidiar of
AT&T Corp., and AT&T Corp. is a wholly-owned subsidiar of AT&T Inc.
With the Application, TCS provided a copy of the Delaware Certificate of Incorporation
and the Idaho Secretar of State's Certificate of Authority. The Company's registered agent for
service in Idaho is CT Corporation System.
TCS states it has contacted CenturyLink and intends to negotiate an agreement to
interconnect with CenturyLink's network.
The Company asserts that it has reviewed the Commission's rules governing
telecommunications services in Idaho and commits to providing service in accordance with these
rules to the extent they are not preempted by federal law. The Company also acknowledges that,
as a non-paging telecommunications carier in Idaho, it wil be subject to numbering conservation
measures, including mandatory one thousand (1,000) block pooling pursuant to Commission Rule
of Procedure 114.08 and Commission Order No. 30425.
STAFF RECOMMENDATION
Staff has reviewed the Application by TCS for compliance with applicable legal
requirements to be registered as a wholesale provider of telecommunications services in Idaho
and believes the Company understands and agrees to comply with Commission Rule of Procedure
114 and Commission Order No. 32277. Staff also believes that the Company possesses the
requisite financial, managerial, and technical qualifications necessar to operate as a provider of
telecommunications services. Staff, therefore, recommends Commission approval that TCS has
successfully registered as a wholesale communications provider subject to the following
conditions:
STAFF COMMENTS 2 FEBRUARY 9, 2012
1. The Company complies with number pooling and reporting requirements of the North
American Numbering Plan Administrator, as set forth in Commission Order No.
30425; and
2. TCS provides necessary reports and contributes as appropriate to the Idaho Universal
Service Fund, Idaho Telecommunications Relay System, Idaho Telecommunications
Service Assistance Program, and complies with all future reporting requirements
deemed appropriate by the Commission for competitive telecommunications
providers.
Respectfully submitted this JZ j1ay of February 2012.
N2~~Neil~~~
Deputy Attorney General
Technical Staff: Grace Seaman
i:umisc:comments/tcstl i. I npgs comments
STAFF COMMENTS 3 FEBRUARY 9, 2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 9TH DAY OF FEBRUARY 2012,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. TCS-T-II-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
JOHN SISEMORE
TC SYSTEMS INC
208 S AKARD ROOM 2532
DALLAS TX 75202
E-MAIL: john.sisemore(igatt.com
,b~SECRÊTA~
CERTIFICATE OF SERVICE