20180208Comments.pdf

SEAN COSTELLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03t2
IDAHO BAR NO. 8743
RECEIVED
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Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-59I 8
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF TIME CLOCK
SOLUTIONS, LLC'S APPLICATION FOR A
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY
CASE NO. TME.T.17.O1
COMMENTS OF THE
COMMISSION STAFF
STAFF OF the Idaho Public Utilities Commission, by and through its Attorney of
record, Sean Costello, Deputy Attorney General, submits the following comments.
BACKGROUND
On November 2,2017, Time Clock Solutions, LLC ("Time Clock") applied to the
Commission for a Certificate of Public Convenience and Necessity ("Application")("CPCN")
authorizing it to provide local and long distance telecommunications service in tdaho pursuant to
IDAPA 31.01.01 .ll4 and Commission Order No. 26665.
STAFF ANALYSIS
Time Clock is a Florida corporation, authorized to do business in Florida and is located at
8725 SW 52nd Avenue, Miami, Florida 33143. Time Clock is registered to do business in Idaho
with the Idaho Secretary of State. Its Foreign Certificate of Registration is attached to the
Application as Exhibit 2.
Time Clock proposes, and requests authority, to 'oprovide resold local exchange services
and to purchase unbundled network elements provided by existing flocal exchange carriers]
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1STAFF COMMENTS FEBRUARY 8,2018
LECs," including Centurylink and Frontier Communications. See Application at 3; Tariff
P.S.C. No. 2 at 33. Time Clock proposes to offer a variety of interexchange (switched and
dedicated services) and local exchange services. Application at 4.
Time Clock provided its Articles of Organization, local exchange tariff, and certain
financial information which it asserts is exempt from public disclosure pursuant to Rule 67. See
Exh. 3; IDAPA 3 1.01.01.067.
Finally, Time Clock agrees to comply with all applicable Commission rules. Application
at 5.
STAFF RECOMMENDATION
Staff has reviewed Time Clock's Application for a CPCN and believes the Company
understands and agrees to comply with the Commission's rules and requirements. Based on this
review, Staff believes Time Clock's Application fulfills the requirements of the Commission
Rules and Procedural Order No. 26665. Staff also believes Time Clock possesses the requisite
financial, managerial, and technical qualifications necessary to operate as a provider of
telecommunications services.
Staff, therefore, recommends approval of the Application for a Certificate of Public
Convenience and Necessity subject to the following conditions:
l. Time Clock must comply with the number pooling and reporting requirements of the
North American Numbering Plan Administrator; I
2. Time Clock must provide necessary reports and contribute, as appropriate, to the
Idaho Universal Service Fund,2Idaho Telecommunications Relay System,3 Idaho
Telecommunications Service Assistance Program,4 and comply with all future
reporting requirements deemed appropriate by the Commission for competitive
telecommunications providers; and
3. Prior to issuance of the Certificate, Time Clock must file a final price list outlining all
its rates, terms and conditions with the Commission.5
I See Commission Order No. 30425.
2 See Commission Order No. 32637.
3 See Commission Order No. 32524.
a See Commission Order No. 32526.
s See Birch Application Second Supplement; IDAPA 31.01.01.133 and OrderNo. 26665 at l0
2STAFF COMMENTS FEBRUARY 8,2018
4. Time Clock will relinquish its Certificate and all telephone numbers if, within one
year of issuance of a CPCN, the Company is not providing local and long distance
telecommunications services in Idaho.
,L
Respectfully submitted this I'-Out of February 2018.
Sean Costello
Deputy Attorney General
Technical Staff: Daniel Klein
i:umisc/comments/tmetl 7. I scdk comments
JSTAFF COMMENTS FEBRUARY 8, 2018
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 8TH DAY OFFEBRUARY2OlS,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. TME-T-I7-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
LANCE JM STEINHART PC
ATTORNEYS AT LAW
1725 WINWARD CONCOURSE
STE I5O
ATLANTA GA 3OOO5
E-MAIL: lsteinhart@telecomcor"rnsel.conr
CERTIFICATE OF SERVICE