20000726Comments.doc

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3283

Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983

Attorney for the Commission Staff

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE JOINT APPLICATION
OF U S WEST COMMUNICATIONS, INC. AND INTEGRA TELECOM OF IDAHO, INC. FOR APPROVAL OF AN AMENDMENT TO A PREVIOUSLY APPROVED INTERCONNECTION AGREEMENT PURSUANT TO 47 U.S.C.  252(e).
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CASE NO. USW-T-00-05

COMMENTS OF THE
COMMISSION STAFF

COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its Attorney of Record, Weldon B. Stutzman, Deputy Attorney General, and in response to the Notice of Amendment to Existing Interconnection Agreement and Notice of Modified Procedure issued in Order No.28424 on July 5, 2000, submits the following comments.
On June 26, 2000, U S WEST Communications, Inc. submitted an Amendment to an existing interconnection agreement between itself and Integra Telecom of Idaho, Inc. for review and approval. The Joint Application states that the Amendment was reached through voluntary negotiations without resort to mediation or arbitration and is submitted for the Commission’s approval pursuant to Section 252(e) of the federal Telecommunications Act of 1996.
The companies claimed the Amendment to the Agreement was not discriminatory against any other company, and that it is consistent with the public interest, convenience and necessity. They requested the Commission approve the Amendment to the Agreement without a hearing or intervention by other parties.
Staff reviewed the language of this Agreement and did not find any terms or conditions that Staff would consider discriminatory. The Amendment basically adds services in compliance with the Federal Communication Commission’s November 5 Order in Docket No. 96-98. The services added include pre-existing combinations of unbundled network elements, shared interoffice transport and customized routing. The terms and conditions contained in this Amendment are available to other competitors. Staff believes the availability of these services will enhance the competitive market. Therefore, Staff concurs with the companies claim that the Agreement is consistent with the pro-competitive policies of the Commission, the Idaho Legislature, and the Telecommunications Act of 1996, and therefore is consistent with the public interest.

STAFF RECOMMENDATION
Staff recommends the Commission approve this Amendment to this Interconnection Agreement as filed.

DATED at Boise, Idaho, this day of July 2000.

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Weldon B. Stutzman
Deputy Attorney General
Technical Staff: Wayne Hart

WS:WH:gdk:i:umisc/comments/USWT005a.wswh

STAFF COMMENTS 1 JULY 26, 2000