uswt0020.jhwh.doc

JOHN R. HAMMOND
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5470

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 JOINT APPLICATION
OF QWEST CORPORATION FKA U S WEST COMMUNICATIONS, INC. AND ARCH PAGING, INC. AND MOBILE COMMUNICATIONS CORPORATION OF AMERICA FOR APPROVAL OF A TYPE 1 AND TYPE 2 PAGING INTER- CONNECTION AGREEMENT PURSUANT TO 47 U.S.C. § 252(e).
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CASE NO. USW-T-00-20

COMMENTS OF THE
COMMISSION STAFF

COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its Attorney of record, John R. Hammond, Deputy Attorney General, in response to Order No. 28458,
the Notice of Joint Application and Notice of Modified Procedure in Case No. USW-T-00-20 issued on August 1, 2000, submits the following comments.
On July 13, 2000, Qwest Corporation fka U S WEST Communications, Inc. and Arch Paging, Inc. and Mobile Communications Corporation of America filed a Joint Application requesting approval of a Type 1 and Type 2 paging interconnection agreement. The Joint Application states that the agreement was reached through voluntary negotiations without resort to mediation or arbitration and is submitted for approval pursuant to Section 252(e) of the Telecommunications Act of 1996. The Joint Application states that the Agreement was reached through voluntary negotiations without resort to mediation or arbitration and claimed 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 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 rates and terms are very similar to those contained in other paging agreements submitted by U S WEST and previously approved by this Commission. 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. Accordingly, it is consistent with the public interest.

STAFF RECOMMENDATION
Staff recommends the Commission approve the Agreement as filed.

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

________________________
John R. Hammond
Deputy Attorney General

Technical Staff: Wayne Hart

WH:JH:gdk:i:umisc/comments/uswt0020.jhwh
STAFF COMMENTS 2 AUGUST 22, 2000