uswt0021.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 ELECTRIC LIGHTWAVE, INC. FOR APPROVAL OF WIRELINE INTERCONNECTION AGREEMENT PURSUANT TO 47 U.S.C. § 252(e).
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CASE NO. USW-T-00-21

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, submits the following comments in response to Order No. 28459, the Notice of Joint Application and Notice of Modified Procedure in Case No. USW-T-00-21 issued on August 31, 2000.
On July 13, 2000, Qwest Corporation fka U S WEST Communications, Inc. and Electric Lightwave, Inc. filed a Joint Application requesting approval of a wireline 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.
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 interconnection agreements submitted by US WEST and previously approved by this Commission. As these terms will be available to other competitors, Staff does not find these terms and conditions to be discriminatory. 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 September 2000.

________________________
John R. Hammond
Deputy Attorney General

Technical Staff: Wayne Hart

WH:JH:i:umisc/comments/uswt0021.jhwh
The parties state that this Agreement supercedes and replaces the previous Agreement approved by the Commission in Case No. USW-T-99-26/ELI-T-99-2.

STAFF COMMENTS 2 SEPTEMBER 21, 2000