980422.docx

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO  83720-0074
[phone]
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 STERLING INTERNATIONAL FUNDING, INC.)CASE  NO.  USW-T-98-2
DBA RECONEX AND U S WEST COMMUNICATIONS,)
INC. FOR APPROVAL OF AN AGREEMENT FOR)
INTERCONNECTION PURSUANT TO  47 U.S.C. )COMMENTS OF THE
§ 252(e).)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, in response to Order No. 27446, the Notice of Joint Petition and Notice of Modified Procedure in Case No. USW-T-98-2 issued April 1, 1998, submits the following comments.
BACKGROUND
On March 19, 1998, U S WEST Communications, Inc. (U S WEST) and Sterling International Funding, Inc., dba Reconex (Reconex), jointly submitted an Interconnection Agreement for approval by the Commission.  The Application indicated that this Agreement was reached through voluntary negotiations and is submitted to the Commission for approval pursuant to Section 252(e) of the Telecommunications Act of 1996 (Act).
Section 252(e) of the Act sets the guidelines for approval of interconnection agreements.  It states:
(e)APPROVAL BY STATE COMMISSION.—
(1)APPROVAL REQUIRED.—Any interconnection agreement adopted by negotiation or arbitration shall be submitted for approval to the State commission.  A State Commission to which an agreement is submitted shall approve or reject the agreement, with written findings as to any deficiencies.
(2)GROUNDS FOR REJECTION.—The State commission may only reject—
(A)an agreement (or any portion thereof) adopted by negotiation under subsection (a) if it finds that—
(i)the agreement (or portion thereof) discriminates against a telecommunications carrier not a party to the agreement; or
(ii)the implementation of such agreement or portion is not consistent with the public interest, convenience, and necessity;
47 U.S.C. § 252 (e)
STAFF INVESTIGATION
The Agreement submitted by U S WEST and Reconex is an update to the original standard agreement offered by U S WEST to companies seeking to provide competitive local exchange service.  The terms are essentially the same as are included in the U S WEST-Citizens Telecommunications Agreement approved by the Commission in Order No. 26778, with the exception of updated non-recurring fees when changing a customer from one provider to another, depending upon whether Reconex uses U S WEST’s automated Operational Support System (OSS) or places the order manually.  Staff believes the differences between the initial Agreement with Citizens and this Agreement with Reconex are consistent with progress U S WEST has made in its OSS system since the Citizens’ Agreement was executed.
STAFF RECOMMENDATION
Staff recommends the Commission approve the interconnection agreement as filed.
DATED  at Boise, Idaho, this            day of April 1998.
_______________________________
Weldon B. Stutzman
Deputy Attorney General
Technical Staff:  Wayne Hart
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