USWT992.WSW.doc

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 U S WEST COMMUNICATIONS, INC. AND ) CASE  NO.  USW-T-99-2
CCCID, INC. DBA CONNECT! FORAPPROVAL )
OF AN AGREEMENT FOR INTERCONNECTION )
AGREEMENT PURSUANT TO 47 U.S.C.  252(e). ) 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, in response to Order
No. 27907, the Notice of Joint Application and Notice of Modified Procedure in Case
No. USW-T-99-2 issued February 5, 1999, submits the following comments.
On January 12, 1999, U S WEST Communications, Inc. (U S WEST) and CCCID, Inc. dba Connect! (Connect!), a competitive local exchange service company, submitted a Joint Application for approval of an interconnection agreement in accordance with Section 252(e) of the Federal Telecommunications Act. The companies indicated the Agreement had been reached through voluntary negotiations, and claimed the Agreement is consistent with the public interest, convenience and necessity. They requested the Commission approve the Agreement without a hearing or intervention by other parties.

Section 252 indicates that such agreements are to be submitted to state commissions for approval. Agreements adopted through negotiation may only be rejected if the state commission 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.

STAFF ANALYSIS
Staff reviewed the terms and conditions of the Agreement, which are essentially the same as those contained in the U S WEST - Sprint agreement previously approved by this Commission, and does not find any of the terms or conditions to be discriminatory. As the Agreement is the result of voluntary negotiations and is not discriminatory, Staff does not believe the Agreement is contrary to the public interest, convenience or necessity.

STAFF RECOMMENDATION
Staff recommends the Commission approve this interconnection agreement as filed.

DATED at Boise, Idaho, this day of February 1999.

_______________________________
Weldon B. Stutzman
Deputy Attorney General

Technical Staff: Wayne Hart

ws:WH:gdk/umsic/comments\uswt994.wsw

STAFF COMMENTS 1 FEBRUARY 25, 1999