20171215Decision Memo.pdf

R.E
DECISION MEMORANDUM
TO:COMMISSIONER KJELLANDER
COMMISSIONER RAPER
COMMISSIONER ANDERSON
COMMISSION SECRETARY
LEGAL
WORKING FILE
FROM:CAROLEE HALL
DECEMBER 13,2017DATE:
INTERCONNECTION AGREEMENT BETWEEN FRONTIER
CoMMUNICATIONS NORTHWEST INC. ('r'RONTTER ') AND AT&T
coRP., cAsE NO. VZN-T-oI-lt
BACKGROUND
Under the provision of the federal Telecommunications Act of 1996, interconnection
agreements must be submitted to the Commission for approval, 47 U.S.C. $ 252(eXl). The
Commission may reject an agreement adopted by negotiations only if it finds that the agreernent:
(l) discriminates against a telecommunications carrier not a party to the agreement; or
(2) implementation of the agreement is not consistent with the public interest, convenience and
necessity. 47 U.S.C. $ 252(eX2)(A). As the Commission nored in Order No. 28427, companies
voluntarily entering into interconnection agreements "may negotiate tcrms, prices and conditions
that do not comply with either the FCC rules or with the provision of Section 251 (b) or (c)."
Order No. 28427 at I I (emphasis in original). This comports with the FCC's statement that o'a
state commission shall have authority to approve an interconnection agreement adopted by
negotiation even if the terms of the agreement do not comply with the requirements of [Part 5l]."
47 C.F.R. $ s1.3.
CURRENT APPLICATION
On December 17, 2017, Frontier filed an amended Interconneclion Agreement with
AT&T Corp. This amendment is a compliance filing per FCC OrderNo. I l-l6l and sets out
rates, terms and conditions bctween the companies for reciprocal compensation, VolP traflic and
other miscellaneous provisions. The Exhibit A of the amendrnent sets out Intercarrier
DECISION MEMORANDUM -l-DECEMBER I3,2OI7
Compensation Reform Rates as set forth in an FCC filing that became effective November I8,
201 I and was released in the USFACC Transformation Order. ,See FCC I l-161. In the order,
the FCC determined that the default intercarrier compensation methodology for all non-access
telecommunications traffrc exchanged between carriers and competitive Local Exchange Caniers
would transition to bill and keep over the six years beginning on July 1,2012.
STAFF'ANALYSIS
Staffhas reviewed the amended agreement between Frontier and AT&T Cory., and finds
it compatible with federal and state guidelines. Moreover, Staffbelieves that this filing is
consistent with the pro-competitive policies of this Commission, the Idaho Legislature, and the
federal Telecommunications Act of 1996. Accordingly, Staffrecommends approval.
COMMISSION DECISION
Does the Commission agree?
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i udmcmos/ intcrconncction rgrccmcnts/VZN-T{l-l I Fmntis od AT&T Corp
DECISION MEMORANDUM 1-DECEMBER 13,2OI7