20190403Comments.pdf

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EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10446
IN THE MATTER OF THE APPLICATION OF
WANRACK LLC FOR A CPCN TO PROVIDE
LOCAL AND LONG DISTANCE
TELECOMMUNICATIONS SERVICE IN
IDAHO
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. WAN.T.19.O1
COMMENTS OF THE
COMMISSION STAFF
STAFF OF the Idaho Public Utilities Commission, by and through its Attomey of
record, Edward Jewell, Deputy Attorney General, submits the following comments.
BACKGROUND
On February 7,2019, WANRack,LLC ("WANRack" or "Company") filed an
Application requesting a Certificate of Public Convenience and Necessity ("CPCN") to provide
local and long distance telecommunications service throughout Idaho.
The Company is seeking a CPCN to provide facilities-based and resold competitive local
exchange telecommunications and interexchange telecommunications services throughout the
entire state of Idaho.
ISTAFF COMMENTS APRIL 3,2079
STAFF ANALYSIS
The Company states it will offer a full range of communications services, including data,
local exchange voice services, and interexchange/long distance to institutional customers such as
public schools, business customers, and other telecommunications carriers for transit or resale.
The Company is a Delaware Corporation and is principally located in Lenexa, Kansas.
Application at 1. The Company states that it is authorized by the Idaho Secretary of State to
conduct business in Idaho.
The Company states that it has reviewed the Commission's rules applicable to local
exchange service providers in Idaho and agrees to provide service in accordance with all laws,
rules and Orders to the extent they are not preempted by the federal Telecommunications Act.
Rule I 14.07,IDAPA 31.01.01 .114.07 . Further, the Company states that it does not require
advance deposits by its customers.
WANRack asserts that it possesses the experience and financial ability to provide local
and long-distance services within Idaho.
STAFF RECOMMENDATION
Staff has reviewed WANRack's Application and believes the Company understands the
Commission's rules and requirements related to the provision of telecommunication services in
Idaho. Staff believes that WANRack possesses the requisite financial, managerial, and technical
qualifications necessary to provide telecommunications services. Therefore, Staff recommends
the Commission issue a CPCN to WANRack, subject to the following conditions:
1. The Company must comply with all number pooling and reporting requirements of
the North American Number Plan Administrator. See Commission Order No. 30425;
2. The Company must comply with all reporting and contribution requirements as
prescribed by the Idaho Universal Service Fund, Idaho Telecommunications Relay System,
Idaho Telecommunications Service Assi stance Pro gram;
3. The Company must comply with all future reporting requirements deemed
appropriate by the Commission for competitive telecommunications providers; and
4. The Company shall relinquish its CPCN and all telephone numbers if, within one year
of issuance of a CPCN, the Company is not providing local exchange telecommunications
services in Idaho.
2STAFF COMMENTS APRIL 3,2019
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Respectfully submitted this day of April2019.
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Deputy,q\*od.y General
Technical Staff: Carolee Hall
i :umisc/comments/want I 9. I ejch comments
JSTAFF COMMENTS APRIL 3,2019
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3RD DAY OF APzuL 2019,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. WAN-T-Ig-OI, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
JASON A DANOWSKY
FOSTER DANOWSKY LLP
904 WEST AVE STE 107
AUSTIN TX 78701
E-MAIL : j danowsky(0fbsterdanorvsk.v*.com
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CERTIFICATE OF SERVICE