20050304Petition to Intervene.pdf

Ingo Henningsen
Regulatory Manager
Citizens Telecommunications Company of Idaho, Inc.
dba Frontier Communications of Idaho
4 Triad Center, Suite 200
Salt Lake City, Utah 84180
Telephone: [phone]
Facsimile: [phone]
E-mail: ingo.henningsen~czn.com
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BEFO RE THE ID AH 0 PUBLIC UTILITIES CO MMISSI 0 N
IN THE MATTER OF THE APPLICATION
OF WWC HOLDING CO., INC. DBA
CELLULAR-ONECID SEEKING
DESIGNATION AS AN ELIGIBLE
TELECOMMUNICATIONS CARRIER
THAT MA Y RECEIVE FEDERAL
UNIVERSAL SERVICE SUPPORT
DOCKET NO. WST-05-
PETITION TO INTERVENE OF
CITIZENS TELECOMMUNI-
CATIONS COMPANY
OF IDAHO
Pursuant to Rules 71 through 75 of the Commission s Rules of Citizens
Telecommunications Company of Idaho, Inc. dba Frontier Communications of Idaho
(Frontier) respectfully petitions the Commission for an order allowing Frontier to
intervene and become a party in the above captioned docket. Frontier has a direct and
substantial interest in the Proceeding for the following reasons:
1. Frontier is an incumbent local exchange carrier certified by the Commission
to provide telecommunications in Idaho. This Proceeding could have an
impact on Frontier and its customers.
2. By virtue of Frontier s status as an incumbent local exchange carrier in Idaho
it will be able to advise the Commission on the potential impacts of the
Proceeding on telecommunications customers and other telecommunications
companies in Idaho.
3. Although Frontier is uncertain about the extent of its participation at this early
stage of the Proceeding, Frontier s participation will not unduly broaden the
issues or delay the adjudication process.
4. If Frontier is not allowed to intervene in the Proceeding, it will not be able to
protect the interests of its customers or the company.
Copies of all filings, discovery and correspondence should be served on:
Ingo Henningsen
Regulatory Manager
Frontier Communications
4 Triad Center, Suite 200
Salt Lake City, UT 84180
Facsimile: [phone]
E- mail: ingo .henningsen~czn. com
With a copy to:
Charles L. Best
Associate General Counsel
Frontier Communications
4400 NE 7ih Ave
Vancouver, W A 98662
E-mail: charles bestCfYeli.net
Based upon the foregoing Petition, Frontier respectfully requests the Commission
issue an order granting Frontier s Petition to intervene.
Respectfully submitted this day of March, 2005.
By: Ingo Henni
Regulatory Manager
Citizens Telecommunications of Idaho, Inc.
Dba Frontier Communications of Idaho
BEFORE THE IDAHO PUBLIC UTiliTIES COMMISSION
IN THE MATTER OF THE APPLICATION OF WWC
HOLDING CO., INC. DBA CElLULAR-ONEc!)
SEEKING DESIGNATION AS AN ELIGIBLE
TELECOMMUNICATIONS CARRIER THAT MAY
RECEIVE FEDERAL UNIVERSAL SERVICE
SUPPORT
DOCKET NO. WST - T -05-
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of this Petition to Intervene of Citizens
Telecommunications Company of Idaho issued March 3 2005 was this day mailed
electronically to the following:
Conley E. Ward
GIVENS PURSLEY LLP
601 W. Bannock Street
O. Box 2720
Boise, 10 83701-2720~ivenspurslev.com
Dan Trampush
MOSS ADAMS LLP
900 Washington Street, Ste. 700
Vancouver, WA 98660
dan. tram~~mossadams. com
Charles Best
ELECTRIC LIGHTWAVE, LLC
4400 N. 77TH Avenue
Vancouver, WA 98662
char es.best~eli.net
DATED this 3rd Day of March 2005.
Citizens Communications Company
Barbara Graves, Administrative Assistant