20050617Comments.pdf

BEFORE THE IDAHO PUBLIC SERVICE COMMISSION
IN THE MATTER OF THE APPLICATION OF
WWC HOLDING CO., INC. DBA CELLULAR-
ONECID SEEKING DESIGNATION AS AN
ELIGIBLE TELECOMMUNICATIONS
CARRIER THAT MAY RECEIVE FEDERAL
UNIVERSAL SERVICE SUPORT
COMMENTS OF CITIZENS
COMMUNICATIONS OF
IDAHO, dba FRONTIER
COMMUNICATIONS
CASE NO. WST-O5-
In it order No. 29791 dated May 27 2005 the Commission requested parties to provide
additional comments on whether or not it should adopt the FCC's ETC rules.
Citizens Communications of Idaho, dba Frontier Communications (Frontier) recommends
that the Commission adopt the ETC designation rules adopted by the FCC in CC Docket
No. 96-, released March 17 2005, as minimum standards for ETC designation.
Further, Frontier recommends that The Commission consider additional conditions for
ETC designations in rural areas.
The FCC and the Joint Board on Universal service conducted extensive analysis and
investigation before adopting the rules now being considered for adoption by the
Commission, and, as stated in the Commission s own order
, "
the FCC encouraged State
commissions to adopt the new FCC Rules when processing an application for ETC
designation Frontier believes that the FCC and Joint board analysis are relevant to
this rulemaking and recommends that the Commission take administrative notice of the
FCC's record in Docket No. 96-45 (FCC 05-46).
In addition, Frontier recommends that the Commission consider favorably the comments
previously filed by Frontier in this docket on April 28, 2005. Frontier also suppci!s the r- c:.n
comments previously filed by Century tel in this docket. :=:4 ~~ 2:
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1 Idaho PUC order No. 29791 See 3. The FCC Rules.
Finally, Frontier recommends that the Commission adopt the following additional
conditions for establishment of an additional ETC in rural areas of Idaho.
All ETCs should be required to assume the same service standards and
reporting obligations. This would include Carrier of last resort obligations.
the current competitive telecommunications environment it is essential that
carriers that expect the same benefits of ETC designation be required to
accept the same obligations. Also, since Federal rules allow an ETC to
withdraw from an area served by more than one ETC, all ETCs must be
willing and able to fulfill all of the expectations and obligations of existing
carrIers.
An applicant for designation as a second or multiple ETC in rural areas should
be required to demonstrate that the benefits of designation clearly outweigh
the costs. Although competition is the goal of Federal and State policy, which
is strongly supported by Frontier, introducing competition into rural areas
raises the costs per line of existing companies. With low customer density,
the costs of providing access to the PSTN in rural areas, which are already
high, must be spread over a smaller customer base. Additional competitors in
rural areas curb the growth of established providers and thereby limit
opportunities for them to offset their higher costs by exploiting economies of
scale and scope. While fewer opportunities to take advantage of economies of
scale and scope are available, both established providers and new entrants will
draw from the USF to cover duplicate network costs. This places greater
pressure on existing USF support mechanisms which will require increases to
the contribution factor and force public policy makers to look for additional
sources of funding for these support mechanisms. ETC applicants must be
required to show that their entry into these high cost areas justifies the
increased costs.
Respectfully submitted this day of June, 2005
Manager, State Government Affairs
Citizens Communications of Idaho dba Frontier
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF WWC
HOLDING CO., INC. DBA CELLULAR-ONECID
SEEKING DESIGNATION AS AN ELIGIBLE
TELECOMMUNICATIONS CARRIER THAT MAY
RECEIVE FEDERAL UNIVERSAL SERVICE
SUPPORT
DOCKET NO. WST-O5-
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of this filing dated June 16, 2005 by
Citizens Telecommunications Company of Idaho was this day mailed (electronically or
by USPS) to the following:
Conley E. Ward
GIVENS PURSLEY LLP
601 W. Bannock Street
O. Box 2720
Boise, ID 83701-2720~ivenspurslev.com
Dan Trampush
MOSS ADAMS LLP
900 Washington Street, Ste. 700
Vancouver, WA 98660
dan .trampush~mossadams.com
Charles Best
ELECTRIC LIGHTWAVE , LLC
4400 N. 77TH Avenue
Vancouver, WA 98662
charles.best(q2eli.net
Dean J. Miller
McDevitt & Miller, LLP
420 W. Bannock St. (83702)
PO Box 2564
Boise , ID 83701
Mark J. Ayott
Briggs & Morgan , PA
2200 First National Bank Building
332 Minnesota St.
St. Paul , MN 55101
Kira D. Pfisterer
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington (83702)
PO Box 83720
Boise, I D 83720-0074
Calvin K. Simshaw
CenturyTel
805 Broadway, VH1065
Vancouver, W A 98660-3277
DATED this 16th Day of June 2005.
Citizens Communications Company
Barbara Graves, Administrative Assistant