20130917Reply Comments.pdf

Mary S. Hobson
Attorney & Counselor
999 Main, Suite trog
Boise, ID 89709
908-t85-8666
September 17,2013
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472West Washington
Boise,ID 83702-5983
RE: Docket Nos. QWE-T-13-05
Dear Ms. Jewell:
Enclosed for filing with this Commission are an original and seven (7) copies of
CenturyLink QC's Reply Comments.
Qwest Corporation dba CenturyLink QC, respectfully requests that the Commission enter
an order consistent with the requested relief contained in its Petition filed July 31,2013.
If you have any questions, please contact me. Thank you for your cooperation in this
matter.
Very truly yoursl
/hr",S#
Mary S/{obson
Enclosure
Mary S. Hobson (ISB. No. 2142)
999 Main, Suite 1103
Boise, lD 83702
Tel: [phone]
mar.v.hob son @ Centurvlink. com
Lisa A. Anderl
Associate General Counsel, CenturyLink
1600 7th Avenue
Seattle, WA 98191
Tel: (206) 34s-r574
Li sa.Anderl @Centurylink. com
Attorneys for Centurylink QC
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
Qwest Corporation dba CenturyLink QC (Centurylink QC), by and through its
undersigned attorneys, files these Reply Comments in support of its request to replace the
company's current Performance Assurance Plan (PAP) with a revised PAP that reflects a
settlement agreement between CenturyLink QC and various Competitive Local Exchange
Carriers (CLECs) that participated in a PAP review before the Colorado Public Utilities
Commission.
Background
CenturyLink QC filed its Petition requesting that the Commission approve the
replacement of its existing PAP with the redesigned PAP on July 31, 2013. On August
14,20t3, the Commission issued its Notice of Petition and Notice of Modified
??
IN THE MATTER OF THE PETITION OF
QWEST CORPORATTON DBA
CENTURYLINK QC FOR APPROVAL TO I Case No. CTL-T-13-05
REPLACE THE PERFORMANCE
IASSURANCE PLAI\ BASED UPON I Reply Comments of
SETTLTMENT AGREEMENT IN I CenturyLink QC
COLORADO
CenturyLink QC's Reply Comments - t -
Procedure, Order No. 32877. The Order provided notice that Commission had
determined that the matter would proceed under modified procedure pursuant to Rules
201 and 204 of the Commissions Rules of Procedure, and set a schedule for those
wishing to file written comments in support or opposition to CenturyLink's Petition.
Initial comments were to be filed within 30 days of the Commission's Order, i.e., on or
before Septernber 13, 2013. The Order further provided for a l4-day period in which
reply comments could be submitted.
Staff Comments
Only the Commission Stafffiled comments within the initial comment period.
Staffrecommended that the redesigned PAP, which is based on the settlernent agreement
in Colorado, should be adopted.r Staffalso conditionally supported CenturyLink QC's
request that the Commission deem all existing interconnection agreements that contain
the Idaho PAP modified to incorporate the revisions contained in the redesigned PAP
effective January 1,2014.2 There modifications are requested to occur without need of
further approvals or filings. Staff noted that those CLECs involved in the Colorado
docket had agreed to these provisions and that all Idaho CLECs were notified and glven
the opportunity to comment. Staff therefore supported this provision, "absent any
objections."3 No other interested party filed an objection or otherwise responded to the
opportunity to comment provided by Order No. 32877.
Conclusion
Based upon the foregoing, CenturyLink QC respectfully asks that the
Commission enter an order granting approval of the redesigned PAP and associated
Performance Indicator Definitionsa effective January l,2OL4. CenturyLink QC further
requests that the Commission, without need for further filings or approvals, deern all
existing interconnection agteements that currently contain the PAP modified to
incorporate the redesigned PAP revisions, effective January 1,2014. Finally the
company asks that the Commission close Docket No. QWE-T-08-04.
l StaffComments at4
2 Id. at 3-43ld.at4
a See Attachments 1 and 2 to CenturyLink QC's Petition herein.
CenturyLink QC's Reply Comments - 2 -
Submitted tnis ffiayof Septerrb er, 2013.
Boise, lD 83702
Lisa A. Anderl
Associate Ge,neral Counsel, CenturyLink
1600 7th Avenue
Seattle, WA 98191
Attorneys for CenturyLink
-3-
Respectfully submitted,
CenturyLink QC's Reply Comments
CERTIF'ICATE OF SERYICE
I hereby certify that I have this ffiayof Septemb er Zll3,served the foregoing
Reply Comments of CenturyLink QC in Case No. QWE-T-13-05, by hand delivery to the
following:
Weldon B. Stutznan
Deputy Attorney General
Idaho Public Utilities Commission
472W Washington Street
Boise,Idaho
-4-CenturyLink QC's Reply Comments