20260908Decision Memo.pdf

DECISION MEMORANDUM
TO: COMMISSIONER LODGE
COMMISSIONER HAMMOND
COMMISSIONER HARDIE
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM: ALLISON MOORE, COMMISSION STAFF
JEFFREY R. LOLL, DEPUTY ATTORNEY GENERAL
DATE: SEPTEMBER 8, 2026
SUBJECT: IN THE MATTER OF QWEST CORPORATION'S APPLICATION FOR
APPROVAL OF AMENDMENT TO THE INTERCONNECTION
AGREEMENT WITH BANDWITH.COM CLEC,LLC; CASE NO. QWE-T-
26-01.
On April 24, 2026, Qwest Corporation dba CenturyLink QC ("Company") filed an
application ("Application") with the Idaho Public Utilities Commission ("Commission") for the
approval of an amendment ("Amendment") to an interconnection agreement ("Interconnection
Agreement") with Bandwith.com CLEC, LLC ("Bandwidth.com").
Under the provisions of the Federal Telecommunications Act of 1996, interconnection
agreements must be submitted to the Commission for approval. 47 U.S.C. § 252(e)(1). The
Commission may reject an agreement adopted by negotiations only if it finds that the
agreement: (1)discriminates against a telecommunications carrier not a party to the agreement;
or(2) implementation of such agreement or a portion thereof is not consistent with the public
interest, convenience, and necessity. 47 U.S.C. § 252(e)(2)(A).
As the Commission noted in Order No. 28427, companies that voluntarily enter into
interconnection agreements "may negotiate terms, prices, and conditions that do not comply
with either the Federal Communications Commission ("FCC") rules or with the provision of
Section 251(b) or(c)." Order No. 28427 at 11. This comports with the FCC's statement that
"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
5 L" 47 C.F.R. § 51.3.
DECISION MEMORANDUM - 1 - SEPTEMBER 8, 2026

STAFF ANALYSIS
Commission Staff ("Staff') reviewed the Company's Application, Interconnection
Agreement, and Amendment. The Company is seeking approval of an amendment to the existing
Interconnection Agreement allowing Bandwidth.com to act as Carrier Partner for Interconnected
Voice over Internet Protocol Provider. Application at 1. The original Interconnection Agreement
was approved by the Commission on April 4, 2008, in Order No. 30527. In the Application, the
Company stated that the Amendment was reached through voluntary negotiations. Id. The
Company represents that approval of the Amendment will increase choices among local
telecommunication service providers. Application at 2. Staff does not believe that the Amendment
discriminates against any telecommunications carrier that is not a party to the Interconnection
Agreement or that implementation of the Amendment is inconsistent with the public interest,
convenience, and necessity.
RECOMMENDATION
Staff recommends that the Commission approve the Company's Application and the
proposed Amendment to the Interconnection Agreement.
COMMISSION DECISION
Does the Commission wish to approve the Company's Application and the proposed
Amendment to the Interconnection Agreement?
A ison Mo e
Commission Staff
I:\Uti1ity\UDMEM0S\QWE-T-26-01 Decision Memo.docx
DECISION MEMORANDUM - 2 - SEPTEMBER 8, 2026