20070427Letter.pdf

STATE OF IDAHO
OFFICE OF THE ATTORNEY GENERAL
LAWRENCE G. WASDEN
April 27, 2007
Molly O'Leary
Richardson & O'Leary, PLLC
PO Box 7218
Boise, ID 83707
Michael C. Creamer
Givens Pursley, LLP
PO Box 2720
Boise, ID 83701
Re:Redacted Document in Case No. EDG-O7-
Dear Molly and Mike
Pursuant to our conversations today, I have enclosed for your information two documents. The
first document is the final "redacted" page 4 of IT A's Motion for a Staff Investigation. Page 4
was redacted to remove highly confidential information at Edge Wireless s request. The second
document is the un-redacted page 4 showing the confidential text in bold.
Please contact me if you have any further questions.
Donald L. Howell, II
Deputy Attorney General
Enclosure
cc:Jean Jewell
Grace Seamen
blslL:EDG- T -07-0 l dh _oleary_creamer
Contracts & Administrative Law Division, Idaho Public Utilities Commission
O. Box 83720, Boise, Idaho 83720-0074, Telephone: [phone], FAX: [phone], E-mail: IpuctWpuc.state.id.Located at 472 West Washington St., Boise, Idaho 83702
Affidavit points out, thorough coverage of Custer s service area would require numerous
cell sites and other facilities.
The ITA members ' reports appear to be confirmed by Edge s Confidential Exhibit
(attached for convenience as Exhibit B), which shows:
' Based on this
. .
info~ation and a review of Edge ' s co"v~;ag~ maps , the ITA believes that Edge.
.. :'" . ':..' -.
u .
. ,
Furthermore, Edge s two year build-out plan (Exhibit D-, attached for convenience as
Exhibit B), does not
In addition to those wire centers where Edge does not provide any service, a
review of Edge s coverage map, attached as Exhibit C, suggests to ITA counsel that there
are
Presumably, these are the least dense and highest cost segments of those wire centers. In
these wire centers, Edge s Application is , in effect, a request fpr ETC designation in a
partial wire center. This Commission has previously rej ected such applications, on the
IDAHO TELEPHONE ASSOCETION'S MOTION FOR A STAFF INVESTIGATION - Page 4 of7
S:\oiio",,\ 1233119811T A Motion for Suffinvcstigalion.DOC