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Home My WebLink AboutCharterCommunications.pdfCharter C 0 N M U N i C A T 0 N S Senior Director-State Government Affairs-West Region 10450 Pacific Center Court-San Diego CA 92121 Office:626430.3426 Cell:626825.1014 Del.HeinwaCharter corn August 26.2016 Joe Cusick Idaho Public Utilities Commission 472 \V.Washington Street Boise,ID 83702 b7 74ma i lho \J uim ii .coiii Subject:Regulation of ‘olP/IP Services Dear Mr.Cusiek: Thank you for your efforts,insights and leadership regarding the Idaho Public Utilities Commission’s (“Commission”)investigation into the question whether Idaho statutes need to be revised to clarify,limit or preempt the Commission’s regulation of VoW and IP-Enabled services (“VolP”). While ICTA and Charter Communications supports legislation that would memorialize the deregulatory status of retail VolP services in the state,in 2015 the ICTA initially opposed AT&T’s draft legislation because it went beyond retail services and would have eliminated the Commission’sjurisdiction over wholesale interconnection in Idaho.After revisions were made to that draft,the ICFA no longer - opposed,but did not stipport the legislation.The ICTA and Charter remain of the opinion that legislation to further deregulate VoW services without limiting such regulation to retail services in Idaho is not only unnecessary but could harm competition. Idaho was on the forefront of deregulating telecommunications services with the Telecommunications Act oft 988 (the “Act”).Idaho (‘ode §62.601 c/seq.The Act exempts CLECs —including (‘LECs that deploy Vow technology —from the more onerous or pervasive rate regulation provisions of Title 61,and instead provides a very light,yet important,scheme of regulation for CLEC VolP services.Several of those Title 62 provisions address imponant intra-industry issties that remain relevant.In particular, statutory provisions that expressly authorize the Commission to implement and enforce federal interconnection obligations and other wholesale rights (62-615),or resolve inter—carrier disputes,( 62-6 13)could become clouded by ne’and potentially conflicting de-regtilatorv code provisions. While AT&T has modified its proposed legislation to carve-out important areas where the Commission should retain Title 62 jurisdiction,such carve-outs arc not specific to retail services and therefore risk unintended deregulatory consequences.Rather,this risk can be entirely avoided if the legislation were expressly limited to deregulate “retail”VoIP services while expressly protecting the Commission’s authority over interconnection and wholesale tariffs underlying such senices tinder state and federally’ delegated authority pursuant to the Federal Telecommunications Act. Such sweeping deregulation of wholesale senices has serious implications on competitive carriers ability to offer services iii the state because such carriers rely on interconnection and other carrier-to- carrier services provided by ILECs.This is especially troubling in light of ILECs transition to I? networks.Attachment A lists several examples of wholesale services that could be implicated if inadvertently deregulated by the present legislative proposal. Thank you fur the opportunity to provide these comments.Please do not hesitate to contact me should you have any questions. Sincerely VthJ.*teCnt’ Del J.lleintz Senior Director-State Government Affairs-West Region Cell:626-825-1014 cc:Mark E.Brown