20021216_349.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KJELLANDER
COMMISSIONER SMITH
COMMISSIONER HANSEN
COMMISSION STAFF
LEGAL STAFF
FROM:JEAN JEWELL
DATE:DECEMBER 13, 2002
RE:REDUCING THE NUMBER OF COPIES AND THE TYPE OF COpy THAT
MUST ACCOMPANY APPLICATIONS FOR INTERCONNECTION
AGREEMENTS AND AMENDMENTS TO INTERCONNECTION
AGREEMENTS. CASE NO. GNR-02-22.
Since enactment of the federal Telecommunications Act of 1996, the Commission has approved more
than 100 interconnection agreements pursuant to Section 252 of the Act. Often the applications for
interconnection agreements and the subsequent amendments to the agreements are voluminous. In
particular, applications to interconnection agreements often include a complete copy of the original
agreement. It is not unusual for agreements to be amended several times.
The Commission s procedural Rule 61 requires parties to file an original and seven (7) copies of all utility
pleadings. We can increase efficiency, save paper and file storage space, and cut costs for the filers by
reducing the number of copies required for filing interconnection agreements and amendments to
interconnection agreements. Moreover, Staff believes that an electronic copy is sufficient.
Telecom staff and legal staff concur that one original and one electronic copy of applications for
interconnection agreements and amendments to the interconnection agreements will meet their needs.
Staff proposes that an electronic copy be stored on the H drive under the assigned case number for easy
access by all staff members. We have consulted the attorney who represents Qwest in interconnection
agreements and she agrees that the reduction in paperwork would be worthwhile. She also agreed that
submitting a complete electronic copy will not be a problem. If any telecommunications companies are
unable to file an electronic copy, we can scan their original paper copy.
COMMISSION DECISION
Does the Commission agree that it is reasonable to reduce the number of copies required for filing
interconnection agreements and amendments to interconnection agreements? Does the Commission find
that an electronic document is sufficient for the copy? Pursuant to Rules 11 and 13 , does the Commission
authorize the Commission Secretary to use her discretion to allow companies to file a paper original and
an electronic copy in lieu of an original and all of the seven (7) paper copies of interconnection
agreements and amendments to interconnection agreements?
Co . ssion Secretary
DECISION MEMORANDUM 12/13/2002