DONALD L. HOWELL, II

DEPUTY ATTORNEY GENERAL

IDAHO PUBLIC UTILITIES COMMISSION

PO BOX 83720

BOISE, IDAHO 83720-0074

(208) 334-0312

Street Address for Express Mail:

472 W. WASHINGTON

BOISE, IDAHO 83702-5983

Attorney for the Commission Staff

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION )

OF CITIZENS TELECOMMUNICATIONS)CASENO. CTC-T-97-2

COMPANY OF IDAHO FOR APPROVAL OF)

AN INTRALATA TOLL DIALING PARITY)

IMPLEMENTATION PLAN.)COMMENTS OF THE

)COMMISSION STAFF

______)

COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its Attorney of record, Donald L. Howell, II, Deputy Attorney General, and in response to Order

No. 26998 and the Notice of Modified Procedure filed June 13, 1997, submits the following comments.

Citizens Telecommunications Company of Idaho (CTC-Idaho) is asking for speedy approval of a plan needed to implement intraLATA dialing parity to meet an FCC deadline. Given the time constraints involved, the willingness of interested parties to compromise on a variety of issues, and the small costs involved, Staff endorses CTC-Idahos implementation plan.

Though not a formal party to the Settlement Agreement, Staff did participate in the negotiation sessions and is satisfied that the major issues have been satisfactorily addressed. There were differences of opinion on a variety of issues, but none large enough as to preclude a

STAFF COMMENTS1 JUNE 27, 1997

final compromise. Staff believes that the inter-company issues of competitive neutrality involved in providing equal access have been satisfactorily handled. Staff also participated in, and agreed with, determination of the final wording of the customer notices.

Estimated costs to implement intraLATA equal access were provided by the Company over a month ago. That same information has been supplied in several different forms, but no additional supporting information has been forthcoming. The PIC change cost estimates are not yet available, but the other upgrade cost estimates total an unremarkable $77,395.38. There are a few questions about the estimates that we have received, such as why sales tax on equipment upgrades is 6% rather than 5%, and why the load/overhead factor percentage is different for the McCall switch than the other 11 switches. Since the costs are bare estimates and are unauditable in their present form, Staff provides no formal opinion as to their correctness.

However, with the overall total so small, currently estimated at $.00137 per access minute, Staff has no significant concerns about approving the Settlement Agreement. In addition to the relative insignificance of the costs, the contemplated procedure for cost recovery as outlined in the Settlement Agreement (point 11) provides for a true-up and adjustment at the end of each of the two years of the proposed recovery period.

Staff recommends that the Commission adopt the Settlement Agreement dated June 6, 1997, and approve CTC-Idahos intraLATA parity plan as amended.

DATED at Boise, Idaho, this day of June 1997.

______

Donald L. Howell, II

Deputy Attorney General

______

Bill Eastlake

Telecommunications Analyst

Technical Staff:Kent Schneider

DLH:BE:jo/comments\ctct972.dh

STAFF COMMENTS1 JUNE 27, 1997