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Home My WebLink About20031103Joint Motion.pdfMary S. Hobson (ISB #2142) Stoe1 Rives LLP 101 South Capitol Boulevard - Suite 1900 Boise, ill 83702 Telephone: (208) 389-9000 Facsimile: (208) 389-9040 mshobson~stoe1.com I f"\ ~~. ~" n .- t)) ~ ~ II H\J;,~ L i\t:CElv EO ~ . ' 1:' i! ,; ~ .'- Ze03 OCT 31 PM 5: 46 i "lid IU UTILI TiES COf1t"1!SSJON Adam L. Sherr (WSBA #25291) Qwest 1600 7th Avenue - Room 3206 Seattle, WA 98191 Telephone: (206) 398-2507 Facsimile: (206) 343-4040 asherr~qwest.com Attorneys for Qwest Corporation BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IPUC RESPONSE TO FCC ORDER ON REVIEW OF SECTION 251 UNBUNDLING OBLIGATIONS OF INCUMBENT LOCAL EXCHANGE CARRIERS (CC DOCKET NO. 01-338) Case. No. GNR-03- JOINT MOTION FOR ADOPTION OF BATCH HOT CUT FORUM NINE-MONTH REVIEW OF ECONOMIC AND OPERATIONAL IMPAIRMENT REGARDING ACCESS TO SPECIFIC UNES Qwest Corporation ("Qwest"), AT&T of the Mountain States, Inc. ("AT&T"), and W orldCom, Inc., on behalf of its regulated subsidiaries ("MCI") (the "Parties ) jointly propose the following process and framework for addressing the batch hot cut requirements of the FCC' Triennial Review Order ("Order JOINT MOTION FOR ADOPTION OF BATCH HOT CUT FORUM - 1 Boise-163720.1 0029164-00004 Overview: The Parties agree that a single, uniform batch hot cut process for all states within the Qwest region provides the most efficient and effective operating environment for both Qwest and CLECs. The Parties also agree that it is appropriate for the industry participants (ILECs and CLECs) to the extent possible, to attempt to reach agreement on a batch hot cut process prior to submitting a process to Commissions for review and approval. Toward that end, the Parties propose a multi-state forum with participation by both industry (ILECs and CLECs) as well as state commission personnel and other interested persons. The Parties further agree it is essential for state commissions to endorse this process. To the extent all of the states do not agree to endorse the process, the Parties reserve the right to withdraw this proposal and proceed on a state-by-state basis. Industry participation The Parties agree that the forum should be structured and conducted in a manner that encourages participation by as many CLECs as possible. The Parties propose to hold the first face-to-face meeting in Denver, Colorado with the option for participants to participate via a conference bridge in the event they are unable to travel to Denver. Should the forum participants determine that additional face-to-face meetings are required, the Parties propose that subsequent meetings be held in Seattle, Washington, and Phoenix, Arizona, to minimize the travel burdens that may be experienced by anyone CLEC. Participation by conference bridge will also be available for any subsequent meetings. All discussions conducted in the forum will be transcribed by a licensed court reporter and be made a part of the record in any state s 9-month proceeding.Qwest will assume the administrative role of creating the agenda for, and documenting the results of, each meeting. All JOINT MOTION FOR ADOPTION OF BATCH HOT CUT FORUM - 2 Boise-163720.10029164-00004 agreements reached by participants during the forum will be documented and will be binding upon the parties that entered into such agreements. hnpasse issues concerning the batch hot cut process remaining at the conclusion of the forum process will also be documented and will be litigated before the State Commissions for resolution during the 9-month proceedings in each of the states. CLECs and other participants will have an opportunity to comment on, and/or revise written materials indicating agreement, disagreement or other with the content of Qwest' documentation of the issues. All proposals and materials to be discussed at the forum will be provided to participants electronically two (2) business days in advance of any face-to-face meetings or conference calls. In addition, the proposals, transcripts of prior meetings, and any other applicable materials will be posted on the Qwest web site at: www.qwestcom/whoiesale/guides/index.html. Timelines Given the rigorous timelines set forth by the FCC in its Order for the state proceedings regarding a batch hot cut process, the Parties propose the following schedule for the forum and the subsequent incorporation of the results of the forum into the 9-month proceedings in each state: ACTIVITY Commission Notice to all CLECs within respective states regarding batch hot cut forum Qwest submits its batch hot cut proposal which will include a detailed description of the process, Including, but not limited to capacity, Pre-order, Ordering and Provisioning, the proposed cost for the batch hot cut activities, and the intervals. CLECs submit comments/counter proposals to Qwest's batch hot cut proposal Initial Forum - Denver, Colorado DUE DATE November 5 , 2003 November 2003 November 18, 2003 December 1-, 2003 JOINT MOTION FOR ADOPTION OF BATCH HOT CUT FORUM - 3 Boise-163720.1 0029164-00004 Weekly conference calls on batch hot cut December 4 2003 - January 15 , 2004 proposal, if useful. Face-to-face meetings as necessary (in Seattle, Washington & Phoenix, Arizona) Simultaneous filing of direct testimony on January 20 2004 impasse issues regarding the batch hot cut process and filing of a Stipulation among parties on areas of agreement/consensus items. Simultaneous filing of rebuttal testimony February 15, 2004 Hearings & Commission Decision Per each state s procedural order in the 9- month dockets Notice The Parties propose each state commission issue a Notice to all CLECs within its respective state advising that it endorses the multi-state forum, adopts the schedule and procedural requirements described above, and strongly encourages interested parties to actively participate in the multi-state forum. The parties further request that such notice be issued by November 5 2003 , to all CLECs and other interested parties. In the interest of making this filing on an expedited basis, the undersigned is authorized to state that AT&T and MCI concur in this proposal and is further authorized to sign and file this pleading on behalf of AT&T and MCI. Respectfully submitted this 31 st day of October, 2003. QWEST CORPORATION ~l~~ Stoel Rives LLP Adam L. Sherr Qwest 1600 ih Avenue - Room 3206 Seattle, WA 98191 Attorneys for Qwest Corporation JOINT MOTION FOR ADOPTION OF BATCH HOT CUT FORUM - 4 Boise-163720.10029164-00004 WORLD COM, INc. Thomas F. Dixon Michel L. Singer Nelson Lesley J. Lehr 707 - 1 ih Street, #4200 Denver, Colorado 80202 303-390-6206 303-390-6333 (fax) Attorneys for WorldCom, Inc. AT&T of the Mountain States, Inc. Mary B. Tribby AT &T Law Department 1875 Lawrence Street, Suite 1503 Denver, Colorado 80202 (303) 298-6508 Attorney for AT&T JOINT MOTION FOR ADOPTION OF BATCH HOT CUT FORUM - 5 Boise-163720.10029164-00004 CERTIFICATE OF SERVICE I hereby certify that on this day of October, 2003 , I served the foregoing JOINT MOTION FOR ADOPTION OF BATCH HOT CUT FORUM follows: Jean Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Street O. Box 83720 Boise, ill 83720-0074 Phone: (208) 334-0300 Fax: (208) 334-3762 i iewell(cvpuc.state.id. us Hand Delivery U S. Mail Overnight Delivery Facsimile Emai1 Weldon Stutzman Deputy Attorney General Idaho Public Utilities Commission 472 West Washington Street O. Box 83720 Boise, ill 83702 Phone: (208) 334-0300 Fax: (208) 334-3762 Hand Delivery U. S. Mail Overnight Delivery Facsimile Email Mary B. Tribby Letty S.D. Friesen AT &T Communications of the Mountain States, Inc. 1875 Lawrence St., Ste. 1575 Denver, CO 80202 Hand Delivery --L U S. Mail Overnight Delivery Facsimile Email Robert M. Pomeroy, Jr. Holland & Hart 8390 East Crescent Parkway, Ste. 400 Greenwood Village, CO 80111 Hand Delivery ----2S- U S. Mail Overnight Delivery Facsimile Email Conley E. Ward Givens Pursley LLP 277 North 6th Street, Ste. 200 O. Box 2720 Boise, ill 83701 Hand Delivery ---t- US. MailOvernight Delivery Facsimile Email JOINT MOTION FOR ADOPTION OF BATCH HOT CUT FORUM - 6 Boise-163720.10029164-00004 Charles Carrathers Verizon Northwest Inc. 1800 41 st Street Everett, W A 98201 Hand Delivery ----..2S.... u. S. Mail Overnight Delivery Facsimile Email Marlin D. Ard Attorney at Law O. Box 2190 Everett, W A 98201 Hand Delivery ----A- u. S. Mail Overnight Delivery Facsimile Email Dean J. Miller McDevitt & Miller LLP 420 W. Bannock Street O. Box 264 - 83701 Boise, ill 83702 Hand Delivery -2L u. S. Mail Overnight Delivery Facsimile Email Brian Thomas Time Warner Telecom 223 Taylor Avenue North Seattle, W A 98109 Hand Delivery $- U. S. Mail Overnight Delivery Facsimile Email /Ult t4 fl' I--k-~ Mary S. bson JOINT MOTION FOR ADOPTION OF BATCH HOT CUT FORUM - 7 Boise-163720.1 0029164-00004