20140324Letter about Filings .pdf

Mary S. Hobson
Attorney & Counselor
999 Main, Suite rros
Boise, lD Bg7o9
908-385-8666
March 20,2014
Weldon Stutzman
Idaho Public Utilities Commission
472West Washington
Boise,ID 83702-5983 TAY+- t4-a t
Dear Weldon,
As a follow-up to our various conversations, outlined below is a proposal for providing the
monthly Idatro Performance Assurance Plan (PAP) reports on an ongoing basis:
Previously the PAP report included an aggregate CLEC payment report that was not confidential
and was filed electronically by email each month with the IPUC. In addition, a summary of
payments made to individual CLECs in Idatro was emailed separately to Staff with the term
"Confidential" in the subject matter line of the email. Reports penaining to aggregate
performance, e.g. performance indicators missed etc., were not filed with the IPUC but were
available at a website. However, with the approval of certain changes to the PAP in Order No.
32899, Docket No. QWE-T-08-04, monthly reports to be provided the state commissions will
now consist of the following:
. Aggregate payment report - Not confidential (The report is 2 months in arrears. For
example the March 2014 rcport will contain the January 2014 results.)
oCLEC.specificpaymentreport.@(Thereportis2monthsinarears.For
example the March 2014 report will contain the January 2014 results.)
. Aggregate per{ormance report - Not confidential (The report contains 13 months of
aggregate data. For example the March 2014 report will contain 13 months of aggregate
performance dataup through February 2014)
oCLEC.specificperformancereport_m(Thisreportcontainsonemonthof
ClEC-specific data. For example, the March 2014 report will provide the January 2014
results.)
The filing of these reports requires certain changes to our reporting process in ldaho. First, it
should be noted that the performance reports, which have not previously been filed in ldaho, are
voluminous. We believe that most effrcient and useful form of submission for these reports is in
electronic format, which will more readily allow review of spread sheets that cannot realistically
be printed out on one page.
The second issue raised by these changes is the requirement to file ClEC-specific information
on payments and perfornance. ClEC-specific information is confidential because it potentially
discloses information about the individual CLEC's business expansion, technologies chosen to
serve its customers etc. CenturyLink proposes that these reports be filed in an electronic format
but, due to the confidential nature of information contained in them, we do not believe that an
email filing is appropriate. Instead CenturyLink proposes providing a compact disc containing
these reports that will allow the IPUC and its Staffto better maintain confidentially while
reviewing the information.
In addition, since each of the four reports is required each month, CenturyLink believes it would
be useful to supply all the information for each month's reports at the same time and in the same
format. Therefore, CenturyLink proposes providing two separate discs: one containing the
aggregate payment report and the aggregate performance report (both non-confidential) and a
second disc containing the ClEC-specific payment and perforrnance reports. This second disc
will be clearly marked "CONFIDENTIAL."
Working with you and the Staff we understand that a new acronym and case have been created
allowing CenturyLink to file the new report information under "PAP-T-14-01." We appreciate
this accommodation, which will allow all of us to keep better track of these filings.
Our initial filing will be accompanied by an Attorney's Certificate for the ClEC-specific
payment and performance reports attesting to their confidentiality. This Certificate will also
reference the continuing obligation under the PAP to file such information each month. Based on
our conversations we understand that this process will be sufficient for maintaining the
confidentiality of such ClEC-specific information on a going forward basis. To preserve the
integrity of this process, Staffwill, of course, be in position to review each filing marked as
confidential to assure itself and the Commission that the information is appropriately designated.
Thank you for your cooperation in developing these procedures. Please feel free to contact me if
you have any questions or concerns.
Very truly yours,
l{rt*l
Ma.y S.@bson
Attorney for CenturyLink QC