200404291st Response of QCC to Staff.pdf

Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoe1.com
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UTILITIES COf'1t1t'SSlON
Adam L. Sherr (WSBA #25291)
Qwest
1600 ih Avenue - Room 3206
Seattle, W A 98191
Telephone: [phone]
Facsimile: [phone]
adam.sherr~qwest.com
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
APPLICATION FOR AMENDMENT
OF CERTIFICATE OF PUBLIC
CONVENIENCE AND NECESSITY OF
QWEST COMMUNICATIONS
CORPORATION
CASE NO. QCC- T -04-
RESPONSES OF QCC TO FIRST
PRODUCTION REQUEST OF THE
COMMISSION STAFF
Qwest Communications Corporation (QCC), by and through its undersigned attorneys
files the, attached Responses to the First Production Request of the Commission Staff.
Dated this 29th day of April, 2004.
// "
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Mary S. bson
Stoel Rives, LLP
Adam L. Sherr
Qwest
Attorneys for Qwest Corporation
RESPONSES OF QCC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF-
Boise-170636.10029164-00033
CERTIFICATE OF SERVICE
I hereby certify that on this 29th day of April, 2004, I served the foregoing RESPONSES
OF QCC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF upon all
parties of record in this matter as follows:
Ms. Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83720-0074
-1L Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Weldon B. Stutzman
Deputy Attorney General
Idaho Public Utilities Commission
O. Box 83720
Boise, ill 83720-0074
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U. S. Mail
Overnight Delivery
Facsimile
urie Rehder
Legal Secretary to Mary S. Hobson
Stoel Rives LLP
RESPONSES OF QCC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 2
Boise-170636.l 0029164-00033
Idaho
Case No. QCC-04-STF 01-001
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:001
What is the intended market of Qwest Communications Corporation (QCC).
What products does QCC intend to sell to which types of customers?
a. Does QCC intend to enter the residential basic local exchange service
(POTS) market?
b. Does QCC intend to enter the small business POTS market?
RESPONSE:
Geographic market for QCC:State of Idaho
Product market for QCC: QCC currently provides inter-exchange data and
services to Idaho customers. At present it intends to offer additional
services, including packaged product offers, using resold PRI, business
exchange service and local T-1 spans to large business and governmentcustomers.
voice
local
QCC has no plans at this time to enter the residential basic local exchangeservice (POTS) market or the small business (5 lines or fewer) POTS market.
Respondent:John R. McCormick, Qwest Manager
Idaho
Case No. QCC-04-
STF 01-002
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:002
QCC is already certified to provide local exchange service in Verizon 'service area in Idaho. Please describe the types of services currently beingprovided in Idaho by QCC. How many local exchange customers does QCC haveVerizon I s service area.
RESPONSE:
QCC is not currently providing local exchange services in Verizon territoryin Idaho. However, QCC is providing interexchange services to customers in
Idaho as described in detail in its Catalog. QCC is also providing data
services in Idaho, including in the Verizon ILEC service area.
Respondent:John R. McCormick, Qwest Manager
Idaho
Case No. QCC-T-04-
STF 01-003
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:003
Does QCC intend to construct or own any facilities?
RESPONSE:
QCC currently has significant transport, private line, and switching/router
facilities in Idaho, used in connection with its existing inter-exchangecarrier and data service operations. With regard to the provision of local
exchange services, QCC will likely rely on the purchase of wholesale and
retail services and facilities that will be used in combination with its own
facilities where appropriate.
Respondent:John R. McCormick, Qwest Manager
Idaho
Case No. QCC-T- 04-1
STF 01-004
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:004
QCC and Qwest Corporation (QC) are currently subject to the federal separate
affiliate requirements of Section 272. Qwest may seek to eliminate someseparation requirements 3 years after Qwest obtained 271 authority. What isthe intent of Qwest in regards to maintaining such separation at the end of
the mandatory period? Will both QCC and QC continue to operate.
RESPONSE:
QCC and QC have not finalized any plans with regard to the possible
elimination of separation requirements at the end of the mandatory period.
Respondent:John R. McCormick, Qwest Manager
Idaho
Case No. QCC-04-
STF 01-005
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:005
What is the extent of joint marketing expected between QC and QCC? Will QCC
use QC customer service representatives (CSRs)? If so, how will branding beprovided for QCC? How will branding be provided for QC? What provisionswill be made to ensure that the CSRs are discussing the correct company
policies, terms and conditions?
RESPONSE:
QC and QCC currently jointly market services within the legal framework
created by Section 272 of the Telecommunications Act of 1996. Qwest intends
to continue to do so, consistent with Section 272 and QCC'expanded authori ty.
As discussed in response to Production Request No. STF 01-001, QCC
anticipates serving large business and government customers in Idaho as a
CLEC. Those types of customers do not typically obtain service by telephoning
into a centralized call center, but instead are served by large business
account teams which sell services provided by various entities within the
Qwest family of companies. Qwest anticipates that QCC large business local
exchange customers will be served by the same large business account teams as
currently assist QC large business customers.
Currently, it is anticipated that both QCC and QC will continue to use the
Qwest brand. As required, Qwest I s various ordering end billing systems, and
their associated methods and procedures, will be developed and maintained in
such a manner as to insure accurate information is provided to all customers.
Respondent:John R. McCormick, Qwest Manager
Idaho
Case No. QCC-04-1
STF 01-006
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:006
How will customers be made aware of the different "Qwest 's"? Will they have
different 800 numbers? If a potential new customer calls "Qwest" to sign upfor basic local exchange service, will they initially be offered such servicefrom Qwest the ILEC or Qwest the CLEC? If the rates or terms are different,
how will this be made clear to the customer? Will the bonuses or commissions
paid to dales personnel be greater of different for QCC than QC?
RESPONSE:
New residenence and small business customers requesting basic local exchange
service from Qwest will be provided services by QC, where available; QCC doesnot presently plan to provide such services. QCC has generally described the
products it initially plans to offer in its application. Subject to the
continuously evolving nature of business plans, Qwest states that it has not
developed detailed Idaho-specific business plans for QCC CLEC operations.
Hence, QCC cannot respond in more detail to that portion of the request
seeking information about rates for services offered by QCC or salesincenti ves for QCC products,
Presently, questions regarding customer billing and customer service mattersare addressed as follows:
Business customers:
If Qwest Corporation is your local provider: [phone]
If Qwest Corporation is not your local provider: [phone]
Residential customers:
If Qwest Corporation is your local provider: [phone]
If Qwest Corporation is not your local provider: [phone]
Primary interexchange carrier ("PIC") disputes:[phone]
Respondent:John McCormick
Idaho
Case No. QCC-04-1STF 01-007
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:007
Can an individual be a customer of QC for some products and a customer of QCCfor other products? (Same location). If so, please describe.
RESPONSE:
Yes. Indi viduals may be, and many currently are, customers of QC localexchange-related products and of QCC interexchange products. Also, anindi vidual or business could be a customer purchasing QC local voice or data
products and also QCC data products.
Respondent:John R. McCormick, Qwest Manager
Idaho
Case No. QCC-04-
STF 01-008
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:008
In its Application, QCC indicated it had obtained certificates to provide
local exchange services in a number of other states in which QC is the ILEC.
What is the scope of QCC operations in those states? How many customers for
what types of services? Please provide the terms under which any joint
marketing may be conducted between QCC and QC in those states?
RESPONSE:
QCC is not yet providing local exchange telecommunications services in any
in-region state, although it is authorized to do so in all or parts of WA,
OR, ID, UT, IA, MT, CO, WYand MN. QCC is providing interexchange and
information services in all 14 in-region states. With regard to joint
marketing, see QCC' s response to Production Request No.
Respondent:John R. McCormick, Qwest Manager
Idaho
Case No. QCC-04-
STF 01-009
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:009
Has QCC signed any interconnection agreements with QC in any other states.
Of so, please identify? With Verizon or other ILECs?
RESPONSE:
No. QCC requested to opt into the 14 QC SGATs. QCC understands that QC is
preparing the contracts for QCC review and execution. QCC and QC have notyet signed any interconnection agreements. As the agreements are completed,
QC will file these with the regulatory commission in each state. With regard
to other ILECs, see Attachment A.
Respondent:John R. McCormick, Qwest Manager
INTERVENOR:
REQUEST NO:
Idaho
Case No. QCC-04-STF 01-010
Staff of the Idaho Public Utilities Commission
010
Will the line splitting policies of QCC be the same as those of QC?please describe.
RESPONSE:
QCC has no line splitting obligations under the Act.
John R. McCormick, Qwest Manager
No.
Respondent:
If not,
Idaho
Case No. QCC-04-
STF 01-011
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:011
Please explain how the presence of a Qwest Corporation affiliate as a
competitor to Qwest I s own services is in the public interest
RESPONSE:
QC's and QCC's operations will serve the public interest by allowing Qwest to
operate through a single entity where customers ' needs demand complex
telecommunications solutions. Many business customers require multiple
complex services that are networked or managed as a single set of sharedservices for their businesses. In such businesses central budgeting, service
management and service activation drive decision makers to seek a single
entity to service its needs on a state-wide, regional, or national basis.
In many states Qwest has been unable to respond competitively to statewide,
regional, or national bids due to its lack of a geographically independent
product set and inability to offer a complete product set through a single
entity. QC (the ILEC) has limitations in its ability to serve multiple LATAs
and QCC (the CLEC) is not certified to operate and/or does not have the
interconnection contracts with ILECs necessary to provide the local
components to be responsive to a typical Request For Proposal (RFP). Qwest
has difficulty competing with CLECs, CLEC/IXC combinations, and ILEC
consortiums that are able to respond in such a manner.
To be at full parity with competitors Qwest requires certification as a CLEC.
Qwest desires to fully develop its functionality so that it may lead and
react to competitive opportunities. As changes in technology, regulation,
and customer needs occur, Qwest needs to be positioned to competitively
respond to and serve customers.
Adding Qwest to the competitive marketplace to provide innovative solutions
for local and interexchange telecommunications services benefits consumers
and serves the public interest by stimulating competition in the market for
telecommunications, which generally results in better service, lower prices,
greater availability, and improved innovation.
Respondent:John R. McCormick, Qwest Manager
Idaho
Case No. QCC-04-
STF 01-012
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:012
What title 62 services, other than long distance services, is QCC currently
providing in QC I S certificated territory?
RESPONSE:
See QCC' s responses to Production Request Nos. 2 and
Respondent:John R. McCormick, Qwest Manager
IDAHO
Case No. QCC-04-
STF 01-009
Attachment A
PacBell
SWBT
Ameritech
Ameritech
Ameritch
Ameritech
Ameritech
Bell Atlantic
Bell Atlantic
Bell Atlantic
Bell Atlantic
Bell Atlantic
Bell Atlantic
Bell Atlantic
Bell Atlantic
SWBT
SWBT
SWBT
SWBT
CBP
GTE"
GTE"
GTE"
GTE"
Sprint"
BeliSouth
BeliSouth
BeliSouth
BeliSouth
BeliSouth