20031204Motion to Withdraw and Substitute Testimony.pdf

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FILED
Mary S. Hobson, ISB #2142
Stoel Rives LLP
101 S. Capitol Blvd., Suite 1900
Boise, ID 83702-5958
Telephone: [phone]
Facsimile: [phone]
mshobson~stoel.com
26fijt~n V 1 2 PKLt: 34
PUBLIC
UTlUHES COMt'tlSSION
Adam L. Sherr (WSBA #25291)
Qwest
1600 7th Avenue - Room 3206
Seattle, WA 98191
Telephone: [phone]
Facsimile: [phone]
asherr~qwest. com
Attorneys for Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF DETERMINING
PRICES FOR UNBUNDLED NETWORK
ELEMENTS (UNEs) IN QWEST
CORPORATION'S STATEMENT OF
GENERALLY AVAILABLE TERMS
(SGAT)
CASE NO.: QWE-Ol-
MOTION TO WITHDRAW AND
SUBSTITUTE TESTIMONY
Qwest Corporation ("Qwest"), by and through its undersigned attorneys, and pursuant to
Commission Rule of Procedure 56, IDAP A 31.01.01.056, moves this Commission for its order
allowing Qwest to withdraw all of the testimony, exhibits and cost studies previously filed in this
case and permitting Qwest to substitute the Direct and Supplemental Testimony of Teresa K.
Terri") Million, including exhibits, and the Direct Testimony of Dick Buckley and exhibits.
MOTION TO WITHDRAW AND SUBSTITUTE TESTIMONY - Page 1
Boise-164173.1 0029164-00072
Background
The present docket to determine prices for Qwest's unbundled network elements (UNEs)
and other interconnection-related products and services was opened by Commission Order No.
28748 , issued June 12 2001. Later that month Qwest filed direct testimony for eight witnesses
that included then-current versions of Qwest's cost studies and models. Since that time Qwest
has supplemented that testimony with two pieces of supplemental testimony for Ms. Million and
with the submission of various updated cost studies.
Since the filing of Qwest's initial direct testimony, Qwest and Staff have been engaged in
a lengthy negotiation process intended to reach agreement on as many UNE and other SGAT
wholesale prices as possible. During the course of these negotiations, Qwest has provided Staff
with voluminous quantities of information concerning its cost models and studies, the
appropriate cost model inputs, and the effect of changing certain inputs in Qwest's models and
studies.
Updated Testimony and Exhibits
As a result of this lengthy negotiation process, Qwest's initial testimony and , to a lesser
extent, some of Qwest' s cost studies and models have become stale. Furthermore, the
submission of various studies over the course of these proceedings could lead to unnecessary
confusion. Therefore, at the request of the Commission Staff, Qwest has agreed to withdraw all
of its previously submitted testimony, exhibits, and cost studies and replace them with the
simplified and updated versions submitted herewith.
The substituted direct testimony of Ms. Million and Mr. Buckley and the accompanying
exhibits will provide the Commission with information to assess the reasonableness of the rates
submitted with Qwest's Motion for Approval of Negotiated Rates and for resolution of the
MOTION TO WITHDRAW AND SUBSTITUTE TESTIMONY - Page 2
Boise-164173.10029164-00072
remaining issues in this docket. Providing the most current version of all of Qwest' s advocacy
on UNE and interconnection costs will assist the Commission and any interested parties as they
participate in the remaining phases of this case.
Requested Relief
Based on the foregoing, Qwest respectfully requests that the Commission enter its order
allowing Qwest to withdraw all of its previously filed testimony, exhibits and other cost
submissions and replacing same with the testimony of Ms. Million and Mr. Buckley filed with
this motion.
Respectfully submitted this 12th day of November, 2003.
~1f---
Stoel Rives LLP
and
Adam Sherr
Qwest
Attorneys for Qwest Corporation
MOTION TO WITHDRAW AND SUBSTITUTE TESTIMONY - Page 3
Boise-164173.1 0029164-00072
CERTIFICATE OF SERVICE
I hereby certify that on this lih day of November, 2003, I served the MOTION TO
WITHDRAW AND SUBSTITUTE TESTIMONY as follows:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ID 83720-0074
Phone: [phone]
Fax: [phone]
ij ewell~puc.state.id. us
Weldon Stutzman, Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ID 83720-0074
Phone: [phone]
Fax: [phone]
wstutzm~puc. state.id.
A vista Communications of Idaho
422 West Riverside - Suite 100-Skywalk
Spokane, WA 99201
David Harmon
Mary B. Tribby
AT &T Law Department
1875 Lawrence Street - Suite 1401
Denver, CO 80202
Telephone: [phone]
Facsimile: [phone]
dsharmon~att. com
Ray Hendershot
GVNW Inc. / Management
O. Box 25969
Colorado Springs, CO 80936
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MOTION TO WITHDRAW AND SUBSTITUTE TESTIMONY - Page 4
Boise-164173.10029164-00072
Molly O'Leary
Richardson & O'Leary
99 East State Street - Suite 200
O. Box 1849
Eagle, ID 83616
Telephone: [phone]
Facsimile: [phone]
moll y~richardsonando leary. co m
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Morgan W. Richards
Moffatt Thomas et al.
101 South Capitol Boulevard - 10th Floor
O. Box 829
Boise, ill 83701-0829
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Lisa K. Strom
Davis Wright Tremaine
1300 SW 5th Avenue - Suite 2300
Portland, OR 9720
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Lance Tade, Director
Electric Lightwave, Inc.
4 Triad Center - Suite 200
Salt Lake City, UT 84180
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Conley E. Ward
Givens Pursley LLP
277 North 6th Street - Suite 200
O. Box 2720
Boise, ID 83701
Telephone: [phone]
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cew(Ci),givenspurslev.com
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Brandi L. Gearhart, PLS
Legal Secretary to Mary S. Hobson
Stoel Rives LLP
MOTION TO WITHDRAW AND SUBSTITUTE TESTIMONY - Page 5
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