20021018Craig Rebuttal.pdf

Mary S. Hobson, ISB #2142
Stoel Rives LLP
101 S. Capitol Blvd., Suite 1900
Boise,ID 83702-5958
Telephone: [phone]
Facsimile: [phone]
Stephanie L. Boyett-Colgan
Qwest Services Corporation
1801 California Street, 47 Floor
Denver,CO 80202-1984
Telephone: [phone]
Facsimile: [phone]
Attorneys Representing Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IDAHO TELEPHONE ASSOCIATION,
CITIZENS TELECOMMUNICATIONS
COMPANY OF IDAHO, CENTLJRYTEL OF
IDAHO, CENTURYTEL OF THE GEM
STATE, POTLATCH TELEPHONE COMPANY
and ILLUMINET, INC.
Complainants
QWEST CORPORATION,
Respondent.
REBUTTAL TESTIMONY OF
JOSEPH CRAIG
QWEST CORPORATION
October 18, 2002
1 I.IDENTIFICATION OF WITNESS
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3 PLEASE STATE YOUR NAME.
4 MY name is Joseph Craig.
5 ARE YOU THE SAME JOSEPH CRAIG THAT PREVIOUSLY FILED
6 DIRECT TESTIMONY IN THIS CASE?
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Yes,I am.
PLEASE EXPLAIN THE PURPOSE OF YOUR TESTIMONY.
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MY testimony responds to issues raised in the direct
testimony of Illuminet witnesses Paul Florack and F.
Wayne Lafferty.Mr. Lafferty also testifies on behalf
of Citizens Telecommunications Company of Idaho,
Electric Lightwave,and the Idaho Telephone Association.
I address these responses from a network, technical
perspective.
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ON PAGE 15, LINES 1 THROUGH 16 OF HIS DIRECT TESTIMONY,
MR. FLORACK DESCRIBES JOINTLY PROVIDED EXCHANGE ACCESS
AND THEN ALLEGES THAT QWEST IS INAPPROPRIATELY BILLING
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FOR THE 557 FUNCTION IT PROVIDES.IS MR. FLORACIC'S
ALLEGATION CORRECT?
No,it is not.This is an example of where Mr. Florack
is confusing SST messaging with calls or traffic.There
is no such thing as a jointly provided exchange access
SS7 message.SSI is an out of band s~ignaling network.
QWE-T-02-11
October 18, 2002
Craig, J (DI)-l-
Qwest Corporation
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To use Mr. Floracks words, "Signaling occurs "out-of-
band" on dedicated channels rather than on the voice
channels"'.Access charges apply to the voice trunk on
the terminating side of a toll call and are billed based
on minutes of use.SS7 message charges are for the SS7
messages that use the Qwest SS7 network and have nothing
to do with the access billed on a voice trunk.This is
an attempt by Mr.Florack to confuse the signaling
network with the voice network, and is contradictory to
his own testimony.
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Also,this really is a non-issue, since the
signaling message requirements to set up a local trunk
or a toll trunk are identical.The only difference is
the information included in the signaling message
parameters.
Q.ON PAGE 19, LINES 9 THROUGH 11 OF HIS DIRECT TESTIMONY,
MR. LAFFERTY ALLEGES THAT QWEST IS ALREADY BEING
COMPENSATED FOR TRAFFIC VIA EXISTING INTERCONNECTION
19 AGREEMENTS.DO YOU AGREE WITH MR. LAFFERTYS ALLEGATION?
20 A. No,I do not. Mr.Lafferty is confusing 557 messaging
21 with trunks,the same mistake that Mr. Florack makes.
22 The ELI Interconnection Agreement addresses the
' Direct testimony of Illuminet witness Florack, filed September 27, 2002,at page 6,lines 18 and 19.
QWE-T-02-11
October 18, 2002
Craig, J (DI)-2-
Qwest Corporation
1 interconnection trunk group and the associated
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transport,and Qwest is compensated for the trunk group
and the associated transport accordingly.This
compensation does not include the 557 messaging function
as asserted by Mr. Lafferty.
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To be clear,Interconnection Agreements ('ICA") are
established between Qwest and Competitive Local Exchange
Carriers ("CLEC") for the purpose of exchanging traffic.
If a CLEC,such as ELI,wants to purchase
interconnection transport and associated trunking from
Qwest as detailed in their ICA, and 557 network
functionality from a third party provider, such as
Illuminet,then they have not purchased any SS7
functionality from Qwest.All the CLEC has purchased
from Qwest is interconnection transport and the
associated trunking.
Q.WITNESSES OF EVERY COMPLAINANT HAVE ALLEGED THAT QWEST
SHOULD DISTINGUISH 557 MESSAGES AS LOCAL AND EXCHANGE
ACCESS (i.e., TOLL).DO YOU AGREE?
A. No.The distinction between local and toll is only
relevant to voice/data calls on the Public Switch
Telephone Network and has no bearing on the 557 network.
The SS7 network has to perform for all messages that
access the 557 network regardless of whether the
QWE-T-02-11
October 18, 2002
Craig, J (DI)-3-
Qwest Corporation
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associated voice/data call traversing the voice network
is local or toll.Costs are generated by each and every
message that accesses the SS7 network.From the
perspective of the 557 network,a message is a message
is a message.
SINCE ALL MESSAGES CREATE COSTS TO TEE SS7 NETWORK, TEEN
WHAT IS GAINED BY SEPARATING MESSAGES INTO LOCAL AND
EXCEANGE ASSESS (i.e., TOLL)?
Nothing.There are no "nonchargeable" messages.
ON PAGE 18, LINE 3 OF HIS DIRECT TESTIMONY, MR. FLORACK
STATES TEAT IT IS NOT TECHNICALLY FEASIBLE TO ESTABLISH~
SEPARATE SIGNALING LINK CONNECTIONS FOR THE EXCBANGE OF
LOCAL AND TOLL CONNECTIONS.IS THIS TRUE?
No it is not.Mr. Florack states earlier in his
testimony that Illuminet does not own or operate Signal
Switching Points ("SSP"), or end office switching
equipment,and then goes on to offer an incorrect
opinion.Switch vendors,such as Lucent and Nortel,
have the capability for multiple point code assignments
in the switch, or SSP.If Illuminet's carrier customers
want to separate their SS7 messages based on the local
or toll nature of their voice trunks, switch vendors
have made this technically possible.
QWE-T-02-11
October 18, 2002
Craig, J (DI)-4-
Qwest Corporation
CERTIFICATE OF SERVICE
I hereby certify that on this l$day of October, 2002, I served QWEST
CORPORATION’S REBUTTAL TESTIMONY OF JOSEPH CRAIG as follows:
Ms. Jean Jewell, Secretary
Idaho Public Utilities Commission
412 West Washington Street
Boise, Idaho 83720-0074
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Conley Ward
Givens Parsley
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QWEST CORPORATION’S DIRECT TESTIMONY OF JOSEPH CRAIG AND
SCOTT A. MCINTYRE-Page 1
*oise-l‘moa., w29,6MKoS2
Richard Wolf
Illwninet, Inc.
4501 Intelco Loop SE
P.O. Box 2909
Olympia, WA 98507
Lance Tade
Citizens Telecommunications
4 Triad Center - Suite 200
Salt Lake City, UT 84180
F. Wayne Lafferty
LKAM Services, Inc.
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McKinney, TX 75070
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Legal Secretary to hmy S. Hobson
Steel Rives LLP
QWEST COP.PORATlON’S DIRECT TESTIMONY OF JOSEPH CRAIG AND
SCOTT A. MCINTYFS - Page 2
Boise-l475OS.l i3329164GMS2