20021203Quintana 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, 47th Floor
Denver, CO 80202-1984
Telephone: [phone]
Facsimile: [phone]

Attorneys Representing Qwest Corporation

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IDAHO TELEPHONE ASSOCIATION, )
CITIZEN TELECOMMUNICATIONS ) CASE NO. QWE-T-02-11
COMPANY OF IDAHO, CENTURY TEL OF )
IDAHO, CENTURY TEL OF THE GEM )
STATE, POTLATCH TELEPHONE COMPANY )
And ILLUMINET, INC. )
)
Complainants )
)
vs. )
)
QWEST COMMUNICATIONS, INC. )
)
Respondent )
___________________________________)

REBUTTAL TESTIMONY OF

KARLA J. QUINTANA

QWEST CORPORATION

December 3, 2002
Boise-149620.2 0029164-00082
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Q. PLEASE STATE YOUR NAME, BUSINESS ADDRESS, AND CURRENT
POSITION.
A. My name is Karla J. Quintana. I am employed by Qwest
Corporation as a Senior Process Analyst in Wholesale
Markets. My work address is 1005 17th Street, Room 950,
Denver, Colorado 80202-1976.
Q. PLEASE REVIEW YOUR EDUCATION, WORK EXPERIENCE, AND
PRESENT RESPONSIBILITIES.
A. I have 23 years service with Qwest and have worked in
various departments including Operator Services,
Finance, Capacity Provisioning and Carrier Marketing now
referred to as Wholesale Markets. My present
responsibilities are as ILEC Service Manager in the
states of Colorado, Idaho, Montana, Utah and Wyoming. I
am actively involved with the independent local exchange
carriers (ILECs) on their network requirements, such as
switch conversions, SS7 conversions, fiber placement and
electronics upgrades and any miscellaneous issues that
arise.
Q. HAVE YOU PREVIOUSLY TESTIFIED IN IDAHO OR OTHER STATES
IN QWEST’S TERRITORY?
A. No.
Q. HAVE YOU PREVIOUSLY PROVIDED TESTIMONY IN THIS
QWE-T-02-11 Quintana, Karla J. (Reb)
November 7, 2002 Qwest Corporation
Boise-149620.2 0029164-00082
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PROCEEDING? 1
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A. No.
PURPOSE
Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY?
A. The purpose of my testimony is to respond to the October
21, 2002 “Direct” Testimony filed by Charles H. Creason
on behalf of the Idaho Telephone Association.
Q. WHEN DID YOU FIRST BECOME AWARE OF SYRINGA NETWORKS LLC?
A. I first became aware of Syringa Networks LLC (Syringa)
in August of 2001 when they were putting in a large
fiber facility in southern Idaho. Syringa contacted me
to work on changing the meet points that were then in
existence between Qwest and various Idaho ILECs so that
the ILECs could use Syringa facilities for transport
across the state instead of Qwest facilities.
Q. WAS THERE ANYTHING UNUSUAL ABOUT THOSE NEGOTIATIONS?
A. Well to me it was unusual because it was always
difficult to pin down exactly what kind of an entity
Syringa claimed to be. At times its representatives
seemed to want to characterize it as simply a group of
ILECs that should be treated in the way Qwest would
treat the ILECs themselves. At other times, it appeared
Syringa preferred to position itself as a another kind
of entity altogether, namely a long-haul or “carriers’”
QWE-T-02-11 Quintana, Karla J. (Reb)
November 7, 2002 Qwest Corporation
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carrier. The otherwise simple entry of Syringa into
Qwest’s Local Exchange Routing Guide (“LERG”) data base
took weeks to finalize because of difficulty in
characterizing Syringa’s operations.
Q. DID YOU DISCUSS SS7 WITH SYRINGA AT THAT TIME?
A. No. My first discussion with any Syringa representative
about SS7 did not occur until March, 2002.
Q. TO YOUR KNOWLEDGE DID SYRINGA DISCUSS SS7 WITH ANYONE
ELSE AT QWEST PRIOR TO THAT TIME?
A. Not to my knowledge, no.
Q. DOES SYRINGA HAVE A CONTRACT WITH QWEST CONCERNING HOW
THE TWO COMPANIES WILL INTERCONNECT AND EXCHANGE SS7
MESSAGES?
A. No it does not.
Q. HOW, THEN, IS SYRINGA PURCHASING SS7 SERVICES FROM
QWEST?
A. Syringa is utilizing an old SS7 services contract
executed in 1995 between Qwest and a company called
“System Seven”. Syringa has never executed any SS7
services contract with Qwest, and, the System Seven
contract with Qwest was never assigned to Syringa.
Q. HOW IS IT THAT SYRINGA CAME TO USE THE SYSTEM SEVEN SS7
CONTRACT?
QWE-T-02-11 Quintana, Karla J. (Reb)
November 7, 2002 Qwest Corporation
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A. In March of this year, Charles Creason first contacted
me to discuss SS7 service arrangements for Syringa. He
identified Syringa as a “LEC consortium” that “does not
engage in regulated local exchange access services or
activities, and has not been certified as a competitive
local exchange carrier.” Mr. Creason stated that
Syringa had purchased System Seven and that he wanted to
establish links from Qwest’s SS7 network to the Syringa
STPs, canceling the links from Qwest’s SS7 network to
the System Seven STPs.
Q. SINCE YOU HAD PREVIOUSLY WORKED WITH SYRINGA, DID YOU
KNOW THAT IT HAD PURCHASED SYSTEM SEVEN?
A. No. This contact was the first time I had heard that
System Seven had been sold.
Q. WHAT WAS YOUR RESPONSE TO MR. CREASON’S REQUESTS?
A. I told him that I needed to check with the SS7 product
management personnel since I was aware that the product
had been restructured, and I was not certain how a
company like Syringa would purchase SS7 services.
Q. WHY DID YOU NOT JUST OFFER MR. CREASON THE SAME SS7
CONTRACT THAT QWEST HAD EXECUTED WITH SYSTEM SEVEN?
A. I did not offer Syringa the same contract for a number of
reasons. First, Qwest had executed the System Seven SS7
contract on February 7, 1995, prior to the passage of the
QWE-T-02-11 Quintana, Karla J. (Reb)
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Telecommunications Act of 1996 and prior to the FCC
issuing is Access Reform Order allowing incumbents to
unbundle SS7. Second, Qwest had typically reserved the
type of SS7 services contract offered to System Seven for
ILECs. Third, since October of 2001, Qwest was no longer
offering to any party, including ILECs, the type of
contract that System Seven had executed. Finally, Qwest
had already restructured its Idaho SS7 product offering
in June 2001 and was determining a course of action
regarding all contracts that were not in accordance with
the catalog restructure, which included the type of SS7
contract Qwest had executed with System Seven.
Q. YOU STATED THAT SYSTEM SEVEN CONTRACT WAS A TYPE
TYPICALLY OFFERED ONLY TO ILECs. DO YOU UNDERSTAND THAT
SYSTEM SEVEN WAS AN ILEC?
A. No. It is my understanding that System Seven was
another, “ILEC consortium”.
Q. DO YOU KNOW WHY SYSTEM SEVEN WAS OFFERED THAT CONTRACT?
A. No, I was not involved in offering that contract to
System Seven and the person who signed the copy that Mr.
Creason attached to his testimony has left the Company.
In fact I never saw that contract until I was asked to
review Mr. Creason’s testimony. It is not in my files.
QWE-T-02-11 Quintana, Karla J. (Reb)
November 7, 2002 Qwest Corporation
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I will note, however, that in 1995 the distinctions that
are so familiar now between various types of
telecommunications companies and the rules that apply to
them were not part of the way we did business then.
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Q. WITH THE OLD SS7 CONTRACT NO LONGER BEING OFFERED, WAS
QWEST STILL ABLE TO OFFER SS7 SERVICES TO SYRINGA?
A. Yes. I discussed with Mr. Creason and Mr. Hettinger of
the Martin-Group, a Syringa consultant, that Syringa
needed to purchase SS7 services out of Qwest’s
tariff/catalog because Syringa was not a
telecommunications carrier.1 Mr. Creason later decided
that Syringa did not want to purchase SS7 services out
of Qwest’s interstate tariff and intrastate catalog and
asked me whether Syringa could utilize System Seven’s
contract since Syringa was the purchaser of Syringa.
Q. HOW DID QWEST RESPOND TO THAT REQUEST?
A. I inquired of the product manager how Qwest should
handle this issue. At that point the Infrastructure
Sharing Agreements (ISAs) that have now been offered to
Idaho ILECs were not yet approved for release, so we had
no alternative to offer the members of this “ILEC
consortium”. As a result, it was decided that, on an

1 See Direct Testimony Pages 3 and 24 of Qwest Witness Scott McIntyre for
a discussion of the treatment for non-telecommunications carriers.
QWE-T-02-11 Quintana, Karla J. (Reb)
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interim basis, Syringa could use the System Seven
agreement in a kind of grandfathered status, i.e. they
could not change or reconfigure the services offered
under that contract. This meant, for example, that
Syringa would not be permitted to establish links from
Qwest’s SS7 network to the new Syringa STPs and cancel
the links to the System Seven STPs.
Q. YOU INDICATED THAT YOU WERE ASKED TO REVIEW MR.
CREASON’S TESTIMONY. DID YOU REVIEW ANY OTHER TESTIMONY
IN THIS CASE?
A. Yes. I reviewed Mr. Creason’s direct testimony and Scott
McIntyre’s direct and rebuttal testimony.
Q. DO YOU AGREE WITH MR. CREASON’S CHARACTERIZATION THAT
MR. MCINTYRE’S TESTIMONY WAS INACCURATE AND MISLEADING?
A. No. Mr. McIntyre is correct that Syringa, like
Illuminet, is a third-party SS7 provider and that, as a
third-party SS7 provider, Syringa should purchase SS7
services out of Qwest’s Access Services Catalog. Mr.
McIntyre is also correct that Syringa has not done so.
However, he was mistaken in that Syringa is not
purchasing SS7 services through Project Mutual.
Q. WAS IT REASONABLE FOR MR. MCINTYRE TO MISTAKE THAT
SYRINGA WAS PURCHASING SS7 SERVICES THROUGH PROJECT
MUTUAL?
QWE-T-02-11 Quintana, Karla J. (Reb)
November 7, 2002 Qwest Corporation
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A. Yes. As I have indicated, the SS7 relationship between
Qwest and Syringa is unlike any other wholesale account
that I am aware of. Qwest receives SS7 messages from
Syringa even though Syringa has not executed a contract
with Qwest for the purchase of SS7 services. In
addition, there are very strong ties between Syringa and
Project Mutual. Nearly all of my contacts with Syringa
have been through Mr. Creason who, of course, is also a
representative of Project Mutual. And, as Mr. Creason
admits, Syringa’s SS7 equipment is located in Project
Mutual’s central office. Thus, all the SS7 messages
that Qwest receives from Syringa contain the point codes
associated with Project Mutual’s STPs.
Q. MR. CREASON IMPLIES ON PAGES 5 AND 6 OF HIS TESTIMONY
THAT HE DID NOT SEEK TO AVOID PAYING THE SS7 RATES QWEST
ESTABLISHED IN ITS CATALOG. IS THAT ACCURATE?
A. No. I received an email from Mr. Creason on April 4,
2002 wherein he stated that he understood Qwest would be
provisioning the links Syringa requested under the
tariff/catalog rather than the System Seven contract and
that as such he needed to pin down the exact pricing. I
gave Mr. Creason all information necessary for him to
place an order under Qwest’s tariff/catalog, as well as
a contact name and phone number to begin the ASR
QWE-T-02-11 Quintana, Karla J. (Reb)
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process. On April 25, 2002, Mr. Creason left me a
voicemail asking if he could leave the existing SS7
arrangement under the System Seven contract in place
because of the economics involved, i.e., the message
usage charges would be assessed under the tariff/catalog
but not under the System Seven contract.
Q. SO MR. CREASON WAS AWARE OF QWEST’S SS7 SERVICES AS
RESTRUCTURED IN ITS ACCESS SERVICES CATALOG?
A. Yes. I exchanged several emails with Mr. Creason and
Mr. Hettinger between April 23, 2002 and April 25, 2002.
Specifically, Mr. Hettinger inquired about the message
usage charges contained in the tariff/catalog and how
the rates were applied.
Q. IS IT REASONABLE FOR MR. CREASON TO ALLEGE IN HIS
TESTIMONY ON PAGE 8 THAT SYRINGA CANNOT DETERMINE
WHETHER QWEST IS CHARGING SYRINGA MESSAGE USAGE CHARGES?
A. No. Mr. Creason knows that Syringa was never assessed
SS7 message usage charges under the System Seven
contract. In fact, that was the very reason why he did
not want to purchase out of Qwest’s tariff/catalog.
Under the System Seven contract, Qwest billed Syringa
only a flat monthly rate for the entrance facility, the
direct link transport, and the STP port. At no time did
QWE-T-02-11 Quintana, Karla J. (Reb)
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Qwest charge Syringa (or System Seven) SS7 message usage
charges.
Q. HAS QWEST CANCELLED THE QWEST/SYSTEM SEVEN SS7 CONTRACT?
A. Yes. Qwest has now cancelled the SS7 contract executed
with System Seven.
Q. WHY WAS THAT CONTRACT CANCELLED?
A. It is my understanding that the contract is inconsistent
with the restructure of Qwest’s Access Services Catalog,
which is the subject of this case. Also I understand
that the ILECs that make up the “ILEC consortium” may be
eligible for ISAs that would continue to provide them
with SS7 signaling without incurring per message
charges, if they choose to take that option. That option
wasn’t available when it was decided to allow Syringa to
continue under the old System Seven contract.
Q. IN ATTEMPTING TO CANCEL THE OLD CONTRACT, DID QWEST
INITIALLY SEND A CANCELLATION LETTER TO PROJECT MUTUAL
RATHER THAN TO SYSTEM SEVEN?
A. Yes. As I previously testified, there was confusion
regarding Syringa’s purchase of SS7 services from Qwest.
With most SS7 customers, Qwest deals with one entity
name. With Syringa, Qwest was dealing with three
different entity names since the contract was with
System Seven and the point codes associated with the SS7
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messages were from Project Mutual, and Mr. Creason, who
was associated with all of these entities, was
attempting to position Syringa to take over for System
Seven. The original letter was sent to Mr. Creason at
Project Mutual. When we became aware of the mistake,
the notice canceling the letter was sent to Mr. Creason
at System Seven at the same address, since our records
show System Seven and Project Mutual as having the same
address.

CONCLUSION
Q. WOULD YOU PLEASE SUMMARIZE YOUR REBUTTAL TESTIMONY?
A. Yes. It is my job to work with Idaho independent
companies and attempt to meet their needs for various
Qwest services including SS7. However, it wasn’t until
March of this year that I became aware that Syringa was
providing SS7 services to Idaho ILECs. When I became
aware of this, I advised Mr. Creason that Syringa would
need to purchase SS7 out of the Qwest Access Services
Catalog. However, because he was reluctant and because
Qwest had no other alternative to offer ILECs at that
time, I eventually agreed, on an interim basis, to allow
Syringa to carry on under an old contract that was
executed with a company that Syringa apparently
QWE-T-02-11 Quintana, Karla J. (Reb)
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purchased sometime earlier. Now that alternatives are
available to ILECs, Qwest has cancelled the old
contract. This unusual history makes it very easy to
mistake who is actually providing SS7 to certain Idaho
ILECs. The confusion is heightened by the fact, among
others, that the STP used by Syringa resides in Project
Mutual’s switch giving all Syringa SS7 messages Project
Mutual’s identification codes.
Q. DOES THIS CONCLUDE YOUR REBUTTAL TESTIMONY?
A. Yes.
QWE-T-02-11 Quintana, Karla J. (Reb)
November 7, 2002 Qwest Corporation
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