20021206McIntyre Supplemental.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

SUPPLEMENTAL TESTIMONY OF

SCOTT A. MCINTYRE

QWEST CORPORATION

December 6, 2002

IDENTIFICATION OF WITNESS AND PURPOSE
Q. PLEASE STATE YOUR NAME, TITLE, AND ADDRESS.
A. My name is Scott A. McIntyre. I work for Qwest Corporation as a Director for
Product and Market Issues. My work address is 1600 Bell Plaza, Seattle,
Washington.
Q. HAVE YOU PREVIOUSLY PROVIDED TESTIMONY IN THIS
PROCEEDING?
A. Yes, I filed Direct and Rebuttal testimony in this proceeding on September 27,
and October 18, 2002, respectively.
Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY?
A. The purpose of my testimony is to notify the Commission that the parties were
unable to settle their disputes.

DISCUSSION OF QWEST’S FINAL SETTLEMENT OFFER
Q. EVEN THOUGH THE PARTIES DID NOT SETTLE, IS QWEST
WILLING TO MAKE A CHANGE TO ITS CATALOG THAT AFFECTS
THE ISSUES IN THIS CASE?
A. Yes. Qwest is willing to modify its current SS7 catalog offering so that Illuminet
and other entities purchasing out of the catalog would not be charged for
messages associated with local traffic. To effectuate this change on local
message billing, Qwest offered to implement a Percent Local Use (PLU) factor in
its billing system similar to the Percent Interstate Use (PIU) factor that is in place
today. Under this proposal, Qwest’s SS7 catalog customer would self-report a
PLU factor for the local, EAS and IntraMTA SS7 messages it sends to Qwest,
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subject to Qwest audit. Catalog customers would not be charged for SS7
messages associated with that traffic.
Q. SO FOR WHAT SS7 MESSAGES WOULD QWEST ASSESS CHARGES
UNDER THE REVISED ACCESS CATALOG?
A. Charges would still be assessed on messages associated with all types of intrastate
toll traffic.
Q. WHY DOES QWEST ASSESS THE SS7 MESSAGE CHARGES ON MEET
POINT BILLED TRAFFIC?
A. In the voice/data network context, when two or more local exchange carriers are
involved in originating or terminating call to/from an IXC, then meet point billing
arrangements are used. Each local exchange carrier bills the IXC the appropriate
rates for its use of their portion of the voice/data network. In the SS7 network
context, however, Qwest’s SS7 network receives a message query from both the
IXC and SS7 provider for the local exchange company (which in the
Complaintants’ case is a third party SS7 provider). Accordingly, it is proper for
Qwest to recover the costs to the SS7 network from the IXC for its SS7 message
query and also from the third party SS7 provider for its SS7 message query.
Q. WHY WILL THE SS7 MESSAGE CHARGES BE ASSESSED ON
ORIGINATING AND TERMINATING TOLL TRAFFIC?
A. The SS7 product that is the subject of this proceeding is an access product rather
than a UNE product. Thus, the rating of this SS7 product, is similar to that of
other access products; that is, both originating and terminating messages are
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subject to charge. Feature Group Switched Access services are another example
of this type of access rating.
The UNE product for SS7, included in Qwest’s SGAT, which is not the
subject of this proceeding, is rated using interconnection principles. For
unbundled SS7 purchase out of the SGAT or interconnection agreements, local
messages are billed in the terminating direction only. Another example of this
type of interconnection rating is for Qwest’s Local Interconnection Service, where
usage is billed by Qwest only for local calls that terminate to Qwest end users.
Q. WOULD QWEST BE WILLING TO ACCEPT THE QWEST-OFFERED
TERMS AND CONDITIONS DISCUSSED IN THIS SUPPLEMENTAL
TESTIMONY AS A COMMISSION ORDER?
A. Yes.
Q. DOES THIS CONCLUDE YOUR TESTIMONY?
A. Yes, it does.