20020906Decision Memo.pdf

DECISION MEMORANDUM
TO:COMMISSIONERKJELLANDER
COMMISSIONER SMITH
COMMISSIONER HANSEN
JEAN JEWELL
RANDY LOBB
DON HOWELL
LYNN ANDERSON
CAROLEE HALL
BIRDELLE BROWN
WAYNE HART
DOUG COOLEY
BEVERLY BARKER
RON LAW
GENE FADNESS
TONYA CLARK
WORKING FILE
FROM:JOE CUSICK
DATE:SEPTEMBER 6,2002
SUBJECT:QWEST TIME-OF-DAY SERVICE
On August 26,2002,Qwest wrote the Commission requesting that the Company
be relieved of its obligation to provide free time-of-day service throughout the state.The
origin of the obligation to provide time-of-day service is the Commission's Order No.
21782,in Case No.U-1000-97,dated February 24,1988.
COMMISSION DECISION
Does the Commission wish to release Qwest from its obligation to provide free
time-of-day service?
Joe Cusiok
udmemos/time of day dmemo
999 Main Street,11t
Boise,Idaho 83702
r ih t
August 26,2002 QWOSt
Jean Jewell
Secretary
Idaho Public Utilities Commission
P.O.Box 83720
Boise,ID 83720-0074
RE:QWEST REQUESTFOR RELIEF FROM TIME-OF-DAY SERVICE
OBLIGATION IN IDAHO PER ORDER NO,21782
Dear Ms.Jewell,
Qwest requests the Idaho Public Utilities Commission relieve it of the obligation to
provide free time-of-day service in its service territoryin Idaho.The origin of the
obligation to provide time-of-day service is the Commission's Order No.21782,in Case
No.U-1000-97,dated February 24,1988.
Current Situation
Qwest has discovered in the normal course of activities associated with replacement of
the Lewiston central office that the time-of-day announcement equipment located in that
switch is nonfunctional and has been inoperablefor some number of months.All eight
Qwest exchanges in northern Idaho are affected by this breakdown;calls to the 1-844-
1111 time-of-day number throughout the northern Idaho service area ring without
answer.Despite this inadvertent and,until now,unrecognized failure of the equipment,
Qwest has not received consumer complaints that would have lead to more rapid focus on
this problem.
Discussion
Ifnecessary,Qwest is willingto comply with the Commission's previouslyordered time-
of-day service requirement.However,before ordering equipment'and making the
investment to do so,Qwest wishes to reconfirm whether the Commission continues to
believe that it is appropriateto require Qwest to provide this service.The Commission
should be aware that a major hurdle in the ordering and installation of the replacement
hardware (this issue also affects the current inoperableequipment)is the lack of
certification of this equipmentunder NEB engineering standards.Such certification
i The cost to replace the current hardware is less than the estimated cost to repair
existing hardware.The minimum order interval for the replacement hardware is 30 days
and the installation interval includingtesting and turn up could be as long as another 3-4
weeks.
relates to the safety,noise,heat and other environmental characteristics of the equipment.The hardware necessary to provide time-of-day service is so rarely installed in RBOC
switches there is,to Qwest's knowledge,no NEB certified hardware available in the
market.Today,any collocated equipment to be placed in a Qwest central office by aCLECmustbeNEBcertified.This puts Qwest in the uncomfortable posture ofpotentiallyordering/installing hardware for time-of-day service that it would not allow aCLECtocollocate.Indeed,Qwest is unaware that any of its fellow RBOCs continue tosupporttime-of-dayservice in their territories,although it may well exist in pockets.
Commission Decision Requested
Qwest requests the Commission acknowledge the major changes in the competitive
landscape since 1988 when it determined that telephonecompany-provided time-of-dayservicewasnecessary.The Commission does not require CLECs to provide such serviceandtheCompanyisunawareofanyIdahoCLECsthatprovideit.Qwest is also unclear
as to whether such service is still provided by the other incumbent local exchange carriersinthestate.
In addition,Qwest requests the Commission consider the many alternative means ofgetting'the time'whether it be watches,cell phones,pagers,pda's,lap tops,computermonitors,telephoneLCD displays,directory assistance,etc.The lack of complaints overthemonthssincetheservicehasbeeninactiveinnorthernIdaholeadsonetoquestionwhetherconsumerdemandjustifiestheconsiderableexpensetoprovisionandmaintain
this service going forward.
Qwest respectfullyrequests that the Commission relieve it of the requirements found in
Order No.21782 and allow the discontinuation of Qwest-provided time-of-day service inIdaho.
Please direct Staff or Commission questions on this issue to me on 208-385-8666.
Since y,
hn Souba
daho RegulatoryMgr.