20030422Teitzel Rebuttal & Exhibits.pdf

Mary S. Hobson , ISB #2142
Stoel Rives LLP
101 S. Capitol Blvd., Suite 1900Boise, ID 83702 - 5958Telephone: [phone]Facsimile: [phone]
Adam L. Sherr , WSBA #25291
Qwest
1600 7 th Avenue, Room 3206
Seattle, WA 98191Telephone: [phone]Facsimile: [phone]
RECEIVED 0fILED
2003 APR 22 AM 8: 11
iU/,1-iU PUE:L!C
UTiLIT!ES COMMISSION
Attorneys Representing Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF QWEST CORPORATION FOR PRICE
DEREGULATION OF BASIC LOCAL
EXCHANGE SERVICES
CASE NO. QWE-T- 02 -
REBUTTAL TESTIMONY OF
David L. Tei tzel
on behalf of
QWEST CORPORATION
April 21, 2003
Boise-155939.1 0029164- 00087
SUBJECT
II.
TABLE OF CONTENTS
INTRODUCTION
OVERVIEW OF TESTIMONY
III. STAFF TESTIMONY OF WAYNE HART
IV.
VI.
FUNCTIONAL EQUIVALENCE
COMPETITIVELY PRICED
STAFF TESTIMONY OF BEN JOHNSON
FUNCTIONAL EQUIVALENCE
COMPETITIVELY PRICED
TESTIMONY OF THE INTERVENORS MEIEROTTO
CONCLUSION AND RECOMMENDATION
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PAGE
INTRODUCT I ON
PLEASE STATE YOUR NAME,ADDRESS AND POSITION
WITH QWEST.
David officeTeitzel.name
located at th Avenue,am aSeattle,Washington.1600
Director - Product and Market Issues for Qwest and have
responsibili ty Qwest Retailforregulatoryadvocacy
Marketing initiatives at the state and federal levels.
HAVE YOU PREVIOUSLY PROVIDED TESTIMONY IN THIS
PROCEEDING?
Yes, I filed direct testimony in this proceeding
on December 17 , 2002.
II.OVERVIEW OF TESTIMONY
PLEASE PROVIDE OVERVIEW YOUR REBUTTAL
TESTIMONY .
My rebuttal testimony addresses issues raised in
this proceeding through the testimonies of Staff witnesses
and Ben Johnson,and witnesses forthe theWayneHart
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Meierotto.testimony,Intervenors
that statutory requirements for price deregulationIdaho
Qwest'basic local exchange service
Specifically,demonstrate that wireless
functionally Qwest' s basicequi valent
wireline service.also show that
provides reasonably available competitively priced
substi tute for desiringconsumers
demonstrate
have been met.
service
local exchange
wireless service
alternative
Qwest's wireline basic local exchange service.The 1 eve 1
now presentcompetition Boise,
Falls,Nampa,Meridian,Pocatello and
clearly findingsufficientsupport
Public Commission
" )
Utilities Commission
Caldwell Idaho
Twin Falls
the Idaho
that Qwest'
basic local exchange services should be price deregulated
in the seven exchanges.
III.STAFF TESTIMONY OF WAYNE HART
Functional Equivalence
PAGES AND HIS TESTIMONY ,HART
MAINTAINS THAT NOT APPROPRIATE
COMMISSION'REVIEW UNDER IDAHO CODE
MR.
LIMIT THE
62-622 (3) (B)
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LOCAL TWO-WAY SWITCHED VOICE COMMUNICATION SERVICES.
YOU AGREE?
and thethisissuealsoaddressed
rebuttal testimony of Mr.Souba.Mr. Hart interprets the
local services 62-622 (3) (b)used sect ionterm
meaning exchangesomethingdifferent"basic localthan
services. "He apparently believes local services" is a
far broader concept incorporating more than local voice
communication.
Idaho Code 62-603 (1) ,"basic local exchange
service"the provision of access lines tois defined as
residential customersandsmallbusiness with the
associated two-waytransmission interacti ve swi tched
voice communication within a local exchange calling area.
(emphasis added)62-622 (2),section the legislature
equated termsthe "basic local exchange services"and
"local services"
The commission shall not regulate the prices
for basic local exchange services for telephone
corporations that were not providing such localserviceon or before February 8, 1996.
Provided however such telephone corporationproviding basic local exchange services shallfile price lists with the commission that
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reflect the availability, price, term, and
conditions for such services." (emphasis added)
It is clear that the terms "local service " and "basic
local were used interchangeably by theexchange service
legislature to mean lines associated with the provision of
swi tched notvoicetwo-way communications.
appropriate scopebroadenthe this proceeding
take into account various ancillary functions of wireline
telephone service,and Johnson haveMr.Hart Dr.
attempted stated,their testimonies.Simply
these ancillary functions are outside the statutory test
Qwest must satisfy in this proceeding.Incl uding them in
the discussion Staff has done,unj ustif iably adds
additional elements to the standard that were not intended
by the legislature.
MR.HART AND DR.JOHNSON AGREE THE
DEFINITION OF "FUNCTIONALLY EQUIVALENT?"
On page 5 lines 3-, Mr. Hart states "theNo.
legislature apparently contemplated that services that are
technically thenot those providedsame
facili ties -based enoughcompetitornonethelesscould
like it that it might serve as a reasonable substitute.
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JohnsonDr.
competing services
the maintainsotherhand,that two
must virtually identical
considered "functionally equivalent.As I explain later
rebuttal
positionext reme
conclusion,would
al ternati ve
Johnson testimony,thisDr.
which,its logicalfollowed
mean that compet i t i vetheonly
qualify for consideration under Dr.
Johnson s standard would be a clone of Qwest' s basic local
exchange service.
legislature envisioned when 62 -
622(3)(b).Had it intended this result,the legislature
I don t believe this is what the Idaho
enacted Idaho Code
would have stopped after it created section 62-622 (3) (a) ,
which defines
facil i ties-based
effective competition terms
competition.the legislatureHowever,
purposefully expanded the kinds of technology that could
provide effecti ve competi tion incl ude technologies
that are "functionally equivalent"(not simply identical)
the incumbent'
adoption of section 62-622 (3) (b)
622 (3) (a)shows that Dr.Johnson s position on this point
is off the mark.
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wireline The legislaturenetwork.
as well section 62-
TEITZEL, D. (REB) -
Qwest Corporation
PAGE
WIRELESS CUSTOMERS
DISTANCE CARRIER.
No.
between local
14,LINES 11,
ARE NOT ABLE
IS THIS RELEVANT?
the wireless
and long distance
eliminated with nationwide calling plans.
the definition
SouthernQwest' s
Local Exchange
MR.HART
Idaho Basic
CHOOSE
market
calling
Service
Local
NOTES THAT
THEIR LONG
the distinction
all but
Furthermore,
provided
Exchange Tariff
indicates that in addition to local calling,
provides access and from
network for long distance calling.
the service
the telecommunications
(emphasis added)The
wireless service providers offering service in Idaho allow
customers access the long distance network just
Qwest allows access to the long distance network through
its basicwireline local exchange service.Furthermore,
the fact that customers can choose from multiple wireless
carriers in each exchange means that they do have choice
carriers
service.
MR. HART RAISES THE ISSUE OF SERVICE QUALITY AS
for long distance well for local
JUSTIFICATION FOR HIS CONTENTION THAT WIRELESS SERVICE IS
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NOT FUNCTIONALLY EQUIVALENT TO WIRELINE SERVICE.PLEASE
COMMENT .
Hart cites dropped calls, 2 dead spots busyMr.
signals,inside buildings as some ofand fading coverage
the problems with wireless service quality.I submi t that
while these problems may have occurred historically with
wireless digi talservicetechnologysuchnew
transmission manysignalshascorrected them.
Verizon Now?"Can You advertising campaignHear
emphasizes the improvements in service quality undertaken
by the Verizon actually leads the industry inindustry.
national billion a yearnetwork investment,averaging
for the two years,last and expects to invest a similar
pressaccordingamount2003,recent company
release.Bear Stearns estimates that at the end of 2001
only about 15%the wireless subscribers the
were still using analog phones.
1 Qwest Corporation, Basic Local Exchange Tariff , Southern Idaho,
Section 2, page 5, Effective 8-18-2000.2 As Mr. Shooshan discusses in his rebuttal testimony, a primary cause
of dropped calls is a failed handoff between wireless towers while a
wireless customer is in transit. since the core issue of this case is
whether wireless service is a substitute for local voice calling from
a fixed location , the issue of dropped calls is truly off topic.3 http://biz.yahoo.com , visited April 7 , 2003.
4 Bear Stearns, Wireline Services. New Opportuni ties, New Challenges,March 2002.
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Digital moretechnologies subscribers thansupport
previous technologies in the same bandwidth.For example,
the AccessCodeDi vision Multiple CDMA" )digital
standard Sprint,utilized Idaho wireless carriers
Veri zon Clear Talk Cellular,and Leap Wireless can
provide analogthreetimesthecapaci tyten
network. 23 to this testimony is a copy ofExhibi t No.
Clear Talk's web page citing the advantages of its CDMA
technology:
Enhanced Voice Quality
Clearer Calls than Analog
Fewer Dropped Call s
Reduced Background Noise and
Greater Call Security
Increased Airwave Capacity
Interference
Other wireless carriers competing with Qwest also use
digi tal technology enhance their service offerings.
For example, T-Mobile s network utilizes Global System for
Mobile
( "
GSM" )digital technology.According
Mobile s website , this technology provides customers with:
integrated voice, high-speed data, paging and
short message service capabilities, as well as
excellent sound quality and call reliability.The well-developed network ensures that all
calls and messages are processed quickly and
Id.
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reliably, and T-Mobile 100 percent digital
network delivers better sound quality thanother wireless services, including crisper,clearer voice quality and less static, fading
and background noise. Independent laboratory
and field test reports validate near paritywith wire lines (emphasis added) (See T-
Mobile web page attached as Exhibit No. 24.
as digital technology becomes the ubiquitousHence,
standard for the wireless industry,the incidence
dropped calls,dead spot s busy signals,and fading
coverage inside buildings rapidly decreasing.Service
quality may have been an issue with some wireless service
in the past, but advancements in technology and conversion
analog networks digital have dramatically reduced
those problems.
It also should not be overlooked that consumers are
flocking to wireless service.Hart would haveWhile Mr.
the Commission believe that his imprecise,uncorroborated
opinion findingabou t service quality precl udespoor
that hiswirelessservicefunctionallyequivalent,
point is at odds with reality.Wireless service continues
and relying primarilygrowmanyconsumersare
exclusively on wireless service for voice communications.
If service quality were, as Mr. Hart implies, a barrier to
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entry and competition , wireless usage would not be growing
at the pace that it has over the past few years.This lS
made evident by Staff's response to Qwest Interrogatory
and by Mr.Hart'own testimony.that Interrogatory,
Qwe s t asked Staff whether Staff believes the average
consumer telephone services the seven exchanges
the allegedly- inferior service qualityaware
wireless gave Idahoservice.Staff appropriately
consumers much credi t ,offering that Staff believes Idaho
fully aware.In his (pagetestimonyconsumersare
ines consumers know when15-20) ,stated thatMr.Hart
they pick up a wireless phone they re making a trade off
between Staff'mobility and service quality. "Both
discovery response and testimonyMr.Hart'support
point differencesQwest' s that whatever service quality
currently areexist,they known and accepted Idaho
customers and are not creating any barrier to competition.
DO TECHNICAL DIFFERENCES IN SERVICE ATTRIBUTES
MEAN THAT WIRELESS AND WIRELINE SERVICES ARE NOT
FUNCTIONALLY EQUIVALENT?
No.Both services are used for two-way switched
voice cancommunicationand therefore considered
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functionally equivalent.The fact remains that
increasing arenumber utilizing wirelessconsumers
service as a substitute for traditional wireline service.
An article last August highlightsin the New York Times
this fact.A customer who had given up her wireline phone
was quoted as saying:
Cellphones are not perfect, but it's worth the
$90 we save each month.
This two tradi tionalparticularcustomergave
phone cablelinesand went with cell phones andtwo
modem connection for Internet access.
The article goes on to identify reasons why consumers
may want to give up conventional phone service:
Cost - If you already have a cellphone, your
overall phone-service cost may be lower.
Portability - There is no need for connectingand disconnecting land-line service for people
who move frequently.
Convenience - You can place and receive calls
and retrieve voice-mail messages anywhere - not
just home, office, or pay phone.Choice Most consumers have many more
options for wireless service than they do forland-line service.
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When customerallsaidandindi vidualdone,
preferences consumerwill telephone servicegovern
selection.The point of this case is that Idaho residence
and aresmallbusiness able choose andconsumers
indeed are choosing - wireless services as alternatives to
wireline two-wayserviceforQwest'swi tched voice
communication.
MR.HART RELATED HIS EXPERIENCE MAKING
SEVERAL TEST"CALLS US ING CRI CKET' SERVICE.WHAT
YOUR REACTION TO HIS TESTIMONY ON THIS SUBJECT?
Mr. Hart indicates in his testimony at page 18
lines that Staff placed fifty21-23,total calls
using a Cricket phone.According to Mr. Hart's testimony,
all a problem withfifty calls completed and there was
only call the fifty.Accordingoutone
calculations,98%that'100%completion andrate
reliability Hart indicated earlier hisrate.Mr.
testimony that 99.99% of calls on a(page 17 lines 8-
wireline Mr.network complete reliably.Assuming that
yielded statisticallyHart'meaningfultest results,
di f f erence rates deri vedreliabilitytwopercent
6 The New York Times, When the Cellphone is the Home Phone, August 29
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through Mr.suggests the two services arestudyHart'
identical, are functionallybutthatnotthey
equivalent. "As Dr.Lincoln explains in greater detail
Hart' salsoimportantthat studynoteMr.
neither scientifically nor statistically meaningful.
made only fifty calls and made every call using one phone
of one carrier from one location on one day at one time.
same telephonethecallsFortyplacedthewere
number.This methodology does providenot
representati ve manythe compet ing wirelessvlew
carriers and locales at issue in this case.
YOU AGREE WITH MR.HART'CONTENTION THAT
DIFFERENCES WITH REGARD 911 SERVICES DEMONSTRATE
WIRELESS SERVICE NOT FUNCTIONALLY EQUIVALENT WITH
QWEST'S WIRELINE LOCAL EXCHANGE SERVICE?
allegesNo.hisMr.Hart testimony that
because servicesis not yetE911 available for wireless
and because calls to 911 from a wireless phone may not go
through weather-relatedduenetworkcongestion
problems,cannotwirelessservice considered
functionally equivalent with wireline The E911service.
2002.
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and aresituations911 entirely different,but neither
claimMr.that wirelesssupportHart'service not
functionally purposesequi val en t"for section 62 -
622 (3) (b) .
I will first address Mr. Hart's E911 point.Wireless
carriers have elected not to implement E911 service in the
affected exchanges this time.theHowever,FCC
providing direction on implementation in CC Docket 94 -102,
and has ordered all wireless carriers to fully implement
caller 2005.E911 autolocate capability December
Meanwhile,Idahoshould be noted that in many Qwest
exchanges wirelinealsoavailableE911not
customers.This simply underscores the fact that E911 is
not part of basic local exchange service.
Wi th regard to 911, Mr. Hart cites a study conducted
by Consumer s Union in which more than 10% of respondents
wi th a wireless phone in reachingclaimed some problems
(Hart,page911.lines 17-19)Hart failed toMr.
state that 911 calls in the Consumer s Union96% of the
test did go through.Furthermore, Consumer s Union admits
that its tests represent a small picture of a situation
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that can change with time and location.It acknowledges
that most problems occurred in California and that a major
consideration in call completion is the make and model of
the cellular handset the wireless network.not
ProductionQwe s t Request No.Mr.Hartresponse
indicated Staff is not aware of any Idaho consumers having
had difficulty in reaching emergency service providers via
a wireless phone The Consumerin the past 12 months.
Union report recommended consumers use phones that use the
CDMA digital format.That technology is used by many of
the wireless carriers offering service in the exchanges at
in thi proceeding,discussed previously in myl S sue
testimony.responsefact,Request forQwest
Production No.not aware ofStaff indicates it 2 -13,
studies compare thedocumentsthatdirectlyany
probability of a problem when calling 911 from home using
wireless phone with calls placed from home using
wireline phone.
pointto Mr.that congestion or weatherHart'
could sameblockcallfrom being completed,911 the
could be adversesaidwirelineservice.Certainly,
weather can result in service outages of wireline service.
7 See Direct Testimony of Wayne Hart, Exhibit 107 , pp 12-13.
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For example,a wireline customerduring a power outage
using a cordless phone will be unable to dial 911.For
Mr.Hart suggest that weather problem unique
wireless service (and hence justification for the
Commisslon not approving Qwest' s application this
proceeding)wi thout meri t .The fact remains that
wireless emergencyservicecallforcustomerscannow
assistance pattern.via the familiar dial ing911"
Indeed,as Mr.Hart points out in his testimony on page
20, lines 24-25, the inherent mobility of wireless service
provides 911"additional funct ional i ty ,that the
caller may access emergency service wherever the caller is
physically located , whether inside or outside the home or
office.
MR.HART ALSO CITES FACTTHE THAT WIRELESS
CARRIERS DO NOT OFFER NUMBER PORTABILITY AS A REASON THAT,
IN HI S ESTIMATION,THERE NOT FUNCTIONAL EQUIVALENCY
BETWEEN WIRELESS SERVICE AND QWEST' BASIC LOCAL EXCHANGE
SERVICE.IS NUMBER PORTABILITY A STATUTORY REQUIREMENT
FOR DEREGULATION OF QWEST'S BASIC LOCAL EXCHANGE SERVICE?
The statute does not require that to haveNo.
effecti ve consumerscompetition,ablemust port
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their numbers.Nor is number portability integral to the
provision of two-way swi tched voice services whi ch are
the services issue in this proceeding.Furthermore,
Qwest is now fully capable of providing number portability
wireless carrlers Wireless carriers have not yet
implemented FCC hasnumberportability,but the
established November deadl ine for such24,2003
implementation by all wireless carriers.Verizon Wireless
one the companies already publicly committed
complying with the reasons,directive.For theseFCC'
Mr. Hart's number portability concerns do not provide the
Commission a basis for rej ecting Qwest' s application.
ACCORDING TO MR. HART ON PAGES 23-24, ACCESS TO
THE INTERNET ANOTHER FACTOR CONSIDERED WHEN
EVALUATING FUNCTIONAL EQUIVALENCY.IS INTERNET ACCESS AN
ISSUE WITHIN THE SCOPE OF THIS PROCEEDING?
incl udedNo,Internet thenotaccess
definition basic local exchange service issue
this providersdocket,and therefore whether wireless
provide "effective competition " for that capability is not
the issue before the Commission in this proceeding.
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Although proof of effective competition for Internet
access is not a statutory requirement Qwest must satisfy
nowthisproceeding,wireless Internet access
available and current data transmission rates for wireless
Internet comparable dial-up wirelineaccessare
Internet speeds.Such speeds will increase wi access
the deployment of 2. 5G and 3G technologies.
DO YOU AGREE WITH MR. HART'S CONCLUSION THAT 85%
IDAHO INTERNET USERS RELY ON A VOICE GRADE LINE FOR
ACCESS TO THE INTERNET?
there are several problems with the
methodology Mr.used arr i ve his conclusionHart
which is another example of Staff raisingin any event,
lssues that are beyond the issue of effective competition
for basic local exchange service.First,
inappropriately uses households and lines
interchangeably same.they and thenotareone
household may have more than one line.the "lineAlso
statistic that he uses in his calculation represents small
business inappropriatelyandresidentiallines.
divides this number that strictly residential
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andhouseholds. "mixingHence,apples
oranges.
Furthermore , he compares two different points in time
the 2001;househol d"information dated the line
information dated additionJune30,2002.the
1 ine statistic ci ted actualMr.Hart count
reported by carriers whereas the "household"statistic is
sampl ing based the September 2001 Census
Bureau s Current Population Survey ("CPS"
) -
a broad survey
acrosshouseholds000 the entire Uni ted States.
Interestingly enough the National Telecommunications and
Information Administration ("NTIA"), Mr. Hart's source for
the household"data,findings thecomments CPS
pertaining to Internet access:
And finally, small but growing number of
Internet connections are increasingly occurringover personal devices, such as wireless phones
and personal digital assistants, in addition to
the computer. 8 (emphasis added)
Another problem I have with Mr. Hart's calculation is
that thedividesthenumberhighspeedlines
number of households accessing the Internet to reach the
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conclusion accessthattheremainder the Internet using
dial-voice grade line.This conclusionover
apparently intended to substantiate his case that Qwest'
wireline service essential for individualsthese and
thus price deregulated.Whatcannot neglects
consider is that the high speed "line " statistichoweve r ,
used nothiscalculation only telephonerepresents
ines ,Internetbutalso alternative means to access the
such as cable modems9 and satellite.Rather than making a
that forwirelineserviceQwest' s essentialcase
Internet data acknowledgesMr.Hart'thataccess,own
there are other means to access the Internet.
Mr. Hart's entire discussion on this topic is fraught
with notflawedmethodologyandshoulddismissed
only being irrelevant the issues in this proceeding,
but also statistically erroneous.
ARE CALLS PLACED TO ACCESS THE INTERNET UNDER
THE JURISDICTION OF THIS COMMISSION?
www.ntia.doc.gov/ntiahome/dn/html/Chapter1.htm, visited March 28,2003.9 For example , CableONE has high speed Internet systems in the seven
exchanges at issue in this proceeding. Prices start as low as $39.
per month for unlimited use, which is comparable to Qwest's recurring
charge for DSL.
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understanding that the Federal
Communications communicationsCommissionhasruledthat
us ing in nature. the interstateInternet Thus,are
addi tion to the fact that basic local exchange service is
limited notvoicecommunicationsstatute
believe access thethattheCommissionincludecan
Internet as part of the definition of basic local exchange
service.
B. Competi ti vely Priced
MR. HART MAINTAINS THAT WIRELESS SERVICES ARE
NOT PRICED COMPETITIVELY WITH QWEST'S WIRELINE LOCAL
(PAGE 3, LINES 12-16)EXCHANGE SERVICE.PLEASE COMMENT.
Lincoln howdiscussesDr.his testimony
customers base purchasing decisions on all attributes of
alternative hasservices,and how primary research
demonstrated that significant proportion Idaho
view wireless servicecustomers substitute for
(not complement to)traditional landline telephone
10 In the Matter of Implementation of the Local Competi tion provision
in the Telecommunications Act of 1996 (FCC Declaratory Order),
R. 3639 (1999), vacated on other grounds, Bell Atl. Tel. Co.
FCC, 206 F. 3d 1 (2000).
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service.and I will show howI agree wi th Dr.Lincoln
contention incorrectMr.Hart'and based flawed
methodology.There can be no doubt that wireless service
competitively priced alternativepresents wireline
service - - and industry research substantiates this fact.
For example,the Heritage Foundation recently published a
report citing wireless services as a viable substitute for
wireline phones due to "their price and functionality. ,,
The report states:
The number of (wireless) subscribers is vast -
some 129 million , a figure approaching the 189
million wireline lines in service. And whileonly about 6.million Americans rely
exclusively on their wireless phones, with no
wireline subscription some 18 percent now
consider their wireless phones to be their
primary phone line. Most important , even forconsumers who do not currently rely
wireless, it serves as a vital check on the
market power of wireline incumbents (emphasis
added) .
In January of this year, INSIGHT Research Corporation
published a review of the telecommunications industry that
corroborates findings.the Heri tage Foundation
According to INSIGHT:
11 Heritage Foundation Reports, Local Telephone Competition:
Unbundling the FCC's Rules, February 10, 2003.
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Wireless services were long considered to be a
necessity for only the business traveler. terrestrial wireless services became widelyavailableservice prices were lowered toattract residential consumers, especiallyduring off-peak hours (evenings and weekends).Today, teenagers are beginning to view the
mobile phone as a necessity.
Wireless service has become the primary meansof connecti vi ty to the network for manysubscribers. In the US, falling prices haveprompted some subscribers to use their mobile
phones as their primary phones, especially whenLD (long distance) services are bundled as part
of the package.
Between 1993 and 1998 the average monthly
local bill in the US fell at an average of percent annually. This decline resulted from
the increased price competition between service
providers in most markets. As shown in Figure
11-(of the INSIGHT report), however the
monthly ARPU began to increase in 1999. This
apparent aberration reflects a larger increasein usage from sources like wireline
displacement and payment for unused minutes insubscription plans. recent USAToday/CNN/Gallup poll found that about
percent of US users regard their cell phones astheir primary phones. INSIGHT expects thewireline/wireless replacement trend continue.
I submit that the trends in wireless displacement of
wireline otherservicesdescribedaboveandthroughout
12 Id.13 The INSIGHT Research Corporation, The 2003 Telecom Industry Review:
An Anthology of Market Facts and Forecasts, January 2003.
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industry notliteraturewould occurring wireless
service is not competitively priced as Mr. Hart alleges.
WHAT YOUR EXHIBIT 101,RESPONSE MR.HART'
WHICH PURPORTS TO SHOW HOW WIRELINE AND WIRELESS SERVICE
PRICES COMPARE?
Exhibit 101 depicts an inaccurate comparison.
have several concerns with the methodology Mr.Hart used
to develop price differences between the calling plans of
the various wireless carriers compared Qwest
wireline residential and business rates.Those include:
did useexcludeminutesMr.Hart not
associated with data applications such as Internet access.
will followingdescribedetailgreater
testimony,usagedata relevant thenot statutory
requirements meet this proceeding.Qwest must
Incl usion averagedata-related inflates theusage
length of a flat residential call in Idaho by more than
100%,and thereby dramatically inflates pricethe
wireless calling plans in Mr. Hart's Exhibit 101.
Mr.Hart used static blocks minutes for each
carrier irrespective how each carrier packages its
service.For example Mr.Hart used the same usage
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assumptions for low,median and high measured residential
service of and100 and 300 in his pricing comparisons,
500 and 3,000 for low , median and high usage flat-500,
rated residential customers.Since wireless carriers,
fact,mannerspackagetheircallingplansdifferent
(for someexample,wireless carriers include free
calling moderately-evening,nights and weekends
priced plans notbut in entry-level plans) ,is more
appropriate to examine only the wireless usage counted by
a particular carrier against the plan s usage allocation.
That usage should then be compared to the wireless plan
price schedule and the result compared to Qwest' s wireline
usage and prices as I have done in Exhibits 20 and 21.
Simply selecting wireline usage break points,then force-
fitting Mr.those break points into wireless plans,
Hart has done, yields misleading results.
Hart did not properly account for peak andMr.
off -peak pricecallingperiods,thereby inflating the
differentials between wireless and wireline services.Mr.
has residentialcalculatedestimatesHart
evening/night/weekend usage of 15%9% ,7% and 8% for flat
residential,andmeasuredresidential,businessflat
measured thesebusinessrespectively,and applied
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percentages each carrier his comparisons.These
estimates are incorrect.As shown in my Exhibit 21, based
Subscriber2002
values are 43%,
calculated by Mr.
chargeable wireless
Line (SLUS)Study data,theseUsage
29% ,36% and 18%.The use of the factors
Hart attributes greater quantity of
minutes the peak period and
overstates the charges the wireless customers will pay.
Mr.Hart
with moreone
value compared
fact,as I discuss later in this testimony,the majority
Qwest wireline
feature,willand
ignores that most wireless plans come
custom features theirwhichadds
with featureless wireline service.
customers subscribe oneleast
find val ue wireless plans that
incorporate such features.
Mr.Hart did not intoadd taxes and fees
his price comparison calculations when,wirelinein fact,
customers pay more taxes and fees than wireless customers
shown
directly the
wireless bills.
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Exhibit These charges contribute20.
net difference andbetweenwireline
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YOU MENTION THAT MR. HART USED STATIC BLOCKS OF
USAGE IN EXHIBIT 101.PLEASE EXPLAIN WHAT YOU MEAN AND
WHY THAT IS A PROBLEM.
Mr. Hart used static blocks of usage,such as
minutes,etc.as his basis for100 minutes 300 minutes
comparing thethevariousofferings.Unfortunately,
wireless are notcarrierscall ing plans structured
such usage allowances vary widelyrigid way,and the
from carrier to carrier.a 250 minute planFor example,
offered usageby Nextel will fit rigidnotMr.Hart' s
structure.Rather, a customer using 250 local minutes per
month will a planshoparoundforthecarrier offering
that better fits those usage characteristics.
WHAT IS YOUR SECOND CONCERN?
Mr.Hart's analysis overestimates the amount of
peak" usage (typically, wireless carriers define the peak
calling period as between 7:00 a.m. and 9:00 p.m., Monday
through Friday)thethat wireless carriers count against
amount of local usage included in the basic monthly rate
a particular plan.stated above,this has the
effect Hart's analysis of driving an artificiallyin Mr.
high level usagechargeable into his comparison of
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wireless causesandwirelineplans,which the wireless
higher comparison.the Whenrateappear
appropriate shown in myoff-peak allocation is used,
Exhibits areandlower-priced wireless plans21,
sufficient to cover the "chargeable " wireless usage.
ARE THE MINUTES - OF - USE THRESHOLDS SHOWN
101 AVERAGEEXHIBITREFLECTIVETHEUSAGELEVELS
QWEST WIRELINE CUSTOMERS?
Qwest flat-rated customers do not typicallyNo.
have zero usage,nor do they typically have 3,000 minutes
of monthly local usage.In fact as shown on Exhibi t 21
fewer customersthanresidential with flat-rated
service in Idaho have 3,000 or more minutes of local usage
per month, even after usage volumes are doubled to account
for inbound and outbound calling.Mr. Hart's use of these
assumptions is based on extremes .in his analysis
Exhibit 21,I have displayed actual Idaho residential and
business For the pricingcalldistributionfor2002.
comparisons shown in my Exhibit 20,I have generally used
call usagevolumelevelslowandhighaverage
thresholds follows:low usage the level which
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approximately 20%Idaho call volume below
average usage the level which approximately 50%
Idaho call volume below and high usage the
point which about 80%call volume below.
These thresholds accurately reflect actual calling
patterns of typical Idaho customers.
DOES MR.HART'ANALYSIS HIS EXHIBIT 101
CONSIDER THAT WIRELESS CALLING PLANS TYPICALLY INCLUDE A
RANGE CALLING FEATURES AND INCORPORATE LONG DISTANCE
CALLING INTO THE BASIC PACKAGE PRICES?
Not that can determine.However these
elements must considered such analysis,
consumers will certainly consider them as they assess the
value proposition of wireless service offerings relati ve
the val ue they percei ve their Qwe s t wireline
service.
DOES MR.HART BACK OUT DATA USAGE WHEN
CALCULATING AVERAGE WIRELINE USAGE TOTALS?
14 Qwest provided local usage data to Staff in response to discovery,
which shows that these usage levels adopted by Staff are on the
extremes of the usage curve.
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He does not.And this more than anything skews
his flatcalculationsandconclusions,particularly for
residence and flat business services.Since section 62-
622(3)Qwe s trequiresonlythat demonstrate that
competi ti vely localpricedal ternati ves exist for basic
exchange notservice(i.e.voice service) ,
appropriate to include other network usage such as dial-
access to the Internet in a price comparison analysis.
discussed Dr.Lincoln his rebuttal
testimony,Centerthe for Communication PolicyUCLA
recently published indicating thatreport 2002
Internet users spent an average of 11.1 hours online per
week.This compares to 9.8 hours in 2001 and 9.4 hours in
The study also found that the more experience users2000.
have with the Internet, the more time they spend on line.
Hart asserted,As Mr.over 50% of Idahoans have Internet
and between average flatand 2 0 02 ,1996 Qwest' saccess
residential call hold time increased by over 100%.These
trends ever- increasingclearlybeingdrivenare
level of network usage by Internet users.Mr. Hart should
have backed out minutes of usage associated with data in
his price comparison calculations.so,theHad he done
15 The UCLA Internet Report, Surveying the Digi tal Future, February2003.
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differentials he calculates between the price of wireless
and wireline services would be significantly reduced.
YOU ALSO MENTIONED ABOVE THAT MR. HART FAILED TO
INCLUDE TAXES AND FEES INTO HIS COST CALCULATIONS.WHY
DOES THAT MATTER?
While both wireless and wireline customers are
assessed a Federal excise tax of 3%a Federal Universal
Service Fund effective April 1(USF)surcharge of 2.59%
2003) and an Idaho Telephone Assistance Plan fee of $0.
there are a number of other fees and taxes applicable only
to wireline service.A fair comparison of end user cost
woul d consider and fees well.taxes For example
wireline Customer Access Lineassessedcustomersare
Charge 911 fee and a Federal(CALC) ,a state USF fee,
number Hartportabilityfee.ignored these addedMr.
charges that increase the price wireline service
compared with wireless alternatives.
HAVE YOU UNDERTAKEN AN ANALYSIS SIMILAR TO THE
ONE DISPLAYED IN MR. HART'S EXHIBIT 101?
ExhibitYes.No.thesummary
relative pricing differences between Qwest residential and
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business basic local exchange service as compared to the
calling plans available I usedin the seven exchanges.
the same wireless carriers used by Mr. Hart in his Exhibit
Exhibit 19 is structured in a format similar to Mr.101.
Exhibit easefor comparison.For thisHart' s 101
analysis,I have corrected the deficiencies I observed in
exhibi t .eachThebackupspreadsheetsforMr.Hart'
wireless carrier Exhibitattachedare
testimony.Exhibit 21 to my testimony provides for each
class flat-ratedservice(measured residence;
residence;a callmeasured business;flat -rated business)
rate distribution, which I used to determine the threshold
for low average and high usage users of wireline basic
local exchange service.
PEAK/ OFF - PEAK PROBLEMHOW DID YOU CORRECT THE
IDENTIFIED ABOVE?
Exhibi t 20,backed out off peak"usage
from the analysis for any carriers offering free
evening, night and/or weekend calling in their plans,such
Verizon Local Digi tal Choice plans.did this
because off peak minutes of use are not counted against
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the usage allotment I will explain howin those plans.
those calculations are shown in Exhibits 19, 20 and 21.
Generally, I approximated that the threshold for "low
the Qwestdemarcationthelowestusage20%
the threshold for thecustomers,50%average usage
mark customersfor and the threshold for highQwe s t
the customers.Using and80% mark for Qwestusage
doubl ing SLUS (whichdata only originatingQwest'
data) ,discussed below found the followingusage
average uses per class of service:
(0 minutesmeasured business for low usage,
minutes for average usage, 152 minutes for high usage) ;
flat-rated business for low usage,(28 minutes
292 for average usage, 1 023 minutes for high usage);
measured residence (0 minutes for low usage,
minutes for average usage, 296 minutes for high usage) ,
flat -rated residence 798 for(168 for low usage,
average usage, 1, 638 high usage) .
having lowdeterminedOncethethresholdsfor
average and high usage for each class of service, I looked
carefully mannereachcarriers countingvery
minutes.For those carriers that offer off -peak minutes,
16 These thresholds and average usages can be seen on Exhibit 21.
They appear in cells that are set off in boxes.
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I then backed out off -peak minutes since customers are not
charged because Nextel'for them.Thus for instance
National Free plans not charge for incomlng calls,the
relevant threshold for the high usage,flat-rated
residential service customer only 819 minutes per
month,minutes.not 638 then identified the
appropriate usage level for each threshold (with off-peak
minutes backed out)the line (entitledtop Qwest
(Minutes) "in carrier andLevelUsagefor each carrier
each theclassserviceExhibitBased20.
appropriate peak-time average usage figures found on that
line thein Exhibi ttop found (for each carrier)20,
cost -appropriate theplanofferingmostandcalculated
that wireless plancost compared to the cost
Qwest's wireline service.
HOW DID YOU BACK OUT DATA USAGE?
calculating the for flataverageusage
business and flat residence service,I used 2002 SLUS call
distribution bestdataandcallholdtimes1996
represent usage of Qwest' s local switched network for non-
data traffic.I did this because hold times17 were fairly
17 "Hold time " means average duration of a switched telephone call.
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consistent 1996,until after which they dramatically
increased.This increase can reasonably be attributed to
growth in dial-up Internet usage,i . e., telecommunications
network usage statutory definition ofoutsidetheIdaho
basic local exchange service.
20?
DID YOU ALSO ADD TAXES AND USAGE FEES TO EXHIBIT
In Exhibit 20,Yes.I have shown all fees and
taxes that are assessed to both types of services.I note
that wireline customers are assessed more taxes and fees
than are wireless customers in Idaho.
IN YOUR EXHIBIT 19, YOU HAVE DISPLAYED THE QWEST
WIRELINE NET RATE WITH AND WITHOUT AVERAGE FEATURE REVENUE
PER LINE.WOULD YOU EXPLAIN?
Yes.As indicated in the footnotes in Exhibit
for each the wireless carriers,the majority
wireless call ing pI ans include package popul ar
features,such call waiting,Caller ID,call
forwarding,etc.inherent,price-included component
of the plan.To the extent Qwest wireline customers use
these features they will be attracted to wireless plans
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that them.incl ude the developedanalyses
Exhibit for use the compar i sons on Exhibit
show average residential and business feature revenue per
line as an additive to the Qwest wireline rate (incl uding
fees residentialand taxes)to approximate that net bill
and business customers pay each month.
IN VIEW OF YOUR PRICING COMPARISON ASSESSMENT,
WHAT CONCLUSIONS CAN BE DRAWN?
Exhibit 19 summarizes the pricing differentials
for each carrier shown in my Exhibit 20 and Mr. Hart' s
Exhibit 101, and shows the net difference between the
wireless and Qwest wireline rates , with and without
f ea t ure revenue. Exhibit 19 demonstrates that for every
category of service and for every usage group there are
mul tiple wireless providers that offer services priced
below, or not significantly above , Qwest' s wireline price.
Furthermore, it must be emphasized that these
differentials do not include a comparison of toll
Many wireless plans include toll callingrevenues.
18 The majority of Qwest residential and business customers in Southern
Idaho subscribe to at least one feature.19 The positive numbers represent the wireless plans that are priced
higher than comparable Qwest wireline service, and the negative
numbers represent wireless plans that are priced below comparable
Qwest wireline rates.
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without incremental charge for calls that would be
assessed toll rates if those same calls were made by a
Qwest wireline customer.If toll calling were included in
this assessment, the net rate differential between Qwest
wireline service and many wireless plans would be reduced
further.
It must also be emphasized that these differentials
do not place any monetary value on the mobility of
wireless service, an attribute that many customers would
consider when comparing the relative value of wireless and
wireline services.
Thus, when proper assumptions are used in making the
comparisons,priceclearthattherelati ve
differentials thebetweenthewirelesscalling plans
various carriers and Qwest wireline basic local exchange
services is not only not as dramatic as portrayed in Mr.
exhibi t ,actually demonstrates wireless pricesHart' s
highly competitive.fact,Exhibi t showsare
number of wireless plans are actually priced lowerthat
than rates.Thecomparablewirel ineQwest'
competitiveness of wireless pricing becomes more apparent
when it remembered that wireless offers mobility and plans
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typically rangeincludes val ue - added features,
well some instances,long distance (incalling
distance calling)call ing includes interstate
incremental usage
As customers make the
charge other than the
minutes in the particular plan.
wireline servlcewireless choice,all
elements are considered.
WAS EXHIBIT NO.YOUR DIRECT
long
with
available
these
TESTIMONY
DESIGNED TO DISPLAY EVERY WIRELESS PLAN IN THE MARKET?
Exhibit No.13 reflects service attributesNo.
representati ve plans offered each the eight
wireless carriers addressed in my direct testimony.The
exhibit simply represented snapshot the
market in Idaho as of November 2002.It was not intended
wireless
to represent all possible permutations of service to which
indi vidual ra ther ,customers may subscribe,but to be
point of reference in examining the similarities between
landline wirelessandcompet it i veQwest
alternatives.containsExhibi tHowever,
listing everyeachand plan offeredcurrent
service
full and
the
unregulated wireless carriers addressed in this docket.
note that to frequentthese plans are subj ect
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change as
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the wireless carriers reposition their services
optimize market areshare,and a number of these plans
offered on a promotional basis.is noteworthy that
there a wide variety of wireless plans available
southern customer uniqueIdahotailoredindi vidual
calling patterns.
Since the time Exhibit 13 was prepared,several new
plans have been made available to Idaho customers.Most
notably,LocalWirelesshasintroducedAT&T its mLife
Plan - Next Generation" which provides customers with 350
anytime minutes addition unlimited night and
weekend minutes - all for $29.99 per month.This is just
one example of how the wireless market is rapidly evolving
consumer demand for affordable callingresponse
plans,attractivemakingthetechnology an increasingly
al ternati ve to wireline service.
ADDITION DR.LINCOLN'SURVEY AND THE
INSIGHT AND HERITAGE FOUNDATION RESEARCH REFERENCED ABOVE,
IS THERE OTHER RECENT EVIDENCE SHOWING THAT CONSUMERS FIND
WIRELESS SERVICE TO BE A COMPETITIVELY PRICED ALTERNATIVE
TO TRADITIONAL WIRELINE SERVICE?
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MarchYes.article17,2003
electricnews. net, new research conducted CIT-
PriMetrica wasand cited indi ca t ing thatErnstYoung
nearly 50 percent of U S households would be prepared to
switch from a wireline service to a family share wireless
option with pershared base minutes600 offered at $50
month. ,,wireless phones usedWith a family share plan,
samevariousfamilymembersablesharetheare
bucket" of minutes in the plan s usage allowance.In the
example cited above,a family with three wireless phones
shared plan would not charged per minute usageon a
fees so long as the combined monthly usage of the three
phones is 600 minutes or less.
10,AT PAGE LINES MR.HART COMPARES A
MEDIAN USAGE"QWEST FLAT-RATED RESIDENTIAL CUSTOMER
AT&T'LOCAL 1400"PLAN,AND CALCULATES SIGNIFICANT
PRICE DIFFERENCE BETWEEN THE PRICES THESE TWO
ALTERNATIVE SERVICES.DOES THIS COMPARISON CONCERN YOU?
Yes.Mr. Hart could have elected to compare the
price median flat -rated residentialusageQwest
20 www. theregister. co. uk/ content/ 68/29779. html.21 Comparable plans are now available to Idaho consumers from AT&T
Wireless, Edge Wireless, Nextel, T-Mobile, and Verizon wireless.
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customer to Cricket's unlimited usage plan in Idaho, which
would have yielded a significantly different conclusion
showing approximately $10,that the price difference
not $91.49 shown by Mr. Hart.The selection of services
for his notpricecomparison representati ve the
wireless plans that best fit customers calling patterns.
A more relevant comparison is contained in my Exhibit Nos.
19 and 2 0 .
13,PAGE 9 -10,LINES STAFF WITNESS HART
MAINTAINS THAT WIRELESS PLANS THAT INCLUDE LONG DISTANCE
USAGE MAKE WIRELESS SERVICE MORE EXPENSIVE AND THUS NOT A
VIABLE ALTERNATIVE QWEST' BASIC LOCAL EXCHANGE
SERVICE.DO YOU AGREE?
Industry proves otherwise.researchNo.
Indeed,the research firm International Data Corporation
IDC" )2002 study of wirelessproj ected in an October
displacement wireline access lines that arge
increments evening and weekend calling minutes with
bundl ed long distance usage will make wireless more
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attractive 2002-2003 timeframethanwirelinethe
thereby increasing the displacement rate.
Taher analyst with communicationsBouzayen,
consul ting,firm Atlantic-ACMandresearchstrategy,
maintains that an obvious reason for wireless displacement
is the flat-rate packages wireless companies are offering
for all calls Because wirelesslocal and long distance.
long any pricedistanceminutesdonhavenow
specifically,youwhen have free nights and weekends,
lowering your per-minute Bouzayenyoucosts, "Mr.
quoted as saying in the October 2002 issue of Wireless
This consistent with findingsDatatheNews.
INSIGHT Research Corporation falling(quoted above)that
prices areandincl usionthe long distance services
prompt ing theirsubscriberswirelessphone suse
primary phones.This research demonstrates that wireless
packages arethatincl ude long distance component
driving wireless displacement in a significant way.
102EXHIBIT ATTACHED MR.HART'TESTIMONY
PURPORTS TO DEMONSTRATE THAT WIRELESS RATES THAT INCLUDE
22 International Data Corporation, Scott Ellison , IDC Study #29018,
Wireless Displacement of Wireline Access Lines Forecast and Analysis,
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TOLL EXCEED QWEST'S RESIDENTIAL AND BUSINESS RATES IN MOST
CASES.WHAT COMMENTS DO YOU HAVE IN REGARD TO EXHIBIT
102?
overlooksMr.that long distanceHart
typically free wi thin the wireless home area (for example,
Edge Wireless home coverage area is throughout
Idaho Qwest' s wirelineandcallsmademany
southern
network
would be billed as toll calls in southern Idaho, while no
toll charges are assessed for Edge Wireless calls within
that manyarea) .addition,wireless plans
intrastate callingandinterstatelongdistance
bucket" of monthly wireless minutes offered.
include
the
Exhibit 102
implies that all long distance minutes are chargeable, and
that shown on Exhibi tthewirelesstollvalues
addi ti ves rates reflectedthewirelesspackage
Exhibit 101.This is simply inaccurate.
addi tion,assumes thatExhibi t 102
residential uses intraLATA minuteswirelinecustomer
and perinterstateminutes month and the
wireline uses 117 intraLATAbusinesscustomer
interstate usageminutesmonth.Theseper
102 are
the average
average
and 151
statistics
2002-2006, page 13, October , 2002.
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according to Mr. Hart's explanation on Exhibit 102were
derived from the FCC's May 22 2002 Trends in Telephone
and fromUsage submission thereportQwest' s
Administrator FundtheIdahouni versal Service
( "
IUSF"
) .
Because the data in the FCC report is national
ln scope,Mr. Hart used Idaho-specific data from the IUSF
report to arrive at a comparison between Qwest Idaho rates
and various wireless carrier rates, assuming the IUSF data
accurately usagereflectsthe level swi tched voice
telephone traffic in Idaho.
There are several flaws in Mr.Hart's methodology,
howeve r .Hart indicates he used TableFor example,Mr.
2 from the FCC's report in his calculations,as well as
Table 11. 2.102Hart explains on page 1 of ExhibitMr.
that used Table split the total number
intrastate minutes from the IUSF report into residential
and business customer classes.It is unclear how he was
able reportthissinceTabletheFCC'
provides averagethe monthly household expendi tures for
local It does notexchangeand long distance carriers.
expendi tures businessbetweenresidenceseparateand
Qwest Productioncustomers.respondingLater
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Request No., Mr. Hart indicated he used Tables 10.3 and
11.2 of the FCC Report.Table 10.3 provides national toll
revenue data split between residential and non-residential
categories.Nevertheless , use of this data by Mr. Hart is
problematic,that the shown Table 10.revenue
intrastate,domestic interstate,represents and
international revenue.toll addition the data
quite dated (Year 2000)
Furthermore,proper allocation minutes between
categories shown on Table 11.2 has become so controversial
that the has ordered interimFCC freeze Part
category relationships and allocation factors in order to
study the matter. the utility of the data isTherefore,
questionable and the FCC has ceased requiring carriers to
produce new data for a five year period.
Finally,use the FCC'report Mr.Hart' s
analysis recentignores deve 1 opmen t s the wireless
market,since the data in the FCC report is almost 3 years
old.wi thin the past three years, the wireless market has
exploded.reportsexample,For that in-buildingIDC
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wireless usage soared to 66% of all residential users and
40% of all business users as of January 2002 up from 36%
and 2000.26% ,respectively,According
Bureau Statistical Abstract the United StatesCensus
nearly million people the Uni t ed110 usedStates
cellular telephone in 2000.2003 theAs of March 26
number of States hadwirelesssubscribersin the United
jumped million.penetrationalmostWireless144
reached over 50% in 2002 , up from 40% in 2000, and average
minutes of use by wireless users increased by 50% in the
last years.currentdoesreflecttwoBecausenot
market manyconditionsanddoesacknow 1 edge thatnot
wireless plans include toll calling,Hart' s analysisMr.
in Exhibit 102 is seriously flawed.
MR.HART ALLEGES THAT WIRELESS CUSTOMERS MAY
INCUR UNEXPECTED ROAMING AND/OR LONG DISTANCE CHARGES EVEN
THOUGH THEY ARE LOCATED IN THEIR HOME AREA EVEN
23 FCC Report and Order, CC Docket No.8 0 - 2 86 In the Ma t ter
Jurisdictional Separations and Referral to the Federal-State Joint
Board, May 22 , 2001.24 International Data Corporation , IDC Study #28707, Top 10 U. S.
Wireless Services Issues in 2003, pages 7-8, January 2003.25 ISP-Planet, The Broadband and Wireless Revolution by Michael
Pastore, January 30, 2002.
26 http://www.wow-com.com , visited March 26, 2003.27 International Data Corporation, IDC Study #28355, Wireless Users Who
Displace Wireline Access Lines: A Survey Study and Analysis, November2002.
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(PAGE 15,IS THIS A PERTINENTTHEIR HOME.LINES 7-16)
ISSUE?
No.In response to Qwest Interrogatory 2 -10,
Mr. Hart cited an article from USA Today as the source for
his information on this topic.Pertaining to unexpected
roaming wirelesschargesthearticleindicatesthat
carriers have addressed this matter by introducing plans
that don ' t charge for roaming in specified areas.Thus,
there is a solution available for consumers concerned with
the possibility of unexpected charges due to roaming.
DOES THE FACT THAT WIRELESS CUSTOMERS MUST PAY
TO HAVE A LISTING PUBLISHED IN THE DIRECTORY MEAN THAT
WIRELESS NOT COMPETITIVELY PRICED ALTERNATIVE FOR
CONSUMERS,AS MR.HART MAINTAINS ON PAGE 15,LINE
PAGE 16, LINE 3?
While wirelessNo.customers whotrue
desire have listing the directory must pay
listings charge the same can said for wireline
carriers who not wish have their listings published
customersthedirectory.Wireline concerned abou t
pri vacy chargepay a non-published or non-listedmust
that wireless In this age wherecustomers do not pay.
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pri vacy concerns is noteworthy that nearlyare high,
one quarter of Qwest residential wireline customers pay to
have thetheir telephone number unlisted.The fact
customersthat serviceboth types havematter
options terms listings.Such options support
Qwest' s contentions that wireless and wireline services
are competitively priced and functionally equivalent.
Finally, the fact that a directory listing is not free has
apparently not hindered wireless subscribership,as there
are now approximately 577,000 wireless units in service in
Idaho,Thisas stated in Mr.Souba s rebuttal testimony.
issue another example barriersStaff'false
competition.
IV. TESTIMONY OF BEN JOHNSON
Functional Equivalence
DR.JOHNSON MAINTAINS THAT FOR TWO SERVICES TO
FUNCTIONALLY EQUIVALENT ,THEY NEED VIRTUALL Y
(JOHNSON, PAGE 9, LINES 16 -17)DO YOU AGREE?IDENTICAL.
with Dr.JohnsonNo,not agree
interpretation of the statutoryfunctionally equivalent"
requirement.discussed above,nei ther does Staff'
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other witness in this proceeding,Dr.JohnsonMr.Hart.
has stretched the definition of "functionally equivalent"
to an extreme.
WOULD YOU REITERATE THE STATUTORY REQUIREMENTS
FOR ECONOMIC DEREGULATION OF QWEST'S BASIC LOCAL EXCHANGE
SERVICES IN IDAHO?
Idaho Code ~62-622 (3)Yes.requires the
applicant compet it iondemonstratethateffecti ve
exists by showing that either a) actual competition from a
facili ties-based presentcompetitor for both
residential exchangeandsmallbusinessbasiclocal
aretherecustomers functionally equivalent,
competi ti vely priced local reasonably availableservices
to both residential f rom aand small business customers
telephone incumbentcorporationunaf f ilia ted with the
telephone corporation.
IN YOUR DIRECT TESTIMONY, YOU STATED THAT IDAHO
LAW DOES NOT REQUIRE THAT COMPETITIVE ALTERNATIVES HAVE
PRECISELY THE SAME ATTRIBUTES QWEST' LANDLINE
RESIDENTIAL AND SMALL BUSINESS SERVICES.DID MR.HART
CONCUR IN THE TESTIMONY HE FILED IN THIS PROCEEDING?
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as explained earlier in my testimony,Yes,Mr.
Hart, on page 5, lines 1 - 16 of his testimony, stated:
...
the very idea of subparagraph (b) (( Idaho Code
~ 62-622 (3))is to make a comparison of twoservices that are not identical. Thelegislature apparently contemplated that
services that are not technically the same as
those provided by a facilities based competitor
nonetheless could be enough like it that itmight serve as a reasonable substitute Theterm used in the statute is "functionally
equivalent. " In comparing the differentfunctions of two different services, although
it is important to review their similarities to
determine if one is a substitute for the otherit is also necessary to compare their
differences. It seems to me a comparison todetermine whether two different services arefunctionally equivalent" would be incompleteand seriously flawed if all that was comparedwas there identical functions and uses. "
(underline added)
Therefore it appears that not only is Dr. Johnson
position in conflict with Qwest' s interpretation but
is contradictory to the interpretation of the Commission
Staff appears to be one offor whom he consul t s .This
many examples of Dr. Johnson taking an extreme position in
persuade the Commissionattempt that Qwest' s
application ul tra- stringentinadequate.This
definition manyfunctionallyequivalent"one
positions that,woul d makeif accepted by the Commission,
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it virtually impossible for any incumbent to ever achieve
price deregulation under section 62-622 (3) (b) .
COURT FEDERALANYSTATEAREYOUAWARE
DECISIONS THAT FOUND WIRELESS OR WIRELESS-TYPE SERVICES TO
BE FUNCTIONALLY EQUIVALENT WITH WIRELINE SERVICES?
In December 1983,the Appellate Court ofYes.
Illinois ruled that two-way radio communication services
fell wi thin jurisdiction thethesubj ect-matter
Illinois Commerce Commission.The court found:
However we believe that two-way radio
communication services do fall within the
subj ect matter jurisdiction of the Commission,this type of activity being functionally
equivalent to telephonic communication.
radio paging service,predecessor to todayHence,
wireless service,was recogni zed as far back as 1983
being traditional wirelinefunctionallyequi valent
services.Advancements in technology make this even more
true today than it was at that time.Dr. Johnson s narrow
definition of - a definition hefunctionally equivalent"
has not shown as having been adopted or utilized by any
28 Houser Communications, Inc., Plaintiff -Appellant, v. Illinois
Commerce Commission et al., Defendents - Appellees, No. 82 - 811
Appellate Court of Illinois, Third District, December 8, 1983, Filed.
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court or commission , and a definition which is in conflict
with Hartthathisco-wi tness,shouldMr.
disregarded.
In addition,week the FCC granted Qwestonlylast
(New Mexico)271 authority based in part(Nevada)and SBC
the f rom aexistencecompetition single wireless
carrier (Leap Wireless) .As Mr. Shooshan discusses in his
rebuttal testimony,the FCC found at paragraphs 18-31 of
Qwest's New Mexico order that wireless servlce can be a
commercial Qwestal ternati ve wireline service
notwi thstanding configuration,differentthe technical
service wirelesscharacteristicsandservicecharges
and wireline services.
17,ON PAGE 12 -LINES OF HIS TESTIMONY ,DR.
JOHNSON MAINTAINS THAT MOST CONSUMERS RESTRICT USE
WIRELESS SERVICE TO CALLS MADE IN THE CAR.DOES RESEARCH
SUPPORT HIS POSITION?
As I indicated earlier in my testimony, in-No.
building wireless usage soared to 66% of all residential
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users and 40% of all business users as of January 2002.
Johnson is,perception the wireless marketDr.
frankly, out of date.According to IDC, wireless became a
standard purposeformcommunicationsforalmostany
rather than premi um mobility product used
primarily in the absence of convenient wireline service in
the 1990s.average wirelesslatealsofoundthatIDC
households reported fewer than half of all their wireless
calls are conducted in the car. 31
Keith Mallinson for the Boston-a wireless analyst
based Yankee Group,recently commented on the evolution in
the wireless market:There s a change in mind-set,
said:" Land line relates to place,wireless relates
people. ,,This reinforced Jeff Kagan,was
independent telecommunications analyst recent New
York Times article:behavioral shift from theIt'
last hundred years in which we called a geographical place
and got a person.re now moving to a model of calling
29 International Data Corporation, IDC Study #28707 Top 10 U. S.
Wireless Services Issues in 2003, pages 7-8, January 2003.30 International Data Corporation , IDC Study #28355, Wireless Users Who
Displace Wireline Access Lines: A Survey Study and Analysis, November
2002.31 International Data Corporation, IDC Study #26994 Soaring Wireline
Displacement and Highest Interest in Location-Based Services: U.
Wireless Household Survey Results, 2002, May 2002.
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a person - regardless of geography.The consequences of
such a change could be profound. ,,
the Dr.contentions throughoutpepperedHence,
Johnson limited,testimony that wireless
complementary technology are directly contrary to current
market evidence and are not supported in his testimony by
any verifiable sources.
DR.PAGES THROUGH HIS TESTIMONY ,
JOHNSON CHARACTER I ZES SERVICESWIRELESSANDWIRELINE
COMPLEMENTARY"AND ONLY SUBSTITUTABLE LIMITED
DEGREE. PLEASE COMMENT.
I don ' t believe it was the intent of the Idaho
legislation that occur in someactualsubstitution must
significant the market before a service may beshare of
price deregulated.Ra ther ,state legislators allowed for
a service to be deregulated once a functionally equivalent
or substitutable service could be used as a replacement.
Johnson right this point,the legislatureWereDr.
would reasonhavehad CodeIdaho 62 -enact
32 Rocky Mountain News, Look Ma, No Wires!; More Consumers Replacing
Home Lines with Mobile Phones, November 14, 2002.
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622 (3) (b) .Uni ted International publishedPress
article recently that characterized wireless service this
way:
Once a purely supplementary telephone service -
too expensive to use regularly - the price ofwireless phone service, combined with its
functionality, is making it a prime substitute
for old-fashioned wireline service.
survey of rural reinforcesA recent thatcustomers
wireless increasingly being used substi tute for
wireline service,in rural Western Wats,even areas.
Utah Westernresearchfirm,surveyed 1000 customers
Wireless eightCorporation in areas with a population of
people perless mile.Fifty-one thepercent
wireless users surveyed indicated their wireless phone has
least Twenty-partially replaced land line phones.
three percent is their primarysaid their wireless phone
phone,percentandfifteen those surveyed said they
plan to replace their wireline phone with a wireless phone
at some point in the future. This data demonstrates that
landline replacement occurring much thanmore
limited" basis, as Dr. Johnson suggests.
33 The New York Times, When the Cellphone Is the Home Phone, August 29,2002.34 United Press International Think tanks wrap-up, January 31 , 2003.
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21 OF HIS TESTIMONY,DR.ON PAGE 23,LINES
JOHNSON TAKES ISSUE WITH THE LIST OF ATTRIBUTES YOU SET
ITEMS THEFORTH IN YOUR DIRECT TESTIMONY AS BEING THE
DETERMINING WHETHERCOMMISSIONCONSIDERSHOULDWHEN
WIRELESS SERVICES ARE FUNCTIONALLYANDWIRELINE
EQUIVALENT .WHAT IS YOUR REACTION TO THIS PART OF DR.
JOHNSON'S TESTIMONY?
Johnson attempts to inappropriately broadenDr.
the scope of issues the Commission is to consider when
evaluating Qwest' s price deregulation application.Rather
than focusing on the core service,i . e., two-way switched
local voice communication , Dr. Johnson expands into areas
such as Internet access,andthe ability to send faxes,
wireless extensions - all of which are irrelevant to the
statutory standard that is the subj ect of this proceeding.
CAN YOU DRAW ANY PARALLELS BETWEEN THE
UNIVERSAL SERVICES"REFERENCED THE COMMISSION
CONCERNING CLEAR TALK'ELIGIBLE TELECOMMUNICATIONS
ETC" )APPLICATION AND THE SERVICES AT ISSUE INCARRIER
THIS DOCKET?
35 http://www.sltrib.com, visited April 7 , 2003.
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considering ETCClearTalk'Yes.
application,the Commission referred Order No.27715
issued No.GNR-T- 98 - 7,which1998Case
designated nine telecommunications services as uni versal
services mustthat provided thoseofferedand
carriers eligiblewhowisheddesignated
telecommunications for potentialcarrierseligibleand
Universal Service Fund support.The nine services are:
voice grade access to the public switched
network
Local usageDual tone multi-frequency signaling or its
functional equivalentSingle-party service or its functional
equi valent
Access to emergency services where available
Access to operator services
Access to interexchange service
Access to directory assistance
Toll Limitation
Only one of the myriad of issues Dr.Johnson would
have the Commission consider in the immediate proceeding
considered identifiedrelevantwhentheCommissionwas
uni versal accessservicecomponents:emergency
services.That capability,available withhowever
wireless service, as explained previously in my testimony.
Access to the Internet and faxing capability do not appear
on the universal service list; nor do ergonomics or sound
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quality.
sharing
members,
The Commission did not include extension phones,
single telephone line multiple family
listings,or number porting in the definition of
uni versal In identifying the services carriersservice.
must provide Dr.in order to gain ETC status,Johnson
lssues were not addressed.That fact speaks for itself.
DID THE COMMISSION,27715,IN ORDER NO.DEFINE
EACH "UNIVERSAL SERVICE"
example accessvoiceYes.gradeFor
defined as:
as:
functionality that enables a user
telecommunications services to transmit voice
communications, including signaling the network
that the caller wishes to place a call , and toreceive voice communications, incl uding
receiving a signal indicating there is
incoming call. (page 1)
The Commission defined "access to emergency services
universal service does not include provision ofthe underlying services themselves, whichcombine telecommunications service and the
operation of the Public Service Access Point
("PSAP"and, in the case of E911 service, acentralized database containing information
identifying approximate end user locations.
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Access to
to 911 and
governmentarea has
systems.
emergency services" includes access
enhanced 911 to the extent the localin an eligible carrier I s serviceimplemented 911 or enhanced 911
(page 2)
Access to interexchange service " is defined as:
the use of the loop, as well as that portion of
the switch that is paid for by the end user, orthe functional equivalent of these network
elements in the case of a wireless carrier,
necessary to access an interexchange carrier
network II . (page 2)
The Commission has thus defined basic local exchange
service contextthe uni versal service.That
definition the immediateprovideguidancecan
proceeding.The wireless service providers operating in
the seven exchanges provide the capabilities listed by the
Commission comprising uni versal service.cannot
imagine how carrier could the standard formeet
designation as an ETC,and yet be deemed not to provide
basic local exchange service defined Idaho
statute.
23,ON PAGE 15-21 OF HIS TESTIMONY,LINES DR.
JOHNSON RECOMMENDS THAT,ABSENT INDIVIDUAL CUSTOMER AND,
EVEN INDIVIDUAL CALL ANAL YSES, DETERMINATION OF WHETHER
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TWO SERVICES ARE FUNCTIONALLY EQUIVALENT CANNOT BE MADE.
IS THIS REASONABLE?
Dr.Johnson recommendationnot.
woul d tensresul t this Commission reviewing
thousands of individual customer records,not to mention
potentially hundreds of thousands of call records.I am
not aware of any other commission finding it necessary or
reasonable such extremely granularrequlre
submi t that woul dassessment.Moreover,
inappropriate and a waste of all parties ' resources to do
so.
DR. JOHNSON DISCUSSES THE MOBILITY ADVANTAGE OF
WIRELESS SERVICE ON PAGE 24 OF HIS TESTIMONY AND CONCLUDES
THAT BECAUSE OF THE MOBILITY FACTOR,WIRELINE SERVICES
ARE NOT FUNCTIONALL Y EQUIVALENT WIRELESS SERVICES.
PLEASE COMMENT ON HIS OBSERVATIONS.
Dr. Johnson seems to have turned the statute on
its head.The requirement is not that Qwest demonstrate
that arewirelineservices functionally equi valent
wireless services;Qwest mustit is the exact opposite.
provide evidence that wireless services are functionally
equivalent to wireline services.The fact that wireless
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service communicate while driving aroundcan be used to
frosting the cake,but the cake thattown
wireline and wireless services are functionally equivalent
al ternati ves voicefororiginatingandrecei ving local
telephone calls from a fixed location.
DR. JOHNSON THEN PROCEEDS, ON PAGES 25-28 OF HIS
TESTIMONY, TO DISCUSS TEN ATTRIBUTES OF WIRELINE SERVICES.
DO YOU AGREE WITH HIS LIST?
As with issues raised by Mr. Hart , many ofNo.
the attributes discussed by Dr.Johnson extend beyond the
definition of Thetwo-way switched voice communication.
ergonomic differences between wireless phone and
wireline phone cited by Dr. Johnson is another example of
the extraneous issues raised throughout his testimony.
The size,like theshape,and feel of a wireless handset,
ability aresendfaxeswithwirelessphone,
completely irrelevant to the issue of the transmission of
voice signals wi thin a local exchange area,which is the
relevant question of this proceeding.Under Dr. Johnson
impossible -to- satisfy twostandards,different styles
traditional notwirelinehandsetswoul d functionally
equivalent because they feel different inergonomically,
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one hand.at tributesMost of Dr.Johnson s ten "key
should dismissed unrelated the statutory
requirements theforpricederegulationarticulated
Idaho legislature.
DR.JOHNSON,AS WELL AS SOME OF THE WITNESSES
FOR THE INTERVENORS MEIEROTTO,SUGGEST THAT EXTENSION
PHONES ARE NOT AVAILABLE WITH WIRELESS SERVICE AND THUS
THE SERVICE IS NOT FUNCTIONALLY EQUIVALENT WITH QWEST'
(PAGE 25, LINES 16 -23 -WIRELINE LOCAL EXCHANGE SERVICE.
PAGE 26, LINES 1-IS THIS A VALID POINT?
Extension phones, as well as other customerNo.
premises equipment issues, are not relevant to theCPE" )
issue two-waywhetherlocal switched voice
communication should be price deregulated under Idaho Code
62-622 (3) (b) .Qwest'wirelineExtension phones for
service are not regulated by this Commission , are not sold
by Qwest, and are not a complement of basic local exchange
service; hence this issue has no place in this proceeding.
However, even though this is well beyond the scope of
this case,in fact available towireless extensions are
Idaho consumers.For example,"The Wireless Store
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Eagle sells a docking station called a "CellSocket," which
plugs The wireless phone isinto a regular phone jack.
then incominginsertedintotheCellSocket"enabling
calls anythewirelessphoneanswered
extension phone in the house or business.Outgoing call s
also anymade with thisextensionphonemayover
The "CellSocket"is currently available forarrangement.
use with AT&T Nokia 5100 and 6300 series phones,as well
as Cricket 5100 and 6300 series phones.It costs between
$99 - $150, depending upon the type of phone used.Radio
Shack sells similar product called VOX. LINK base
station.Therefore,even extension capability was
valid part the statutory requirement - -which not - -
the contention that this capability doesn exist
erroneous.
YOU HAVE ANY ADDITIONAL COMMENTS MAKE
CONCERNING
LINE?
THE ABILITY OF WIRELESS USERS TO SHARE THE SAME
(page 26,line Dr. Johnson and some ofYes.
the Intervenor wi tnesses allege that wireless service
cannot reasonably be considered functionally equivalent to
wireline thebasiclocalexchangeservicebecause
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inability of individuals to share a single line.Again
issues the capabili ty for multiple shareusers
single line transcend the statutory requirements at issue
in this proceeding.However wireless service thrives in
deregulated technology.market where dri vesdemand
Such is the case here.Companies such as Ascendent are
introducing hardware and software solutions that allow for
the integration of wireless and PBX applications for small
businesses.Ascendent's products allow wireless phones to
become extensions of the office PBX.Ascendent describes
the features provided by its technology as:
Hold/Park - allows a call in progress to be
put on hold, independent of remote device.
This allows the user to recapture the call
from another telephone.
Transfer - allows the transfer of calls from
a cell phone, just as you can from an office
phone.
Multiple Device Ringing wiRing Control -
controls how many rings you want on which
device. Ability to ring up to three devices
(desk phone and two other phones or VOIP)
simultaneously or sequentially cell phone, as
you can from an office phone.Full Scheduling Capabilities Ability schedule which phones ring at differenttimes.
PBX Dial ing - Ascendent provides
phone with a dialtone just likeyour office allowing youextensions and perform other
your desk phone.
your remotethe one into accessfunctions of
36 www.ascendenttelecom.com , visited April 1 , 2003.
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Exhibi t No.25 to this testimony contains material
describing Ascendent's products in more detail.Ascendent
technology is available to Idaho companies.
DR.JOHNSON CONTENDS
NOT FUNCTIONALLY EQUIVALENT
THAT WIRELESS SERVICE
QWEST'BASIC LOCAL
EXCHANGE SERVICE BECAUSE THE INTERNET CANNOT BE ACCESSED
WITH THE SAME RELIABILITY,
(PAGEWIRELESSSERVICES.
COMMENT .
SPEED,EASE"AND THROUGH
26,13-14)PLEASELINES
Just as the issue of Internet access in general
is outside of the scope of
Internet reliability,speed,
this docket,issues such as
and ease of use are beyond
the scope of the issues to be considered by the Commission
in this case.
All oncethatsaid,
Johnson assessment
again issue with Dr.take
the industry.Bell Howe 11
Information and Learning proj ected during a Cato Institute
Seminar summer thatlast
virtually perfect substitute for the wireline connection
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for voice and low-speed data calls. My understanding lS
that the speed of Internet access is currently comparable
dial-technologywirelineandInternetaccess
advances,Internetso will the deployment high speed
access options for wireless users.
The its review ofINSIGHT Research Corporation
the 2003 telecom industry, stated:
The initial availability of data services
increased the attractiveness of wirelessservices. Wireless modems now connect notebook
computers and personal digital assistants
PDAs ) to the network. Smart phones equipped
with voice and data capabilities provide e-mail
connectivity for business travelers and
teenagers alike. Mobile devices with Internet
access have the potential to eventually outpace
wireline devices as the means by which peopleaccess the Internet.
INSIGHT also found that the use of wireless services
for data access is increasing as companies such as Verizon
Wireless,InstantWireless,and Sprint offerAT&T PCS
Messaging,largershort messaging service SMS" )and a
selection of enhanced data services. Indeed mul timedia
37 Bell & Howell Information and Learning, ABI/INFORM , Cato Institute
A somewhat better connection Summer, 2002.38 The INSIGHT Research Corporation, The 2003 Telecom Industry Review:
An Anthology of Market Facts Forecasts January 2003.
39 Id.
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messaging is the latest trend in wireless Internet usage.
Exhibi t No.website26 contains pages from AT&T Wireless
that describe how wireless phone users are able to send
participate in chat rooms,andtext messages,play games,
send demonstrategreet ing cards.These funct ionseven
that wireless service can be used to access the Internet
wi th relative ease and speed.
ON PAGE 27, LINE 1 OF HIS TESTIMONY, DR. JOHNSON
CONTENDS THAT ONLY WIRELINE SERVICE OFFERS THE OPTION OF
TRANSMITTING AND RECEIVING PAPER FAXES.IS HE CORRECT?
again feel obligated beginOnce
response by pointing out functionality is notthatthis
part of basic local exchange service.he isThat said,
Exhibi t No.27 displays just one of severalnot correct.
options for
service.
sending and recei ving via wirelessfaxes
According to one device manufacturer s website,
The possio PM70 Mobile Fax and Phone is aflexible and lightweight mobile device that
allows you to send and receive fax messages on
paper, perform voice calls, and print incoming
SMS.
The Possio PM70 is used every day, all around
the world by business travelers,transportation companies, fire and rescue
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services , and other professionals who requireinformation on paper.
This contradicts Dr.Johnson conj ecture,which is
not substantiated in his testimony by any evidence.
DR.JOHNSON MAINTAINS THAT BECAUSE WIRELESS
SUBSCRIBER MAY OPT NOT TO HAVE HIS OR HER TELEPHONE NUMBER
LISTED IN THE DIRECTORY,MAJOR FUNCTIONAL DIFFERENCE
EXISTS. (PAGE 27, LINES 10-12)DO YOU AGREE?
don for the reasons discussed
previously in my rebuttal of Mr. Hart's testimony.Let me
add that seen news report that indicates wireless
carriers are establishing centralized database
wireless numbers that may available early next
year.
listing
obtain
Customers would obtain wireless telephone number
information from this database,just they
wireline telephone numbers from the wireline
listings database.Regardless,I am confident that if the
need exists,the market will respond.This key
attribute Dr.Johnson does not hold water for
40 www.possio.com , visited April 3, 2003.41 The Associated Press, Cell Phone Industry Nears 411 Info Service
March 19, 2003.
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purposes is,theagain,beyondthisproceedingand
scope of the statutory test Qwest must meet.
FINALLY, DR. JOHNSON RAISES SAFETY CONCERNS WITH
WIRELESS SERVICE, AND CONTENDS THAT FOR THESE REASONS THE
SERVICE IS NOT FUNCTIONALLY EQUIVALENT WITH QWEST'S BASIC
LOCAL EXCHANGE SERVICE.(PAGE 27, LINES 17-23 - PAGE 28,
LINE 1)
wireless
aware
Nor does
PLEASE COMMENT.
With allegation thatregardDr.Johnson
phone brain am notcancer,usage may cause
support ing thi s claim.any conclusive evidence
Dr.Johnson cite any in his testimony.This
appears to be another instance of Dr.Johnson theorizing
without providing verifiable supporting facts or empirical
evidence.Qwest, on the other hand, has presented strong
evidence in this proceeding that wireless services present
functionally Qwest' s
wirel ine
equi valent"al ternati ve
basic local exchange service.Dr.Johnson
testimony should be disregarded.
B. Competi ti vely Priced
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ACCORDING TO JOHNSON,THE REASONSONEDR.
WIRELESS IS NOT A VIABLE SUBSTITUTE FOR WIRELINE SERVICE
IS THE USAGE
17,LINE 14)
No.
(PAGEFEES ASSOCIATED WITH WIRELESS SERVICE.
IN YOUR ESTIMATION, IS THIS CONCERN VALID?
Wireless service affordablepresents
value-added Qwest' s basicalternativewireline local
exchange service for Idaho consumers.The AT&T mLife plan
referenced example.earlier in my testimony prime
The consumersplan Caller ID,Call Waiting,offers
Detailed Billing,Text Messaging,voice Mail,Three-Way
Calling,nationwideCall Forwarding,350 anytime minutes,
long distance and unlimited night and weekend minutes -
all for $29.99 per month.
Johnson s assertion pricing can noContrary to Dr.
longer be considered a barrier to wireless subscribership.
The average price per minute of wireless usage has been
more than cut in hal f ,from $.35 in 1998 to $ .13 in 2001
and was expected to drop lower in 2002, according to Bear
an investment banking and brokerage firm.Stearns
indicated earlier in my testimony, new research from CIT-
PriMetrica per centthatnearlysuggests
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Qwest Corporation
households wirelinewouldswi tchprepared from
service to a family share wireless option with 600 shared
base minutes month.Additionaloffered$50 per
findings oneindicatethat third of households would
drop their wireline service for a similar wireless package
with month. shared base $130minutescosting2000 per
Based on the survey results,CIT-PriMetrica describes the
wireless potentiallythrea t wireline companies
staggering. "
Lincoln hisdiscussesdetailDr.more
rebuttal testimony,Idaho consumers view wireless serVlce
as a competitively priced substitute for wireline service.
This due,bucket"pricing schemespart,
prevalent consumerthemarket,which allow the
purchase per month,therebyhighvolumeminutes
stimulating airtime Consul t ing ,Fourceusage.
specialist strategy and marketing consul t ing firm,
suggests that such price plans will have a stronger effect
42 Bear Stearns, Wireline Services.
March 2002.
43 http: / /theregister. com/content/68/29779 .html , visited 3/20/03.
Qwest is acquiring the complete CIT-PriMetrica study which is
scheduled to be released in April , 2003.
44 Id.
New Opportunities, New Challenges,
QWE-T- 02 -
April 21 , 2003
Boise-155939.1 0029164 -00087
TEITZEL , D. (REB) -71-
Qwest Corporation
wireless resul t from merelysubsti tution than woul d
lowering the wireless price per minute.
IDC found that in the 2001-2002 time frame, wireless
pricing declined to the point at which wireless is viewed
cost -effective al ternati veandcompelling
wireline.illustrated by the dramatic increaseThis is
usagereport ing wirelesssubstantialconsumers
home are readilyandworkwherewirelinealternatives
available, "recent analysisreporteditsIDC
wireless displacement of wireline services. Therefore
Johnson usagefearsthat fees resul t in wirelessDr.
service arebeingconsidered unfounded" 1 uxury and
without merit.
V. TESTIMONY OF THE INTERVENORS MEIEROTTO
WHAT ARE THE PRIMARY ISSUES RAISED THE
INTERVENORS MEIEROTTO?
the perception theappears
Intervenors that wireless service does not allow the use
45 M2 communications Ltd., EuropeMedia, Bucket pricing: way forward fixed-mobile substi tution November 19, 2002.
QWE-02-April 21, 2003
Boise-155939.1 0029164-00087
TEITZEL , D. (REB) -72-
Qwest Corporation
of extension phones and,does not allow usein addition
provided explainedfeaturesPBXsystem.
earlier extensions arethistestimony,tel ephone
available with wireless service,as people visiting stores
such as in Eagle or Radio Shack canThe Wireless Store
discover.recognizingFurthermore,wireless carriers,
that consumers have dramatically increased the use
wireless are expanding geographicalat home and at work
serving areas,andimproving interoperability of services,
integrating carrier networks with corporate PBX networks.
For example,Sprint recently announced that planningPCS
its strongsi tes includescellfor 2003over 2,000
focus bothincreasingin-building coverage for
commercial and residential neighborhoods. IDCIn fact,
characteri zes thein-building last wirelesscoverage
frontier. ,,more marketfoundthatIDCcoverage
entrants and carriers in-buildingfocus on the issues of
and integration displacementbusinesslinecoveragePBX
will evenbecome issue local exchangelargerfor
46 International Data Corporation , IDC Study#28018, Wireless
Displacement of Wireline Access Lines Forecast and Analysis, 2002-
2006, October , 2002.47 International Data Corporation, IDC Study #28707 Top 10 U. S.
Wireless Services Issues in 2003, January 2003.
48 Id.
QWE - T - 02 - 2 5April 21, 2003
Boise-155939.1 0029164 -00087
TEITZEL , D. (REB) -73-
Qwest Corporation
carriers and opportunity for the wireless industry.
Solutions such that offered Ascendent described
previously testimony demonstrate that any
perceptions that wireless service not viable
substitute for wireline service for these reasons
simply not raised byTherefore,theaccurate.concerns
the being bothMeierottoshould beIntervenors seen
misperceptions and beyond the scope of this proceeding.
CONCLUSION AND RECOMMENDATIONVI.
PLEASE SUMMARIZE YOUR TESTIMONY.
testimony,evidencehaveprovided
demonstrating that,contrary to the position of Mr. Hart,
Johnson Meierotto,Qwe s t hasandtheDr.Intervenors
satisfied the statutory requirements of Idaho Code 62-
622 (3) (b)areapplicantthattherethattheshow
competitively equi valent andpriced,functionally
reasonably available to Qwest'. s basic localal ternati ves
exchange services in the seven exchanges listed in Qwest' s
application.evidencethisevidence,and theBased
presented by other Qwest witnesses,I respectfully request
49 Id.
QWE-02-April 21, 2003
Boise-155939.1 0029164-00087
TEITZEL, D. (REB) -74-
Qwest Corporation
this Commission to approve Qwest' s application for price
deregulation of Qwest' s basic local exchange services
the seven southern Idaho exchanges.
DOES THIS CONCLUDE YOUR TESTIMONY?
Yes , it does.
QWE - T - 02 - 2 5
April 21 , 2003
Boise-155939.1 0029164 -00087
TEITZEL , D. (REB) -75-
Qwest Corporation
Difference Between Qwest and Wireless Service
Residential Plan Comparison: Including All Taxes And
Fees Paid By Wireless And Qwest Wireline Customers
Qwest Measured Rate Qwest Flat Rate
Wireless Carrier
Edge Wireless
wI features
Low Usage
0 Minutes
US Cellular
wI features
Sprint PCS
wI features
$18.
$11.
Verizon Wireless
wI features
AT&T Wireless
wI features
T -Mobile
wI features
Nextel
wI features
$19.
$12.
$16.43
n/a
Cricket
wI features
ClearTalk
(Magic Valley)
wI features
$16.
n/a
ClearTalk
(Southern Idaho)
wI features
$23.
n/a
Average
Usage
$18.
$11.
$19.
$12.
$16.43
n/a
$16.
n/a
$23.
n/a
High Usage Low Usage
$21 .
$14.46
$16.
Average
Usage
$58.
$51 .45
$11.
High Usage
$122.
$114.
$16.45
$63.
$56.
$88.
$81.
$53.
$46.
$27.
$19.
n/a
$16.
n/a
NOTES: 1) Assumes no Toll revenue on Owest access line in this comparison (wireless plans typically include Toll calling in
allowed "bucket" of minutes). If Toll included , wireless plan rates are an even greater value.
2) Owest usage values are taken from "Call Rate Distribution" spreadsheet (Exhibit 21), reflecting 2002 Idaho SLUS
data. For carriers that do not count evening/night/weekend usage against the wireless call plan usage allocation
only "peak" (7 a.m. to 9 p.) SLUS minutes were used for those comparisons.
3) Neither Cricket nor Clear Talk include features in their core package rates.
4) Shaded cells are cellular rates no more than $10 higher than comparable Owest wireline rates, excludin Toll.
Exhibit No. 19
page 1 of 2
Case No. OWE-02-
Teitzel, D. (REB) Owest
April 21 , 2003
$18.
$11.
$21 .
$14.
$27.
$20.
$16.43
n/a
$16.
n/a n/a n/a
$23.
n/a
$16.
n/a
$16.
n/a
Difference Between Qwest and Wireless Service
Bu~~~ess Plan Comparison: Including All Taxes And
Fee~ Paid By Wireless And Qwest Wireline Customers
Qwest Measured Rate Qwest Flat Rate
Average
Usage
Low Usage Average
Wireless Carrier 0 Minutes Usage
Edge Wireless
wI features
US Cellular
wI features
Sprint PCS
wI features
Verizon Wireless
wI features
AT&T Wireless
wI features
T -Mobile
wI features
Nextel
wI features
Cricket
wI features
ClearTalk
(Magic Valley)
wI features
ClearTalk
(Southern Idaho)$16.$15.$14.
wI features n/a n/a n/a
High Usage
$63.
$59.
$38.
$33.49
$63.
$59.
$37.
$32.
NOTES: 1) Assumes no Toll revenue on Qwest access line in this comparison (wireless plans typically include Toll calling in
allowed "bucket" of minutes). If Toll included, wireless plan rates are an even greater value.
2) Qwest usage values are taken from "Call Rate Distribution" spreadsheet (Exhibit 21), reflecting 2002 Idaho SLUS
data. For carriers that do not count evening/nighUweekend usage against the wireless call plan usage allocation
only "peak" (7 a.m. to 9 p.) SLUS minutes were used for those comparisons.
3) Neither Cricket nor Clear Talk include features in their core package rates.
4) Shaded cells are cellular rates no more than $10 higher than comparable Qwest wireline rates, exciudin Toll.
Exhibit No. 19
page 2 of 2
Case No. QWE-02-
Teitzel , D. (REB) Qwest
April 21 2003
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AT&T WIRELESS - CALLING PLANS
Calling
Features
Included
Night &Mobile to Long Caller 10, Call
Anytime Weekend Mobile Distance Waiting, Voice
Plan Name Description Minutes Minutes Minutes Included Mail Monthly Price
mUte Local Plan - Next Generation 45,
250,400,600,1000,1400,2200,3200,
4800
Ideal if you make mostly local calls, want lots 45 - 5 000 Unlimited nfa Yes Yes $19.99 - $299.of minutes and rarely travel outside your local
area. Large home service area on Next
Generation Network. Coverage includes AT&T
Wireless area in Idaho.
mUte Local Plan - Next Generation
MultiBand 45, 250, 400, 600 , 1000, 1400,
2200, 3200, 4800
Ideal if you make mostly local calls , want lots
of minutes and rarely travel outside your local 45 - 5 000 Unlimited nfa Yes Yes $19.99 - $299.
area. Expanded home service area on Next
Generation Network. Coverage includes AT&T
Wireless areas in CO, 10, OR, UT, WA, WY.
mUte Local Plan - Digital 45, 250,400,available
600,1000,1400 2200,3200,4800 for plans
Ideal if you make mostly local calls, want lots $39.99 or
of minutes and rarely travel outside your local 45 - 5 000 Unlimited more Yes Yes $19.99 - $299.
area. Large home service area on Digital 500 minutes
Network. Coverage includes AT&T Wireless $4.99/mo
1000 minutesarea in Idaho.$9.99 Imo
mUte National Plan - Next Generation
30,200,350,500,900,1200 2000,3000,
4500
Ideal solution, offering coverage to select
cities, while paying no roaming or domestic 30 - 4 700 Unlimited nfa Yes Yes $19.99 - $299.
long distance when calling within your home
coverage area. AT&T Wireless Next
Generation is Home Service Area. Coverage
includes AT&T Wireless areas nationwide.
mUte National Plan - Next Generation
MultiBand 30,200,350,500,900,1200,
2000, 3000, 4500
Ideal solution, offering coverage to select
cities, while paying no roaming or domestic 30 - 4 700 Unlimited nfa Yes Yes $19.99 - $299.long distance when calling within your home
coverage area. AT&T Wireless Digital
National Network is Home Service Area.
Coverage includes AT&T Wireless areas
nationwide.
Exhibit No. 22
Page 1 of 12
Case No. QWE-02-
Teitzel, D. (REB) Qwest
April 21 , 2003
AT&T WIRELESS - CALLING PLANS
Calling
Features
IncludedNight &Mobile to Long Caller ID, Call
Anytime Weekend Mobile Distance Waiting, Voice
Plan Name Description Minutes Minutes Minutes Included Mail Monthly Price
mUte National Plan - Digital 30, 200,
350, 500, 900, 1200, 2000, 3000, 4500 available
Ideal solution, offering coverage to select for plans
cities, while paying no roaming or domestic $39.99 or
long distance when calling within your home 30 - 4 700 Unlimited more Yes Yes $19.99 - $299.
coverage area. AT&T Wireless Digital 500 minutes
National Network is Home Service Area.$4.99/mo
1000 minutes
Coverage includes AT&T Wireless areas $9.99 Imo
nationwide.
mUte Digital One Rate Plan - Digital
450, 650, 900, 1100, 1500, 2000, 3000
No roaming or nationwide long distance 450 nfa nfa Yes Yes $59.99 - $299.charges across the U.S. Every call within the 000
S. is like a local call. Nationwide coverage in
AT&T Wireless areas.
mUte Digital One Rate Plan - Next
Generation MultiBand 450, 650, 900,
1100, 1500, 2000, 3000 450
No roaming or nationwide long distance 000 nfa nfa Yes Yes $59.99 - $299.
charges across the U.S. Every call within the
S. is like a local call. Nationwide coverage in
AT&T Wireless areas.
mUte Shared Plans $59.99 - $119.
Large Home Service Area in AT&T Wireless 500 Shared Shared (includes 2 lines of service)
area in Idaho 500 Unlimited Unlimited Yes Yes ($19.99/month up to 3 add'
lines)
Exhibit No. 22
Page 2 of 12
Case No. QWE-02-
Teitzel, D. (REB) Qwest
April 21 , 2003
CLEAR TALK - WIRELESS CALLING PLANS
Calling
Features
Included
Night &Mobile to Long Caller ID, Call
Anytime Weekend Mobile Distance Waiting, Voice
Plan Name Description Minutes Minutes Minutes Included Mail Monthly Price
Clear Talk Magic Valley Package
(Zone 1)
Unlimited Unlimited nfa No - can No - can $32.The mobile local phone. All calls in Zone purchase purchase
are local. Unlimited calling in Zone 1.
Clear Talk East Idaho Package
(Zone 1 & No - can No - canThe mobile local phone. All calls in Zones Unlimited Unlimited nfa $39.
1 & 2 are local. Unlimited calling in Zones 1 &purchase purchase
Exhibit No. 22
Page 3 of 12
Case No. QWE-02-
Teitzel, D. (REB) Qwest
April 21 , 2003
CRICKET - WIRELESS CALLING PLANS
Calling
Features
Included
Night &Mobile to Long Caller ID, Call
Anytime Weekend Mobile Distance Waiting, Voice
Plan Name Description Minutes Minutes Minutes Included Mail Monthly Price
Cricket
Unlimited local calls in Cricket Idaho service Unlimited Unlimited nla No - can No - can $32.
area. Includes all incoming calls.purchase purchase
Cricket Talk Caller 10, Call
Unlimited local calls in Cricket Idaho service Yes Waiting, 3-
area. Caller 10, Call Waiting, 3-Way Calling,Unlimited Unlimited nla 500 Way Calling.$39.minutes500 anytime U. S. Long distance minutes per Imo (Voice Mail
month $3.99/mo)
Exhibit No. 22
Page 4 of 12
Case No. QWE-02-
Teitzel , D. (REB) Qwest
April 21 , 2003
EDGE WIRELESS - CALLING PLANS
Calling
Features
Included
Night &Mobile to Long Caller 10, Call
Anytime Weekend Mobile Distance Waiting, Voice
Plan Name Description Minutes Minutes Minutes Included Mail Monthly Price
Yes in No - can
SafetyPlan nfa nfa coverage purchase $14.
area
LocalEdge 100, 250, 400, 550, 750,1000,500 for
1300, 2000, 4000 100 -plans Yes in
Locals always get a great deal. Home 000 $39.99 &nfa coverage Yes $24.99 - $199.
coverage in Edge Wireless areas in Idaho higher area
Western Edge 150, 300, 450, 700, 1000,
1600, 2000, 2500 Yes inTravel all over the west without leaving home.150 -Yes
No roaming or domestic long distance 500 nfa nfa coverage $29.99 - $199.
charges. Coverage in Edge Wireless areas in
area
, NV, OR, UT, WA, WY
NationalEdge 250, 450, 650, 900, 1100
1500,2000 250 -No long distance, no roaming, nationwide,000 nfa nfa Yes Yes $49.99 - $199.
anytime. It's just that simple. Nationwide
coverage in Edge Wireless areas.
LocalShare Plans 2650, 3650, 4750 Yes in $50.00 - $110.Easiest way to keep your family or small 650 -
business connected. Home coverage in Edge 750 nfa nfa coverage Yes ($9.99 /mo for up to 4 add'
Wireless areas in Idaho.area lines)
WesternShare Plans 2075, 2875, 3775
Easiest way to keep your family or small 575 -Yes in $45.00 - $105.
business connected. Coverage in Edge 275 nfa nfa coverage Yes ($9.99 /mo for up to 4 add'
Wireless areas in CA, 10, NV, OR, UT, WA area lines)
Access Edge (Prepay Plan)
No monthly bills, no credit checks, no annual depends depends Voice Mail Prepay purchase
contracts, no activation fee. Home coverage in on amount on amount nfa
Edge Wireless areas in Idaho purchased purchased included $10.00 - $100.
Local airtime $0.25 per minute
Access Edge Bucket Plans (Prepay
Plan)
No monthly bills, no credit checks, no annual 50 - 600 100 -Voice Mail Prepay purchase
contracts, no activation fee. Home coverage in Peak 000 Off nfa included $19.99 - $99.
Edge Wireless areas in Idaho Peak
Local airtime $0.25 per minute Peak;$0.1 0 Off Peak
Exhibit No. 22
Page 5 of 12
Case No. QWE-02-
Teitzel, D. (REB) Qwest
April 21 2003
NEXTEL - WIRELESS CALLING PLANS
Calling
Features
IncludedNight &Direct Long Caller 10, Call
Anytime Weekend Connect Distance Waiting, Voice
Plan Name Description Minutes Minutes Minutes Included Mail Monthly Price
National Free Incoming Plans 400, 600
800,1100 400 -Great for small and large businesses and busy Unlimited Unlimited Yes Yes $59.99 - $119.
families. Includes Free Incoming Calls.100
Coverage in Nextel service areas in Idaho.
National Value Plans 300, 500
Great value plans for businesses and families.300 - 500 200 -100 Yes Call Waiting $35.99 - $45.Coverage in Nextel service areas in Idaho.000 3 Way Calling
National Shared Value Plans 300, 500 3,450 -Call Waiting $39.99 - $49.
Free nationwide long distance. Coverage in 300 - 500 250 Yes ($20.00 per month plan
Nextel service areas in Idaho.250 3 Way Calling available)
National Shared Plans 200, 500, 700
1000 200 -Everything you need in one low monthly rate.000 n/a Unlimited Yes Yes $49.99 - $99.
Free nationwide long distance. Coverage in
Nextel service areas in Idaho.
Local Get Right Through 50, 250, 500
Everything you need in one low monthly rate.100 -000 -500 -Yes Call Waiting $35.99 - $55.Free nationwide long distance. Coverage in 000 000 000 3 Way Calling
Nextel service areas in Idaho.
National Unlimited Plus
Unlimited incoming and outgoing calls. Free
Unlimited Unlimited Unlimited Yes Yes $199.nationwide long distance. Coverage in Nextel
service areas in Idaho.
Exhibit No. 22
Page 6 of 12
Case No. QWE-02-
Teitzel , D. (RES) Qwest
April 21 2003
SPRINT - WIRELESS CALLING PLANS
Calling
Features
IncludedNight &Mobile to Long Caller 10, Call
Anytime Weekend Mobile Distance Waiting, Voice
Plan Name Description Minutes Minutes Minutes Included Mail Monthly Price
PCS Free & Clear Plans with Vision
PCS vision provides more ways to connect 000 -nfa - $45 $45.00 - $100.
always on advance multimedia services, high-300 -$45 plan plan (2nd line share $20 /mo for
speed data transfer, and flexibly usage 000 Unlimited Unlimited Yes Yes $55.00 - $90.00 plans, free
options. Coverage in Sprint service areas in all other all other for $100 plan)
Idaho.plans plans
PCS Free & Clear Plans 000 -nfa - $35Enjoy no roaming charges and crystal-clear $35 plan plan $35.00 - $100.
calls. Coverage In Sprint service areas in 300 -Unlimited Unlimited Yes Yes (2nd line share $20 /mo for
Idaho.000 all other all other $45.00 - $80.00 plans, free
plans plans for $100 plan)
Exhibit No. 22
Page 7 of 12
Case No. QWE-02-
Teitzel, D. (REB) Qwest
Apri121 2003
MOBILE - WIRELESS CALLING PLANS
Calling
Features
IncludedMobile to Long Caller 10, Call
Anytime Weekend Mobile Distance Waiting, Voice
Plan Name Description Minutes Minutes Minutes Included Mail Monthly Price
Boise Regional Rate Plan Yes inFree digital roaming and free long distance In $49.
home state. Regional coverage includes T-000 n/a coverage Yes
Mobile service areas in ID, OR, UT.area
FamilyTime Plan $69.
Nationwide coverage in T-Mobile service (includes 2 lines of service)
areas.800 Unlimited Unlimited Yes Yes ($20.00 Imonth up to 3 add'
lines)
FamilyTime Plus Plan $99.
Nationwide coverage in T-Mobile service (includes 2 lines of service)
areas.200 Unlimited Unlimited Yes Yes ($20.00 Imonth up to 3 add'
lines)
National Rate Plan - Basic $10.001
Nationwide coverage in T-Mobile service 500 mo for Yes Yes $19.
areas.Buddy
Time
National Rate Plan - Basic Plus $10.001
Nationwide coverage in T-Mobile service 300 Unlimited mo for Yes Yes $29.
areas.Buddy
Time
National Rate Plan - Get More $10.001
For people who travel and spend up to half an mo for
hour per work day on the phone. Nationwide 600 Unlimited unlimited Yes Yes $39.
coverage in T-Mobile service areas.Buddy
Time
National Rate Plan - Get More Plus $10.001
For people needing 45 minutes of use per mo for
work day on the phone. Nationwide coverage 000 Unlimited unlimited Yes Yes $59.
in T-Mobile service areas.Buddy
Time
National Rate Plan - Get More Ultra $10.001
For users needing just over an hour of talk mo for
time per work day. Nationwide coverage in T-500 Unlimited unlimited Yes Yes $79.
Mobile service areas.Buddy
Time
National Rate Plan - Get More Max $10.001
This plan gives you over 110 minutes per work mo for
day. Nationwide coverage in T-Mobile service 500 Unlimited unlimited Yes Yes $99.
areas.Buddy
Time
National Rate Plan - Get More Supra $10.001
This plan gives you more than 225 minutes per mo for
work day. Nationwide coverage in T-Mobile 000 Unlimited unlimited Yes Yes $129.
service areas.Buddy
Time
Exhibit No. 22
Page 8 of 12
Case No. QWE-02-
Teitzel, D. (REB) Qwest
April 21 2003
MOBILE - WIRELESS CALLING PLANS
Calling
Features
IncludedMobile to Long Caller 10, Call
Anytime Weekend Mobile Distance Waiting, Voice
Plan Name Description Minutes Minutes Minutes Included Mail Monthly Price
Sidekick Plan 200 $10.00/
One flat rate per month, calls to/from anywhere mo for
in the country with GSM coverage. Nationwide 200 000 unlimited Yes Yes $39.
coverage in T-Mobile GSM service areas.Buddy
Time
Sidekick Plan 500 $10.00/
One flat rate per month, calls to/from anywhere mo for
in the country with GSM coverage. Nationwide 500 Unlimited unlimited Yes Yes $59.
coverage in T-Mobile GSM service areas.Buddy
Time
Exhibit No. 22
Page 9 of 12
Case No. OWE~02-
Teitzel, D. (REB) Owest
April 21 , 2003
s. CELLULAR - WIRELESS CALLING PLANS
Calling
Features
IncludedMobile to Long Caller 10, Call
Anytime Weekend Mobile Distance Waiting, Voice
Plan Name Description Minutes Minutes Minutes Included Mail Monthly Price
Local 125 Call Waiting
Nationwide long distance. Local coverage in 125 nfa nfa Yes Call $25.
S. Cellular Idaho service area.Forwarding
Local 700, 1100, 1400, 1800,2200,2500,nfa -1100
3600 700 -Unlimited Sharetalk Yes Yes $35.00 - $200.Nationwide long distance. Coverage area in 600 all other $15fmo
S. Cellular Idaho service area.plans
Regional 500, 650, 800, 1300, 1500,
2300, 3300
Multistate calling area. Nationwide long 500 -Unlimited Sharetalk Yes Yes $35.00 - $200.distance. Regional coverage in U.S. Cellular 300 $20 fmo
service areas in CA, 10, NV, OR, UT, WA, WY.
SpanAmerica 200 , 250, 400, 700, 1000,
1500,2000 200 -Nationwide plans with no roaming charges.000 nfa nfa Yes Yes $35.00 - $200.
Nationwide long distance. Nationwide
coverage in U.S. Cellular service areas.
TalkTracker (Prepay Plan)Initial Purchase $129No monthly bills , no credit checks, no annual depends depends Call Waiting includes phone & 70contracts, no activation fee. Local coverage in on amount on amount nfa 3 Way Calling minutes airtimeS. Cellular Idaho service area.purchased purchased
Local airtime $0.35 per minute
Exhibit No. 22
Page 10 of 12
Case No. QWE-02-
Teitzel, D. (REB) Qwest
April 21 , 2003
VERIZON WIRELESS - CALLING PLANS
Calling
Features
Included
Night &Mobile to Long Caller 10
Anytime Weekend Mobile Distance Voice Mail
Plan Name Description Minutes Minutes Minutes Included Call Waiting Monthly Price
America s Choice 300, 400, 550, 900,
1200, 2000, 3000 400 -
Nationwide coverage in VerizonWireless 500 Unlimited 000 Yes Yes $39.99 - $204.
areas
Promotional America s Choice Family
SharePlans 300, 400, 550, 900, 1200,
2000, 3000 400 -Shared $39.99 - $204.
Nationwide coverage in VerizonWireless 500 Unlimited 000 Yes Yes ($20 fmonth for 2nd line)
areas
Can add 2nd line only
Anytime 700, 1000 700 -000 Yes in
Home coverage includes Idaho & Utah 000 Unlimited Local home rate Yes $49.99 - $64.
area
Local DigitialChoice 300, 350, 500, 650 nfa
1000,1400,2200 000 -$29.
Home coverage area includes Idaho &$29.plan Yes in300 -planUtah000Unlimited 000 home rate Yes $29.99 - $154.
all other Local for area
plans all other
plans
Local DigitialChoice Family SharePlans
500,650,1000,1400,2200 650 -Shared 000 Yes in $49.99 - $154.
Home Coverage includes Idaho & Utah 000 Unlimited Local home rate Yes ($20 fmonth for up to 3
Can add up to 3 add'llines area add'llines)
National SingleRate 150, 400, 600, 900,
1500, 2000, 3000 150 -nfa nfa Yes Yes $35.00 - $300.
Nationwide coverage 000
Promotional Family SharePlan 700,
1000 700 -Shared 000 Yes in $49.99 - $64.
Home Coverage includes Idaho & Utah 000 Unlimited Local home rate Yes ($20 fmonth for up to 3
Can add up to 3 add'llines area add'ilines)
SingleRate West 300, 400, 500, 750,
1100,1750,2500 400 -000 Yes in
Home coverage includes AZ., CA, CO, HI 000 Unlimited Local home rate Yes $39.99 - $204.
, MT, NM , NV, OR, UT, WA, WY area
SingleRate West Family SharePlan 300,
400,500, 750, 1100, 1750,2500 Yes in $59.99 - $224.
Home coverage includes AZ., CA, CO, HI 400 -Unlimited 000 home rate Yes ($20 fmonth for up to 3
, MT, NM, NV, OR, UT, WA, WY 000 Local area add'ilines)
Can add up to 3 add'llines
Exhibit No. 22
Page 11 of 12
Case No. QWE-02-
Teitzel , O. (REB) Qwest
April 21 , 2003
VERIZON WIRELESS - CALLING PLANS
Calling
Features
Included
Night &Mobile to Long Caller 10
Anytime Weekend Mobile Distance Voice Mail
Plan Name Description Minutes Minutes Minutes Included Call Waiting Monthly Price
Express Network 150, 400, 600, 900,
1500, 2000, 3000 Yes in
Calling plan with wireless Internet access 150 -nfa nfa home rate Yes $35.00 - $300.
Home coverage includes Idaho Verizon 000 area
Wireless areas
Unlimited Express Network
Calling plan with wireless Internet access Yes in
Home coverage includes Idaho Verizon Unlimited Unlimited nfa home rate Yes $79.
Wireless areas
area
Verizon Wireless PREPAY
Wireless service with no contract, monthly depends depends depends
bills or credit check.on amount on amount on amount Yes Yes Prepay purchase cards
Rates per minute: $0.30 Weekday; $0.15 Mobile to purchased purchased purchased begin at $15.
Mobile; $0.15 Night & Weekend; $0.05 Mobile
Messenger
Exhibit No. 22
Page 12 of 12
Case No. QWE-02-
Teitzel, D. (REB) Qwest
April 21 2003
CLEAR TALK Wireless Page 1 of 1
CLEAR TALK wireless phones use radio signals to send and receive calls.
Unlike some other wireless phones, however, CLEAR TALK uses digitalPCS which operates at higher frequency.
CLEAR TALK's PCS utilizes COMA (Code Division Multiple Access)
technology rather than analog cellular used by other carriers. COMA is the
leading technology in today s digital PCS market.
CDMA Benefits include:
. Enhanced Voice Quality
. Clearer Calls than Analog
. Fewer Dropped Calls
. Reduced Background Noise and Interference
. Greater Call Security
Increased Airwave Capacity
http://www.cleartalk.net/T7fxc98/technology.html
Exhibit No. 23
page 1 of 1
Case No. QWE- T-02-
Teitzel, D. (REB) Qwest
April 21, 2003
_-- ----
Mobile - About our technology
~ T.Moblle USA home
. . .
~ . 'Mobile.
' , / ,.' ,;... ..:' .
Products Plans Coverage Company Info.
About our technology
.-------......
., About our company
.. Quick facts
., Meet Catherine Zeta-Jones
- About our technology
,. Safety information
.. TTY Polley Overview
Moblle USA Technology OvelView
GSM Technology: The Global Standard
Moblle$ is the only U.S. wireless carrier operating ublquijous GSM(Global System for Mobile) network in more than 8000 cijiesnationwide. Adopted by 179 countries, GSM Is the most widely used
digital wireless standard in the world with more than 700 million
subscribers.
GSM's proven, feature-rich digital technology provides customers wijh
Integrated voice, high-speed data, paging and short message servicecapabllilles, as well as excellent sound quality and call reliability. Thewell-developed network ensures that all calls and messages are
processed 9uickly and reliably, and T-Mobiles 100 percent digitalnetwork delIVers better sound quality than other wireless servicesindudlng crisper, dearer voice quality and less static, fading andbackground noise. Independent laboratory and field test reports validate
near parity with wire lines.
GPRS (General Packet Radio Servlce)lT -Mobile Internet
GPRS is a standardized packet-swllched data service that Is an
extension of the GSM archllecture. GPRS is what makes the Intemet
wireless.
The GPRS standard uses upgraded radio base stations linked to a new
network based on 'packer technology. WIth circuli switched networks,the user dials the required number and the network connects the call,
allocating a circuli between the two parties until the call is ended.Packet technology allows the user to be connected to their home carrier
data services via the subscribe~s handset, PDA or laptop, and then
send and receive data as required throughout the day. T-Moblle s 2.GPRS network Is only used when data is being transmitted, but the user
retains a virtual connection to the chosen computer network throughout
the day.
The benefits ofthe T-Mobllelnternet using GPRS technology:
. The user can be "always connected, always on-lIne' to the datanetwork.
" GPRS provides high-speed data transmission. GPRS handsels are
capable of operating at speeds up to five times faster than on
current GSM networks.
" The network Is used far more efficiently than circuit switched
networks. It is only used when data is being transmitted, which
reduces the cost of mobile data.
. GPRS Is based on the Intemet Protocol (IP). This provides ease of
connectivity from mobile data terminals to the Internet and to IP-
based company In!lanels.
WI.f1 (802.11b)
Wl-FI is a member of the family of IEEE standards for wireless LANs
first Introduced in 1997. The first standard to be Implemented, 8O2.11bspecifies from 1 to 11 Mbps in the unlicensed 2.4GHz band using directsequence spread spectrum (DSSS) technology. The WIreless Ethernet
Compatibility AssocIation (WECA) brands II as Wireless Fidelity
or "WI-FI..
An 802.11 system works In two modes. T -Mobile HotSpot service
operates In Infrastructure mode, where wireless devices communicate
to the Internet via access points. Each access point and Its wireless
devices are known as a Basic Service Set (BSS).
T -Mobile HotSpot service Is reliable and fast enough to accommodate
the full spectrum of applications from checkIng e-mail to multi-mediavideo conferenclng with a high-speed wireless connection as much as
40 to 50 times faster than standard dlal-up Internet access.
The T-Moblle WSmart Cardw: Privacy, Security and Convenience
The T-Moblle Smart Card (also known as a SIM card) is the .braln. ofthe T-Mobile digital personal communications services (PCS) phone. It'
a plastic card that comes with the T -Mobile phone, featuring an
embedded computer microchip, which can easily be Inserted or
transferred Into other T -Mobile phones, retaining customers' phonebookand personalized service Information.
The T-Moblle Smart Card also helps secure T -Mobile phones against
unauthorized use. The phones won~ operate without this programmable
computer microchip. Even after the T -Mobile Smart Card is inserled Intothe phone, a personal identification number (PIN) chosen by the
customer must be verified before the phone can be used. The Smart
Card also helps T .MobBes network to ensure that all calis are private -ail transmissions are digitally encrypted to prevent eavesdropping orcloning" of a phone number.
http://www . t- mobile. com! company/about/techno 10 gy. asp
Page 1 of 2
See all T -Mobile Internallonal sites
Get more from life-
Help MyT-Mobile
.. Select a new location
,. My cart
.. Check Order Status
Exhibit No. 24
page 1 of 1
Case No. QWE-02-
Teitzel, D. (REB) Qwest
Apri121 2003
Ascendent Telecom, Inc.http://www.ascendenttelecom.com!co... p ?page=pressrelease&subpage=press4
~ASCENOENT
~ "'"'"""'' ""'"
-~_I_'Disaster Recovery Industry Solutions 1_1-
" Press Releases
Articles
!. Events
; Contact Ascendent
Press Releases
Ascendent Gains Traction with Wireless Carriers,
Provides Mobile Enterprise Solution to the Fortune 500
LOS ANGELES - March 13, 2002 - Ascendent Telecommunications Inc., aninnovator in providing converged network solutions for the enterprise
announced today that it will further an existing marketing agreement with
Nextel Communications Inc. (NASDAQ: NXTL), the leading provider of fullyintegrated wireless communications services. Nextel, which currently markets
Ascendenti:s WirelessConnectTM telephony product to its enterprise customers
under the name Mobile ExtensionSM , has also implemented the productinternally with great success.
The demand for this type of solution continues to grow, as existing enterprisevoice systems are unable to keep up with the needs of mobile workers and
telecommuters " said Stephen Forte, CEO and founder of Ascendent. "Our goalwith WirelessConnect is to provide enterprises with the ability to conduct
business closer to customers, partners and suppliers while reducingcommunications costs and providing mobile workers with complete access to
the corporate network.
WirelessConnect is a hardware and software solution that allows any wireless
phone or remote device to be linked quickly and seamlessly to a corporate
private branch exchange (PBX), extending the features and functions of
corporate networks to remote offices, telecommuters and mobile workers.
With WirelessConnectTM technology, Ascendent is offering an effective solutionto the growing demand among large companies for ways to use their
corporate PBXs to expand office mobility and improve mobile workers
productivity.
Nextel first introduced WirelessConnect technology and the Mobile Extensionservice to its corporate customers in June 2000 in response to tremendous
customer demand for a more complete wireless PBX integration solution.Nextel customers using the service to date include Accenture, Steel case Inc.
the U.S. Marine Corps Air Station at Miramar, Walt Disney World Theme ParkOrlando, Tellabs Ltd. and General Motors Corp. among others. Today
announcement demonstrates Ascendent's strength in the burgeoning marketfor mobile workers and telecommuters.
# # #
WirelessConnect is a registered trademark of Ascendent Telecommunications
Inc.
Other product or service names mentioned herein are the trademarks of their
respective owners
For more information:
Steven Apple
Jane Greenstein
Ascendent Telecommunications
[phone]
marketi no (6)asce ndenttel ecom .com
lof2
Exhibit No. 25
page) of)
Case No. QWE-02-
TeitzeI, D. (REB) Qwest
April 21 , 2003
----.---...--------.-----------..-.--.....----.----..-.... ---..----.-.---...-
AscenclentCS".' IS d hrreill\tllI.ougI1 product tli;lt f~IJSll!P.'; tllefe
is no in\erruptioll in ('ss,.:IIII;1I voict" corllll1unicdllorls.
When Your Voice System Goes Down
Don t Let Your Business Go Down With It.
Exhibit No. 25
page 2 of 11
Case No. QWE-02-
Teitzel, D. (REB) Qwest
Apri121,2003
The AscendentCSTM is the
first complete solution
aimed at ensuring
seamless operations of
voice communications at
all times. It also gives
employers the
unprecedented ability to
monitor and control
remote and wireless phone
usage by the existing PBX
class of service, and
provides an easy method
for communicating to an
entire staff with just one
phone call.
Keeping a business
running 24/7 is more than
a sales pitch. It's about
accountability,
communications and
staying connected.
The main office number is your company
lifeline. How much revenue would you lose
if your building is suddenly closed or if the
phones go down?
Your sales force is out in the field,
constantly calling in to check messages.
Wouldn t is be easier if they had only one
phone number?
Being able to instantly and seamlessly
reach and communicate with staff and
customers is crucial whether it's a normal
business day or an emergency. Just as
your company replicates its computer
data, the same standard should be in
place to safeguard voice communication.
When a phone system outage occurs, be
prepared.
The AscendentCSTM allows you to stay in
contact when the main communications
hub - the Private Branch Exchange (PBX)
or Centrex switch - is down or an entire
staff has been evacuated or displaced. It
also serves to monitor remote phone
usage, interconnect cellular phones with
the PBX, and provides an efficient method
of reaching hundreds of employees with a
single call.
Continuity of
Communications
The AscendentCSTM affords the
unprecedented ability to communicate at
all times, regardless of circumstances.
. Integrating cellular, home phones, VolP
and other remote devices to your existing
voice network is vital, even when there is
no crisis. Our system allows for significant
cost savings that result from fewer
missed calls, increased productivity,
decreased long distance charges
increased efficiencies in accounting and
the ability to monitor the usage of all
remote phone devices.
. The AscendentCSTM ensures essential
voice communications are uninterrupted
in the event of evacuation, or local or
regional telecom outages, by utilizing
satellite, Volp, cellular and other remote
devices. Recovery is immediate in the
event of a crisis, and continuity is
maintained as communications shift to
our off-site recovery server.
. The immediate recovery and
uninterrupted communication allows
management to quickly and efficiently
check the status of its staff and
communicate to customers without
skipping a beat.
Exhibit No. 25
page 3 of 11
Case No. QWE- T-02-
Teitzel, D. (REB) Qwest
April 21, 2003
----.
With the AscendentCS1Tt1
there is no change in
user behavior, regardless
of the circumstances.
The AscendentCSTM utilizes the
revolutionary mobility technology
developed by Ascendent
Telecommunications which allows
remote telephones (including cellular,
satellite and VoIP) to be seamlessly
linked to most any Private Branch
Exchange (PBX). This technology
converts any remote telephone into a
portable " extension" of the desktop
PBX phone and allows users access to
the same features and functions of
their desktop phone.
All calls may be placed and received as
though the user was dialing on the
primary office voice network, including
internal extensions, long distance and
private network dialing, even if the PBX
is inoperable.
The AscendentCSTM offers the
additional benefit of a remotely located
recovery server which functions regard-
less of the condition of the main PBX.
Recent terrorist events have shown
how ineffective phone-trees and other
broadcast methods can be in times of
crisis. The AscendentCSTM RollCallTM
(f)
'+-
:;. The RoliCaWM
feature allows an
administrator or
supervisor to conduct
interactive polls or
broadcast information
to employees via voice
call, emai! or SMS
messaging. This
fei.'lture provides
administrators with
critical tool to account
for staff safety.
feature allows an administrator or
supervisor to conduct interactive polls
or broadcast information to employees
via voice call , email or SMS
messaging. This feature provides
administrators with a critical tool to not
only account for staff safety but to
communicate with staff at all times.
The AscendentCSTM is a powerful
technology that is being embraced by
leading communications service
providers.
The Ascendent technology is a critical
element of our corporate disaster
recovery plan," said Chris Harrington
Vice President, Strategy, of Toshiba
Computer Systems Group. "Being able
to transition our operations
instantaneously and automatically will
allow us to retain the ability to
communicate with our customers and
the outside world."
When tragedy strikes, the
communications structure of an
organization is usually one of the first
critical systems to be affected," said
Mark Hull, Vice President, Custom
Network Solutions, of Nextel
Communications. "Re-estab1ishing
communications Is generally the first
step required to assess the extent of
damage and start the recovery
process. The AscendentCSTM provides
the solution."
40% of businesses
that suffer a disaster
go out of business
within two years:'
GartnerGroup
:;. AscendentCSm
users have
immediate C1ccess
to desk phone
functions. inclucting
abbrevii.'lted dialing
of internal
extension numbers.
hold. park. and
transfer.
:;. All AscendentCSTM
enabled company
employee phones
become "virtual
extensions.' of tlleir
desk phone.
:;. While operating
busi ness as usual, the
AscendentCSTM allows
employees to make and
receive calls via one
number (the existing
corporate DID or
organization extension)
through their desktop or
any remote device. Users
also enjoy fC1vorably
priced. corporate line
long distance rates. the
use of a single voicemail
box and abbreviatecl
dialing.Exhibit No. 25
page 4 of 11
Case No. QWE-02-
Teitzel, D. (REB) Qwest
April 21, 2003
About:
Ascendent Telecommunications is
a privately held company that has
specialized in providing telecom-
munications solutions since 1993.
Contact:
Ascendent Telecommunications is
headquartered in Los Angeles,
California, with offices in New York
and Northern Virginia.
Ascendent offers its products
nationally direct, on GSA Schedule
and other prime contracts, and
through partners which include
Nextel, Cingular, Verizon, Telus
and Toshiba.
Phone: [phone]
Email: sales(gjascendenttelecom.com
Website: www.ascendenttelecom.com
Its systems have processed tens of
millions of calls since the introduction
of its core product, Ascendent MX, for
companies including Four Seasons
Hotel, United States Marine Corp,
Nextel, Daimler-Chrysler, Steelcase,
FedEx, Danone, General Motors,
USAID, Telus, OMD and many others.
1\....................,.....,..................
Exhibit No. 25
page 5 of 11
Case No. QWE-02-
Teitzel, D. (REB) Qwest
April 21. 2003
N1~
.&.~.".;..~ .""".""
Ascendent Telecommunications Continuity Solution
The A TI continuity solution provides for the seamless transition of your business operation from
normal to emergency (and back again) without human intervention or loss of communications.
This is possible because the system works with your business on a day-fo-day basis not just in
an emergency requiring no change in equipment or dialing plans.
Ascendent Telecommunications Architecture
The Ascendent Telecommunications Solution is based on a platfonn using a Continuity Server
(Ascendent ) and Recovery Server (Ascendent ) and is designed to allow for seamless
communications in the event of an outage, evacuation, or disaster.
Ascendent servers interface with existin~ telephony and LAN infrastructure
. AscendentCS has three connections:
I. To the PBX or PSTN via ISDN PRI
2. To the Corporate LAN
3. To the Internet - allowing real-time operation with the Ascendenfs
The amount of bandwidth required for each connection depends upon the number of users
and the call model.
The AscendentCS is co-located in the data or telco equipment room, while the Ascendenfs
can be located at either an A TI remote site, customer-controlled location, or third-party site.
Asc8IJdenlCS
CorpDnIID
LAN
F"1I8WIII
PBX phone
RemolB phone
~9~-
- - - - - - - - - -
WDlksbilloo
SIP Enabled
Phone
AsI:8ndentRS Exhibit No. 25
page 6 of 11
Case No. QWE-02-
Teitzel, D. (REB) Qwest
April 21, 2003
Ascendent Telecommunications, Inc.
Automatic call routing to the AscendentRS ensures constant and continuous communication
during an outage
~ Real-time communication between the AscendentCS and AscendentRS servers ensures up-to-
date user information at the recovery site
Compatible with SIP enabled communications devices
Roll-call allows managers to check employee status and availability during an outage
~ Call-in-progress remains connected when traveling from inside to outside of building
Simultaneous ringing of both the "desk-phone" and the remote phone (wireless phone, home
office, SIP enabled phone, conference room, or emergency contact number)
User access to corporate abbreviated dialing plan from remote phone
Access to company long distance plan and discounts through PBX (eliminates the need for a
calling card while traveling away from the office)
One consolidated voicemail (corporate) with voicemail notification to remote device (SMS
text pager, etc.
Customizable end-user configurations via a Web interface
Mobile Phone Reconnect keeps the calling party connected in the event the remote caB is
dropped by the cellular network
~ Do Not Disturb with Screening aBows meetings to go uninterrupted by phone calls unless the
users specifies that calls from certain parties are allowed through
MessageExpress with Extract from Voicemail allows one-touch speed dial access to a
corporate voicemail box, and permits the user to retrieve a caller who is in the process of
leaving a voicemail message
International Callback allows traveling users to place international calls from overseas at U.
landline rates
Immediate communications recovery in the event of a PBX or telecommunications outage
Affordable price allows companies of all sizes, as well as departments within larger
companies, to benefit from advanced telecommunications capabilities
Compatible with existing remote phones (home office, mobile, SIP phones)
Installs into Corporate phone system quickly, easily and non-intrusively
Extends PBX functionality to traveling executives while they are on the road
Communications becomes "person" based instead of location based
Increased accessibility and productivity
Reduced Long Distance expenses
Improved employee and customer communication
Eliminates expensive moves, adds, and changes
Empowers home office, transient, or telecommuting employees
Eliminates need for permanent desk phone
Contact Information
Renee Steiger, Director
7039320148
rste IgercQ!asce n den tteleco Ill. COIll
Ascendent Telecommunications, Inc.
Exhibit No. 25
page 7 of 11
Case No. QWE-02-
Teitzel, D. (REB) Qwest
April 21,2003
Major Value Proposition Features
User efficiency and availability
Users can be reached anywhere in the world on any phone by simply dialing their
Company s internal extension or direct dial number. No more confusing list of contact
numbers.
Dialing convenience
Once the caller gets dial tone from the WirelessConnect from their cellular or remote
phone, their dialing behavior is identical to that of their desk top PBX phone. Therefore
users can dial internal extensions, 0 for Company operator, or take advantage of entire
Company network dialing plan. There is nothing to train, user dialing behavior stays the
same.
Long distance toll savings
By routing long distance, and particularly international calls through the
WirelessConnect, all long distance is routed through the Company land-line telephone
network, achieving the lowest rate available to the Company, including private network
calling to other offices. No more expensive wireless international tolls, and no more
blocked" countries from your wireless phone.
International toll savings while traveling abroad
While traveling abroad, users can take advantage of the Wireless Connect international
call back feature. This service allows users to place calls from their cellular/GSM phone
while traveling overseas, for the price of a land-line international call from the office to
the user. How does it work? The user places a call from their GSM (or other remote
phone) to a special number to the WirelessConnect. WirelessConnect disconnects the
call once it is detected (without answering). Immediately the WirelessConnect calls the
user s GSM or other remote phone. The wireless portion of the call is usually free (in
most other countries, incoming wireless call are free), and the international portion are at
the worlds lowest rates - USA outbound dialing. User s can make multiple calls with a
single connection. Therefore, a wireless call from Paris to New York, is made at the
price of a land-line call from New York to Paris.... With the wireless portion free. The
toll savings are substantial!
Single voicemail box even if cell phone is dialed directly
Users can enjoy the convenience and consistency of using a single voicemail box on the
corporate voicemail system, eliminating cellular and home office voicemail (and their
associated cost). Even calls that are placed directly to the cellular phone, can be routeddirectly to user s corporate voicemail box with DirectRouteTM enabled on the
WirelessConnect.
Desktop replacement
Exhibit No. 25
page 8 of 11
Case No. QWE- T-02-
Teitzel, D. (REB) Qwest
April 21. 2003
Desktop phones are not necessary to offer users all of the advantages of the corporate
PBX or Centrex system. Users can be issued a Company extension, phone number and
voicemail box as though they had a standard desktop phone. . .. All without the expense
and administration of a PBX phone. Now, remote workers can feel part of the
organization, share voice messages with colleagues and have their callers get operator
assistance if necessary.
Branch office support
Wireless Connect can be an effective PBX replacement for a small branch office or
hoteling environment. The WirelessConnect can be located at a central facility servicing
the branch office with PBX functionality, without the need to locate a separate PBX and
voicemail server at the branch location. If desktop phones are required, WirelessConnect
can utilize standard Centrex lines, providing dual-ring capability with the desktop and
cellular phone saving the expense and administration of a local PBX.
Hoteling
WirelessConnect is the ideal employee hoteling solution. Since a user can detennine
their wired and wireless devices, individuals can temporarily "log-" to shared
workstations, without the assistance of an administrator allowing all of their calls to ring
their temporary office location while still maintaining their voicemail and otherindividual settings.
Single purpose cell phones
For the first time, Companies can distribute single-purpose wireless phones to their staff
without the potential liability of abuse. The cellular phone can be programmed on the
handset (or on the carrier s network) to only dial the WirelessConnect access number
regardless of digits dialed by the user. This setup effectively restricts the cell phone to
only make calls through the WirelessConnect. Since all calls are routed through the
WirelessConnect, the administrator can attach a PBX network class of service to each
individual user, restricting their dialing to internal extension only, or any other control
schema deemed appropriate. Furthennore, cell phone utilization can be automatically
disabled if a minute utilization threshold is exceeded, or even at certain times of day.
Real time control of all telecom utilization from cellular phones, home
office and calling cards
WirelessConnect offers unparallel control of corporate telecom costs. WirelessConnect
eliminates the need for dedicated home office phone lines (and the expense
reimbursement process) and corporate calling cards (which offer no control functions),
while tracking all telecom utilization real-time with the company s existing call
accounting process --- all while enjoying the reduced calling rates available on the
corporate infrastructure.
Reduced cost calling card replacement
Exhibit No. 25
page 9 of 11
Case No. QWE-O2-
TeitzeI, D. (REB) Qwest
April 21. 2003
With WirelessConnect calling cards become a thing of the past. Using the same access
number and authentication, remote users dialing through the WirelessConnect can enjoy
the lowest rates available (corporate land-line rates), while offering the CFO real-timemonitoring of utilization, and the ability to restrict users to a specific PBX network class
of service, offering enhanced control and fraud prevention from unauthorized calls not
available on calling cards.
Call restriction capability for all remote device
For the first time, the organization can have the same call restriction capability on all
voice devices for staff including, cell phones, home phones and calling card users.
Enhanced security and administrative control
By disabling a user profile in the WirelessConnect, the administrator can effectively
shutdown all remote devices of a user if so configured, allowing for immediate control of
abusive behavior.
Company control of employee contact points
Whether your industry is automobiles or phannaceuticals, mobile employees are gaining
increasing control of customer relationships. As with most mobile workers, their mobile
phone is likely their main point of contact for the customer --- where ever the mobile
numbers goes, so do the customer phone calls. With WirelessConnect, companies and
employees can publish the use of the corporate DID number for the mobile worker
enabling the employer to make an immediate redirection of all inbound calls for a
representative who is terminated. Seemless to the customer, and the company retains
ownership of the customer s contact point --- a critical factor in today s competitive
environment.
Single number solution
One person, one number. WirelessConnect allows the publishing of a single number for
all of your communication needs. Fax calls are automatically detected, and rerouted per
the user s profile settings, without ringing the desktop or cellular phone.
Control telecom utilization by time of day or day of week
Finally, you can restrict your voice network like your date network for authorized times
of use or days of week for added cost control and fraud protection.
Now you no longer need to control wireless utilization by physically collecting the
devices in off hours.
Single solution for all PBX platforms
Whether you run a homogeneous voice network world wide, of have a mixture of legacy
platforms, WirelessConnect is the single solution for all PBX installations making the
deployments of the WirelessConnect simple and scalable offering the same user
experience enterprise wide.
Disaster recovery
Exhibit No. 25
page 10 of 11
Case No. QWE- T-02-
Teitzel, D. (REB) Qwest
April 21. 2003
WirelessConnect is the only solution that can have all users in an enterprise receiving
calls in the event the PBX or central office is rendered inoperable. With multiple
WirelessConnect installations at separate locatio , each location may be set to
synchronize user databases with each other. Therefore, one location is no longer
available, the telephone company can redirect ALL company numbers to the alternate
location, and all calls will be immediately routed to the users remote phones. In addition
users will immediately have access again to the corporate voice network and dialtone
from the alternate PBX.
VolP compliant for next generation connectivity
WirelessConnect fully supports H.323 and SIP for connectivity to advanced networks, IP
PBXs and hybrid systems.
Remote voicemail notification with caller
When some leaves a message on your corporate voice mail, you get message notification
on your remote handset and/or PDA with the date, time and caller ID of the person who
left the message.
Reduced PBX administration
Many daily tasks such as moves/adds/changes to users is now actually easier, in many
instances eliminating the need to make any changes in the PBX. Administration is
simple and efficient local or remote via the WirelessConnect web based interface.
Increased individual user flexibility of ring counts, voicemail and other
features by empowering users
Your users can finally change their own usability setting (within the parameters set by the
administrator) for their extensions. Ring counts on the desk and cell phone, voice mail
notification, fax routing and many other functions easing the administrative burden of the
PBX and offering enhanced functionality and personalization of the user experience.
Exhibit No. 25
page 11 of 11
Case No. QWE-02-
Teitzel, D. (REB) Qwest
April 21. 2003
AT&T Wireless I Messaging - Home
_..=:::
Page 1 of 2
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Fire awayl Send, receive, and reply tomessages.
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Make friends and keep up on all thafs
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Sending and receiving messages is more fun
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join in a group chat. W~h AT&T WIreless, you
can communicate without limits, your way!
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Create messages with pictures, sound andtext.
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News. Weather. Entertainment. Horoscopes.
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let your favorite artlst-music or cartoon-be the messenger.Congrats. Birthday wishes. I'm sony. Keep In touch and say what
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"""""'1
...-.--..
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ring tones
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Golhere now.
HOT PROMOTIONS
TXT2 VOTE
)0 FINO OUT HOW
, AT&T WIRELESS
: COlUGE BASKETBALl
....
ONLINE 1'U,ORIAl
Take a look at our In-depth
how tos, customized to
your phone.
Trv It nowl
VIEW OEMC
Is the thumb a finger? Is
the tomato a fruit?
sea demo ::-
TEXT DICTIONARY
&:-J
1 am handsome wnh a
square jaw.
More lInao
THUMB FUN
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TImMS HAIKU
With X.O-O-cllck-sendmy two opposable (~endstap out a love note.
Thumbina II
Exhibit No. 26
page 1 of 4
Case No. QWE- T-02-
Teitzel, D. (REB) Qwest
Apri121.2003
AT&T Wireless 12-Way Text Messaging - How To Page 1 of 4
Datlcomhome DAT&TConsumer aAT&TBuslness aAT&TWlreless
Home I Order status I Store locator I Send a text message
===
features and UN ic..
mMode I messaging I ring lones & graphics I #121 voice services
text messaging
how 10
thumb fun
american idol sweeps
Instant messaging
multimedia messaging
multimedia alerts
games
community chat
phones
l1li Looking for
ring tones
Text messaging Is easy-follow these simple )~~t
:':~~~
steps. Ji.!I )0 Sendlna a text me_e from your wireless phone
I!iJ )0 Sendina a text messaae from your PC to a wireless phone TXT 2 YOTE)0 Recelvln a text messa e on our wireless hone
)0 ReDlvtna to a text me_e on your wireless phone
)0 How to tum on Predictive Text (T9)
)0 How to enter a space between words
)0 How to tooale between upper and lowercase letters )0 FIND OUT HOW
)0 How to enter slJeClal characters
)0 Tips tricks. & shortcuts
)0 Good to know
Jl1eSsaglng
DETAILED INSTRUCTIONS BY PHONE MODEL.
And If you want comprehensive Instructions for text messaging onyour particular phone model, we've got that, too.
)-
Go there now
SENDING A TEXT MESSAGE FROM YOUR WIRELESS PHONE...
To a wireless deYIc:e:
Select Menu.
Select Messages.
Select Text messages.
Select Write message or similar option from your
Messaging menu.
Using your phone keypad, enter your message (which can '
be up to 160 characters).
Select Opllons, and then Send.
Enter the 1!k!lgn mobile phone number or select a
number from your address book.
Select Send again.
" Some phone models prompt for the 1 O~lgn mobile phone number
first.
To an Internet e-mail address:
Select Menu.
Select Messages.
Select Text messages.
Select Write message or similar oplion from your
Messaging menu.
Using your phone keypad. first enter the e-man address
followed by a space.
Write your message (which can be up to 160 charactersIncluding the e-mail address).
Select Options, and then Send.
Send to 0000.
Select Send again.
http://www.attws.comlmessagingitextihowTo.jhtml
--.-.. L..
..........-...........
..i
,"1,1,. TOOtS.1;. TOYS
HOT PROMOTIONS
AT&.TWIRElESS
COLLEGE BASKETBALL
Ot/UHf TUTORIAL
Take a look at our In-depth
how tos, cuslomized to
your phone.
Try n nowl
VIEW DEMO
Is the thumb a flnger1ls
the tomato a fruit?
sl!e demo :=-
TEXT DICTIONARY
&:-)
I am handsome with a
square jaw.
More UnQo
rHUMB rUN
~qr \i\v:;~'d......
. .
"4c "
THUMB HAIKU
WIth X.X-O-O-click-send
my two opposable frtends
tap out a love nole.
)Thumbln
Exhibit No. 26
page 2 of 4
Case No. QWE- T-02-
Teitzel, D. (REB) Qwest
Apri121.2003
AT&T Wireless 12-Way Text Messaging - How To
Back to too
SENDING A TEXT MESSAGE FROM YOUR PC TO A WIRELESS
PHONE...
From Internet e-mail:
Address the e-mail to the 1O-dlgit wireless phone number followed by
IIDmoblle.att.net. For example, If the phones number is206.123.4567, then the e-mail address Is: 2O6123456711Dmobile.att.net.
From the attwlreless.comItext site:
Visit attwlreless.comllext.
Click Send messages.
Enter the following:
1. TO: (the 1O-digit wireless phone number)
2. FROM:3. SUBJECT:
4. MESSAGE: (110-character limit)
Click Send message.
Back to too
RECEMNG A TEXT MESSAGE ON YOUR WIRELESS PHONE
Your phone will notify you that you have received a newtext message; the words "Message received" and anenvelope icon will appear In the display. (VIsual notification
varies, depending on the make and model of your phone.
Use the scroll keys (up, down) on your keypad to review
the entire message.
Then choose to either reply, forward, save, or delete themessage.
Back to too
REPLYING TO A TEXT MESSAGE ON YOUR WIRELESS PHONE
After reading a text message, you can reply by selectingOptions, then Reply.
Type your message, select Options, and then select Send.
That's itl Your phone automatically takes care of the addressing.
Back to too
HOW TO TURN ON PREDICTIVE TEXT(T9)
Nokia
While typing a text message, select OpUons, then scroll to
Predictive Tex\" or "Dictionary" (depending on the phone),then press Selact.
Choose the appropriate language, such as English.
Then select OK or Select.
Ericsson TB8
While typing a text message, press and hold the pound key (#)
repeatedly (that Is, press and hold, press and hold, and so on) until"T9 English. appears.
Panasonlc
While typing a message, press the upper-right soft key until "WordT9" is displayed.
Motorola V80, Tlmeport, and T193
While typing a text message, press the menu key andscroll to the appropriate entry method, such as iTAP
English or ITAP Espanol.
You may have to press Select.
Back to too
HOW TO ENTER A SPACE BETWEEN WORDS
http://www,attws.comlmessaging/textihowTo.jhtml
Page 2 of 4
Exhibit No. 26
page 3 of 4
Case No. QWE- T -02-
Teitzel, D. (REB) Qwest
Apri121,2003
AT&T Wireless 12-Way Text Messaging - How To
While typing a text message, press 0 or 1 (depending on your phone
model) to enter a space.
Back to top
HOW TO TOGGLE BETWEEN UPPER AND LOWERCASE
LETTERS
Nokia, Ericsson, and Panasonlc
While typing a text message, press the pound (#) or star (') key totoggle between upper and lowercase letters.
Motorola T193, Tlmeport
While typing a text message, press and hold the appropriate key. For
example, ~ you want a capital.A" press and hold the 2 (abc) key.
Motorola TeO, V2397
While typing a text message, press the upper and lower arrows to
toggle between uppercase and lowercase.
Back to too
HOW TO ENTER SPECIAL CHARACTERS
Nokia
While typing a text message. press the star key (.
Scroll to select the desired symbol. Select Insert or Use.
Ericsson
While typing a text message, press the pound key (#),
then 0 or the star key (0) repeatedly until the desired
symbol appears.
You may have to select Yes to insert the symbol.
Panasonlc
While typing a message, press the right soft key until
SYM" Is displayed.
To scroll through the symbols. press the arrow keys (,,:0)
or the star key ('
To select the desired symbol, press the number that
conesponds to that symbol.
Motorola veo
While typing the message, press the Menu key, then
select Symbol from the menu.
Press the number that corresponds to the desired symbol.
Press Select to enter the symbol.
Motorola V2397
While typing the message, press the 1 or 0 key repeatedly
until the desired symbol is displayed.
Back to top
TIPS, TRICKS, & SHORTCUTS
. Instead of entering the 10-lllgil wireless number, you can select an
entry from your phones address book.
. Instead of completely typing out your lext message, useabbreviations such as 2nite (tonight) and THNO (thank you).
. Instead of repeatedly typing the same words, turn on your phonepredictive text feature. Refer to your phone manual for detailedInstructions.
Back to toP
GOOD TO KNOW
Maximum message length Is up to 160 characters, which Includes
the e-mail address. Any characters over the maximum wRI be omitted
from the message sent.
If your phone is turned off, your phones memory Is full, or you areoutside the service area, the network will store and resend any
message for up to 72 hours. Messages not delivered after 72 hours
wRI be deleted.
Coveraae Map
Back to toD
http://www.attws.comlmessaging/text/howTo.jhtml
Page 3 of 4
Exhibit No. 26
page 4 of 4
Case No. QWE-02-
Teitzel, D. (REB) Qwest
April 21 , 2003
wireless fax
WIRELESS FAX BJ8C:!
PM70 mobile fax and phone
The Posslo PM70 Mobile Fax and Phone Is a flexible and
lightweight mobile device that allows you to send and
receive fax messages on paper, perform voice calls, and
print incoming SMS. The Posslo PM70 connects to the
latest cellular phones, such as the Possio Connectivity
Card (PCe). The Posslo PM70 and PCC together are a
stand alone mobile fax and phone.
The Posslo PM70 is used every day, all around the world
by business travellers, transportation companies, fire and
rescue services, and other professionals who require
information on paper.
The Possio Connectivity Card (PCe) is a full featured trlple-
band cellular card phone. It Is designed by Possio for
complete integration with the PM70 Mobile Fax and Phone.ill
PMBO
The PM80 is no longer offered for sale by Possio but is still
available at some of our retailers around the world. Possio
offers extensive support for the PM80.
.111111111181..
The PMBO battery-less version Is still
!.........
available for purchase from Komsa,
Germany.
. View the list of retailers.
. Visit the PM80 Support.
.2003-01-70 up I print
http://www . possio .com!.../ default. asp ?dynfile=mobilefax&id=english&pJ
Page 1 of 1
Exhibit No. 27
page 1 of 1
Case No. QWE-02-
Teitzel, D. (REB) Qwest
Apri121 2003
CERTIFICATE OF SERVICE
I hereby certify that on this 21 st day of April, 2003, I served the foregoing REBUTTAL
TESTIMONY OF DAVID L. TEITZEL ON BEHALF OF QWEST CORPORATION upon
all parties of record in this matter as follows:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, ill 83720-0074
Phone: [phone]
Fax: [phone]
ii ewell(0,puc.state.id. us
Weldon Stutzman, Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington Street
o. Box 83720
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
W stutzmCcvpuc.state.id. us
Marlin D. AId
Willard L. Forsyth
Hershner, Hunter, Andrews, Neill & Smith LLP
180 East 11 th Avenue
O. Box 1475
Eugene, OR 97440-1475
Attorneys for Verizon
Executed protective agreement
John Gannon, Esq.
1101 West River - Suite 110
Boise, ill 83702
Telephone: [phone]
Attorney for Meierotto, Padget, Herrick Neal
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Hand Delivery~ U.Mail
Overnight Delivery
Facsimile
Email
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Dean J. Miller
McDevitt & Miller LLP
420 West Bannock Street
O. Box 2565
Boise, ill 83701
Telephone: [phone]
Facsimile: [phone]
i oe~mcdevitt- miller. com
Attorneys for World Com, Inc.
Attorneys for AT&T
Attorneys for Time Warner Telecom
Executed protective agreement
Dean Randall
Verizon Northwest Inc.
17933 NW Evergreen Parkway
Beaverton, OR 97006-7438
dean.randall~verizon. com
Executed protective agreement
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Hand Delivery
--.2L U. S. Mail
Overnight Delivery
Facsimile
Email
Mary Jane Rasher
10005 South Gwendelyn Lane
Highlands Ranch, CO 80129-6217
Telephone: [phone]
mirasher~msn.com
Hand Delivery
--.2L u. S. Mail
Overnight Delivery
Facsimile
Email
Adam Sherr
Qwest
1600 ih Avenue - Room 3206
Seattle, W A 98191
Telephone: [phone]
Facsimile: [phone]
asherr~qwest.com
Hand Delivery
--.2L U. S. Mail
Overnight Delivery
Facsimile
Email
Clay R. Sturgis
Moss Adams LLP
601 West Riverside - Suite 1800
Spokane, W A 99201-0663
Hand Delivery
--.2L U. S. Mail
Overnight Delivery
Facsimile
Email
Brian Thomas
TimeWarner Telecom
223 Taylor Avenue North
Seattle, W A 98109
Brian. Thomas~twtelecom.com
Hand Delivery
--.2L U. S. Mail
Overnight Delivery
Facsimile
Email
Susan Travis
WorldCom, Inc.
707 1 ih Street - Suite 4200
Denver, CO 80202
Telephone: [phone]
Susan. a. Travis~worldcom.com
Conley E. Ward, II.
Givens Pursley LLP
277 North 6th Street - Suite 200
O. Box 2720
Boise, ill 83701-2720
Telephone: [phone]
Facsimile: [phone]
cew~givenspursley.com
Attorneys for Idaho Telephone Association
Executed protective agreement
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Hand Delivery
-.lL U. S. Mail
Overnight Delivery
Facsimile
Email
6t~ '/f? ~/zd
Brandi L. Gearhart, PLS
Legal Secretary to Mary S. Hobson
Stoel Rives LLP