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Mary S. Hobson, ISB #2142
Stoel Rives LLP
101 S. Capitol Blvd., Suite 1900
Boise, ill 83702-5958
Telephone: [phone]
Facsimile: [phone]
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Thomas M. Dethlefs
Qwest Services Corporation
1801 California Street - 10th Floor
Denver, CO 80202-1984
Telephone: [phone]
Facsimile: [phone]
Attorneys Representing Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF LEVEL 3
COMMUNICATIONS, LLC'S PETITION FOR
ARBITRATION PURSUANT TO SECTION
252(B) OF THE COMMUNICATIONS ACT
OF 1934, AS AMENDED BY THE
TELECOMMUNICATIONS ACT OF 1996,
AND THE APPLICABLE ST ATE LAWS FOR
RATE, TERMS, AND CONDITIONS OF
INTERCONNECTION WITH QWEST
CORPORATION
CASE NO. QWE-05-
DIRECT TESTIMONY OF
PHILIP LINSE
QWEST CORPORATION
AUGUST 12, 2005
(Disputed Issue Nos. 1 , 2, 6, 8 and 20)
Boise-186365.1 0061273-00018
TABLE OF CONTENTS
Page
IDENTIFICATION OF WITNESS .......................................................................
II.PURPOSE OF TESTIMONY.....
........... ......... ........ ............ .....
..................... ......... 2
III.DISPUTED ISSUE NO.1: COSTS OF INTERCONNECTION ......................... 3
IV.DISPUTED ISSUES NO. 2A AND 2B: ALL TRAFFIC ON
INTERCONNECTION TRUNKS .......................................................................
DISPUTED ISSUE NO.6: AMA SWITCH TECHNOLOGY.......................... 40
VI.DISPUTED ISSUE NO.8: DEFINITION OF CALL RECORD....................... 41
VII.DISPUTED ISSUE NO. 20: SIGNALING PARAMETERS ............................. 48
VIII. SUMMARY/CONCLUSION .............. .................... ........ ........... .................. ....... 57
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IDENTIFICATION OF WITNESS
PLEASE STATE YOUR NAME, BUSINESS ADDRESS AND POSITION
WITH QWEST CORPORATION.
My name is Philip Linse. My business address is 700 West Mineral Avenue
Littleton Colorado. I am employed as Director - Technical Regulatory in the
Network Policy Organization. I am testifYing on behalf of Qwest Corporation
Qwest"
PLEASE GIVE A BRIEF BACKGROUND OF YOUR EDUCATIONAL
AND TELEPHONE COMPANY EXPERIENCE.
I received a Bachelors degree from the University of Northern Iowa in 1994. I
began my career in the telephone communications industry in 1995 when I joined
the engineering department of CDI Telecommunications in Missoula, Montana.
In 1998, I accepted a position with Pacific Bell as a Technology Planner with
responsibility for analyzing network capacity. In 2000, I accepted a position with
U S WEST as a Manager, Tactical Planning. In 2001 , I was promoted to a staff
position in Technical Regulatory Interconnection Planning for Qwest. In this
position, I developed network strategies for interconnection of unbundled
Switching, Signaling System 7 ("SS7") and other switching-related products.
responsibilities also included the development of network strategies based on the
evaluation of new technologies. I was one of the network organization s subject
matter experts. In 2003 , I was promoted to my current position as Director of
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Page
Technical Regulatory in the Network organization. Since my promotion in 2003
the Technical Regulatory group has been realigned and is now part of the Policy
organization. In addition to my oversight responsibilities of Qwest's network
regulatory interconnection and switching requirements for sections 251 and 252
of the Telecommunications Act of 1996, I also develop and direct the
implementation of network policies. In addition to these internal functions, I also
represent Qwest in industry technical standards setting groups such as the FCC'
Network Reliability and Interoperability Council ("NRIC") and the Network
Interconnection Interoperability Forum ("NIIF"
II.PURPOSE OF TESTIMONY
WHAT IS THE PURPOSE OF YOUR TESTIMONY?
The purpose of my testimony is to detail Qwest's positions, from a technical
perspective, as they relate to certain disputed issues between the parties. My
testimony will show that the Qwest position on these issues is reasonable
appropriate and more than adequately provides for the interconnection needs of
Level 3. Specifically, my testimony will address the following issues from the
Matrix of Unresolved Issues filed by Level 3 in this arbitration:
Issue 1:Costs of Interconnection
Issue 2:Combining Traffic on Interconnection Trunks
Issue 6:AMA and Switch Technology
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Issue No. lA
Issue 8: Definition of Call Record
Issue 20: Signaling Parameters
In port~ons of my testimony that follow, where the disputed language is similar
but contain modifications to Qwest's language, I have underlined the language
that Level 3 wishes to delete or add.
III.DISPUTED ISSUE NO.1: COSTS OF INTERCONNECTION
PLEASE EXPLAIN DISPUTED ISSUE NO. lA.
Issue lA involves disputed language regarding points of interconnection. Level3
mischaracterizes the issue as having to do with its right to interconnect at a single
point in the LATA and Qwest'obligation on its , side of the Point of
Interconnection ("POI"). However, Qwest believes that the POI is not the real
issue here. The real issue is whether Qwest should be required to provide
interconnection where it is not technically feasible or to provisionlbuild transport
facilities to Level 3 without compensation for the provisioninglbuilding of such
transport facilities. As such, the real issue here is one of Level 3 not wanting to
compensate Qwest for the u~e of its network. Whereas my testimony addresses
Issue 1A from a technical perspective, the testimony of Bill Easton will more
fully address compensation issues and why Level 3 is required to compensate
Qwest for interconnection facilities provided by Qwest.
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WHAT LANGUAGE DOES QWEST PROPOSE?
Qwest proposes the following language, which is also found on page 66 of the
interconnection agreement ("ICA") filed by Qwest with its Supplement to Initial
Response to Petition for Arbitration on June 28, 2005. The ICA contains the
language proposed by Qwest juxtaposed against the language proposed by Level
This Section describes the Interconnection of
Qwest's network and CLEC's network for the purpose ofexchanging Exchange Service (EAS/Local traffic ),
Exchange Access (IntraLA T A Toll carried solely by local
exchange carriers), ISP-Bound traffic, and Jointly Provided
Switched Access (InterLATA and IntraLATA) traffic.
Qwest will provide Interconnection at any Technically
Feasible point within its network. Interconnection, which
Qwest currently names "Local Interconnection Service
(LIS), is provided for the purpose of connecting End Office
Switches to End Office Switches or End Office Switches to
local or Access Tandem Switches for the exchange
Exchange Service (EAS/Local traffic); or End Office
Switches to Access Tandem Switches for the exchange of
Exchange Access (IntraLA T A Toll carried solely by local
exchange carriers) or Jointly Provided Switched Access
traffic. Qwest Tandem Switch to CLEC Tandem Switch
connections will be provided where Technically Feasible.
New or continued Qwest local Tandem Switch to Qwest
Access Tandem Switch and Qwest Access Tandem Switch
to Qwest Access Tandem Switch connections. are not
required where Qwest can demonstrate that such
connections present a risk of Switch exhaust and that
Qwest does not make similar use of its network to transport
the local calls of its own or any Affiliate s End User
Customers.
1 CLEC agrees to allow Qwest to conduct
operational verification audits of those network elements
controlled by CLEC and to work cooperatively with Qwest
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to conduct an operational verification audit of any other
provider that CLEC used to originate, route and transport
VoIP traffic that is delivered to Qwest, as well as to make
available any supporting documentation and records in
order to ensure CLEC's compliance with the obligations set
forth in the VoIP definition and elsewhere in this
Agreement. Qwest shall have the right to redefine this
traffic as Switched Access in the event of an "operational
verification audit failure . An "operational verification
audit failure" is defined as: (a) Qwest's inability to conduct
a post-provisioning operational verification audit due to
insufficient cooperation by CLEC or CLEC'other
providers, or (b) a determination by Qwest in a post-
provisioning operational verification audit that the CLEC
or CLEC's end users are not originating in a manner
consistent with the obligations set forth in the VoIP
definition and elsewhere in this Agreement.
2 Prior to using Local Interconnection Service
trunks to terminate VoIP traffic, CLEC certifies that the (a)
types of equipment VoIP end users will use are consistent
with the origination of VoIP as defined in this Agreement;
and (b) types of configurations that VoIP end users will use
to originate calls using IP technology are consistent with
the VoIP configuration as defined in this Agreement.
WHAT LANGUAGE DOES LEVEL 3 PROPOSE?
Level 3 proposes the following:
This Section describes the Interconnection of
Qwest's network and CLEC's network for the purpose ofexchanging Telecommunications Including Telephone
Exchange Service And Exchange Access traffic. Qwest
will provide Interconnection at any Technically Feasible
point within its network.
1.1.1 Establishment of SPOI: Qwest agrees to
provide CLEC a Single Point of Interconnection (SPOI) in
each Local Access Transport Area (LATA)
..
for the
exchange of all telecommunications traffic. The SPOI may
be established at any mutually agreeable location within the
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LATA, or, at Level 3' s sole option, at any technically
feasible point on Qwest's network. Technically feasible
points include but are not limited to Qwest's end offices
access tandem, and local tandem offices.
2 Cost Responsibility. Each Party
responsible for constructing, maintaining, and operating all
facilities on its side of the SPOI, subject only to the
payment of intercarrier compensation in accordance with
Applicable Law. In accordance with FCC Rule 51. 703(b),
neither Party may assess any charges on the other Party for
the origination of any telecommunications delivered to the
other Party at the SPOI, except for Telephone Toll Service
traffic outbound from one Party to the other when the other
Party is acting in the capacity of a provider of Telephone
Toll Service, to which originating access charges properly
apply.
1.3 Facilities included/transmission rates.
Each SPOI to be established under the terms of this
Attachment shall be deemed to include any and all facilities
necessary for the exchange of traffic between Qwest's and
Level3's respective networks within a LATA. Each Party
may use an Entrance Facility (EF), Expanded Interconnect
Channel Termination (EICT), or Mid Span Meet Point
Interconnection (POI) and/or Direct Trunked Transport
(DTT) at DS 1 , DS3 , OC3 or higher transmission rates as
in that Party s reasonable judgment, is appropriate in light
of the actual and anticipated volume of traffic to beexchanged. If one Party seeks to establish a higher
transmission rate facility than the other Party would
establish, the other Party shall nonetheless reasonably
accommodate the Party'decision to use higher
transmission rate facilities.
1.4 Each Party Shall Charge Reciprocal
Compensation for the Termination of Traffic to be carried.
All telecommunications of all types shall be exchanged
between the Parties by means of from the physical facilities
established at Single Point of Interconnection Per LATA
onto its Network Consistent With Section 51.703 of the
FCC's Rules:
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1.4.Level 3 may interconnect
with Qwest at any technically feasible point on Qwest'
network for the exchange of telecommunications traffic.
Such technically feasible points include but are not limited
to Qwest access tandems or Qwest local tandems. When
CLEC is interconnected at the SPOI. separate trunk groups
for separate types of traffic may be established in
accordance with the terms hereof. No separate physical
interconnection facilities, as opposed to separate trunk
groups within SPOI facilities, shall be established except
upon'express mutual agreement of the Parties.
WHY DOES QWEST OBJECT TO LEVEL 3'S PROPOSED LANGUAGE?
As Mr. Easton s testimony explains, the POI is not necessarily the financial
demarcation point between Level 3 and Qwest. Level 3 also incorrectly defines
its POI as a point that is physically located on Qwest's network. In addition Level
3' s proposed language is inconsistent and attempts to extend Qwest'
interconnection responsibility until it stretches from any point on the Qwest
network to a points that are not even within Qwest's serving territory. Level 3'
proposed language would impose a requirement on Qwest to accept traffic where
there are technical limitations and requires higher transmission rates than may be
necessary or justified. Qwest also disputes the portions of Level 3' s proposed
language in Issue No. lA as they apply or support other issues in dispute. The
testimony of Larry Brotherson addresses the portions of Issue No.1A that concern
Voice over Internet Protocol ("VoIP"
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DOES QWEST'LANGUAGE PROHIBIT SIN GLE POINT
INTERCONNECTION?
No. Qwest's proposed language does not prohibit Single Point of Interconnection
SPOI"); in fact it allows for SPOI under conditions that have been found
acceptable by other similarly situated carriers and commissions throughout
Qwest's 14 state territory, including Idaho.As I will explain later in my
testimony when addressing issue IB, Level 3 has multiple methods available to it
to establish interconnection to its POI under Qwest's proposed language. Qwest'
position is that it is entitled to compensation for the facilities Qwest provides to
enable Level3's selection of a SPOI.
WHAT IS SINGLE POINT OF INTERCONNECTION?
A SPOI is a physical demarcation point where Level 3 and Qwest can exchange
traffic originating from or destined formultiple Qwest end offices within a LATA
using Qwest provided transport facilities between Level 3' s network and Qwest's
network. This allows Level 3 to serve customers that are located in different
Qwest exchanges without having to build its own interconnection facilities to
each exchange where Level 3 wishes to provide local service. As my testimony
will explain when addressing issue 1B there are multiple methods of
interconnection that would allow Level 3 to establish these transport facilities
between Qwest and Level3's SPOI.
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, 4
IS LEVEL 3 CORRECT TO SUGGEST THAT IT MAY ESTABLISH ITS
POI ON QWEST'S NETWORK?
No. While a POI may be located within a Qwest office, interconnection
accomplished by means of cross-connections between components of Qwest'
network and components of the interconnecting CLEC's network. These cross-
connections are the physical demarcation point between the networks and
facilitate the exchange of traffic between two separate networks. Level 3'
language incorrectly and inappropriately suggests that it has the right to establish
a POI that is directly connected to Qwest's equipment.What Level 3
requesting, in actuality, is integration into Qwest's network, and not
interconnection with Qwest's network. Level 3's proposal prevents Qwest from
retaining sole responsibility for the management, control, and performance of its
own network and is contrary to the intent of the Ace. It is Qwest's position that
interconnection is appropriately obtained by establishing a demarcation point (or
POI) between Qwest's network and Level3's network.
WHAT IS A DEMARCATION POINT?
A demarcation point is a point where the facilities of two networks meet. This
allows each network operator to maintain and control the performance of its
respective network without potential adverse impacts that may be created by the
FCC 96-325, First Report And Order, ~ 203 Aug. 8th 1996.
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other network operator. Such demarcation points can include such locations as a
main distribution frame. 2 The demarcation point between Qwest and CLECs
including Level 3 is its POI.Without a demarcation point where the two
networks can meet, neither Qwest nor Level 3 may be assured the ability to
maintain or control the performance of its network.
ARE THERE OPTIONS AVAILABLE LEVEL FOR
ESTABLISHING A DEMARCATION POINT/POI?
Yes. For Level 3 to establish interconnection with Qwest, Level 3 must create its
PO~ for demarcation at a point in each LATA within Qwest's serving territory.
Level 3 would then choose a method of interconnection that best fits its needs.
The methods for establishing interconnection are explained in my testimony for
Issue lB.
HOW IS LEVEL 3'S PROPOSED LANGUAGE INCONSISTENT?
Level 3' s language is inconsistent because it describes interconnection "within
Qwest's network in section 7.1.1 and then "" Qwest's network in section
1.4 and 7.l.4.1. While Qwest agrees that the word "within" represents
interconnection within Qwest's serving territory, the use of "" in Level 3'
proposed language increases the potential for future disputes.
FCC 96-325, First Report And Order, ~ 210, Aug. 8th 1996.
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HOW MIGHT LEVEL 3'S PROPOSED LANGUAGE OBLIGATE QWEST
TO EXCHANGE TRAFFIC WHERE IT IS NOT TECHNICALLY
FEASIBLE?
Level 3' s proposed language obligates Qwest to accept telecommunications
traffic of all types through Level 3' s SPOI at any technically feasible point. All
types of telecommunications traffic includes toll traffic. Level 3 then defines the
technically feasible points to include Qwest's access tandems and local tandems.
Qwest's network currently consists of a combination of access tandems for the
routing of toll traffic, and local tandems for the routing of local traffic. Qwest'
local tandem architecture, however, does not have the capability of routing toll
traffic. Qwest's local tandems do not have the connections to end offices and to
other carriers that would allow for the appropriate routing of traffic that is not
local to the end offices that subtend each local tandem. To achieve that capability
would require a substantial modification of Qwest' s current network, which is not
an obligation under the Act. Level 3 proposes language which would permit it to
insist on interconnecting at points where it is technically feasible.
WOULD THE ESTABLISHMENT OF A SINGLE POI IN A LATA
REQUIRE LEVEL 3'S USE OF QWEST'S NETWORK?
Yes.To facilitate the connection between Level 3's network and Qwest'
network Level 3 must establish a POI for its network. Then transport facilities
would be typically provisioned or built by Qwest to Level 3' s POI to connect the
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two networks. This transport is typically used for the sole purpose of Level 3'
interconnection with Qwest. Level 3' s decision to interconnect with Qwest is a
decision made solely by Level 3.
IS IT APPROPRIATE TO REQUIRE HIGHER TRANSMISSION RATES
WHEN TRAFFIC VOLUME DOES NOT JUSTIFY IT?
No. Level3's language proposes that each party provide higher transmission rates
upon the request of the other party. This would force the placement or the
augmentation of facilities to Qwest's existing network. Again, this is a
redefinition of Qwest's obligation and a modification of its existing architectures
and netw~rk capabilities. The argument for adequate facilities to deliver higher
transmission rates as proposed by Level 3 would promote inefficient use of the
network. It is inappropriate and unreasonable to expect the upgrading of facilities
or the adding of unnecessary capacity to the network when the network demand
for such capacity is possibly not justified.
WHAT PORTIONS OF ISSUE NO. lA ARE ADDRESSED ELSEWHERE
IN THIS ARBITRATION?
Level 3' s language at 7.1.1.1 , 7.1.1.2 and 7.1.1.4.1 suggests that Level 3 be
allowed to route switched access traffic over interconnection trunks.This
language implicates Issue No.2 and as described in my testimony for Issue No.
Qwest objects to Level3's language.
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Issue No. IB
PLEASE EXPLAIN DISPUTED ISSUE NO. lB.
Issue 1B, on page 68 of the ICA, involves disputed language in which Level 3
incorrectly proposes methods of establishing its POI that are actually methods of
interconnection.
WHAT LANGUAGE DOES QWEST PROPOSE?
Qwest proposes the following:
Methods of Interconnection
The Parties will negotiate the facilities arrangement used to
interconnect their respective networks. CLEC shall
establish at least one (1) physical Point of Interconnection
in Qwest territory in each LATA CLEC has local
Customers. The Parties shall establish through
negotiations at least one (1) of the following
Interconnection arrangements, at any Technically Feasible
point: (1) a DS 1 or DS3 Qwest provided facility; (2)
Collocation; (3) negotiated Mid-Span Meet POI facilities;or (4) other Technically Feasible methods of
Interconnection, such as an OCn Qwest provided facility,
via the Bona Fide Request (BFR) process unless a
particular arrangement has been previously provided to a
third party, or is offered by Qwest as a product. OCn
Qwest provided facilities may be ordered through FCC
Tariff No.
WHAT LANGUAGE DOES LEVEL 3 PROPOSE?
Level 3 proposes the following:
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Methods of Interconnection
CLEC may establish a POI through: (1) a collocation site
established by CLEC at a Qwest wire center, (2) a
collocation site established by a third party at Qwest wire
center, or (3) transport (and entrance facilities where
applicable).
CLEC shall establish one POI at any technically feasible
point on Qwest's network within each LATA in which
CLEC desires to exchange traffic directly with Qwest by
any of the following methods:
1. a collocation site established by CLEC at a Qwest
Wire Center2. a collocation site established by a third party at
Qwest Wire Center, or;3. transport (and entrance facilities where applicable)
ordered and purchased by CLEC from Qwest; or
Fiber meet point.
CLEC shall establish one POI on Qwest's network in each
LATA. POls maybe established by CLEC through:1. a collocation site established by CLEC at a Qwest
Wire Center2. a collocation site established by a third party at
Qwest Wire Center3. transport (and entrance facilities where applicable)
ordered and purchased by CLEC from Qwest at the
applicable Qwest intrastate access rates and charges; or
Fiber meet point.
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WHAT CONCERNS DOES QWEST HAVE WITH LEVEL 3'
LANGUAGE?
Level 3' s proposed language confuses the methods of obtaining interconnection
with establishment of its POI "within" Qwest's network. Level3's language sets
a requirement to interconnect "" Qwest's network and then lists facility
arrangements or methods used to interconnect with Qwest.
WHAT THE DIFFERENCE BETWEEN POINT
INTERCONNECTION AND INTERCONNECTION?
As I have explained above, a POI is the physical demarcation point to which
Level 3 may have Qwest provisionlbuild transport facilities between Level 3'
network and Qwest's network. This demarcation point/POIallows separation of
responsibility for the respective network operators to maintain and control the
performance of each network. Interconnection, on the other hand, includes the
actual establishment of the transport connection between Level 3' s POI and
Qwest's network.
WHAT FACILITY ARRANGEMENTS DOES QWEST PROVIDE FOR
INTERCONNECTION WITH LEVEL 3?
There are four facility arrangements or methods of establishing interconnection
with Qwest: (1) DS 1 or DS3 Qwest provided facility; (2) Collocation; (3)
negotiated Mid-Span Meet POI facilities; and (4) other Technically Feasible
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methods of Interconnection. Level 3 may use any or all of these options to
establish interconnection with Qwest.
The "DS 1 or DS3 Qwest provided facility is an option for establishing
interconnection where Qwest provisionslbuilds a transport facility to the Level 3
POI either at the DSI level of transmission or at a DS3 level of transmission.
DS 1 s and DS3s are merely different bandwidths or capacities of transport
facilities that Qwest provisionslbuilds to Level 3' s POI that are located within the
same Qwest wire center. The Qwest provided facility described here is also
known as an entrance facility.
Collocation is an option by which Level-3 may extend its facilities into a Qwest
central office and terminate them to collocate within that central office to
establish a POI. Qwest would then provisionlbuild interconnection facilities to
the Level 3 Collocation. This Collocation may also be a third party Collocation.
Negotiated Mid-Span Meet POI facilities" is an option where Level 3 extends its
own facilities to a negotiated point approximately half way between the Level 3
SPOI and Qwest's wire center building. With this arrangement, Level 3 builds its
portion of the transport facilities while Qwest builds its portion of its transport
facilities to an agreeable location for interconnection at the midpoint between
Level 3's POI and Qwest's network. This allows Level 3 and Qwest to equally
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share in the cost of building the transport required for Level 3 to interconnect with
Qwest.
Other Technically Feasible methods of Interconnection" is an option when there
is an alternate method of interconnection. This is done through a Bona Fide
Request ("BFR"
).
The BFR enables Qwest to validate the technical feasibility of
the alternate method to facilitate interconnection. Interconnection is not the only
use of the BFR. A BFR can be used for other requests such as those associated
with access to Unbundled Network Elements that may not be available.
PLEASE SUMMARIZE WHAT THESE OPTIONS PROVIDE?
These options provide Level 3 the flexibility to have Qwest build facilities to
Level 3 , or have Level 3 build to Qwest's wire center (Collocation), or meet
somewhere in the middle. Qwest also provides the flexibility to use an alternate
technical feasible method not covered by the previous three options.
ARE THERE ANY OTHER FACILITIES THAT MAY BE REQUIRED
FOR INTERCONNECTION?
On occasion, yes. For example, if Level 3 has established its POI in a particular
Qwest wire center and then wishes to interconnect with switches located in other
Qwest wire centers, then Direct Trunked Transport could be supplied by Qwest to
connect Level3's POI to these other Qwest switches.
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IS LEVEL 3'S PROPOSED LANGUAGE CONSISTENT WITH THESE
METHODS OF INTERCONNECTION?
No. Level 3's proposed language mischaracterizes these methods as a way to
establish its POI rather than the methods by which to connect its POI to the Qwest
network. However, among these methods, only one involves establishing a POI
and the others provide the underlYing transport for interconnection to Level 3'
POI. Although Collocation does not provide interconnection, it does provide the
basis of the facility arrangements needed to establish interconnection.For
example, if Level 3 were to collocate in a Qwest central office, the Collocation
only provides Level 3 with space within the Qwest central office to establish
Level 3's POI. Interconnection facilities would then have to be provisioned to
Level 3's Collocation POI. Such a facility could be as simple as a wire jumper
that connects existing Qwest transport facilities with Level 3' s facilities.
In short, interconnection is provided after a POI is established. Each of the
methods my testimony describes above are methods for establishing the transport
for interconnection or in the case of Collocation for establishing the basis of the
facility arrangement to obtain interconnection.
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WHAT SERVICE DOES QWEST PROVIDE THAT USES THESE
FACILITY ARRANGEMENTS FOR THE EXCHANGE OF TRAFFIC?
Qwest provides Local Interconnect Service ("LIS"using these facility
arrangements. Qwest will and does provision LIS to Level 3 using the facility
arrangement that Level 3 has found best fits its needs.
WHAT IS LIS?
LIS is a bundled trunk-side service that provides switching and transport for the
mutual exchange of traffic that originates and terminates within a Qwest Local
Calling Area (LCA) or an Extended Area Service (EAS) exchange. LIS provides
the logical connections that are necessary for the exchange of traffic and are
established over the physical facility arrangement that is chosen by Level 3 to
connect Level3's POI with Qwest's network.
HOW IS LIS PROVISIONED TO INTERCONNECT LEVEL 3 AND
QWEST?
LIS is provisioned by using transport facilities and logical trunk connections that
are programmed into Qwest'switches.Switches are also equipped with
interfaces so that they may be connected to one another with transport facilities.
The facility options my testimony describes above are the transport options Level
3 may use to connect its switches with Qwest's switches.Logical trunk
connections then must be created to allow calls to be routed onto and off of these
facilities in order for telecommunications traffic to flow between the switches.
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Both Qwest and Level 3 must coordinate the creation of these trunks during the
provisioning of LIS. Each trunk that is created between switches allows a voice
conversation to take place between the switches. Each switch must have a trunk
connection for a call to route to the other switch. Based on the coordinated
provisioning of LIS, each switch is programmed to know which trunk to route the
call across using the subscriber s dialed digits as directions. The switch would
then route the call to the predetermined trunk that connects the two switches for
completion of the call.
WHAT TRUNKING OPTIONS ARE THERE FOR LIS?
There are essentially four local trunking options available to Level 3: (1) LIS to
Qwest's End Office; (2) LIS to Qwest's local tandem; (3) LIS to Qwest's access
tandem; and (4) Single Point of Presence ("SPOP"
LIS to Qwest's End Office allows for Level 3 to send and receive its end users
local traffic to and from each end office that Level 3 has established LIS.
LIS to Qwest's local tandem allows for Level 3 to send and receive its end users
local traffic to and from a local tandem for delivery of that traffic to and from all
end offices that subtend that local tandem. This traffic may also consist of transit
traffic to a third local carrier.
LIS to Qwest's access tandem allows for Level 3 to send and receive its end
users' traffic to and from IXCs that are connected to that access tandem. This
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traffic may also consist of IntraLATA transit traffic to a third local carrier. In
addition, Level 3 may send intraLA T A toll that its end users originate.
SPOP allows for Level 3 to send and receive its end users' local traffic to and
from all end offices that subtend Qwest's access tandem. SPOP also allows for
Level 3 to send and receive its end users' traffic to and from IXCs that are
connected to that access tandem. In addition, Level 3 may send intraLA T A toll
that its end users originate. This traffic may also include both IntraLA T A and
Local transit traffic to a third local carrier.
WHAT ARE THE BENEFITS OF SPOP?
Where volumes of local traffic are low, Level 3 only has to establish trunks to the
access tandem. This avoids trunking between Level 3's POI and each Qwest end
office and local tandem.
ARE THERE LIMITATIONS TO SPOP?
Yes. Not all local carriers, Interexchange Carriers ("IXCs ) or Qwest end offices
have trunking with each Qwest access tandem. Therefore, separate trunking to
each access tandem may be required to the extent there is more than one access
tandem in a LATA. In addition, and as I explain in issue IF, it may be necessary
for Level 3 to establish trunking, where traffic volumes justify, directly to local
tandem switches or end office switches. Although additional trunking may be
required within a LATA, it will not require more than a single POI per LATA.
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Issue No. IF
IS LEVEL REQUIRED TO INTERCONNECT AT EVERY ACCESS
T AND EM IN THE LATA?
No. Level 3 must only interconnect its POI to an access tandem where Level3'
traffic is destined for a local carrier, IXC or Qwest end office that subtends that
access tandem. For example, in Idaho, Level 3 would only be required to connect
to one access tandem in Boise at this time.
WHY SHOULD QWEST'S LANGUAGE BE ADOPTED?
Qwest language more appropriately reflects the interconnection between Qwest'
network and Level 3's network. Unlike Level 3's language, Qwest's language
does not confuse what is required to create a POI with what is realistically
required to interconnect two networks.
PLEASE EXPLAIN DISPUTED ISSUE NO. IF.
Level 3 removes the language describing how Level 3 may interconnect at
Qwest's local and access tandem switches. Level 3 also removes the requirement
for Level 3 to establish trunking as requested by Qwest where traffic volumes
justify alternate trunking. My testimony will explain why this language
important from a technical perspective. In addition, Level 3 again inappropriately
inserts the disclaimer that it should not have to pay for the use of the Qwest
network. The testimony of Mr. Easton explains that Level 3's language not only
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ignores Level 3' s obligations under the law, but is also clearly misplaced in a
section describing the techtiical aspects of interconnection.
WHAT LANGUAGE IS QWEST PROPOSING?
Qwest proposes the following, which is found on page 80 of the ICA:
The Parties shall terminate Exchange
Service (EAS/Local) traffic on Tandem Switches or End
Office Switches. CLEC may interconnect at either the
Qwest local tandem or the Qwest access tandem for the
delivery of local exchange traffic. When CLEC is
interconnected at the access tandem and when there is a
DSI level of traffic (512 BHCCS) over three (3)
consecutive months between CLEC's Switch and a Qwest
End Office Switch, Qwest may request CLEC to order a
direct trunk group to the Qwest End Office Switch. CLEC
shall comply with that request unless it can demonstrate
that such compliance will impose upon it a material adverse
economic or operations impact. Furthermore, Qwest may
propose to provide Interconnection facilities to the local
Tandem Switches or End Office Switches served by the
Access Tandem Switch at the same cost to CLEC as
Interconnection at the Access Tandem Switch. If CLEC
provides a written statement of its objections to a Qwest
cost-equivalency proposal, Qwest may require it only: (a)
upon demonstrating that a failure to do so will have a
material adverse affect on the operation of its network and
(b) upon a rIDding that doing so will have no material
adverse impact on the operation of CLEC, as compared
with Interconnection at such Access Tandem Switch.
WHAT LANGUAGE IS LEVEL 3 PROPOSING?
Level 3 proposes the following:
When CLEC is interconnected at the access
tandem and when there is a DS1 level of traffic (512
BHCCS) over three (3) consecutive months between
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CLEC's Switch and a Qwest End Office Switch Qwest
may request CLEC to order a direct trunk group to the
Qwest End Office Switch. Notwithstanding references to
Qwest's ability to requests that CLECs order direcUrunk
grnyps to the Qwestend office. nothing in this agreement
shall be construe4Jo require CLEC to pay Qwest for any
services or facilities on Qwest'side of the POI in
connection with the origination of raffic from Qwest
CLEC~ and nothing herein shall be construed to re~
CLEC to pay for any services or facilities on Qwest's side
of the POI in connection with the termination of traffic
from CLEC by Qwes . other than reciprocal compensatim!
payments as provided in this Agreement.
WHY IS QWEST OPPOSED TO THE LEVEL 3 LANGUAGE?
Level 3 has removed the language that specifies tandems and end offices as points
where traffic terminates. Level 3' s proposed language ignores Qwest' s existing
network architecture, creating ambiguity and non-specificity that may lead to later
disputes. (There are no other locations on Qwest' s network where traffic may be
delivered.More disturbingly, Level 3 removes the requirement to establish
trunking to sub tending network switches when increases in traffic volumes justify
the alternate trunking. This is critical in maintaining a robust and reliable network
for not only all interconnecting carriers (including Level 3), but also for Qwest
customers as well, by insuring that network capacity may be managed and
maintained efficiently.
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.12
ARE THERE ANY OTHER METHODS BY WHICH LEVEL 3 MAY
EXCHANGE TRAFFIC?
No. By removing the language that allows for the exchange of Local/EAS traffic
to Qwest tandems, Level 3 implies that there are other locations that Level 3 may
exchange traffic with Qwest's network. There are no other methods for Level 3
to exchange Local/EAS traffic directly with Qwest than through Qwest's tandems
and end offices.
ARE THERE OTHER TERMINATION POINTS IN THE PUBLIC
SWITCHED TELEPHONE NETWORK ("PSTN"THAT OPERATE
DIFFERENTLY THAN AN END OFFICE OR A TANDEM?
No.Switches perform essentially two functions in the telecommunications
network. They either operate with a tandem function or an end office function.
WHAT IS THE DIFFERENCE BETWEEN AN END OFFICE AND A
TANDEM?
An end office serves end user customers. It is typically the last point of switching
before traffic reaches the end user customers and is the point from which an end
user customer draws dial tone and which performs the initial processing of a call
from an end user served by that end office. A tandem switch on the other hand
serves other switches. In other words tandem switches route traffic to other
switches. This network architecture is not unique to Qwest, and Level 3' s refusal
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to acknowledge its existence is illogical, considering that it wants to interconnect
with such a network.
WHY IS IT IMPORTANT TO ESTABLISH THE FUNCTION OF THE
SWITCHES WHERE LOCAL TRAFFIC SHOULD TERMINATE?
It is important to identify the function of switches so that there is no confusion as
to the network switching functions to which the Interconnection Agreement
ICA") applies.Without this language, Level 3 may seek interconnection
utilizing a function that the Qwest network is not capable of providing. It is
important that the agreement identify the type of traffic and the function of the
switches where that traffic will be accepted so that this is clear to both parties.
Qwest's language provides this clarity. Level3's language does not.
WHY DOES QWEST OPPOSE THE REMOVAL OF LANGUAGE THAT
REQUIRES LEVEL 3 TO ESTABLISH TRUNKING TO SUBTENDING
NETWORK SWITCHES WHEN VOLUMES JUSTIFY ALTERNATE
TR UNKIN G ?
Level 3' s proposed language removes any responsibility for Level 3 to establish
alternate trunking to maintain efficient use of network resources that are shared by
all interconnecting carriers. By removing language that requires efficient use of
the network Level 3 has the potential to negatively impact Qwest's switching
resources, their reliability and their availability to all other interconnecting
camers.Level 3 attempts to avoid its responsibility to maintain network
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robustness and efficiency which other carriers interconnected with Qwest have
previously acknowledged and assumed.
DOES THE REQUIREMENT TO ESTABLISH ALTERNATE TRUNKING
CREATE A FINANCIAL BURDEN ON LEVEL- 3?
No. Direct trunking will typically save Level 3 money because with it Level
would avoid tandem switching charges. However, if the result of establishing
alternate trunking is an economic burden, then Qwest's language provides a
mechanism for Level 3 to avoid that burden. Under Qwest' s proposed language
if Level 3 demonstrates that an economic burden exists, the requirement to
establish alternate trunking is waived.
DOES QWEST PROVIDE ANY ASSISTANCE IN IDENTIFYING
TRUNKING THAT HAS BECOME INEFFICIENT?
Yes Qwest monitors the volumes of traffic exchanged with Qwest that are
destined to and from Qwest end offices. Qwest then generates reports that
identify inefficient trunking. These reports are then shared with Level 3 along
with a request to establish direct trunking and instructions as to which end
office(s) direct trunking should be established.
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HAS LEVEL 3 BEEN COOPERATIVE WHEN WORKING WITH QWEST
ON TRUNKING ISSUES?
Yes. Level 3 has historically been very cooperative when working with Qwest'
trunk administration group.Level 3's proposed language which refuses to
maintain network efficiencies is surprising given the cooperative history that has
in the past existed between Qwest and Level 3.
WHAT IS THE 512 BHCCS?
512 BHCCS or 512 Busy Hour Centum Call Seconds is the measure of usage
capacity of a DS1 trunk during the busiest hour of the day. Usage is measured in
Centum Call Seconds ("CCS") or one hundred call seconds. A line or trunk that
is in use for one hour,. or sixty minutes, is being used for 3600 seconds, or
hundred call seconds, or 36 CCS. As stated in Newton s Telecom Dictionary
CCS is
: "
One hundred call seconds or one hundred seconds of telephone
conversation.One hour of telephone traffic is equal to 36 ccs
(60*60=3600/100=36) which is equal to one erlang.Newton s Telecom
Dictionary Volume 17 at 131 (February 2001).512 BHCCs is essentially
equivalent to a DS 1 worth of usage. Telecommunications switch ports typically
are provisioned in increments of DS 1 capacity. It is generally recognized by the
industry as the traffic threshold that indicates a sufficiently high volume of traffic
that would warrant the provisioning of alternative, direct trunking arrangements.
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WHAT IS THE 512 BHCCS RULE?
The 512 BHCCS rule establishes the threshold of usage which when reached
means that direct trunking between end offices is typically more efficient than
trunking that usage through a tandem switch.
HOW DOES QWEST LANGUAGE CREATE EFFICIENT USE OF THE
NETWORK?
Qwest's language establishes a threshold that facilitates efficient interconnection
between Qwest and all CLEC switches. The threshold allows Qwest to manage
traffic through tandem switches when traffic volumes justify a direct connection
with a specific end office. As can be seen in Qwest Exhibit Nos. 304 and 305, as
CLEC traffic that is destined for a Qwest end office reaches or exceeds 512
BHCCS, or a DS l' s capacity it becomes logical to direct trunk to that end office.
Qwest Exhibit No. 304 shows that the traffic volume spread across all end offices
is less than the capacity of a single switch port, whereas, PL-2 demonstrates that
end office A is at the capacity of a single switch port and has a direct trunk with
the CLEC switch. This creates network efficiencies by eliminating the need to
provide additional switching through the tandem.
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DOES QWEST USE THE SAME THRESHOLD TO EVALUATE ITS
OWN NETWORK TRUNKING EFFICIENCIES?
Yes. Qwest applies the same network threshold in its own trunking analysis so
that it may better utilize the trunking capacity between its end offices and
tandems.
WHAT WOULD BE THE RESULT IF NO INTERCONNECTING
CARRIERS FOLLOWED THE 512 BHCCS RULE?
All switches have limits for trunking capacity. As carriers add more and more
trunking to each tandem, the tandems would begin to reach capacity. Once a
tandem reaches its maximum trunking capacity, an additional tandem would have
to be installed.
IV.DISPUTED ISSUES NO. 2A AND 2B: ALL TRAFFIC ON
INTERCONNECTION TRUNKS
PLEASE EXPLAIN DISPUTED ISSUES NO. 2A AND 2 B.
Issues 2A and 2 B concern the types of traffic that may be combined over LIS
trunks and whether Qwest is entitled to compensation for the interconnection
trunks it provides to Level 3. The testimony of Mr. Easton addresses the
compensation issue while my tes.timony addresses the network and technical
Issues.
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26
29-
WHAT LANGUAGE IS QWEST PROPOSING?
Qwest is proposing the following language, found on pages 78 and 79 of the ICA:
9.3.1 Exchange Service (EAS/Local), ISP-Bound
Traffic IntraLATA LEC Toll VoIP traffic and Jointly
Provided Switched Access (InterLA T A and IntraLA T A
Toll involving a third party IXC) may be combined in a
single LIS trunk group or transmitted on separate LIS trunk
groups.
9.3.1.1 If CLEC utilizes trunking
arrangements as described in Section 7.9.3., Exchange
Service (EAS/Local) traffic shall not be combined with
Switched Access, not including Jointly Provided Switched
Access, on the same trunk group, i.e. Exchange Service
(EAS/Local) traffic may not be combined with Switched
Access Feature Group D traffic to a Qwest Access Tandem
Switch and/or End Office Switch.
9.3.CLEC may combine originating
Exchange Service (BAS/Local) traffic, ISP-Bound Traffic
IntraLA T A LEC Toll, VoIP Traffic and Switched Access
Feature Group D traffic including Jointly Provided
Switched Access traffic, on the same Feature Group D
trunk group.
9.3.1 CLEC shall provide
Qwest, each quarter, Percent Local Use (PLU) factor(s) that
can be verified with individual call detail records or theParties may use call records or mechanized
jurisdictionalization using Calling Party Number (CPN)
information in lieu of PLU, if CPN is available. Where
CLEC utilizes an affiliate s Interexchange Carrier (IXC)
Feature Group D trunks to deliver Exchange Service
(EAS/Local) traffic with interexchange Switched Access
traffic to Qwest Qwest shall establish trunk group(s) todeliver Exchange Service (EAS/Local), Transit, and
IntraLATA LEC Toll to CLEC. Qwest will use or establish
a POI for such trunk group in accordance with Section 7.
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WHAT LANGUAGE IS LEVEL 3 PROPOSING?
Level 3 proposes the following language:
9.3.1 Where CLEC exchanges Telephone
Exchange Service Exchange Access Service Telephone
Toll Service, and Information Services traffic with Qwest
over a single interconnection network, CLEC agrees to pay
Qwest, on Qwest's side of the POI, state or federally
tariffed rates applicable to the facilities charges for
InterLATA and/or InterLATA traffic in proportion to the
total amount of traffic exchanged over such interconnection
facility. Otherwise each party remains 100% responsible
for the costs of its interconnection facilities on its side
the POI. Thus, by way of illustration only, where 20% of
such traffic is interLATA (intrastate and interstate) and the
remaining 80% is Section 251 (b )( 5) Traffic, CLEC would
pay Qwest an amount equal to 20% of the applicable
tariffed transport rate that would apply to a tariffed facility
used solely for the exchange of such access traffic for such
traffic exchanged on Qwest's side of the POI over a single
interconnection trunk.
Except as expressly provided in Section 7.3.1.1.3 , each
party shall bear all costs of interconnection on its side
the network in accordance with 47 C.R. ~ 51.703.
Accordingly, unless otherwise expressly authorized
according to Section 7.3 .1.3, neither Party may charge the
other (and neither Party shall have an obligation to pay) any
recurring and/or nonrecurring fees, charges or the like
(including, without limitation, any transport charges),
associated with the exchange of any telecommunications
traffic including but not limited to Section 251(b)(5) Traffic
on its side of the POI.
Each party is solely responsible for any and all costs arising
from or related to establishing and maintaining the
interconnection trunks and facilities it uses to connect to
the POI. Thus, neither party shall require the other to bear
any additional costs for the establishment and operation of
interconnection facilities that connect its network to its side
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of the POI. If traffic is combined, Section 7.3.9 of this
Agreement applies.
9.3.CLEC may combine Exchange Service
(EAS/Local) traffic, ISP-Bound Traffic, Exchange Access
(IntraLA T A Toll carried solely by Local Exchange
Carriers), VoIP Traffic and Switched Access Feature Group
traffic including Jointly Provided Switched Access
traffic, on the same Feature Group D trunk group or over
the same interconnection trunk groups as provided in
Section 7.3.
WHAT CONCERNS DOES QWEST HAVE WITH LEVEL 3'
PROPOSED LANGUAGE?
Level 3 is proposing to route switched access traffic over local trunks. This
creates several technical problems that have various impacts to Qwest, CLECs
and independent companies. These technical problems are mainly associated with
the recording of the switched access traffic. Switched access traffic is typically
routed over access service trunks such as Feature Group D ("FGD") trunks. Level
3 ' s proposed language creates technical difficulties that would otherwise be
avoided by using the access service trunks which all other Interexchange service
providers establish with Qwest. Qwest has also provided Level 3 with language
that would allow Level 3 to route all its traffic over FGD. The routing of Level
3' s traffic over FGD trunking provides Level 3 with the same efficiencies that it
will argue that it would obtain if it were allowed to route traffic over local
interconnection trunking. Furthermore, Qwest's proposed language is in keeping
with industry practice.
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WHAT IS SWITCHED ACCESS TRAFFIC?
Switched access traffic is InterLATA and IntraLATA traffic that routes to and
from IXCs. This traffic typically routes between IXCs and Local Exchange
Carriers ("LECs ). IXCs purchase switched access services from LECs so that
they may receive and deliver InterLATA toll and IntraLATA toll traffic to and
from LECs networks. This switched access service typically utilizes Feature
Group trunking.Feature Group trunking is a software feature of
telecommunications switch that allows IntraLA T A toll and InterLA T A toll traffic
to be routed to IXC networks. FGD is the most common software feature used to
route traffic to IXCs on an equal access basis. This traffic is specific to IXCs.
IS YOUR DESCRIPTION OF SWITCHED ACCESS CONSISTENT WITH
THE DEFINITION AGREED TO IN THE PROPOSED ICA?
Yes.
WHAT TYPES OF TRAFFIC DOES LEVEL 3 INTEND TO ROUTE
OVER LIS TRUNKING?
Level 3 intends to route switched access traffic that Level 3 carries on behalf of
other IXCs over LIS trunks established by Level 3 with Qwest. This is traffic that
other IXCs agree to send to Level 3 to facilitate the termination of switched
access traffic on the IXC's behalf.
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WHAT OPTIONS DOES LEVEL 3 HAVE TO ROUTE AND TRANSPORT
SWITCHED ACCESS TRAFFIC?
Level 3 has several options that it may use to transport and route switched access
traffic on behalf of other IXCs. Level 3 may route the traffic directly to the
corresponding Level 3 end user customer, the appropriate location designated by
the terminating LEC network, or to yet another IXC.
IS THE ROUTING OF SWITCHED ACCESS TRAFFIC THAT YOUR
TESTIMONY DESCRIBED ABOVE DIFFERENT FROM THE WAY
OTHER IXCS MAY ROUTE SWITCHED ACCESS TRAFFIC?
No. Other IXCs typically route traffic in the same manner as I have just described
in my testimony.
WHAT SPECIFIC TECHNICAL PROBLEMS WOULD BE CREATED IF
LEVEL 3 ROUTES SWITCHED ACCESS TRAFFIC OVER LIS
TRUNKS?
The most significant problem with routing switched access traffic over LIS trunks
is Qwest's inability to generate a record for billing.Specifically, Qwest'
recording of LIS trunks is not designed or engineered to record switched access
traffic for the purposes of billing switched access charges for that traffic.
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WHAT METHODS DOES QWEST USE TO RECORD TRAFFIC?
There are two methods that Qwest uses to record traffic for intercarrier
compensation. The first is through a switch-based recording and the second is
through a link monitoring recording based on SS7 signaling. The switch-based
recording uses memory in the switch to record and format the information that is
received by the switch. The SS7 based recording tool records traffic using
information provided in the SS7 signaling stream.
HOW ARE THESE TWO METHODS OF RECORDING TRAFFIC USED
FOR INTERCARRIER CO MPENSA TI ON?
Switch-based recordings are used for Access Service billing of IXCs and billing
of Wireless carriers. The use of these recordings is based on the Access Service
or Interconnection Service that is requested by a carrier. As I explained above
IXCs obtain connections to Qwest's network using access services such as FGD.
Wireless Service providers typically request interconnection using Type
interconnection trunking.
CroSS7 recordings on the other hand are used for billing CLECs and some
independent companies.The CroSS7 recording capability has been set up
associated with LIS trunks so that local traffic may be recorded.
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IS A SWITCH-BASED RECORD CREATED ON LOCAL CALLS?
No. Prior to 1996 and the Telecom Act there was no need to record local traffic
for the purposes of intercarrier compensation. Before the 1996 Act local service
was provided exclusively by Incumbent Local Exchange Carriers ("ILEC") and
was typically provided at a flat rate. However, after the 1996 Act and the
introduction of CLECs, reciprocal compensation for local traffic became an issue.
As a result, CroSS7 was developed to record traffic that was exchanged between
Qwest and CLECs over LIS trunks.
DOES CROSS7 RECORD SWITCHED ACCESS FOR BILLING
PURPOSES?
No. There was no need to enable CroSS7 to record switched access traffic or to
incur the expense of monitoring additional services, because access service
recording was done by a switch based recording associated with access service
trunking. CroSS7 was developed solely to record local traffic that was exchanged
with CLECs.
IF LEVEL 3 WERE TO ROUTE SWITCHED ACCESS TRAFFIC OVER
LIS TRUNKS, WOULD QWEST HAVE THE ABILITY TO CREATE A
SWITCHED ACCESS RECORD?
No. Because CroSS7 was not engineered to record switched access traffic, Qwest
would not have the ability to create a switched access record for billing purposes.
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WHAT OTHER PROBLEMS WOULD OCCUR IF LEVEL 3 WERE
ALLOWED TO ROUTE SWITCHED ACCESS TRAFFIC OVER LIS
TRUNKS?
If Level 3 were to route switched access traffic over its local LIS with Qwest
other carriers such as independent companies and other CLECs would not receive
a jointly provided switched access record.In other words CLECs and
independent companies that terminate Level 3' s switched access traffic routed
over LIS trunks would not have the ability to bill terminating access charges to
Level 3.
WILL QWEST PROVIDE LEVEL 3 THE CAPABILITY TO ROUTE
BOTH SWITCHED ACCESS TRAFFIC AND LOCAL TRAFFIC OVER A
SINGLE TRUNK GROUP?
Yes.
WHAT IS QWEST OFFERING TO LEVEL 3 THAT PROVIDES LEVEL 3
THE CAPABILITY IT IS SEEKING?
Qwest's proposed language gives Level 3 the capability it is seeking. Qwest'
language allows Level 3 to route both its local and toll traffic over FGD trunking.
As I described above, these trunks are typically used for routing switched access
traffic. Qwest has developed a methodology for Level 3 to route its local traffic
over these same trunks. Furthermore, Qwest has also developed the ability to
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record this traffic so that local traffic and access traffic are billed appropriately.
AT&T has similar routing provisions in its agreement with Qwest.
ARE THE NETWORK EFFICIENCIES DIFFERENT IF LEVEL 3 WERE
TO ROUTE SWITCHED ACCESS TRAFFIC AND LOCAL TRAFFIC
OVER FEATURE GROUP D VERSUS OVER LIS TRUNKS?
No. Network efficiency is not an argument against using an established method
for routing Level 3' s switched access traffic and local traffic over FGD trunking.
Once again, Level 3' s argument can be distilled down to the charges it might pay
and not network efficiencies or technical feasibility. Level 3 does not want to pay
the same rates as all other IXCs to provision its ability to route switched access
traffic to Qwest.
WHY SHOULD QWEST'S LANGUAGE BE ADOPTED?
Qwest's language more appropriately provides Level 3 with the capability to
combine traffic on a single trunk group. At the same time, Qwest's language
provides for routing and recording of switched access and local traffic that is
consistent with the way other IXCs and CLECs route traffic. It is consistent with
industry practice and does not require a "one-off' solution developed solely for
Level 3.
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DISPUTED ISSUE NO.6: AMA SWITCH TECHNOLOGY
PLEASE EXPLAIN DISPUTED ISSUE NO.
This issue was never a point of contention during the negotiation of the ICA and
only became an issue upon Level 3' s filing of its petition for arbitration. The issue
in dispute here is the use of the term "inherent in Switch technology" within the
definition of Automated Message Accounting ("AMA"). Level 3 disputes the use
of the language "inherent in Switch technology.
WHAT LANGUAGE IS QWEST PROPOSING?
Qwest proposes the following, on page 12 of the ICA:
Automated Message Accounting or "AMA" is the
structure inherent in Switch technology that initially
records telecommunication message information. AMA
format is contained in the AMA document, pub Ii shed by
Telcordia Technologies, or its successors, as GR-II00-
CORE which defines the industry standard for message
recording.
WHAT LANGUAGE IS LEVEL 3 PROPOSING?
Level 3 proposes the following:
Automated Message Accounting or "AMA" is the
structure that initially records telecommunication message
information. AMA format is contained in the AMA
document, published by Telcordia Technologies, or its
successors, as GR-1100-CORE which defines the industry
standard for message recording.
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IS QWEST WILLING TO REMOVE THE LANGUAGE THAT LEVEL 3
PROPOSES TO REMOVE IN THE DEFINITION FOR AUTOMATED
MESSAGE ACCOUNTING?
Yes. The phrase "inherent in Switch technology" has no significant impact on the
definition of AMA and can be removed.
VI.DISPUTED ISSUE NO.8: DEFINITION OF CALL RECORD
PLEASE EXPLAIN DISPUTED ISSUE NO.
The disputed issue No.8 concerns what information should be included in the
record of a call. Specifically, what call information must be provided in a call
record so that the record may be used for intercarrier billing purposes? Although
there are some technical limitations in some cases that prohibit the identification
of the origination of a call, a call record must include certain fundamental
information to create a record for billing purposes. Qwest objects to Level 3'
redefining of longstanding industry practice. Level 3' s proposed language would
require call information that is not necessary for the creation of a call record but
omit other information that that is required for the creation of a call record.
WHAT LANGUAGE IS QWEST PROPOSING?
Qwest proposes the following, on page 13 of the ICA:
Call Record" means a record that provides key data about
individual telephone calls. It includes originating telephone
number, terminating telephone number, billing telephone
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number (if different from originating or terminating
number) time and date of call, duration of call, long
distance carrier (if applicable), and other data necessary to
properly rate and bill the call.
WHAT LANGUAGE IS LEVEL 3 PROPOSING?
Level 3 proposes the following:
Call Record" shall include identification of the following:
charge number, Calling Party Number ("CPN"), Other
Carrier Number ("OCN"), or Automatic Number Identifier
ANI"), Originating Line Indicator ("OLI"
).
In the
alternative, a "Call Record" may include any other
information agreed upon by both Parties to be used for
identifYing the jurisdictional nature of the calling party
for assessing applicable intercarrier compensation charges.
WHY IS QWEST OPPOSED TO LEVEL 3'S PROPOSED DEFINITION
OF A CALL RECORD?
Level 3' s definition of a call record obligates both parties to provide certain types
of information about a call that may not be available on every call and requires
information about a call that has never been required by industry standards. Level
3 also omits information that is essential for a complete call record. In addition
Level 3 uses terms that are unclear and undefined by the telecommunications
industry.
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WHAT DOES LEVEL 3'S LANGUAGE REQUIRE THAT MAY NOT BE
AVAILABLE FOR ALL VALID CALL RECORDS AND WHY DOES
QWEST 0 PPOSE THE OBLIGATION PROVIDE THIS
INFO RMA TI 0 N?
Qwest opposes Level 3' s language because it obligates both parties to provide call
information that is not necessary to generate a valid call record. There are two
examples of call information specified by Level 3 that are not necessary to create
a valid call record.
Level 3' s language requires a "charge number" or "Originating Line Indicator
OLI"). The Charge Number parameter and the Originating Line Information
OLI") parameter are optional SS7 parameters that identify the billing telephone
number and class of service of a call respectively. Local signaling does not
require either Charge Number or OLI.3 As a result, valid call records would not
be created under Level 3's definition for local calls. In addition, because IXCs
typically strip Charge Number and OLI when terminating a call through Qwest to
. other local service providers via Jointly Provided Switched Access, terminating
access records would also become invalid call records under Level 3' s definition.
3 GR-246-CORE, Te1cordia Technologies Specification of Signaling System
Number 7, Issue 6 December 2001.
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Level 3 obligates both parties to provide specific call information
incorporating the word "shall" in its proposed definition of a call record.
WHAT IS SS7 AND HOW IS IT USED AS REFERENCED ABOVE?
Signaling System 7 or SS7 is an out of band Common Channel Signaling ("CCS"
protocol that enables the set up and release of calls between switches throughout
the PSTN. SS7 CCS also enables and initiates the recording of traffic for billing
purposes. SS7 CCS uses a separate network than the one that carries the voice
conversations between switches, thus the term out of band signaling. Unlike its
Multifrequency signaling predecessor SS7 CCS also uses digital transmission
that enables more call associated information in less amount of time to
transmitted between switches that serve the end points of a call. A portion of the
SS7 protocol is made up of parameters which are used to provide specific
information about a call. These signaling parameters are defined by industry
, standards and populated under specific defined circumstances. Some parameters
are mandatory with any call. For example, the called party number parameter
must always he populated in the signaling stream for a call to complete.
However, some parameters are mandatory with only specific types of calls. For
example, the OLI parameter is needed for call completion only when the call is
signaled to an IXC.
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DOES QWEST HAVE A WAY OTHER THAN SIGNALING TO PROVIDE
CHARGE NUMBER OR ORIGINATING LINE INFORMATION?
No. Signaling is the only way that Qwest is capable of providing real time
Charge Number and OLI that would enable Level 3 to create a call record as
defined by Level 3' s proposed definition. I am not aware of any proposal from
Level 3 that would provide Qwest with the same Charge Number or OLI on all
calls, both local and non-local, without the use of signaling.
WHAT CALL INFORMATION ELEMENT DOES LEVEL 3 OMIT WITH
ITS PROPOSED DEFINITION OF CALL RECORD AND WHY IS IT
IMPORT ANT?
Level 3 has omitted call duration in its proposed definition of call record. It is
important to include call duration in a call record because intercarrier
compensation is based on network usage which is determined by the fundamental
information provided by the call duration.Because today intercarrier
compensation is usage sensitive, the lack of call duration on a call record used for
billing would void any record that does not have call duration information. In
addition to call duration, Level 3 has also omitted the time and date call
information. Time and date are also important so that the call information can be
associated specific to each particular call that is made throughout each day. This
type of information is essential when trouble shooting discrepancies in billing
information.
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WHAT TERMS DOES LEVEL 3 USE THAT APPEAR TO BE UNCLEAR
AND UNDEFINED?
Charge number
, "
Other Carrier Number
" ("
OCN"
), "
Automatic Line Identifier
ANI"), and "OLI" are four terms that are unclear, undefined, or inconsistent
with the other uses of the terms that are defined in the proposed ICA.
Charge number The term "charge number" as Level 3 references in the
definition of Call Record is used with a different meaning than the undisputed
definition in the ICA. Level 3' s use of "charge number" creates the potential for
differing interpretations of what constitutes a charge number. It is important that
the definition be specific when using terms that are otherwise defined in other
parts of the proposed ICA.
OCN". This acronym is undefined in the proposed ICA and its equivalent
acronym has an alternate meaning in the telecommunications industry. The
industry uses the abbreviation "OCN" to represent "Operating Company
Number." Without a defInition of OCN in the proposed ICA that either confirms
the same definition for both terms or specifically defines OCN to mean something
different from its use in the telecommunication industry there will be disputes
about its meaning.
ANI" and "OLI"These terms are defined differently in the proposed ICA from
the way Level 3 has defined these terms in their proposed definition of Call
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Record. The undisputed proposed ICA definitions of these terms are "ANI" and
OLI where the "I" in ANI is not Identifier and the "I" in OLI is not "Indicator" as
is otherwise derIDed in the Qwest proposed ICA and in the telecommunications
industry. These terms are specifically defined in this ICA to correspond with the
Industries' definition of the SS7 parameters that correspond to these terms.
WHAT OTHER PROBLEMS WOULD ARISE IF CALL RECORD WERE
DEFINED BY LEVEL 3'S PROPOSED LANGUAGE?
Qwest would then be required to provide a call record specifically for Level 3 and
then a second call..-record for all other carriers with which Qwest exchanges
records. This would then require Qwest to implement two different processes and
potentially enhance its billing systems to accommodate the different call record
requirements. All CLECs that follow industry standard would follow one type of
call record requirement and Level 3 would then use an entirely new process that
may.require potential systems enhancements. This could take a number of years
to develop. Regardless of whether Qwest were to develop this new call record
and enhance the current systems to handle the changes or develop a separate
manual process, it will require additional capital expense based solely on Level
3' s request to change the existing call record requirements that to this point all
other carriers in the industry follow.
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WHY SHOULD QWEST'S DEFINITION OF CALL RECORD BE USED
IN THE ICA BETWEEN LEVEL 3 AND QWEST?
Qwest's definition of call record should be used because it includes the
fundamental information that is required to create a valid call record and the
flexibility to include other data that may be used to rate and bill calls for
intercarrier compensation purposes.In addition Qwest uses terms that are
specific enough to identify what is required while at the same time remaining
flexible enough to encompass all of the optional parameters that Level 3 wishes to
require should they eventually become industry requirements. Unlike Level 3'
language, Qwest's language does not include call information that could create
disputes over the interpretation of the terms used in the defInition. Likewise
Qwest's language eliminates any potential dispute as to whether the existence of
call duration and the time and date a call occurred are required in a valid call
record. Simply put, Qwest's language addresses all of Level 3's concerns, more
clearly establishes the expectations of both companies for the creation of a valid
call record, and has the flexibility to include additional call information that may
be required to generate a valid call record in the future.
VII.DISPUTED ISSUE NO. 20: SIGNALING PARAMETERS
PLEASE EXPLAIN DISPUTED ISSUE NO. 20.
The issue at dispute here is what SS7 signaling information should be required for
the exchange of traffic between Qwest and Level 3.
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WHAT LANGUAGE IS QWEST PROPOSING?
Qwest proposes the following, on page 87 of the ICA:
7.3.Signaling Parameters: Qwest and CLEC are
required to provide each other the proper signaling
information (e., originating Calling Party Number and
destination called party number, etc.per 47 CFR 64.1601
to enable each Party to issue bills in a complete and timely
fashion. All CCS signaling parameters will be provided
including Calling Party Number (CPN), Originating Line
Information Parameter (OLIP) on calls to 8XX telephone
numbers, calling party category, Charge Number, etc. All
privacy indicators will be honored. If either Party fails to
provide CPN (valid originating information), and cannot
substantiate technical restrictions (i.e..MF signaling) such
traffic will be billed as Switched Access. Traffic sent to the
other Party without CPN (valid originating information)
will be handled in the following manner. The transit
provider will be responsible for only its portion of this
traffic, which will not exceed more than five percent (5%)
of the total Exchange Service (EAS/Local) and Exchange
Access (IntraLA T Toll) traffic delivered to the other
Party. The Switch owner will provide to the other Party,
upon request, information to demonstrate that Party
portion of no-CPN traffic does not exceed five percent
(5%) of the total traffic delivered. The Parties will
coordinate and exchange data as necessary to determine the
cause of the CPN failure and to assist its correction. All
Exchange Service (EAS/Local) and IntraLATA LEC Toll
calls exchanged without CPN information will be billed as
either Exchange Service (EAS/Local) Traffic or IntraLA T A
LEC Toll Traffic in direct proportion to the minutes of use
(MOD) of calls exchanged with CPN information for the
preceding quarter, utilizing a PLU factor determined in
accordance with Section 7.9.3.2 of this Agreement.
DOES QWEST HAVE ANY MODIFICATIONS TO ITS PROPOSED
LANGUAGE?
,Yes. To clarify 7.3.8 Qwest wishes to replace the following sentence:
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All CCS signaling parameters will be provided including
Calling Party Number (CPN), Originating Line Information
Parameter (OLIP) on calls to 8XX telephone numbers,
calling party category, Charge Number, etc.
With the following sentence:
All CCS signaling parameters will be provided including
Calling Party Number (CPN), Originating Line Information
Parameter (OLIP), calling party category, Charge Number
etc. on calls to 8XX telephone numbers.
The preceding changes are only intended to correct a clerical error in the original
sentence structure.
WHAT LANGUAGE IS LEVEL 3 PROPOSING?
Level 3 proposes the following:
7.3.8 Signaling Parameters: Qwest and CLEC are required
to provide each other proper signaling information (e.
- originating Calling Record Information and destination
called party number, etc.) to enable each Party to issue billsin a complete and timely fashion. All CCS signaling
parameters will be provided including Call Record
Information (CRI), Originating Line Information Parameter
(OLIP) on calls to ~XX telephone numbers, calling party
category, Charge Number, etc. All privacy indicators will
be honored. If either Party fails to provide CRI (valid
originating information), and cannot substantiate technical
restrictions ~, MF signaling, IP origination~ etc.) such
traffic will be billed as interstate Switched Access. Transit
Traffic sent to the other Party without CRI (valid
. originating information) will be handled in the following
manner. The transit provider will be responsible for only its
portion of this traffic, which will not exceed more than five
percent (5%) of the total Exchange Service (EAS/Local)
and Exchange Access (IntraLA T A Toll) traffic delivered to
the other Party. The Switch owner will provide to the other
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Party, upon request, information to demonstrate that Party
portion ofno-CRI traffic does not exceed five percent (5%)
of the total traffic delivered. The Parties will coordinate and
exchange data as necessary to determine the cause of the
CRI failure and to assist its correction. All Exchange
Service (EAS/Local) and Exchange Access calls exchanged
without CRI information will be billed as either Exchange
Service (EAS/~ocal) Traffic or Exchange Access Traffic in
direct proportion to the minutes of use (MOD) of calls
exchanged with CRI information for the preceding quarter
utilizing a PLU factor determined in accordance with
Section 7.9.3.2 of this Agreement.
WHY DOES QWEST OBJECT TO LEVEL 3'S PROPOSED LANGUAGE?
Qwest objects to Level 3's language because it mischaracterizes IP origination
(emphasis added) as a technical limitation to providing signaling parameters.
Level 3' s proposed language also creates an obligation to populate a signaling
parameter, specifically Call Record Information ("CRI"), which does not exist
within the SS7 protocol. In addition, Level 3 does not define CRI. To the extent
Level 3' s definition of CRI would use similar terms as are used in Level 3' s
definition of Call Record, it is not at all clear that the requirement to provide the
CRI can be met. Level 3's proposed language also fails to acknowledge that the
FCC has recognized certain limitations exist that prohibit or limit the delivery of
specific types of signaling information.Qwest further objects to Level 3'
language because it inappropriately applies interstate switched access rates onto
traffic that is intrastate.
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WHY IS IT NOT NECESSARY TO ADDRESS VOIP ORIGINATED
TRAFFIC AS LEVEL 3 PROPOSES?
Voice over Internet Protocol ("VoIP") uses a different protocol than is used by the
operators of the PSTN.' Because of the different protocols , a conversion from the
Internet Protocol ("IP") to the Time Division Multiplex ("TDM") protocol of the
PSTN is required to enable a voice call to be established between an IP network
and the PSTN. However, the PSTN does not currently have the ability to
determine if traffic was originated in IP, at what point the conversion from IP to
TDM takes place, or if the traffic was originated with TDM protocol. As the
testimony of Mr. Brotherson explains, the ESP exemption allows an ESP, such as
VoIP service providers to establish a POP within a local calling area and receive
service that is treated as local service. It is the FCC's ESP exemption and the
existence of a standard signaling protocol that eliminates the need to identify
VoIP traffic as a signaling requirement. Thus, industry standards have not been
established that specify signaling as the method to identify VoIP traffic.
IS IT TRUE THAT VOIP IS A TECHNICAL RESTRICTION FOR
PROVIDING CPN?
Absolutely not. Contrary to Level 3' s petition and their proposed language, there
is no technical limitation that would prevent Level 3 from populating CPN for
VoIP originated traffic. In fact VoIP traffic is subject to all of the same
limitations as any PSTN originated call after the IP to TDM conversion takes
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place and the traffic enters the PSTN. All limitations that are identified by
Qwest's language apply once the traffic enters the PSTN. Level 3 is attempting to
make VoIP traffic more than it really is. It is just a voice call that is routed and
transported with a different protocol until the protocol changes at which point it is
like any other TDM call.
HAS THERE BEEN AN INDUSTRY STANDARD DEVELOPED TO
ADDRESS VOIP ORIGINATED CALLS?
No. Level 3 wishes to address the signaling of VoIP traffic even though there has
been no industry standard established to address the identification of VoIP
originated traffic. Until such time as an industry standard is developed, the
industry must use the existing standards for signaling traffic through the PSTN
and the well established FCC ESP exemption ~les that determine how the traffic
from VoIP service providers is treated. Level 3 is attempting to jump the gun
with regard to the identification of VoIP originated traffic by putting into place a
signaling solution for the identification of VoIP originated traffic that benefits
only itself and not the needs of the industry as a whole. It has yet to be
determined by industry standards whether signaling is the most appropriate
solution for identifYing VoIP originating traffic.
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HOW DOES LEVEL 3'. PROPOSED LANGUAGE CREATE A
SIGNALING PARAMETER THAT DOES NOT EXIST?
Section 7.3.8 addresses signaling parameters. Level 3 seems to be attempting to
create a new signaling parameter called CRI by including the reference to CRI in
the list of SS7 signaling parameters. There is no such signaling parameter as CRI
that exists in the SS7 protocol. Level3's proposed language, however, attempts to
prematurely redefine signaling that occurs between two networks and changes the
meaning and intent of the language to encompass all call record information that
might exist within signaling protocols.
WHAT WOULD BE INVOLVED IN THE CREATION OF A NEW
SIGNALING PARAMETER?
The creation of a new signaling parameter would be a colossal undertaking. The
industry would first have to come to agreement on the definition of the parameter.
Once the parameter was defined by the industry then all vendors and carriers that
use the SS7 protocol in their equipment and network would have to incorporate
the new protocol parameter. This would have to occur for all existing and new
signaling equipment. This would include modification to practically every switch
in the United States and would also impact other countries to the extent that SS7
is used outside of the United States. This could take years to implement and cost
tens of millions of dollars. In addition, some carriers may not use the parameter
and others may expect to be compensated for transporting the additional data.
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DOES LEVEL 3 DEFINE CRI?
No. One of the ,problems Qwest has with CRI is that Level 3 does not define the
term in its proposed contract language. Since Level 3 does not define CRI, its
meaning in the ICA would then be left open for dispute.
WHAT PROBLEMS WOULD ARISE IF CRI WERE TO BE DEFINED BY
THE SAME INFORMATION THAT IS USED BY LEVEL 3 TO DEFINE
CALL RECORD?
The same problems that arise in issue No.8 would arise here. In addition, call
records and signaling serve different functions. Call signaling is real time data
that is used to set up and release calls across the PSTN. Call records are
generated using post call processing and are used for the purposes of billing.
Although call records may include some signaling related information, call
records include information that is not provided within the signaling stream such
as date, time, and call duration that are captured outside the signaling stream.
Level 3 has made section 7.3.8 more confusing and more cumbersome to manage
by inserting call record information that may not exist in the signaling protocol.
WHAT PROBLEMS DOES QWEST SEE IF LEVEL 3 WERE TO DEFINE
ONLY THE SIGNALING PARAMETERS AS ARE USED IN LEVEL 3'
DEFINITION OF CALL RECORD?
While Level 3 identifies several signaling parameters in its definition, there is
only one call parameter that could always have a substantial impact on the
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creation of a call record. This is the Calling Party Number ("CPN") parameter.
The CPN parameter is the number of the party that places a call e. the "from
number. Level3's language inserts signaling parameters that mayor may not be
present, thus making a call record that would otherwise be valid for billing
purposes invalid. Based on Level 3' s definition of call record, a call that contains
enough information to create a call record for Qwest and other carriers would be
classified as a no-CRI by Level 3. For example, if a local call is routed to Level 3
that lacks either a Charge Number or the Originating Line Indicator, under Level
3' s language, this local call would be defined as a no-CRI call even if the called
party number and calling party number were present in the signaling stream.
Typically, local calls are not signaled with Charge Number or OLI. It is for these
reasons that Level 3' s language will lead to disputes over what signaling
information is necessary for billing.
IS RATING NO-CPN TRAFFIC BASED ON "INTERSTATE SWITCHED
ACCESS RATES" APPROPRIATE AS PROPOSED BY LEVEL 3?
No. Qwest opposes Level 3's proposal to route interstate switched access over
LIS trunks as my testimony explains for Issue 2. Therefore, interstate switched
access charges would not be appropriately applied to No-CPN traffic.
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WHY IS QWEST'S LANGUAGE MORE APPROPRIATE?
Qwest's language uses terms that are clearly defined by the contract and the
industry. Qwest language provides clear expectations for the signaling of traffic
between the parties' networks.
VIII. SUMMARY/CONCLUSION
PLEASE SUMMARIZE YOUR TESTIMONY.
Although complex at times, the issues of my testimony revolve around three
issues: 1) Level 3's ability to establish a SPOI in a LATA; and 2) the types of
traffic that may be combined on interconnection trunks; and 3) the call
information that should be required in a call record.
Although, Level 3's ability to establish a SPOI is more about compensation for
providing interconnection facilities, the FCC contemplated the logistics for
interconnecting two networks when it required LECs to provide interconnection.
It recognized that each carrier must be able to retain responsibility for the
management, control, and performance of its network.The FCC also
acknowledges that networks had interconnected prior to the Telecommunications
Act of 1996. In support of its recognition of maintaining network reliability and
interoperability, and the existence of network interconnections, the FCC
acknowledged certain logical methods to interconnect networks such as cross
connect points and main distribution frames as technically feasible points of
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interconnection. Qwest provides such technical feasible points for the purpose of
interconnection with Qwest's network. However, Level 3's proposed language
attempts to forgo these well established arrangements not for technical reasons
but in an attempt to avoid the cost of interconnection.
As to the types of traffic that can be carried on interconnection trunk groups
Qwest has attempted to be responsive to Level 3' s desire to combine traffic on
trunk groups. Qwest is willing to allow all traffic types, with the exception of
switched access traffic, to be carried over LIS trunks. The law is also clear about
interexchange traffic and the requirement for Qwest to provide switched access
services to IXCs for such interexchange traffic. Because of billing issues, systems
issues and Qwest's obligation to provide jointly provided switched access records
to other ILECs and CLECs, Qwest requires that switched access traffic be carried
over Feature Group trunks. This is entirely consistent with Section 251(g) of the
Act which requires that Qwest provide interconnection for the exchange of
switched access traffic in the same manner that it provided for such traffic prior to
the passage of the Act. Nonetheless, Qwest has attempted to accommodate Level
3' s desire for network efficiencies by agreeing to let Level 3 combine all of its
traffic over Feature Group D trunks. This solution achieves the efficiencies
sought by Level 3 while at the same time allowing Qwest to continue to use its
existing billing systems and processes. For these reasons, Level 3's proposed
combining of traffic on LIS trunks should be rejected.
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Finally, a call record must include certain fundamental information to create
record for billing purposes. Although there are some technical limitations in some
cases that prohibit the identification of the origination of a call, Level 3 attempts
to go beyond the fundamental information and create requirements for a call
record that may not legitimately be provided. Qwest's definition provides for all
of the fundamental information needed in a call record and at the same time
provides the flexibility to accept additional information to create a call record
which may be used for billing. Level 3 goes beyond what is recognized by the
industry and then inappropriately places financial penalties for non-compliance.
DOES THIS CONCLUDE YOUR TESTIMONY?
Yes it does.
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Qwest Corporation
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CERTIFICATE OF SERVICE
I do hereby certify that a true and correct copy of the foregoing DIRECT TESTIMONY OF
PHILIP LINSE was served on the 12th day of August, 2005 by first class mail, postage prepaid on the
following individuals:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ill 83720-0074
i i ewell~puc .state.id. us
Weldon Stutzman
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ill 83720-0074
Telephone: [phone]
weldon .stutzman~puc .Idaho. gov
Erik Cecil
Regulatory Counsel
Level 3 Communications, LLC
1025 Eldorado Boulevard
Broomfield, CO 80021
erik.cecil~leve13 .com
Henry T. Kelly
Joseph E. Donovan
Scott A. Kassman
Kelley Drye & Warren LLP
333 West Wacker Drive
Chicago, Illinois 60606
[phone] (telephone)
[phone] (facsimile)
hkelly~kelleydrye.com
Dean J. Miller
McDevitt & Miller LLP
420 West Bannock Street
O. Box 2564
Boise, ill 83702
ioe~mcdevitt-miller.com
..x.Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
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~~cJ-
Brandi L. Gearhart
Legal Assistant
Stoel Rives LLP
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