20050921Errata re Linse direct.pdf

Mary S. Hobson
TO EL RIVES LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702-5958
Telephone: [phone]
Facsimile: [phone]
mshobson~stoe1. com
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Thomas M. Dethlefs
Qwest Services Corporation
1801 California Street - 10th Floor
Denver, CO 80202
Telephone: [phone]
Facsimile: [phone]
Thomas .Dethl efs~qw est. com
Attorneys for Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MA TIER 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 STATE LAWS FOR
THE RATES, TERMS, AND CONDITIONS OF
INTERCONNECTION WITH QWEST
CORPORATION
Docket No.: QWE-05-
ERRATA NOTICE CONCERNING
THE DIRECT TESTIMONY OF
PHILIP LINSE
Qwest Corporation, by and through its undersigned attorneys, file the following Errata
Notice concerning the Direct Testimony of Philip Linse filed August 12 2005.
ISSUE NO.1 - Errata
On page 4 of Mr. Linse s Direct testimony, he sets out Qwest's proposed language for
Section 7.1. This testimony requires correction to the first sentence and third sentence of that
paragraph as follows:
ERRATA NOTICE CONCERNING THE DIRECT TESTIMONY OF PHILIP LINSE - Page 1
Boise-187758.1 0061273-00018
1.1 This Section describes the Interconnection of Qwest' s
network and CLEC's network for the purpose of exchanging
Exchange Service (EAS/Local traffic), ~ange ,Access
fIntraLA T A Toll carried solely by local exchange carriers~ and not
by an IXC (IntraLATA LEC toll), ISP-Bound traffic, and Jointly
Provided Switched Access (InterLATA and IntraLATA) traffic.
Making those changes, Qwest's proposed language for the first sentence of section 7.1 should
read as follows:
This Section describes the Interconnection of Qwest'
network and CLEC's network for the purpose of exchanging
Exchange Service (EAS/Local traffic), IntraLA T A Toll carried
solely by local exchange carriers and not by an IXC (IntraLA T A
LEC toll), ISP-Bound traffic, and Jointly Provided Switched
Access (InterLATA and IntraLATA) traffic.
The second sentence in paragraph 7.1 is correct. However, the third sentence in the
proposed language found at Mr. Linse s direct testimony page 4, lines 14 through 23 also
requires correction as shown in the following paragraph in legislative format:
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 of Exchange Service (EAS/Local traffic); or End Office
Switches to Access Tandem Switches for the exchange of
IntraLA TAT oll carried solely by local exchange carriers and not
by an IXC (IntraLATA LEC toll)or Jointly Provided Switched
Access traffic.
With this addition, Qwest's proposed language for the third sentence of section 7.1.1 should read
as follows:
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 of Exchange Service (EAS/Local traffic); or End Office
Switches to Access Tandem Switches for the exchange of
ERRATA NOTICE CONCERNING THE DIRECT TESTIMONY OF PHILIP LINSE - Page 2
Boise-187758.1 0061273-00018
IntraLATA Toll carried solely by local exchange carriers and not
by an IXC (IntraLATA LEC toll) or Jointly Provided Switched
Access traffic.
ISSUE NO. 20 - Errata
Mr. Linse s Direct testimony at page 50, lines 29 through 33 also requires correction to
accurately reflect Qwest's proposed language for Section 7.3.8. In the fifth sentence of Section
, the phrase "Exchange Access (IntraLA T A Toll) traffic" should be deleted and the phrase
IntraLATA Toll carried solely by local exchange carriers and not by an IXC (IntraLATA LEC
toll) before the word "delivered" should be added as shown in the following legislative format:
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~hange .L ccess
IntraLA T A Toll carried solely by local exchange
carriers and not by an IXC (IntraLATA LEC toll)Jraffic delivered
to the other Party.
With those additions and deletions, Qwest's proposed language for the fifth sentence of section
7.3.8 should read as follows:
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 IntraLA T A Toll carried
solely by local exchange carriers and not by an IXC (IntraLA T A
LEC toll) traffic delivered to the other Party.
Accompanying this Notice are corrected pages 4 and 50 for Mr. Linse s Direct testimony
that reflect these changes.
ERRATA NOTICE CONCERNING THE DIRECT TESTIMONY OF pmLIP LINSE - Page 3
Boise-187758.10061273-00018
DATED: September 21 2005.
STOEL RIVES LLP
/u~
Mary S. Iz!obson
Attorneys for Qwest Corporation
ERRATA NOTICE CONCERNING THE DIRECT TESTIMONY OF PHILIP LINSE - Page 4
Boise-187758.1 0061273-00018
CERTIFICATE OF SERVICE
I do hereby certify that a true and correct copy of the foregoing ERRATA NOTICE
CONCERNING THE DIRECT TESTIMONY OF PHILIP LINSE was served on the 21
day of September, 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
ij 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
John Antonuk
Liberty Consulting Group
65 Main Street
O. Box 1237
Quentin, PA 17083-1237
Telephone: [phone]
Facsimile: [phone]
antonuk(fYlibertyconsul tinggroup. com
Erik Cecil
Regulatory Counsel
Level 3 Communications, LLC
1025 Eldorado Boulevard
Broomfield, CO 80021
erik.cecil(~Jeve13 .com
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Email
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ERRATA NOTICE CONCERNING THE DIRECT TESTIMONY OF PHILIP LINSE - Page 5
Boise-187758.1 0061273-00018
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
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Dean J. Miller
McDevitt & Miller LLP
420 West Bannock Street
O. Box 2564
Boise, ill 83702
ioe~mcdevitt-miller.com
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Brandi L. Gearhart
Legal Assistant
Stoel Rives LLP
ERRATA NOTICE CONCERNING THE DIRECT TESTIMONY OF PHILIP LINSE - Page 6
Boise-187758.1 0061273-00018
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 of
exchanging Exchange Service (EAS/Local traffic),
IntraLA T A Toll carried solely by local exchange carriers
and not by an IXC (IntraLATA LEC toll), ISP-Bound
traffic, and Jointly Provided Switched Access (InterLATAand IntraLA T A) 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 of Exchange Service
(EAS/Local traffic); or End Office Switches to Access
Tandem Switches for the exchange of IntraLATA Toll
carried solely by local exchange carriers and not by an IXC
(IntraLATA LEC toll) 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
QWE-05-
August 12, 2005
Linse (DI)
Qwest Corporation
Page 4
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:
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 bills
in 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 8XX 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 IntraLATA Toll carried solely by local exchange
carriers and not by an IXC (IntraLA T A LEC toll) traffic
delivered to the other Party. The Switch owner will provide
to the other Party.
...
QWE- T -05-
August 12, 2005
Linse (D I)
Qwest Corporation
Page 50