20080627Brigham Affidavit.pdf

Mar S. Hobson (lSB. No. 2142)
999 Main, Suite 1103 i
Boise, ID 83702
Tel: [phone]
mar.hobson(fqwest.com
10: 12
Adam L. Sherr
Corporate Counsel, Qwest
1600 7th Avenue, Room 3206
Seattle, W A 98191
Tel: [phone]
adam.sherr(0qwest.com
Attorneys for Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITITES COMMISSION
IN THE MATTER OF QWEST
CORPORATION'S PETITION FOR
APPROVAL OF NON-IMPAIRED WIRE
CENTER LISTS PURSUANT TO THE
TRIENNIAL REVIEW REMAND ORDER
Case No. QWE-T-08-07
AFFIDAVIT OF ROBERT BRIGHAM
STATE OF COLORADO )
) ss.COUNTY OF DENVER )
I, ROBERT BRIGHAM, being first duly sworn, depose and state that:
1. My name is Robert Brigham. I am employed by Qwest Corporation as a Staff
Director in the Public Policy Organization. My business address is 1801
California St., Suite 4700, Denver, Colorado 89202.
BRIGHAM AFFIDAVIT - 1 -
2. On June 20, 2008, Qwest fied a Petition for Commission Approval of Non-
Impaired Wire Center Lists Pursuant to the Triennial Review Remand Order
("TRRO''). Qwest and several major CLECs ("Joint CLECs") who were paries
to similar TRRO proceedings in six other states in Qwests 14-state ILEC
region, reached a Settlement Agreement (see Attachment A of Qwests June 20,
2008 petition), that defined, among other things, (1) the method to be used to
calculate TRRO business line counts and (2) the supporting line information
that was to be provided by Qwest. All but one of the commissions in these six
states have approved this settlement. l In adherence to terms of the settlement,
Qwest filed a list of Non-Impaired Wire Centers in Idaho with its June 20, 2008
petition. Qwest also fied the list of additional Non-Impaired Wire Centers with
the Federal Communications Commission ("FCC").
3. In support of the fiing, Qwest has prepared business line data that is in
compliance with the requirements of the Triennal Review Remand Order
("TRRO"), and that follow the methodology defined in Section V(A) of the
Settlement Agreement. The Idaho business access line data are attached hereto
as Highly Confidential Attachments A, B, C and D to my affdavit.
4. Highly Confidential Attachment A includes the December 2007 TRRO business
line counts, by line type, for each additional non-impaired wire center that is
classified as non-impaired based on the number of business lines. These data
are based on the TRRO business line methodology defined in Section V(A) of
the Settlement Agreement. These data are provided in a form that meets the
requirements defined in Section VI(E)(2)(a) of the Settlement Agreement.
5. Highly Confidential Attchment B includes UNE-L and EEL data by type of
circuit (voice grade, DS 1, DS3) for each additional non-impaired wire center
that is classified as non-impaired based on the number of business lines. These
data, along with the data in Highly Confidential Attachment C, meet the
requirements defined in Section VI(E)(2)(b) of the Settlement Agreement.
1 The Settlement was approved in Arizona, Minnesota, Oregon, Utah and Washington. It has not yet been
BRIGHAM AFFIDAVIT 2
6. Highly Confidential Attchment C includes the UNE-L and EEL data by tye of
circuit (voice grade, DSl, DS3) and by Competitive Local Exchange Carier
("CLEC") for each additional non-impaired wire center that is classified as non-
impaired based on the number of business lines. These data, along with the data
in Highly Confdential Attachment B, meet the requirements defined in Section
VI(E)(2)(b) of the Settement Agreement.
7. Highly Confidential Attachment D includes the Qwest Platform Plus ("QPP")
business line data, by Competitive Local Exchange Carier (CLEC), for each
additional non-impaired wire center that is classified as non-impaired based on
the number of business lines. These data meet the requirements defined in
Section VI(E)(2)(c) of the Settlement Agreement.
8. All of the data provided in Highly Confidential Attachments A, B, C and D are
prepared, to the best of my knowledge, in a maner that complies with the
requirements of the TRRO and the methodology defined in Section V(A) of the
Settlement Agreement. All of the data provided in Highly Confidential
Attachments A, B, C and D are also prepared in a form that meets the
supporting data requirements defined in Section VI(E)(2) of the Settlement
Agreement.
approved in Colorado.
BRIGHAM AFFIDAVIT 3
Further affiant sayeth not
SUBSCRIBED AND SWORN to before me the 20th day of June, 2008.
kA
My Commission Expires:
4/l3 )O(Q
BRIGHAM AFFIDAVIT 4
Highly Confidential Attachments A, A
(redacted), B, B (redacted), C and Dare
filed under seal and subject to the terms of
the Protective Agreement.
CERTIFICATE OF SERVICE
I do hereby certify that a true and correct copy ofthe foregoing AFIDAVIT OF ROBERT
BRIGHA was served on the 27th day of June, 2008 on the following individuals:
Jean D. Jewell
Idao Public Utilities Commssion
472 W est Washigton Street
P.O. Box 83720
Boise, il 83702
Telephone [phone]
Facsimile: [phone]
jj ewel1q?puc. state. id. us
.. Hand Delivery
U. S. Mail
Overnght Delivery
Facsimile
Email
~Ab'-Mars:n
Attorney for Qwest Corporation