20080627Torrence Afffidavit.pdf

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Mary S. Hobson (ISB. No. 2142)
999 Main, Suite 1103
Boise, ID 83702
Tel: [phone]
mary.hobson(igwest.com
27 M'j 10: t 2
Adam L. Sherr
Corporate Counsel, Qwest
1600 7th Avenue, Room 3206
Seattle, WA 98191
Tel: [phone]
adam.sher(iqwest.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 REMAD ORDER
Case No. QWE-T-08-07
AFFIDAVIT OF RACHEL TORRENCE
STATE OF COLORAO )
) ss.COUNTY OF ARAHOE )
I, RACHEL TORRENCE, being first duly sworn, depose and state that:
1. My name is Rachel Torrence. I am employed by Qwest Corporation as a
Director in the Network Policy Group of the Local Network Organization. My
business address is 700 W. Mineral Avenue, Littleton Colorado, 80120.
TORRENCE AFFIDAVIT 1
2. Consistent with the processes and procedures contained in the "Multi-State
Settlement Agreement Regarding Wire Center Designations and Related
Issues"i which was included as Attachment A to Qwest's Petition for
Commission Approval of Non-Impaired Wire Center Lists Pursuant to the
Triennial Review Remand Order filed with the Commission on Friday, June 20,
2008 (here after refered to as the "Settlement Agreement"). Qwest also filed a
list of additional Non-Impaired Wire Centers on June 20,2008 with the varous
state regulatory commissions including the Idaho Public Utilities Commission.
Qwest also fied the list of additional Non-Impaired Wire Centers with the
Federal Communications Commission ("FCC").
3. In support of the filing, I conducted an inventory of Fiber-Based Collocators in
Qwest Wire Centers to ascerain the number of fiber-based collocators in each
wire center and the appropriate "Tier" designation (See Highly Confidential
Attachment A to this affdavit as referenced in paragraph 5). The Tier was
subsequently used to establish Non-Impairment.
4. As par of that inventory, and consistent with the processes and procedures
contained in the Settlement Agreement, I conducted a physical field verification
of the inventoried fiber-based collocators, and cross-referenced the physical
inventory data with the corresponding order and construction records and biling
data. The results of that physical field verfication (The Collocation
Verification Worksheets) are contained in Highly Confidential Attachment B to
this affidavit.
5. As necessary to validate the inventory data, I researched actual order records
and engineering design and constrction records to validate the physical
configuations and the presence of an active power supply. I also researched
and validated the RFS ("Ready for Service") dates which are noted on Highly
Confidential Attachment A; "Collocations by Wire Center."
1 The "Multi-State Settlement Agreement Regarding Wire Center Designtions and Related Issues" was
fied in multiple states and has been adopted in Arzona, Oregon, Minnesota, Utah and Washington.
TORRENCE AFFIDAVIT 2
6. I also researched the billing records for the collocation space and the active
power supply to the collocation to ensure that it was an active Fiber-Based
Collocation.
7. Qwest sent the identified fiber-based collocators a letter requesting fuer
validation of their status as a fiber-based collocator and any updated
information with respect to changes in ownership, mergers and/or acquisitions
(See Highly Confidential Attachment C for a copy of the letter(s), and Highy
Confidential Attachment D for a sumary of the responses received and copies
ofthe correspondence between Qwest and responding CLECs).
8. Qwest undertook a thorough analysis to ensure that the number of Fiber-Based
Collocators in Qwest Wire Centers was accurately counted. Its process for
identifying qualifying collocators produced an accurate and verified count. This
accurate and verfied data on the number of Fiber-Based Collocators was one of
two factors in deterining which Idaho wire centers were Non-Impaired. The
other factor was the number of Business Lines in each Wire Center based on the
most recently filed ARMIS 43-08 data. The resulting list of Non-Impaired
Idaho Wire Centers, is based on the above-described accurate and verfied.
Furher this affant sayeth not.
TORRENCE AFFIDAVIT 3
DATE:June 20, 2008
SUBSCRIBED AND SWORN to before me the 20th day of June, 2008.
My Commission Expires:
~:€-
TORRENCE AFFIDAVIT 4
HIGHLY CONFIDENTIA
ATTACHMENTS A-D
and
ATTACHMENTS A-D (RDACTED)
filed under seal and subject
to protective agreement
CERTIFICATE OF SERVICE
I do hereby certify that a true and correct copy ofthe foregoing AFFIDAVIT OF RACHEL
TORRNCE was served on the 27th day of June, 2008 on the following individuals:
Jean D. Jewell
Idao Public Utilties Commssion
472 West Washington Street
P.O. Box 83720
Boise, ID 83702
Telephone [phone]
Facsimle: [phone]
j j ewell(iuc.state.id. us
.. Hand Delivery
U. S. Mail
Overnght Delivery
Facsimle
Email
~lht-
MarS. bson
Attorney for Qwest Corporation