20090417Hunnicutt Direct.pdf

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2009 APR 17 PH 2= 24BEFORE THE ini,!..i(¡
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IDAHO PUBLIC UTILITIES COMMSSION"IUï!ES
INTHEMATTEROFQWEST )
CORPORATION'S PETITION ) CASE NO. QWE-T-08-07
FOR APPROVAL OF NON-IMPAIRED )
WIRE CENTER LISTS PURUANT TO )
THE TRIENNIAL REVIEW REMAD )ORDER )
)
DIRECT TESTIMONY OF VICTORIA HUNNICUTT
QWEST CORPORATION
APRIL 17, 2009
TABLE OF CONTENTS
Page
I. IDENTIFICATION OF WITNESS .....................................................................1
II. PURPOSE OF DIRECT TESTIMONY................................................................3
III. FCC GOVERNING RULES AND RATE JURISDICTION .............................4
iv. UNE TO PRIVATE LINE CONVRSION ......................................................12
v. APPLICATION OF UNE PRICING STANDARS TO NON-UNES...........19
VI. CONCLUSION ....................................................................................................20
CASE NO. QWE-T-08-07
4/17/09
HUNICUTT, V (Di) i
QWEST CORPORA nON
1
2 I.IDENTIFICATION OF WITNESS
3 Q.PLEASE STATE YOUR NAME, BUSINESS ADDRESS AND
4 POSITION WITH QWEST CORPORATION.
5 A.My name is Victoria Huncutt. My business address is 1801 Californa
6 Street, Denver, Colorado. I am employed by Qwest Corporation as a Director supporting
7 costs and issues management.
8 Q.PLEASE DESCRIBE YOUR EDUCATIONAL BACKGROUND
9 AND EMPLOYMENT EXPERIENCE.
10 A.I have eared a Bachelor of Science in Electrcal Engineering from the
1 1 University of Virginia. In addition, I have taken numerous telecommuncations seminars
12 and classes including graduate courses in Telecommuncations Management.
13 I have been employed by Qwest (formerly, US West) since 1998. My original
14 position was with the transport modeling team in the Pricing and Regulatory Matters
15 deparment as a Cost Analyst. In 1999, I assumed responsibility for the Collocation Cost
16 Model, programing the model and producing the cost studies for the varous Qwest
l7 Corporation cost dockets. In 2003, I began working on analyses and documentation as
18 par of the Loop Modeling team. In 2004, I began work as a techncal analyst and
19 developer in the Public Policy deparent. Presently, my responsibilities include, but are
20 not limited to, technical and cost analyses, as well as providing subject matter expert
21 support on collocation issues in regulatory proceedings.
CASE NO. QWE- T -08-07
4/17/09
HUICUTT, V (Di) 1
QWEST CORPORATION
1 Prior to coming to Qwest, I worked as a computer consultat/programer, as well
2 as a resource management consultant for a softare company.
3
4
5
Q.HAVE YOU TESTIFIED BEFORE THIS COMMISSION BEFORE?
A.No, I have not.
CASE NO. QWE-T-08-07
4/17/09
HUICUTT, V (Di) 2
QWEST CORPORATION
1 II.PURPOSE OF DIRECT TESTIMONY
2 Q.WHAT IS THE PURPOSE OF YOUR DIRECT TESTIMONY?
3 A.I have been called upon to describe the signficance of Qwest s
4 nonrecurng charge ("NRC") to recover the costs that it incurs when implementing the
5 requisite facility conversions for the competitive local exchange carers ("CLECs") that
6 request to remain on Qwests facilities in the state ofIdaho following a non-impairment
7 finding by this Commission. In addition, I show that the conversion rate is no longer
8 associated with an unbundled network element ("UNE,,)l and, therefore, no longer
9 adheres to the UNE rate restrctions. To provide for a better understading of the
10 conversion process, I describe the work activities that Qwest must pedorm in converting
11 a UNE service to a Qwest-provided commercial equivalent service (i.e., a special
12 access/private line circuit). Ths conversion is required in those wire centers deemed
13 "non-impaired" under the stadards set by the Federal Communcations Commission
14 ("FCC") in the Triennial Review Order ("TRO,,)2 and the Triennial Review Remand
15 Order ("TRRO,,).3
16 1 Unbundled network elements are identifiable portions of an incumbent local exchange carer's
("ILEC's") network that may be leased or assigned for use by other, competitive local exchange carriers
("CLECs"). The Telecommunications Act of 1996 has required certin (incumbent) telecommunications
carers to allow other companies to lease UN portions of their network to rapidly deploy new services
and to allow for more competition.
2 Review of the Section 25I Unbundling Obligations of Incumbent Local Exchange Carriers,
Implementation of the Local Competition Provisions of the Telecommunications Act of 1996, Deployment
of Wireline Services Offering Advanced Telecommunications Capability, CC Docket Nos. 01-338, 96-98,
98-147, Report and Order and Order on Remand and Furher Notice of Proposed Rulemaking (adopted
02/20/2003; released: 08/21/2003) ("Triennial Review Order" or "TRO").
3 Unbundled Access to Network Elements, Review of the Section 251 Unbundling Obligations of
Incumbent Local Exchange Carriers, WC Docket No. 04-313, CC Docket No. 01-338, Order on Remand
(adopted 12/15/2004; released: 02/04/2005) ("Triennial Review Remand Order" or "TRRO").
CASE NO. QWE-T-08-07
4/17/09
HUICUTT, V (Di) 3
QWEST CORPORATION
1 III. FCC GOVERNING RULES AND RATE JURISDICTION
2 Q. IS QWEST ENTITLED TO RECOUP THE COSTS FOR SERVICES
3 RENDERED ON BEHAF OF CLECs IN CONVRTING FROM UNE
4 SERVICES TO FEDERALLY TARIFFED SPECIAL ACCESSIPRIVATE LINE
5 ("PRIVATE LINE") SERVICES?
6 A.Yes. Qwest incurs costs in the process of converting the requesting
7 CLEC's UNE transport or high-capacity loops to alternative facilties and arangements
8 and, therefore, should be permitted to assess an appropriate charge.4 If the CLEC
9 chooses to avail itself of facilities other than those offered by Qwest, the CLEC would
10 not be charged because Qwest would not incur the costs of performing the tasks
11 associated with conversion ofUNE facilities to alternative facilities precipitated by a
12 determination of wire center non-impairment.
13 Q.IS THIS DOCKET THE CORRCT VENUE TO DETERMINE
14 THE APPROPRIATE RATE AMOUNT TO CHARGE FOR THE CONVERSION
15 PROCESS?
16 A.No, I do not believe so. This docket addresses the non-impairment status
17 of two Idaho wire centers. As I discuss in greater detal below, this is not the appropriate
18 venue to address issues that fall under the FCC's jursdiction. Furhermore, the TRRO is
The TRRO reversed the TRO, in par. The TRRO also clarified the impairent stadard adopted in
the TRO and modified its application of the unbundling frework. Please refer to Ms. Albersheim's
Direct Testimony (Idaho Case No. QWE-T-08-07, dated April 17,2009) ("Albersheim Direct") for a
summar of the FCC's TRO and the TRRO.
4 Please see Albersheim Direct regarding UN transport and high-capacity loops.
CASE NO. QWE-T-08-07
4/17/09
HUICUTT, V (Di) 4
QWEST CORPORATION
1 clear that with a non-impairment designation the paries must negotiate, in good faith,
2 reasonable processes and procedures to ensure that the completion of the conversion
3 process is timely.5 As discussed in Ms. Albersheim's Direct Testimony, Qwest and a
4 number of CLECs have negotiated these processes and procedures and arved at a
5 settlement that includes an appropriate conversion charge.
6 Q.WHAT FCC RULES GOVERN THE PRICING OF UNEs?
7 A.Sections 251 and 252 of the Act under Part II - Development of
8 Competitive Markets, address the carer obligations and the stadards for pricing UNs.
9 Section 251, Interconnection, details the duties and obligations of all local exchange
10 carers, including the obligation of the ILEC to provide unbundled access to any
11 requesting telecommuncations carier in order to fuer the development of competitive
12 markets. Section 252 of that same Par, Procedures for Negotiation, Arbitration, and
13 Approval of Agreements, sets fort the expectations associated with negotiations of rates,
14 terms and conditions for interconnection, services, and network elements pursuat to
15 section 251. Under Section 271 of the Act,6 adherence to Sections 251 and 252 was a
16 requirement for Bell Operating Companes ("BOCs") to enter into interLA T A services
17 such as interLAT A long distance. The FCC is clear in sections 251 and 252 that the state
18 commissions have jurisdiction over UNE rates, terms and conditions.
5 See TRRO, ir 233, at page 133.
6 Section 271, Bell Operating Company Entr Into InterLATA Services, falls under Part III-
Special Provisions Concerning Bell Operating Companies and provides a competitive checklist with which
each Bell Operating Company ("BOC") was required to demonstrte compliance with in order to offer
interLA T A long distace services.
CASE NO. QWE- T -08-07
4/17/09
HUICUTT, V (Di) 5
QWEST CORPORATION
1 Q.ONCE COMPETITION HAS BEEN CONFIRMED THROUGH
2 THE DESIGNATION OF A NON-IMPAIRED WIRE CENTER, WHT PRICING
3 RULES GOVERN THE RATES, TERMS AND CONDITIONS ASSOCIATED
4 WITH THE NON-UNE ELEMENT?
5 A.Sections 201 and 202 under Part I-Common Carrier Regulation, of the
6 Act address the standards for pricing elements that have been removed from the list of
7 Section 251 UNEs (delisted UNEs). Section 201, Service and Charges, addresses the
8 duties of every common carier engaged in interstate or foreign communication to
9 fuish such communication services such that all charges, practices, classifications, and
10 regulations for and in connection with such communcations service shall be just and
11 reasonable.7 The FCC has jursdiction over delisted UNEs that fall under section 271 and
12 which rates are filed in interstate taffs.
13 Q.DOES THE FCC ADDRESS PRICING OF "DELISTED" UNEs
14 (FORMER UNEs THAT HAVE BEEN REMOVED FROM THE LIST OF
15 SECTION 251 UNEs)?
16 A.Yes, the FCC is clear on ths issue. In paragraph 656 of the TRO, the FCC
17 made the following statement addressing sections 251, 252 and pricing under a non-
18 impairment scenaro:
19 Where there is no impairment under section 251 and a network element is no
20 longer subject to unbundling, we look to section 271 and elsewhere in the Act
7 See the FCC's Communications Act of 1934, Title II - Common Carriers, Part I - Common
Carrier Regulation, Section 20 1 (b), at page 36.
CASE NO. QWE-T-08-07
4/17/09
HUICUTT, V (Di) 6
QWEST CORPORATION
1 to determine the proper standard for evaluating the terms, conditions, and
2 pricing... 8 (Emphasis added.)
3 In that same paragraph of the TRO, the FCC is more specific in its discussion of
4 transitional pricing issues:
5 Congress established a pricing standard under section 252 for network elements
6 unbundled pursuat to section 251 where impairment is found to exist. Here,
7 however, we are discussing the appropriate pricing stadard for these network
8 elements where there is no impairment. Under the no impairment scenaro,
9 section 271 requires these elements to be unbundled, but not using the statutorily
10 mandated rate under section 252. As set fort below, we find that the appropriate
11 inquiry for network elements required only under section 271 is to assess whether
12 they are priced on ajust, reasonable and not uneasonably discriminatory basis-
13 the stadards set forth in sections 201 and 202. (Emphasis is original.)9
14 In the next paragraph, the FCC specifically addresses the appropriate application of
15 sections 251 and 252 on network elements:
16 Section 252( d)(l) provides the pricing stadard "for network elements for
17 puroses of (section 251(c)(3))," and does not, by its terms, apply to network
18 elements that are required only under section 271. Indeed, section 252(d)(l) is
19 quite specific that it only applies for the purposes of implementation of section
20 251 (c )(3) - meaning only where there has been a finding of impairment with
21 regard to a given network element. (Footnote omitted.) (Emphasis added.io
22 To sumarze my point, before any conversion is required by the FCC ruing, there must
23 be a non-impairment designation. Once a state commission has confrmed non-
24 impairment, according to the FCC, the pricing stadards set fort in sections 201 and 202
25 of the Act (not those in sections 251 and 252) govern.
8 See TRO, ~ 656, at page 409.
9 See TRO, ~ 656, at page 409. Although the TRO was reversed in par by the D.C. Circuit in the
USTA II decision, this par of the TRO was not reversed.
10 See TRO, ~ 657, at page 409.
CASE NO. QWE- T -08-07
4/17/09
HUICUTT, V (Di) 7
QWEST CORPORATION
1 Q.FOR A NETWORK ELEMENT UNDER SECTION 271 AS
2 DISCUSSED IN THE QUOTATION IN THE PREVIOUS ANSWER, WHT IS
3 THE BASIS FOR DETERMINING AN APPROPRIATE RATE?
4 A.The FCC has stated that such elements must "be priced on a just,
5 reasonable and not uneasonably discriminatory basis - the standards set forth in sections
6 201 and 202." (Footnote omitted.)l1
7 Q.HAS THE FCC ADDRESSED HOW A BELL OPERATING
8 COMPANY ("BOC") LIKE QWEST MIGHT SATISFY THIS STANARD?
9 A.Yes, in the TRO, the FCC listed two examples of how a BOC might satisfy
10 this stadard:
11 1. "(Demonstrate) that the rate for a section 271 network element is at or below
12 the rate at which the BOC offers comparable fuctions to similarly situated
13 purchasing carers under its interstate access taiff, to the extent such14 analogues exist," 12 or
15 2. "(D)emonstrate that the rate at which it offers a section 271 network element
16 is reasonable by showing that it has entered into ars-length agreements
17 with other, similarly situted purchasing carers to provide the element at18 that rate.,,13
11 TRO, ~ 656, at page 409.
12 TRO, ~ 664, at page 412.
13 Id.
CASE NO. QWE-T-08-07
4/17/09
HUICUTT, V (Di) 8
QWEST CORPORATION
1 Q.REGARDING THE FIRST EXAPLE, ABOVE, CAN QWEST
2 DEMONSTRATE THAT THE CONVERSION CHARGE IT INTENDS TO
3 ASSESS IS AT OR BELOW THE RATE AT WHICH QWEST OFFERS
4 COMPARLE FUNCTIONS TO SIMILARY-SITUATED CARERS UNDER
5 ITS INTERSTATE ACCESS TARFF?
6 A.Yes. The $25 conversion rate is based on the Design Change Charge
7 found in Qwest's FCC Tariff No. 114 with a 50% rate reduction applied when assessed for
8 the conversion of UNE services to finished Private Line services. The 50% reduction
9 factor applied to the federally tarffed Design Change Charge was a negotiated amount,
10 pursuat to the FCC transitional Rules, and agreed to in the settlement discussions
11 described in Ms. Albersheim's Direct Testimony. The Settlement Agreement that
12 resulted from those discussions has been approved in five states and provides for the
13 conversion rate at $25.
14 Q.REGARING THE SECOND EXAPLE, ABOVE, HAVE
15 SIMILARLY-SITUATED CARRERS ENTERED INTO AN ARS-LENGTH
16 AGREEMENT TO PROVIDE THE ELEMENT AT THE SAME RATE?
17 A.Yes, numerous CLECs have entered into the Settlement Agreement,
18 mentioned above, providing for the $25 conversion charge. In addition, 146
19 interconnection agreements containing the same conversion charge have been entered
14 See Qwest's FCC Tariff No. 1, Section 5.2.2.C, at 2nd Revised Page 23. Qwest's FCC Tarff
No. 1 can be found at http://tariffs.gwest.com:8000/0TariffsIFCC/index.htm. The 50% reduction of
the Design Change Charge is noted in the footnote associated with the rate.
CASE NO. QWE-T-08-07
4/17/09
HUICUTT, V (Di) 9
QWEST CORPORATION
1 into across Qwest s 14-state region. Of the 146 agreements providing the element at that
2 rate, eight of them were with CLECs operating in Idaho.
3 Q.is QWEST ASKING THIS COMMISSION TO ACKNOWLEDGE
4 ITS RIGHT TO ASSESS AN APPROPRIATE CHARGE FOR THE WORK THAT
5 IT PERFORMS IN THE CONVRSION PROCESS?
6 A.Yes. I am demonstrating with this testimony the natue and cause of the
7 work activities that Qwest will pedorm in processing the conversions from UNE services
8 to Qwest Private Line services that will occur at those wire centers the FCC has deemed
9 non-impaired. For the reasons stated above and pursuat to the FCC rules, Qwest
10 believes that its existing, federally tariffed Design Change Charge represents an
11 appropriate, albeit conservative, charge to CLECs for costs incured by Qwest to process
12 these conversions on behalf of the CLECs. Qwest respectfully asks this Commission
13 merely to acknowledge Qwests right to assess such a negotiated and federally taffed
14 charge to recoup a portion of its costs incured for the work that it pedorms on behalf of
15 the CLEC.
16 Q.IF QWEST BELIEVES THIS is NOT THE PROPER
17 JURISDICTION FOR RATE APPROVAL OF A FORMER UNE, WHY is IT
18 PRESENTING THE RATE TO THIS COMMISSION?
19 A.The FCC declined suggestions to adopt rules establishing specific
20 procedures that ILECs and CLECs must follow to convert to non-section 251 services,
21 with the expectation that both paries have enough incentive to negotiate, and not litigate,
CASE NO. QWE- T -08-07
4/17/09
HUICUTT, V (Di) 10
QWEST CORPORATION
1 to establish any necessar procedures to perform conversions.15 For this reason, Qwest is
2 neither submitting a cost study nor is it requesting approval of a paricular rate. Rather,
3 Qwest is simply asking that this Commission acknowledge that Qwest is entitled to be
4 compensated for the costs that it incurs in the seamless conversion from UNE services to
5 alternative services (such as finished Private Line services) should a CLEC request to
6 remain on Qwest facilities after a non-impairment designation. Qwest makes this request
7 with the hope that such acknowledgement will serve the FCC's goal of encouraging
8 ILECs and CLECs to negotiate in good faith regarding any rates, terms, and conditions
9 necessary to implement the FCC rule changes,16 and to ensure that paries do not engage
10 in unecessar delay in implementing the FCC's rule changes,17 through litigation or by
11 other means.
12
15 See TRO, ir 585, at page 371.
16 See TRRO, ir 233, at page 133.
17id.
CASE NO. QWE- T -08-07
4/17/09
HUICUTT, V (Di) 11
QWEST CORPORATION
1 iv. UNE TO PRIVATE LINE CONVERSION
2 Q.GIVEN A NON-IMPAIRMENT FINDING, DOES A CLEC HAVE
3 CHOICES OTHER THA TO CONVRT ITS UNE SERVICES TO QWEST
4 PRIVATE LINE SERVICES?
5 A.Absolutely. A determination of non-impairment means that substatial
6 competition exists. For non-impaired wire centers, CLECs have facilities available to
7 them from other carers and no longer remain reliant on the ILEC.
8 For wire centers that this Commission has confrmed to be non-impaired, the FCC
9 has found that sufficient alternatives are available to CLECs in the affected wire centers
10 to preclude CLECs' exclusive reliance on Qwest facilities in order to maintan a
11 competitive marketplace. Not only do CLECs have facilities available to them from
12 other cariers, but CLECs have the option to construct their own facilties, thereby
13 makng reliance on Qwest s, or any other providers' , DS 1 and DS3 facilities unecessary.
14 Q.SHOULD IT CHOOSE TO DO SO, COULD A CLEC REMAIN ON
15 QWEST'S FACILITIES RATHER THAN DISCONNECTING AND USING ITS
16 OWN FACILITIES OR THOSE OF OTHER CARERS?
17 A.Yes, it can. As a result of a non-impairment determination, Qwest is no
18 longer required to provide UNE access to DS 1 or DS3 loops, or DS 1 or DS3 inter-office
19 transport in wire centers that have met the FCC thresholds for non-impairment.
20 However, comparable facilities are stil offered as Private Line services instead of as
21 UNE services. A CLEC may request to remain on Qwest s facilities, but its existing
22 UNE facilities must be converted to federally taffed Special AccesslPrivate Line
CASE NO. QWE-T-08-07
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HUNICUTT, V (Di) 12
QWEST CORPORATION
1 Services. When a CLEC requests to remain on Qwest facilities rather than disconnecting
2 entirely and availing itself of alternative facilties, the CLEC has implicitly decided that
3 converting from UNE services to Qwests Private Line services is the most attactive
4 business choice among varous alternatives. If Qwest were not permitted to charge
5 CLECs for the costs incured to perform the conversion, such no-cost conversions could
6 distort the appropriate economic assessments and create an inappropriate incentive for the
7 CLECs to convert to Qwests facilities, rather than explore other alternatives, such as
8 building its own facilities. Furhermore, if Qwest were required to pedorm the activities
9 associated with the conversion, but were prevented from recovering the costs of such
10 activities, the economic burden would be inappropriately shifted to Qwest. This
11 inappropriate shift of the economic burden would ultimately and negatively affect
12 Qwests end-user customers, thus, placing Qwest at a disadvantage in a marketplace that
13 the FCC deemed to be competitive and underminng importt goals of the Act.
14 Therefore, to the extent that Qwest incurs costs to facilitate the CLEC's
15 conversion from a UNE service to a Special AccesslPrivate Line service, Qwest is
16 entitled to assess an appropriate, nonrecuring charge to recover its costs.
17 Q.TO GET A BETTER UNERSTANING OF THE PROCESS,
18 WHAT STEPS AR INVOLVED IN CONVRTING A UNE SERVICE TO A
19 SPECIAL ACCESSIPRIVATE LINE SERVICE?
20 A.The conversion of a UNE service to a Special AccesslPrivate Line service
21 involves three functional areas within Qwests ordering and provisioning organizations.
22 The personnel within the three fuctional areas involved with a conversion are: (1) the
CASE NO. QWE-T-08-07
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HUICUTT, V (Di) 13
QWEST CORPORATION
1 Service Delivery Coordinator ("SDC"), (2) the Circuit Designer, and (3) the Service
2 Delivery Implementer. Within each of these three job fuctions, there are a varety of
3 steps that Qwest must undertake to ensure the data for the converted service is accurately
4 recorded and tracked in the appropriate systems.
5 Upon the request from a CLEC to remain on Qwest facilities and, therefore,
6 convert its UNE services to Qwest Private Line services, the SDC reviews and confrms
7 the data in the Access Service Request ("ASR") and ensures the data is accurately
8 incorporated into the two service orders required to transfer from the Customer Record
9 and Information System ("CRIS") biling system (for UNE services) to the Integrated
10 Access Biling System ("lABS") biling system (for Private Line services).18 The SDC is
11 the primar contact for the CLEC and provides end-to-end order coordination from
12 request to order completion. In addition, the SDC must change the circuit identifier
13 ("circuit ID") to reflect the fact that the circuit will be tracked, handled and maintained as
14 a Private Line service rather than a UNE service upon completion of the conversion
15 process.19 This change in the circuit ID is critical since the circuit identifier determines
16 the processes and personnel that handle, bil and maintain the circuit going forward. I
18 An ASR is an industr-stadard order form used by a carer, such as a CLEC, for the ordering
of a carer-to-carier service. The CRIS biling system is used for the majority of residential and business
account bils for exchange services. It calculates, prints, and prepares the bils to be sent to individual retail
end-user customers for retail products, and to CLECs for some interconnect (wholesale) products. The
lAS biling system is focused on access or facilty-driven biling, whose fuctionality includes switched
and special service orders, meet-point biling, mechanized adjustments for interexchange cariers and other
facilities-based CLEC accounts.
19 The circuit identifier ("circuit ID") is an alpha/numeric identifier whose sequence of letters and
numbers define the characteristics of a paricular circuit and indicates attibutes of the circuit, such as the
LATA and jurisdiction, as well as the tye of circuit, service code and service modifiers. In addition, the
circuit ID contains a serial number for the circuit to ensure that no duplication occurs, and an identifier for
the region in which the circuit is physically located. The circuit ID follows Telcordia (formerly Bell Labs)
stadards and allows lower-level trcking for maintenance and reporting puroses.
CASE NO. QWE-T-08-07
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HUNICUTT, V (Di) 14
QWEST CORPORATION
1 discuss this in fuher detail later in this testimony. The SDC must then pedorm the
2 validation of Work Force Administration ("WFA") and Service Order Assignent
3 Control ("SOAC") data.2o
4 The Circuit Designer reviews and validates the circuit design and ensures that the
5 design records for the converted, non-UNE service match the original UNE service. The
6 Circuit Designer also ensures that no physical changes to the circuit are needed and
7 reviews the circuit inventory in the Tru Integrated Record Keeping System ("TIRKS")
8 database to ensure accuracy and database integrty.zi This effort assists other Qwest
9 deparents that are "downstream" from the Circuit Designer to ensure that there is no
10 service interrption for the CLEC's end-user customer.
11 Finally, the Service Delivery Implementer assumes overall control for the order
12 provisioning. The SDI verifies the "record-out" and "record-in" orders and completes the
13 update of the circuit orders in the WF A system.22
20 The Work Force Administration ("WFA") is a mechanized system that support and simplifies
the coordination, trcking, pricing, and assigning of work requests, while the Service Order Assignent
Control ("SOAC") is a Telcordia system that controls the flow of service order activity from Qwest service
order processors ("SOPs") to other "downstream" systems. Based on the service order input, SOAC
determines which operations systems need to be involved in activating service, and provides instrctions
and sequencing to those operations systems.
21 The Tru Integrted Record Keeping System ("TIRKS") database is a Telcordia application
that trcks and inventories central offce and outside plant facilties. TIRKS contains the inventory
information to update equipment components, frame data, circuit assignents, and other data related to
telephone equipment.
22 Record-in and Record-out orders are the in- and out-service orders that establish the "new"
private line service for the CLEC and that disconnect the existing UNE by moving the circuit data from one
biling system to another. These in- and out-service orders also reflect the updated circuit data for all the
various databases which track circuit status/activity.
CASE NO. QWE- T -08-07
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HUNICUTT, V (Di) 15
QWEST CORPORATION
1 Q.WHY MUST THE "CIRCUIT ID" BE CHAGED WHEN
2 CONVRTING FROM A UNE SERVICE TO A PRIVATE LINE SERVICE?
3 A.The FCC rules require that telephone carrers accurately maintain records
4 that track inventories of circuits. Specifically, 47 C.F.R. 32.12(b) and (c) provides as
5 follows:
6 (b) The company's financial records shall be kept with suffcient paricularty to
7 show fully the facts pertaining to all entres in these accounts. The detail
8 records shall be fied in such maner as to be readily accessible for
9 examination by representatives of this Commission.
10 (c) The Commission shall require a company to maintain financial and other
11 subsidiar records in such a maner that specific information, of a type not
12 waranting disclosure as an account or sub-account, wil be readily available.
13 When this occurs, or where the full information is not otherwse recorded in
14 the general books, the subsidiar records shall be maintained suffcient detail
15 to facilitate the reporting of the required specific information. The subsidiar
16 records, in which the full details are shown, shall be sufficiently referenced to
17 permit ready identification and examination by representatives of this
18 Commission (FCC).
19 Thus, Qwest is required to maintain subsidiar records in sufficient detail to align
20 specific circuits with the biling, accounting, and jursdictional reporting requirements
21 related to the services that these circuits support. These subsidiar records include cable
22 engineering and assignment records, one of which is the circuit ID. In order to
23 sufficiently maintain its subsidiar records to support its accounting for UNE services
24 versus its Private Line services, Qwest must maintain accurate circuit IDs that properly
25 track circuits separately. Furher, the unque circuit ID is maintained as a means of
26 measuring the different service pedormance requirements that apply to UNE services and
27 Private Line services.
CASE NO. QWE-T-08-07
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HUNICUTT, V (Di) 16
QWEST CORPORATION
1 Q.is QWEST'S PROCESS FOR CONVRTING A UNE SERVICE TO
2 A PRIVATE LINE SERVICE TRASPARENT TO THE CUSTOMER?
3 A.Yes. The process that Qwest has established for converting UNE services
4 to Private Line services is specifically designed to ensure that the conversion is seamless,
5 or transparent, to both the end-user customer and the CLEC serving that customer.
6 However, it is importt to note that the efforts to ensure the seamless natue of the
7 conversion require some manual intervention.
8 Q.TO ENSURE THAT THE CONVERSION PROCESS is
9 TRANSPARENT TO THE CLEC AND THE CLEC CUSTOMER, WHAT
10 MANUAL FUNCTIONS MUST QWEST PERFORM?
11 A.Because conversion necessitates a change from a UNE product to a
12 Private Line service, and because these services are biled, inventoried and maintained
13 differently in Qwests systems, Qwest must process them as a "record-out" and a "record-
14 in," and change the circuit IDs to move them from one product category to the other. In a
15 number of Qwest's systems, the TIRKS database and the WFA system, circuit IDs
16 identify, among other things, whether a circuit is classified as a UNE or a private line,
17 what tye of testing parameters apply, and which maintenance and repair center is
18 responsible for that circuit.
19 To be certin that the conversion process is transparent (no service disruption) to
20 the CLEC and its customers, Qwest interjects a number of manual activities into the
21 process so that certn automated steps (designed to aid in the provision of other tyes of
22 services) do not occur that could otherwse result in disruption of those services. The
CASE NO. QWE-T-08-07
4/17/09
HUICUTT, V (Di) 17
QWEST CORPORATION
1 purose of many of the tasks included in the conversion process is to avoid placing the
2 CLECs' end-user customers' service at risk. To date and to my knowledge, afer more
3 than 1500 conversions involving this tye of service change, there have been no
4 complaints from CLECs about customers whose service has been disrupted as a result of
5 this conversion process.
6
CASE NO. QWE- T -08-07
4/17/09
HUICUTT, V (Di) 18
QWEST CORPORATION
1 V. APPLICATION OF UNE PRICING STANDARDS TO NON-UNEs
2 Q. IS THE FORWAR-LOOKING TELRIC COST METHODOLOGY
3 APPROPRIATE FOR QWEST'S CONVRSION CHARGE?
4 A.No. Assignng a Total Element Long Run Incremental Cost
5 ("TELRIC"i3 rate for the nonrecuring charge associated with a federally taffed Private
6 Line service would be both an inappropriate application of TEL RIC rates and outside the
7 scope of this Commission's jursdiction. Nonrecurng TELRIC charges are only
8 associated with the establishment ofUNE products. In this case, the product being
9 established is a federally tarffed Private Line service.
10 Q.HAS THE FCC ADDRESSED THE APPLICATION OF TELRIC
11 PRICING FOR NETWORK ELEMENTS THAT AR NO LONGER SUBJECT
12 TO UNE PRICING?
13 A.Yes. In paragraph 656 of the TRO, at page 409, the FCC spoke
14 specifically to the application of TELRIC to delisted UNEs:
15 Contrar to the claims of some commenters, TELRIC pricing for checklist
16 network elements that have been removed from the list of section 251 UNEs is
17 neither mandated by statute nor necessar to protect the public interest. 24
18
23TELRlC is a calculation method that the FCC requires ILECs to use to charge CLECs for
interconnection and collocation that results in forward-looking rates based on economic cost principles
applicable to UNs. It provides a price ceiling for UN services.
24 TRO, ir 656, at page 409.
CASE NO. QWE-T-08-07
4/17/09
HUNICUTT, V (Di) 19
QWEST CORPORATION
1 VI.CONCLUSION
2
3
Q.
A.In non-impaired wire centers, Qwest is required to convert the former
PLEASE SUMMAZE YOUR TESTIMONY.
4 UNE service to a fmished Private Line service in order to transition the services
5 purchased by CLECs when they request to continue these services with Qwest. The FCC
6 has determined that CLECs are not impaired without access to DS 1 and DS3 UNEs in
7 these non-impaired wire centers. This determination reflects the fact that there are
8 sufcient, competitive alternatives to those UNE services beyond Qwests finished
9 Private Line service offerings. Should a CLEC request to remain on Qwest, finished
10 Private Line facilities, Qwest respectfully asks that this Commission acknowledge
11 Qwest s right to assess an appropriate charge for the activities that it pedorms in the
12 requisite conversion process performed on behalf ofthe CLEC. The rate Qwest intends
13 to assess for CLEC conversion requests is half of an existing, federally tarffed rate, the
14 Design Change Charge.
15 Congress established a pricing stadard under section 252 for network elements
16 that are unbundled pursuat to section 251 where impairment is found to exist. Once a
17 state commission has confirmed non-impairment, however, sections 201 and 202 of the
18 Act (which, unike sections 251 and 252, fall under the jursdiction of the FCC), apply
19 and the requisite conversions are trggered. At that point, the FCC has stated that such
20 elements must be priced on a just, reasonable and not uneasonably discriminatory basis
21 and are not subject to UNE rate restrctions such as TELRIC pricing.
CASE NO. QWE- T -08-07
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HUICUTT, V (Di) 20
QWEST CORPORATION
1 I have demonstrated that the rate amount at which Qwest offers the conversion
2 charge, a rate associated with a network element provided under section 271, is
3 reasonable, albeit conservative, by showing that it has been included in a Multi State
4 Settlement Agreement approved by varous state commissions and interconnection
5 agreements with other, similarly-situated carers. Furher, the rate is below the rate at
6 which Qwest offers comparable fuctions to similarly-situted cariers under its interstate
7 access taiff, specifically Qwests FCC Tariff No. 1.
8 Furher stil, the FCC declined suggestions to adopt rules establishing specific
9 procedures that ILECs and CLECs must follow to convert to non-section 251 services,
10 with the expectation that both paries have enough incentive to negotiate, and not litigate,
11 to establish any necessar procedures to perform conversions,z5 For ths reason, Qwest is
12 neither submitting a cost study nor a rate for approval. Rather, as stated above, Qwest is
13 simply asking that this Commission acknowledge that Qwest is entitled to be
14 compensated for the costs that it incurs in the seamless conversion from UNE services to
15 alternative services (such as finished Private Line services). Qwest makes this request
16 with the hope that such acknowledgement will serve the FCC's goal of encouraging
17 ILECs and CLECs to negotiate in good faith regarding any rates, terms, and conditions
18 necessar to implement the FCC rule changes,26 and to ensure that paries do not engage
25 See TRO, ~ 585, at page 371.
26 See TRRO, ~ 233, at page 133.
CASE NO. QWE-T-08-07
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HUICUTT, V (Di) 21
QWEST CORPORATION
1 in unecessar delay in implementing the FCC's rule changes,27 through litigation or by
2 other means.
3 Q.DOES THIS CONCLUDE YOUR TESTIMONY?
4 A.Yes, it does.
27id.
CASE NO. QWE- T -08-07
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HUICUTT, V (Di) 22
QWEST CORPORATION