20090901Albersheim Affidavit.pdf

Mar S. Hobson (ISB. No. 2142)
999 Main, Suite 1103
Boise, ID 83702
Tel: [phone]
mary.hobson~gwest.com
RECEIVED
2009 AUG 3/ PH 3: 46
U. "'L1iDTlli.NO PU, i,,,,,,,, f,Jr, i,I . ¡~S '"1' '-'l.I..C i.1.J~fVi C '"If ~"" ,¡ I' . f i ,r.;;:,.. ~..) j"~;,¡
Alex M. Duare
Corporate Counsel, Qwest
421 SW Oak St, 810
Portland, Oregon 97204
Tel: [phone]
alex.duare~gwest.com
Attorneys for Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITITES COMMISSION
IN THE MATTER OF QWEST
CORPORATION'S PETITION FOR
APPROVAL OF NON-IMPAIRMENT
STATUS FOR DS3 LOOPS IN THE
BOISE MAIN WIRE CENTER
Case No. QWE-T-09-/~
AFFIDAVIT OF RENÉE ALBERSHEIM
STATE OF COLORADO )
) ss.COUNTY OF DENVER )
I, RENEE ALBERSHEIM, being first duly sworn, depose and state that:
1. My name is Renée Albersheim. I am employed by Qwest Corporation as a
Staff Witnessing Representative in the Wholesale Organization. My business
address is 1801 California St., 24th Floor, Denver, Colorado 80202.
ALBERSHEIM AFFIDAVIT - 1 -
2. On June 20, 2008, Qwest filed various petitions for state commission approval
of its "non-impaired" wire center lists pursuant to the Federal Communications
Commission's ("FCC's") Triennial Review Remand Order ("TRRO") with
various state regulatory commissions, including the Idaho Public Utilties
Commission. This Commission docketed Qwest s petition regarding its Idaho
wire centers as Case No. QWE-T-08-07. Qwest also fied the list of non-
impaired wire centers with the FCC.
3. On July 27, 2009, the Idaho Commission issued its Order No. 30866 in Case
No. QWE-T-08-07, in which it found that Qwests Boise Main wire center, with
five "fiber-based collocators," as that term is defined in the TRRO and the
FCC's associated implementation rule, 47 CFR 51.5, is a "Tier 1" wire center
and, therefore, is non-impaired with regard to DS 1 and DS3 transport services.
The Commission also found that Qwests Boise West wire center, with three
fiber-based collocators, is a "Tier 2" wire center and, therefore, is non-impaired
with regard to DS3 transport services.
4. However, in its Order No. 30866, the Commission declined to make a
determination of non-impairment for DS3 loops at the Boise Main wire center,
and stated: "The record does not reveal whether the 2008 year-end data supports
a find of non-impairment for DS3 loops in the Boise Main wire center." Order
30866, p. 5.
5. On August 31, 2009, Qwest will file a petition with the Idaho Commission
requesting approval of non-impairment status for DS3 loops at the Boise Main
wire center. DS3 loop non-impairment results when a wire center houses a
minimum of four fiber-based collocators and supports at least 38,000 "business
lines," as that term is defined in the TRRO and the FCC's associated
implementation rule, 47 CFR 51.5. This affidavit speaks to the number of
business lines at the Boise Main wire center. Rachel Torrence has filed an
affidavit that speaks to the number of fiber-based collocators in the Boise Main
wire center.
ALBERSHEIM AFFIDAVIT 2
3. In support of the fiing, Qwest has prepared business line data that is in
compliance with the requirements of the TRRO and this Commission's Order
No 30866. The Idaho business access line data are attached hereto as Highly-
Confdential Attchments A, B, C and D to my affidavit.
4. Highy-Confdential Attchment A includes the December 2008 TRRO business
line counts, by line type, for the Boise Main wire center. These data are based
on the TRRO business line methodology that the Commission approved in
Order No. 30866 in Case No. QWE-T-08-07 on July 27,2009.
5. Highly-Confidential Attachment B includes December 2008 UNE-L and EEL
data by type of circuit (voice grade, DS1, DS3) for the Boise Main wire center.
These data, along with the data in Highly-Confdential Attchment C, are based
on the TRRO business line methodology that the Commission approved in
Order No. 30866 in Case No. QWE-T-08-07 on July 27,2009.
6. Highly-Confdential Attachment C includes December 2008 UNE-L and EEL
data by type of circuit (voice grade, DS1, DS3) and by Competitive Local
Exchange Carier ("CLEC") for the Boise Main wire center. These data, along
with the data in Highly-Confidential Attchment B, are based on the TRRO
business line methodology that the Commission approved in Order No. 30866
in Case No. QWE-T-08-07 on July 27,2009.
7. Highly-Confidential Attachment D includes December 2008 Qwest Platform
Plus ("QPP") business line data, by Competitive Local Exchange Carier
(CLEC), for the Boise Main wire center. These are based on the TRRO business
line methodology that the Commission approved in Order No. 30866 in Case
No. QWE-T-08-07 on July 27,2009.
8. All of the data provided in Highly-Confdential 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 are based on the TRRO
business line methodology that the Commission approved in Order No. 30866
ALBERS HElM AFFIDAVIT 3
in Case No. QWE-T-08-07 on July 27,2009. Redacted versions of Exhibits A,
B, C and D are attched to this affdavit. Highly-Confdential versions of these
exhibits will be provided upon request to parties that sign a confidentiality
agreement with Qwest.
Furher affant sayeth not
z~ A./~LJRENEE ALBERSHEIM
tiSUBSCRIBED AND SWORN to before me thedZday of August, 2009.
My Commission Expires:
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