20090901Torrence Affidavit.pdf

Mary S. Hobson (ISB. No. 2142)
999 Main, Suite 1103
Boise, ID 83702
Tel: [phone]
mary.hobson(fqwest.com
RECEIVED
1009 AUG 31 PM 3: 45
IOAHO PUBLIC
UTILITIES COMMISSION
Alex M. Duarte
Corporate Counsel, Qwest
421 SW Oak St, 810
Portland, Oregon 97204
Tel: [phone]
alex.duarte(fqwest.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
IS-
Case No. QWE-T-09-)3
AFFIDAVIT OF RACHEL TORRNCE
STATE OF COLORADO )
) ss.COUNTY OF ARAHOE )
I, RACHEL TORRNCE, being first duly sworn, depose and state that:
1. My name is Rachel Torrence. I am employed by Qwest Corporation as a
Director specializing in Network Issues. My business address is 700 W.
Mineral Avenue, Littleton, Colorado 80120.
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
TORRNCE AFFIDAVIT 1
various state regulatory commissions, including the Idaho Public Utilities
Commission. This Commission docketed Qwests 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. In support of these filings, I had conducted an
inventory of "fiber-based collocators," as that term is defined in the TRRO and the
FCC's associated implementation rule, 47 CFR 51.5, in Qwests wire centers to
ascertain the number of fiber-based collocators in each wire center, and the
appropriate "tier" designation. The tier designations were subsequently used to
establish non-impairment of those wire centers that qualify as being non-
impaired.
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, was a "Tier 1" wire center and therefore, is non-
impaired with regard to DS 1 and DS3 transport services.
4. However, in its Order No. 30866, the Commission declined to make a
determination of non-impairment for DS3 loops, 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 wil fie 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 affdavit speaks to the number of fiber-
based collocators at the Boise Main wire center. Renee Albersheim has also
fied an affdavit that speaks to the number of business lines at the Boise Main
wire center.
6. Having already been designated by this Commission as a "Tier 1" wire center
by virte of having exceeded the minimum number of fiber-based collocators,
TORRNCE AFFIDAVIT 2
the Boise Main wire center wil remain a Tier 1 non-impaired wire center in
perpetuity. Thus, the Boise Main wire center already meets the minimum fiber-
based collocator requirement for DS3 loop non-impairment.
7. Because this Commission has already established the Boise Main wire center as
a Tier 1 non-impaired wire center, based on the number of fiber-based
collocators in that wire center, Qwest does not believe that the number of fiber-
based collocators at that wire center needs to be readdressed for purposes of a
finding that the wire center has the requisite number of fiber-based collocators
for DS3 loop non-impairment. Nevertheless, I have reviewed the number of
fiber-based collocators in the Boise Main wire center and have once again
confirmed the presence of five fiber-based collocators in that wire center, which
is suffcient for non-impairment status.
8. Specifically, during the first quarer of each year, I conduct a review of the
number of fiber-based collocators in Qwest wire centers, in preparation for
Qwests annual filings for additions to its non-impaired wire center lists. In
2009, I determined that no collocations in the Boise Main wire center had been
de-commissioned. Furhermore, on April 13, 2009, in preparation for the
scheduled hearing in Case No. QWE- T -08-07, I confirmed that the Boise Main
wire center stil housed the previously identified five fiber-based collocators.
TORRNCE AFFIDAVIT 3
9. Accordingly, the Commission's previous designation of the Boise Main wire
center as a Tier 1 wire center, and the recently confirmed number of five
existing fiber-based collocators, support a Commission finding of DS3 loop
non-impairment for the Boise Main wire center.
Furher this affant sayeth not.
DATE: August 26,2009
SUBSCRIBED AND SWORN to/~~foremet~6th day of August, 2009.\.~,~NOTARYPUBLIC -
My Commission Expires:
S-l! ~d-cJ/ d-PATRICIA II COPER
STATE OF COLORADO
NOTARY PUBLIC
TORRNCE AFFIDAVIT 4
CERTIFICATE OF SERVICE
I do hereby certify that a true and correct copy of the foregoing Qwest's Petition for
Approval of Non-Impairment Status for DS3 Loops in the Boise Main Wire Center
and the Affidavits of Renee A1bersheim and Rachel Torrence were served on the 31st
day of August, 2009 on the following individuals:
Jean D. Jewell
Idaho Public Utilities Commssion
472 West Washington Street
P.O. Box 83720
Boise, il 83702
Telephone [phone]
Facsimile: [phone]
jjeweiicguc.state.id.us
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A i-MarS~ .
Attorney for Qwest Corporation