20091013Integra Comments.pdf

riegra
TELECOM RECEIVED
Integra Telecom
6160 Golden Hills Drive
Golden Valley, MN 55416
ww.integratelecom.com
2009 OCT f 3 AM 9: I I
October 12, 2009
Jean D. Jewell, Secretary
Idaho Public Utilties Commission
472 West Washington
Boise, ID 83702-5983
Via Email: jean.jewellrÆuc.idaho.gov
and Via Overnight Delivery
Re: In the Matter of Qwest Corporation's Petition for Approval of Non-Impairment
Status for DS3 Loops in the Boise Main Wire Center
Docket No. QWE-T-09-15
Dear Ms. Jewell:
Enclosed for fiing are an original and seven copies of the Public and Non-Public
Comments of Integra Telecom in connection with the above-referenced matter. Also
enclosed is a Certificate of Service.
Sincerely,~KiK.Wag~
Legal and Regulatory Administrator
Integra Telecom
763-745-8468 (Direct)
763-745-8459 (Dept. Fax)
Kim. Wagner(fintegratelecom.com
Enclosures
cc: Mary Hobson
Alex Duare
R. r.Cc \\1 r.: r)....c' ,,-r',"'). ,,_.c.'"
\l OC1 \ 3 ~M 9: \ G
i do ~ereby certify that on the 12th day of October, 2009, a ie and corr.eç,c;"
of the foregomg Coinents of Integra Telecom was filed and/or served . '~\ji~S\ONfollowing individuals: \JT\U ,,.' ,~,L ¡,¡illl'~
CERTIFICATE OF SERVICE
Via E-mail and Overnight Mail
Jean D. Jewell
Idaho PUC
472 West Washington Street
Boise,ID 83702
Jean. j ewell(fpub.idaho. gov
Via E-mail and U.S. Mail
Mary S. Hobson
999 Main, Suite 1103
Boise, ID 83702
Mary .hobson~qwest.com
Via E-mail
Weldom Stitzman
Idaho PUC
472 West Washington Street
P. O. Box 83720
Boise, ID 83702
Via E-mail and U.S. Mail
Alex M. Duarte
Qwest Corporation
421 SW Oak Street, Room 810
Portland, OR 97204
Alex.duare~qwest.com
Dated: October 12,2009.
REeE!
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSIONno O'C-T f Jllllu7 _ AM 9= , 2
IN THE MATTER OF QWEST
CORPORATION'S PETITION FOR
APPROVAL OF NON-IMPAIRMENT
STATUS FORDS3 LOOPS IN THE BOISE
MAIN WIRE CENTER
)
)
)
)
)
CASE NO. QWE-T-09-15
COMMENTS OF INTEGRA
PUBLIC
I. INTRODUCTION AND SUMMARY
Integra Telecom of Idaho, Inc.; Electric Lightwave, LLC dba Integra Telecom; and
Eschelon Telecom, Inc. dba Integra Telecom (collectively referred to as "Integra")l oppose the
Petition of Qwest Corporation (Qwest's Petition) to classified the Boise Main wire center as non-
impaired for DS3 loops. Qwest's Petition is incomplete and contains a number of errors that
raises into question whether or not Qwest meets the FCC's threshold for DS3 loop non-
impairment? The issues with Qwest's filing are as follows: (A) Integra is unable to verify the
loop count data Qwest associates with Integra; (B) Qwest's methodology for counting CLEC
switched business lines overstates the number of business lines; (C) The data upon which Qwest
has relied to support its switched business line counts is almost a year old; (D) Qwest failed to
provide fiber-based collocation supporting data, which is required to classify Boise Main as non-
impaired for DS3 loops; and (E) Highly Confidential Albersheim Attachment A, which contains
a summary of line count data, is unclear as the data is referenced as both December 2007 and
2
Eletric Lightwave, LLC dba Integra Telecom ("ELI") curently serves customers in Idaho.
C.F.R. § 51.19(a)(5).
1
December 2008 - both of which can't be correct. As a result of these inadequacies, Qwest's
petition should be denied.
Integra requests that the Commission require, (1) Qwest to exclude CLEC residential
loops and CLEC non-switched lines from the CLEC switched business line counts; (2) Qwest to
use current data when requesting a change in the non-impairment status or Tier classification of a
wire center; and (3) Qwest to provide all supporting data when making a request for a change in
the non-impairment status or Tier classification of a wire center.
II. ANALYSIS
A. INTEGRA is UNABLE TO VERIFY THE LOOP COUNT DATA QWEST
ASSOCIATES WITH INTEGRA.
In most non-impairment cases to date, Integra has been able to verify Qwest's Integra
specific line counts to such a degree that any discrepancies were minor and would not impact the
proposed non-impairment designation. One exception is the Eagan-Lexington wire center in
Minnesota, where Integra along with another CLEC found significant discrepancies with
Qwest's data. Qwest subsequently was forced to withdraw its non-impairment proposal for that
wire center admitting that its initial line count estimates were in error. 3
Qwest's loop count data for Integra in the Boise Main is also proving difficult to validate,
as was the case with Eagan-Lexington. For example, Qwest shows a significant number of EEL
circuits belonging to Integra for the Boise Main wire center, while Integra canot find a single
Minesota Docket No. 07-865, Qwest Letter Withdrawing Wire Center, March 7, 2008. It is important to
note that no signal CLEC had enough disputes to alter Qwest's line counts beyond the non-impairent
threshold, but because two CLECs closely reviewed their data in combination the discrepancies were
enough to challenge and force a withdrawal ofQwest's fiing.
2
EEL circuit associated with a customer that resides in those wire centers.4 However, in its
review of its most recent loop count data,5 Integra has identified significantly more DS 1 loop and
2-wire loop circuits than Qwest has counted for Integra in these wire centers. The highly
confidential table below shows the differences in the Integra and Qwest loop counts.
Table 1: Integra Loop Count Discrepancies
(Begin Highly Confidential -- Redacted)
Boise Main
Qwest counts Integra Counts
for Integra
2-wire loops XX XX
DSI loops XX XX
DSI EELs XX XX
(End Highly Confidential -- Redacted)
B. QWEST'S METHODOLOGY FOR COUNTING CLEC SWITCHED BUSINESS
LINES OVERSTATES THE NUMBER OF SWITCHED BUSINESS LINES.
The FCC defines a Business Line as follows:6
A business line is an incumbent LEC-owned switched access line used to
serve a business customer, whether by the incumbent LEC itself or by a
competitive LEC that leases the line from the incumbent LEC. The
number of business lines in a wire center shall equal the sum of all
incumbent LEC business switched access lines, plus the sum of all UNE
loops connected to that wire center, including UNE loops provisioned in
combination with other unbundled elements. Among these requirements,
business line talles (1) shall include only those access lines connecting
end-user customers with incumbent LEC end-offces for switched
services, (2) shall not include non-switched special access lines, (3) shall
4 Note that we have a number of EEL circuits terminating to the Boise Main wire center serving customers
that reside in other wire centers. However, these should not be included in the Boise Main loop counts.
This has not been a point of contention in the past and it is not clear that this is the cause of the
discrepancy in this case.
Integra's data is as of August 31, 2008, the date of Qwest's request for DS3 loop non-impairent.
47 C.F.R. § 51.5, Terms and Definitions, Business Line.6
3
account for ISDN and other digital access lines by counting each 64 kbps-
equivalent as one line. For example, a DSI line corresponds to 24 64-
kbps-equivalents, and therefore to 24 business lines.
There are a number of problems with Qwest's switched business line counts used to
support its petition. Qwest makes two related errors that lead Qwest to overstate CLEC switched
business line counts and thus makes Qwest's total switched business line counts uneliable.
Qwest has previously made clear that Qwest counted all UNE loops in its count of business
lines.7 By doing so, Qwest improperly inflates the count of business lines in the following ways:
. Qwest improperly counts UNE-L lines that are used to serve residential and
not business customers.
. Qwest improperly counts unutilized capacity and capacity used to provide
data services in its UNE- L line counts.
RESIDENTIAL LOOPS SHOULD NOT BE COUNTED IN THE SWITCHED
BUSINESS LINE COUNTS
It is improper to count UNE loops used to serve residential customers because the point
of the TRRO's line count measure is to size the business (not residential) market. This is evident
from the first sentence of the FCC's business line definition, which is as follows:
A business line is an incumbent LEC-owned switched access line used
to serve a business customer, whether by the incumbent LEC itself or
by a competitive LEC that leases the line from the incumbent LEC. The
number of business lines in a wire center shall equal the sum of all
incumbent LEC business switched access lines, plus the sum of all UNE
loops connected to that wire center, including UNE loops provisioned in
combination with other unbundled elements. Among these requirements,
7 Albersheim Direct, Docket QWE-08-07, p. 34, line i.
4
business line talles (1) shall include only those access lines connecting
end-user customers with incumbent LEC end-offices for switched
services, (2) shall not include non-switched special access lines, (3) shall
account for ISDN and other digital access lines by counting each 64 kbps-
equivalent as one line. For example, a DSl line corresponds to 24 64
kbps-equivalents, and therefore to 24 "business lines."g
Qwest reads the second sentence of the above rule in isolation from the rest of the
definition to prop up Qwest s proposal to include CLEC residential and non-switched lines
(served via Qwest UNE loops) in the switched business line count. As correctly observed by the
ALJ in the Colorado Wire Center Case, while on the surface the second sentence may suggest
counting all UNE loops, a complete reading of this rule indicates the exact opposite. Below is
the Colorado Commission's explanation of why UNE loops serving residential customers should
be excluded:
According to the ALl's reasoning, to include residential loops in the court
of business lines in a wire center would impermissibly conflict with the
first sentence and would not give meaning to the entire rule.
Consequently, the ALJ determined that the term "business lines" in the
second sentence must restrict the subsequent phrase "such that all UNE
loops must be confined within the scope of business line as defined in the
first sentence of the paragraph."... As such, the ALJ concluded that given
the plain language of 47 C.F.R. § 51.5, it is ilogical to conclude that a
residential line is a business line. A non-switched UNE loop providing
service to a residential customer conflcts with both the first sentence of
the rule, as well as the third sentence; therefore, the UNE loop component
of the business line calculation by wire center, is to be modified to exclude
residential and non-switched lines. 9
The FCC's rule requires that the business line counts include only lines used to serve
business customers that are switched. In contrast, Qwest s business line count methodology
9
47 C.F.R. § 51. Terms and Definitions, Business Line. (emphasis added).
Colorado RR Decision, p. 3 (footnote referencing the specific paragraph of the AU Recommended
Decision is omitted), attached to this testimony as par of Exhibit 202.
5
includes lines used to service residential (not business) customers as well as lines that are not
switched. In addition to violating the express language of the rule and being inconsistent with
the intent of the rule, Qwests claim that a residential or non-switched line should be counted as a
switched business line simply does not make sense.
Qwest could have easily removed residential loops from its switched business line
counts. When a CLEC orders a loop from Qwest there is a mandatory field on the Local Service
Request ("LSR") where the CLEC indicates whether the loop wil be used to serve a business,
residence or governent customer. Thus, Qwest has information in its possession to enable it to
remove residential loops from its calculation of switched business line counts.
NON-SWITCHED CAPACITY OF LOOPS USED TO SERVE BUSINESSES
SHOULD NOT BE INCLUDED IN SWITCHED BUSINESS LINE COUNTS
In addition to its error in counting residential loops, Qwest counts all UNE- L at their
maximum potential capacity and assumes that this full capacity is dedicated to serve voice
switched demand, which means that Qwest counts all high-capacity/digital DSI UNE-L as 24
individual business switched lines. This approach inappropriately counts chanels on the high-
capacity/digital UNEs that do not provide switched business services - a prerequisite to a line
being counted as a business line. This method inappropriately assumes that every available
chanel on an unbundled high-capacity loop (or its equivalent digital capacity) is being used to
support switched business services, when in fact, much of that capacity might not be used at all
(vacant), and some portion of that capacity in most circumstance wil almost certainly be used
for data services.
6
The lines that are included in the business line count must comply with the entire
definition of business line, which means that these lines must be: (1) used to serve a business
customer; and (2) used to provide switched services (i.e., voice); and to the extent consistent
with these requirements, (3) each 64 kbps chanel should be evaluated as one line. In addition,
as discussed above, whether a line is counted as a business line or not, should not depend upon
whether the customer is served by Qwest or the CLEC.lo Qwest must use the same methodology
for counting CLEC lines as it does in counting its own business lines.
The FCC is clear that Qwest retail switched business line counts should be counted the
same as unbundled loop counts. Immediately after identifying the types of lines that are
candidates to be counted as business lines, the definition adopts limiting language with the
phrase "among these requirements," thereby making clear that the limiting criteria of the
definition apply equally to UNE-L arrangements as well as ILEC retail line counts.
Qwest has not applied the FCC's limiting criteria correctly. Just like the above discussed
case of UNE loops that serve residential customer, Qwest's application of the FCC definition is
based on reading isolated components of the definition of business line in a way that conflcts
with other provisions:
First, Qwest places great emphasis on the second sentence of the definition which, when
read in isolation, states:
The number of business lines in a wire center shall equal the sum of all
incumbent LEC business switched access lines, plus the sum of all UNE
10 This parity requirement is contained within the first sentence of the business line defmition: "an
incumbent LEC-owned switched access lines used to serve a business customer, whether by the
incumbent LEC itself or by a competitive LEC that leases the line from the incumbent LEC."
7
loops connected to that wire center, including UNE loops provisioned in
combination with other unbundled elements.
As interpreted by Qwest, it claims that the sentence permits it to count all UNE- L,
without regard to whether the lines satisfy any of the requirements to be considered a "business
line."
Second, Qwest exploits an example in the definition as an unconditional directive that the
maximum potential capacity of high-speed digital services should be counted, again without
regard to whether any of the threshold requirements to be counted as a business line are being
satisfied.
Importantly, however, there are no absolute instructions in the definition that require that
all UNE loops - much less every 64 kbps chanel - be counted as a business line, whether or not
they otherwise meet the requirements of the definition. As explained above, the definition
applies additional requirements to both UNE loop arrangements and Qwest's retail lines that also
must be satisfied before "a line" can be counted as a "business line." This is true for individual
analog lines, as well as each digital line to which Qwest has counted at its maximum, theoretical
capacity.
It is incorrect to count every DS 1 loop by its maximum potential capacity (i.e., as
switched business lines in all instances). Qwest counts every high capacity/digital UNE loop
assuming that the maximum potential capacity is used to provide switched business line service,
when it understands fully, that such a circumstance is by far the exception, as opposed to the
rule, in today's marketplace. Qwest appears to base its view on its selective reading of the final
instruction, which indicates that the business line count:
8
. . . shall account for ISDN and other digital access lines by counting each
64 kbps-equivalent as one line. For example, a DSI line corresponds to
2464 kbps-equivalents, and therefore to 24 "business lines."
Importantly, a proper reading of the above instruction does not direct Qwest to count
each channel in a high capacity circuit as a "business line." The critical sentence in the quote
cited above is that Qwest "shall account for ISDN and other digital access lines by counting each
64 kbps-equivalent as one line" (emphasis added). This requirement, however, does nothing
more than what it plainly states, i.e., that each 64 kbps-equivalent should be considered "one
line." Whether or not these lines should be counted as business lines, however, depends upon
whether the remaining requirements of the FCC definition are satisfied.
The fact that the definition provides an example of how the analysis might count a DS 1
does not require that Qwest or the Commission, ignore situations in which a similar DS 1 might
provide very little switched business service. Indeed, had the FCC wanted to declare all high
capacity services and circuits as business lines, it could have easily simplified the definition to
say so. But the FCC did not. It directed that each 64-kbps equivalent be considered one line,
and then directed that other criteria - most specifically, that the line also be used to provide
switched access line service to a business customer (i. e., voice service) - be used to determine
whether each "line" should be considered a business line.
Qwest's ARMIS data does not count Qwest s retail switched business lines at their
maximum potential capacity. The ARMIS instructions permit Qwest to count "only those access
lines connecting end-users with their end offces for switched services,"ll which is the same
II http://www.fcc.gov/wcb/armis/documents/2004PDFs/4308c04.pdf at page 20.
9
requirement as in the FCC's definition of "business lines" for its unbundling framework. 12 And
explained earlier, the FCC's business line definition directs that lines be counted whether the line
is served by the ILEC or the CLEC. Thus, whether the line is a Qwest retail line, or a UNE loop
arangement used by a CLEC to provide service, the same criteria apply. Importantly, the term
"business switched access lines" is a defined term in ARMIS 43-08, which is the report that the
FCC directed be used to measure ILEC retail lines.13 The ARMIS reporting instructions require
that Qwest report its lines in voice-equivalents,14 but, importantly, does not permit Qwest to
count empty circuits or data circuits.
is Simply put, Qwest may not count empty or data circuits
on a DS 1 used to provide service to one of its customers (it may only count the activated circuit-
paths) That is perfectly consistent with the FCC's rules with respect to counting business access
lines relative to impairment, unfortunately, that is not the process Qwest undertook.
Since empty (unused) and non-switched circuits would not be counted under Qwests
retail line counts, but would be counted under CLEC UNE-L counts, Qwest would be allowed to
count empty capacity and data circuits simply because the customer switched to the CLEC.
CLECs do not use high capacity UNE-L at their maximum potential capacity for
purposes of providing exclusively switched business services. CLECs provide sophisticated data
services (e.g., high speed internet access, web hosting, IP address, DNS, email services) over
14
The first limiting factor in the FCC's definition of a business line is that "business lines": "shall include
only those access lines connecting end-user customers with incumbent LEC end-offices for switched
services." 47 C.F.R. § 51.5.
TRRO, ~ 105, fn. 303.
See http://www.fcc.gov/wcb/armis/documents/2004PDFs/4308c04.pdf (page 21) defining ARMIS 43-08
Business Switched Access Lines as "total voice-grade equivalent analog or digital switched access lines
to business customers." (emphasis added)
Page 20 of the instrctions for ARMIS 43-08 -like the FCC's business line definition - makes clear that
Qwest may count "only those lines connecting end-user customers with their end offices for switched
services."
12
13
15
10
these loops. These services, while utilizing bandwidth (or 64 kbps channels) on the CLEC's
DS 1 loop, are not switched business lines, and should therefore not be included in the count of
business lines.
Complying with the FCC's full and complete definition of "business line" is not simply a
matter of convenience. The rule makes clear that only switched business lines are to be counted
- not the maximum potential capacity which would include empty circuits and data circuits.
Hence, even if Qwest does not know the utilization rate of CLEC UNE-L for switched business
lines, Qwest canot simply toss out par of the FCC's definition and count all UNE-Ls at their
maximum potential capacity regardless of whether they meet the other applicable criteria. One
option would be for Qwest could request this information from CLECs as part of its request for a
change in the non-impairment status of a wire center. Another option would be for the
Commission to require CLECs to provide this data when Qwest makes a filing involving
switched business line counts.
C. THE DATA UPON WHICH QWEST HAS RELIED TO SUPPORT ITS
SWITCHED BUSINESS LINE COUNTS IS ALMOST A YEAR OLD.
Qwest has relied upon switched business line count data that is at least 8 months old at
the time of Qwest's request for DS3 non-impairment in Boise Main.16
The issue of the appropriate time period to review both the switched business line count
and the fiber-based collocation data is crucial as updates are made to Qwest s Wire Center List.
This Commission should make clear that, as Qwest makes updates to its list, Qwest should use
data that is contemporaneous with Qwest's claim for "non-impaired" status. First, Qwest should
16 See issue E below. Qwest's supporting documentation makes it unclear whether Qwest relied upon
December 2007 or December 2008 line count data.
11
not be allowed to go fishing back through time in attempts to classify wire centers as non-
impaired that do not curently meet the non-impairment status. As described above, it is difficult
for CLECs to validate Qwests line count data. It becomes exponentially more difficult the older
the data becomes. Second, Qwest should not be allowed to select one set of data from one time
period and another set of data from a different time period and then yet another time period to
actually make its claim for non-impairment. For example, suppose there exists a wire center
today that has four fiber-based collocators, but fewer than 38,000 lines. Suppose that the wire
center surasses 38,000 lines in the future, but by this time there are only three fiber-based
collocators. Qwest should not be allowed to choose line counts from the present and fiber-based
collocators from the past. The determination of "non-impaired" status should be made at the
point in time that Qwest is claiming an office is "non-impaired," not from a combination of
counts from different time periods that best advantages Qwest.
Allowing Qwest to selectively choose the time period and data upon which it chooses to
rely would put CLECs at a further substantial disadvantage regarding validation of Qwests data.
It would also disadvantage CLEC business planning as to when and how to expand its presence
in Idaho since it would have to take into account not only the curent conditions of the market,
but also the conditions as they existed in the past.
D. QWEST'S FAILURE TO SUPPLY FIBER-BASED COLLOCATION DATA,
WHICH IS REQUIRED TO SUPPORT THE CLASSIFICATION OF BOISE
MAIN AS NON-IMP AIRED FOR DS3 LOOPS.
When Qwest makes a request for DS3 (or DSl) loop non-impairment, Qwest needs to
meet two tests. First, Qwest needs to demonstrate that the number that the number of switched
business lines exceeds the line count threshold established by the FCC. Second, Qwest needs to
demonstrate that the number of fiber-based collocators exceeds the fiber-based collocation
12
threshold established by the FCC. In this petition Qwest only fied supporting data for switched
business lines, but failed to provide supporting data for fiber-based collocations.
Qwest argues, "(b )ecause 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 the puroses of a finding that the wire center has the requisite
number of fiber-based collocators fro DS3 loop non-impairment.,,17 This is incorrect.
The FCC determined that once a wire center meets both line count and fiber-based
collocation thresholds for DS3 loops, "no future DS3 loop unbundling will be required in that
wire center.,,18 Qwest interprets this to mean that it can apply the fiber-based collocation
standard from one time period and the switched business line standard from another time period.
While Integra acknowledges that once Qwest has obtained Tier 1 status in a wire center the wire
center canot subsequently be reclassified as Tier 2 or Tier 3,19 this does not imply that Qwest no
longer needs to meet the relevant criteria outline to obtain non-impairment status for a DS 1 or
DS3 loop.
Ms. Torrence states that she has reviewed the fiber-based collocations and confirmed "the
presence of five fiber-based collocators in that wire center,,,20 but Qwest failed to supply the
17 Torrence Affidavit, ,r 7.
C.F.R. § 51.319 (a)(5). A similar rule applies to DS 1 loops.
C.F.R. § 51.319 (d)(3)(i). A similar rule applies to Tier 2 status.
Torrence Affidavit, ,r 7.
18
19
20
13
required supporting documentation to support that claim and thus Qwest's petition should be
rejected.21
E. IT is UNCLEAR WHAT TIME PERIOD QWEST'S SWITCHED BUSINESS
LINE COUNTS REPRESENT.
Qwest s switched business line count sumar for Boise Main contains two headings
which make it unclear upon what time period Qwest relied upon to support its request for DS3
loop non-impairment. Highly Confidential Albersheim Attachment A contains the heading
"Idaho 2008 Business Line Counts - December 2008," while the actual table containing
switched line count summary data lists "200712" under "YRMO Data." This presumably refers
to December 2007 as the Year ("YR") and the Month ("MO") of the data.
As discussed above,22 Qwest should have relied upon line count data that is curent with
its request for non-impairment. However, in no event should Qwest have relied upon line count
data that was 20 months old at the time Qwest made its filing.
III. CONCLUSION
Qwest's petition requesting DS3 non-impairment status in the Boise Main wire center
should be rejected simply based on the fact that Qwest failed to supply the required supporting
fiber-based collocation data. In addition, Qwest's line count support should be rejected as it is
unclear as to what time period it represents. Further, Qwests line count data should reflect the
21 Integra recognizes that this Commission recently reviewed the number of fiber-based collocations in the
Boise Main wire center and there were likely not material changes since that review that would impact
whether or not Qwest meets the DS3 loop fiber-based collocation non-impairment threshold. However,
this should not alter Qwest's obligation to supply all supporting data when requesting a change in the
non-impairent status or Tier classification for a wire center.
See section C.22
14
time period associated with Qwest's fiing and Qwest should exclude residential and non-
switched lines from CLEC switched business line counts.
Integra requests that the Commission require Qwest to properly file all supporting data
before a wire center is classified as non-impaired. In addition, Integra requests that the
Commission clarify whether Qwest should exclude CLEC residential loops and CLEC non-
switched lines from the CLEC switched business line counts and whether Qwest must use
curent data when requesting a change in the non-impairment status or Tier classification of a
wire center.
Dated this 12th day of October, 2009.
Respectfully submitted,
Douglas K. Denney
Director, Costs & Policy
1201 Lloyd Blvd, Suite 500
Portland, OR 97232
503.453.8285 (Direct)
Company Representative, Integra
15