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Home My WebLink About20030721Complainants Letter.pdfBoise Idaho Falls Pocatello Moffitt Thomas MOFfATT THOMAS BARRE1'T ROCK & FIELDS , CHTD. Eugene C. Thomas John W. BarrettR. B. Rock Richard C. Fields Robert E. Bakes John S. Simko John C. Ward D. James Manning Gary T. DanceLarry C. Hunrer Morgan W. Richards Mark A. Ellison Randall A. Peterman Mark S. Prusynski Stephen R. Thomas Glenna M. Christensen Gerald T. Husch Scott 1. Campbell Michael G. McPeek Robert B. Burns James C. Dale Michael E. Thomas Patricia M. Olsson James C. deGleeBradley J Williams Lee Radford Michael O. Roe David S. Jensen James 1. Martin C. Clayton Gill David P. Gardner Casey C. Robertson Julian E. GabiolaAngela Schaer Kaufmann Benjamin H. Schwartz Jon A. Stenquist Bradley J. Dixon Keasa 1. Hollister Mark C. Peterson Andrew J. Waldera Shawn C. Nunley Willi, C. Moffatt 1907-1980 Kirk R. He/vie '956-2003 US Bank Plaza Building 101 S Capitol Blvd 10th PO Box 829 Boise Idaho 83701 0829 July 18, 2003 via Hand Delivery 208 345 2000 800 422 2889 208 385 5384 Fax www.moffatt,com =ic r--;I W.) c:: j ::::U ::::: rrl /1 0)r:1 rrI Ms. Jean Jewell Idaho Public Utilities Commission 472 West Washington Post Office Box 83720 Boise, Idaho 83720-0074 rri ::: (/) ;::i0,.. 3:': (f) c:~(fJ 1;! \. ......... (X) :J:.t:;,., .r:- Re: July 11,2003, Qwest SS7 Catalog Changes Case No. QWE-02- PUC Order No. 29219 MTBR&F File No. 15-881.15 and 19-313 Dear Ms. Jewell: We are writing to the Commission on behalf of the Complainants in the above-entitled PUC docket concerning certain revisions to the Qwest Access Services Catalog relating to Common Channel Signaling Access Connection Call Set-Up (the "Catalog Amendments ). The Catalog Amendments were filed by Qwest with the Idaho Public Utilities Commission on or about July 2003, and have an effective date of July 21 2003. Representatives of Qwest and the Complainants have had in-depth discussions of the Catalog Amendments. Such discussions have proven productive, and a number of issues relating to the Catalog Amendments have been addressed. By letter dated July 7 2003 , from Richard R. Wolf to Perry W. Hooks, Jr. (the "Wolf Letter , copy attached), the Complainants provided Qwest with written confirmation of certain of the issues relating to the Catalog Amendments that require resolution. In addition to the Wolf Letter, the Complainants have also provided Qwest with proposed revisions to the Catalog Amendments that would address the concerns that the Complainants have regarding the Catalog Amendments. (However, final resolution regarding the Catalog Amendments will not resolve all the issues addressed in Case No. QWE- T -02- and Order No. 29219.) By letter dated July 10, 2003, from Perry W. Hooks, Jr. to Richard R. Wolf (the "Hooks Letter , copy attached), Qwest confirmed its agreement in principle with the resolution of the Complainants ' concerns stated in the Wolf Letter relating to the Catalog BOI MT2:517431. Ms. Jean Jewell July 18, 2003 Page 2 Amendments. However, Qwest advised that additional time would be required to analyze the specific language changes to the Catalog Amendments that the Complainants proposed. The Complainants are choosing not to object to the Catalog Amendments based on the following conditions: (1) Complainants do not waive, and hereby specifically reserve, any and all rights and remedies granted by the Commission in its Order No. 29219 dated April 15 , 2003; (2) Complainants' failure to object to the Catalog Amendments is specifically made in reliance on Qwest's commitments as set forth in the Hooks Letter; and (3) that the Commission direct Qwest, consistent with the overall objectives of Order No. 29219, to continue to discuss and work cooperatively with the Complainants in an effort to address and to resolve all issues relating to the Catalog Amendments and relating to the complaint in Case No. QWE- T -02-11. Thank you for your consideration. Very truly yours Very truly yours Very truly yours Morgan W. Richards, Jr. ?- '-J.1:.9.) Conley E. Ward ry- V R-v Thomas J. Moorman MWRljrt Enclosures cc: Weldon Stutzman (w/encls. Mary Hobson (w/encls. Charles Steese (w/encls. Stephanie Boyett-Colgan (w/encls. BOI MT2:517431. July ?, 2003 Perry W. Hooks, Jr. Director Network Access & Customer Operations Services Qwest 1801 California Street, Suite 2330 Denver, CO 80202 Dear Perry: I would like to thank you again for your efforts in helping all those involved from VeriSign and its carrier customers in gaining a clearer understanding of the terms and conditions in Qwest's recently filed amended State Access Service Tariffs ('Tariff(s)") relating to SS? message charges. To ensure our mutual understanding of the various discussions that have taken place, below I have summarized the agreement reached on three specific issues that were raised. 1. Qwest does not mean to limit or specify the actual data source(s) used by an access customer or SS? signaling third party hubbing provider for developing their respective percent other messages ("paM") declaration. While Qwest's Tariffs use one term ("call detail records ) in Section 2.10. C.a to describe the data used for developing a PIU, Qwest uses a different term ("signaling message records ) for the paM in Section 2.1 0.a that would seem to dictate that signaling records, not call records, must be used. Qwest explained that its intent was that call detail records or signaling message records could be used as a basis for the paM development. 2. For purposes of properly implementing the tariff, the PIU declaration associated with CCSAC is to be reported separately from any other PIU. This requirement is necessary because the CCSAC charges are to be based on message counts associated with all underlying end user calls and the other PIUs are to be based on minutes of use or other quantification associated with that particular end user traffic. 3. Consistent with the development of the PIU when Qwest first introduced SS? signaling message charges in its FCC Access Tariff, Qwest agrees that SS? third party hubbing providers, like VeriSign , may provide a weighted PIU and paM based on the reported traffic data and PIU/POM factors received from its carrier/customers, since it will be those carrier/customers that initiate the SS? messages at issue. Perry W. Hooks, Jr. July?2003 Page 2 As you can well imagine, your concurrence with our understanding of the above matters will go a long way toward successful resolution of our issues with the Tariffs and allow us to proceed with the development of the appropriate PIU and paM factors. Again, thank you for your help in resolving these matters and please let me know as soon as possible if you disagree within any of the above three statements. Sincerely, Richard R. Wolf Director, Government Relations cc: Don Lewis, Qwest Karen Ferguson, Qwest Marvel Vigil , Cox Valerie Wimer, JSI Jim Naumann, USCC Pam Fuller, AIiTel Wayne Lafferty Lance Tade, Citizens Mark Pohlman , Frontier July 10, 2003 Richard R. Wolf Director, Government Relations VeriSign 4501 Intelco Loop SE O. Box 2909 Olympia, W A 98507 Dear Richard: Thank you for your letter dated July 7 2003. Qwest strongly desires to expeditiously make clear the understanding of Veri Sign and its carrier customers of the Qwest's recently filed tariff amendments relating to SS7 message charges. For that reason, Qwest has conferred with Verisign and its customers several times in the past few weeks to further their understanding. The purpose of this letter is to confmn the understanding that you described in the three numbered paragraphs in your letter. Specifically, Qwest intends to accept an SS7 customer s Percent Other Messages ("POM") declaration that is derived from either call detail records or signaling message records. The language in the proposed tariff amendment was simply copied from the preexisting tariff. For purposes of properly implementing the tariff as it relates to signaling, the PIU declaration for signaling purposes is different than the PIU associated with switched access traffic. Qwest agrees that SS7 third party hubbing providers like VeriSign may provide a weighted PIU and paM based on the traffic data and PIU/POM factors received from its carrier/customers. Hopefully, this response allows two actions to take place. First, Veri Sign will now complete its development of the PIU and POM factors and submit them to Qwest in time for implementation in the coming quarter. As you are aware, we need to receive VeriSign s PIU and POM factors no later than close of business Monday, July 14th in order for the declarations to be applied in the third quarter. Ifneeded, we would be happy to provide further assistance in the calculation of Veri Sign s PIU and POM factors. Second, this addresses the substantive issues that VeriSign has with the tariff amendments and positions VeriSign to withdraw its interventions. As Qwest has previously offered, we will consider specific language changes that Verisign wishes Qwest to consider. However, Qwest believes that implementation of the paM amendments at this time is in the best interests of Qwest's signaling customers such as VeriSign because of the lower bills that are likely to result. I look forward to hearing from you soon regarding the withdrawal of Veri Sign s interventions and any other matters that we may need to discuss. Very Truly Yours Perry W. Hooks, Jr. Director, Wholesale Product Management