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Home My WebLink About200403161st Response of Qwest to Staff.pdfSTOEL ~~,) ' : (' c \1 r: -'\:...\.1L v 1- HID r-' 'fI 'At:,l'l tt: 53 l. \) J' \""" 101 S, Capitol Boulevard, Suite 1900 Boise, Idaho 83702 main 208.389.9000 fax 208.389.9040 ATTORNEYS AT lAW :. , ': , . i"' II 1 '::-C ~" c6hHISSION ~. IVWW.sloel.com March 15 2004 MARY S. HOBSON Direct (208) 387-4277 mshobson(ij)stoeI.com VIA HAND DELIVERY Jean D. Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Boise, ill 83702-5983 RE:Docket No. GNR-OO- Dear Ms. Jewell: Enclosed for filing with this Commission is an original and three (3) copies of QWEST CORPORATION'S RESPONSES TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF. Copies ofthe confidential attachment are provided under separate cover. If you have any questions, please contact me. Thank you for your cooperation in this matter. Very truly yours -:fs ~ f!o :blg Enclosurescc: Service List Oregon Washington Caiifornia U I a h Boise-I 68791.1 0029164-00101 Idaho i~ECEjVED '" D Mary S. Hobson (ISB#2142) Stoel Rives LLP 101 South Capitol Boulevard - Suite 1900 Boise, ID 83702-5958 Telephone: (208) 389-9000 Facsimile: (208) 389-9040 mshobson~stoel.com fin! L\/.V\.;-J riii;\ 11 "1 ' i- UTiLITiES CO/';r-jISSION Adam L. Sherr (WSBA#25291) Qwest 1600 ih Avenue - Room 3206 Seattle, W A 98191 Telephone: (206) 398-2507 Facsimile: (206) 343-4040 adam.sherr~qwest.com Attorneys for Qwest Corporation BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE PETITION FROM THE RESIDENTS OF THE THREE CREEK AREA FOR EXTENDED AREA SERVICE INTO THE MAGIC V ALLEY REGIONAL CALLING AREA CASE NO.: GNR-00- QWEST CORPORATION'S RESPONSES TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION ST AFF Qwest Corporation (Qwest) through its undersigned attorneys provide the following Responses to the First Production Request of the Commission Staff. Qwest understands that the requests are continuing and will supplement its responses, should additional information become available. QWEST CORPORATION'S RESPONSES TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - Page Boise-I 68774. I 0029164-00101 RESPECTFULLY SUBMITTED this 15th day of March, 2004. -' ~t-. Mary s. son Stoel Rives LLP Adam L. Sherr Qwest Attorneys for Qwest Corporation QWEST CORPORATION'S RESPONSES TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - Page 2 Boise-I 68774.1 0029164-00101 CERTIFICATE OF SERVICE I hereby certify that on this 15th day of March, 2004, I served the foregoing QWEST CORPORATION'S RESPONSES TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF as follows: Jean D. Jewell, Secretary Idaho Public Utilities Commission 472 West Washington O. Box 83720 Boise, ID 83702 Telephone: (208) 334-0300 Facsimile: (208) 334-3762 iiewell~puc.state.id. us LXJ Hand Delivery (~ U. S. Mail (~ Overnight Delivery (~ Facsimile (~ Email Lisa Nordstrom Deputy Attorney General Idaho Public Utilities Commission 472 West Washington O. Box 83720 Boise, ID 83702 Telephone: (208) 334-0314 Facsimile: (208) 334-3762 LXJ Hand Delivery (~ U. S. Mail (~ Overnight Delivery Facsimile (~ Email David A. Carpenter Rural Telephone Co 41241 Manitau Road SE Stayton, OR 97383-9709 (~ Hand Delivery(lJ U. S. Mail (~ Overnight Delivery Facsimile J Email Filer Mutual Telephone 405 Main Street O. Box 89 Filer, ID 83328-0089 J Hand Delivery(lJ u. S. Mail (~ Overnight Delivery Facsimile (~ Email James R. Martell Rural Telephone Co 892 West Madison Avenue Glenns Ferry, ID 83623 (~ Hand Delivery(lJ u. S. Mail Overnight Delivery (~ Facsimile J Email QWEST CORPORATION'S RESPONSES TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - Page 3 Boise-I 68774 I 0029164-00101 Harlan Mink House Creek Ranch Rogerson, ID 83302 (~ Hand Delivery(lJ U. S. Mail Overnight Delivery (~ Facsimile J Email Adam L. Sherr (WSBA#25291) Qwest 1600 ih Avenue - Room 3206 Seattle, W A 98191 Telephone: (206) 398-2507 Facsimile: (206) 343-4040 adam.sherr~qwest.com (~ Hand Delivery(lJ U. S. Mail (~ Overnight Delivery (~ Facsimile J Email Clavin K. Simshaw CenturyTel of the Gem State, Inc. O. Box 9901 Vancouver, W A 98668 (~ Hand Delivery(lJ U. S. Mail Overnight Delivery (~ Facsimile (~ Email Kathy Taylor CenturyTel of the Gem State, Inc. 290 North Main Kalispell, MT 59901 (~ Hand Delivery(lJ U. S. Mail Overnight Delivery Facsimile (~ Email ~::h Ld4 Legal Assistant to Mary S. Hobson Stoel Rives LLP QW,EST CORPORATION'S RESPONSES TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - Page 4 Boise-I 68774.1 0029164-00101 Idaho Case No. GNR-00- STF 01-001 INTERVENOR:Staff of the Idaho Public Utilities commission REQUEST NO:001 The commission is considering the EAS requested by the approximately 50 residents of Rural Telephone I s Three Creek exchange (prefix 857) into the Magic Valley Calling Area. Qwest currently serves the Magic Valley Calling Area exchanges of Twin Falls, Jerome, Kimberly, Eden , Hazelton, Murtaugh Dietrich, Shoshone , Gooding, Hagerman, Wendell, Bliss, Buhl and Castleford. Please describe any facility upgrades or new equipment/ facilities, labor required and the estimated cost. Additionally, please describe and document any other costs or lost revenues that Qwest would seek to recover if this EAS were granted. RESPONSE: Currently, Qwest does not have local trunk facilities to Three Creek. Three Creek uses its own facilities to terminate traffic in the Boise accesstandem. At a minimum, an additional facility would have to be built from the Twin Falls local tandem to a meet point. A DS1 or higher port termination at the tandem, links to the meet point, and a termination at the meet point would be necessary to carry the local traffic. Qwest can not estimate a cost of facilities necessary to accomplish this EAS conversion without input from Rural Telephone. Qwest will need to know how many trunks Rural Telephone will require and determine a meet point for the local traffic originating from and terminating to Qwest offices. Additionally, Qwest only has access to Qwest originating access and toll traffic and revenue. Estimates of reciprocating traffic and access revenue as well as traffic volumes using competitive providers that will be converted to local traffic must be received from Rural Telephone to know the total impact to Qwest and RuralTelephone. As of March 10, Qwest has not received a reply from Rural Telephone to its request for information related to EAS in the Three Creekarea. Confidential Attachment A contains the Qwest' s toll and access revenues for 2003. Respondent:Maryann Klasinski, Qwest Manager Boise-168789.10029164-001O1 Idaho Case No. GNR-00- STF 01-002 INTERVENOR:Staff of the Idaho Public Utilities Commission REQUEST NO:002 Does Qwest foresee any significant problems in providing the described EAS? Does Qwest suggest any alternatives to this EAS? RESPONSE: Qwest must have input on traffic volumes and routing information before it can determine whether any significant problems are presented by the proposal and before Qwest can suggest alternatives. Respondent:Maryann Klasinski , Qwest Manager Boise-168789,10029164-00101 STOEL ~~, CEIVED iLED r-1 101 S. Capitol Boulevard. Suite i900 Boise. Idaho 83702 main 208.389.9000 fax 208.389.9040 www.stoel.com zeoli lit;R 15 PM ~: 55 ATTORNEYS AT lAW i ,Y I " ~: ,~~ ~, i l:' 'J IlL! i ICJ L,tJr'lt;iS~ION March 15 2004 MARY S. HOBSON Direct (208) 387-4277 mshobson(ij)stoel.com VIA HAND DELIVERY PROPRIETARY AND CONFIDENTIAL Jean Jewell Deputy Attorney General Idaho Public Utilities Commission 472 West Washington Boise, ID 83702-5983 RE:Docket No. GNR-OO- Dear Ms. Jewell: Enclosed for filing with this Commission is an original and three (3) copies ofthe confidential attachment A for Response to Request No.1 to QWEST CORPORATION'S RESPONSES TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF in the above-referenced matter. Also enclosed is an Attorney Certificate in support of this confidential filing. Thank you for your cooperation in this matter. Very truly yours .-A4/V~~ !Ioh- Mary S. IMson :blg Enclosurescc: Service List (letter only) Oregon Washington California Utah Boise-I 68790.1 0029164-00101 Idaho ATTORNEY'S CERTIFICATE QWEST CORPORATION GNR-OO- This Certificate is made pursuant to Rule 233 of the Idaho Public Utilities Commission s Rules of Procedure I.D.A. 31.01.01000. Filed herein is Attachment for Response to Request No.1 to QWEST CORPORATION'S RESPONSES TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF. This specific information is considered proprietary and confidential due to its competitively sensitive nature. The undersigned hereby asserts that she is familiar with the material claimed not to be available for public inspection, examination and copying, and that she, in good faith, believes that there is a basis in law for that claim, namely that the information contained therein constitutes confidential employee-related information subject to protection. DATED this 15th day of March, 2004. ~thtpf 1/01;, Mary S. bson Stoel Rives LLP Attorneys Representing Qwest Corporation Boise-I 68792.1 0029164-00101