200311071st Request of Staff to Local Ex Carriers.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3283
Street Address for Express Mail:
472 W WASHINGTON
BOISE ID 83702-5983
Attorney for the Commission Staff
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IPUC RESPONSE TO
FCC ORDER ON REVIEW OF SECTION 251
UNBUNDLING OBLICATIONS OF
INCUMBENT LOCAL EXCHANGE
CARRIERS (CC DOCKET NO. 01-338).
NINE-MONTH REVIEW ON ECONOMIC
AND OPERATIONAL IMPAIRMENT
REGARDING ACCESS TO SPECIFIC UNES.
CASE NO. GNR-03-
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO COMPETITIVE
LOCAL EXCHANGE
CARRIERS
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record
Weldon Stutzman, Deputy Attorney General, requests that each Competitive Local Exchange
Carrier (CLEC) provide the following documents and information on or before WEDNESDAY
NOVEMBER 26, 2003.
The Company is reminded that responses pursuant to Commission Rules of Procedure must
include the name and phone number of the person preparing the document, and the name, location
and phone number of the record holder. Reference IDAP A 31.01.01.228.
This Production Request is to be considered as continuing, and each CLEC is requested to
provide, by way of supplementary responses, additional documents that it or any person acting on its
behalf may later obtain that will augment the documents produced.
FIRST PRODUCTION REQUEST
TO CLECS NOVEMBER 7, 2003
Please provide answers to each question; supporting workpapers that provide detail or are
the source of information used in calculations; the name and telephone number of the person
preparing the documents; and the name, location and telephone number of the record holder.
For each item, please indicate the name of the person(s) preparing the answers, along with
the job title of such person(s) and the witness who can sponsor the answer at hearing.
Responses for which confidential treatment is requested will be handled in accordance with
the Commission s standard procedures for proprietary information (IDAP A 31.01.01.233). Staff
anticipates the development of appropriate agreements between the parties prior to the sharing of
any such information. If additional protections are desired ("super-confidentiality" procedures, such
as aggregation of data before release to competitors, etc.), please specify any additional procedures
that are requested, and the information for which the additional procedures are requested, as soon as
possible.
Mass Market Switching
Request No.1: Provide a list of all switches that you currently use to provide a qualifying
service (as defined in 47 C.R. ~ 51.5, as that section will be amended by the Final Rules issued by
the FCC pursuant to the Triennial Review Order) anywhere in the state, regardless of whether the
switch itself is located in the state. Do not include ILEC switches utilized by you on an unbundled
basis in the ILEC's service territory or through the resale of the incumbent's services at wholesale
rates.
Request No.2: Identify each ILEC wire center district (i.the territory served by a wire
center of the ILEC) in which you provide qualifying service to any end user customers utilizing any
of the switches identified in your response to Request No.1. Wire centers should be identified by
providing their name, address, and CLLI code.
FIRST PRODUCTION REQUEST
TO CLECS NOVEMBER 7, 2003
Request No.3: For each ILEC wire center identified in response to Request No., identify
the total number of voice-grade equivalent linesl you are providing to customers in that wire center
from your switch(es) identified in response to Request No.1. For purposes of this request
, "
voice-
grade equivalent lines" should be defined consistent with the FCC's use ofthe term.
Request No.4: For each switch identified in response to Request No. I , identify the
approximate capacity of the switch - that is, the maximum number of voice-grade equivalent lines it
is capable of serving - based on that switch's existing configuration and component parts.
Request No.5: With respect to the voice-grade equivalent lines identified in response to
Request No., separately indicate the number being provided to (a) residential customers;
(b) business customers to whom you provide only voice-grade or DSO lines.
Request No.6: For each of the switches identified in your response to Request No., state
whether the switch is owned by you, or whether you have leased the switching capacity or otherwise
obtained the right to use the switch on some non-ownership basis. If the facility is not owned by
you, identify the entity owning the switch and (if different) the entity with which you entered into
the lease or other arrangement, identify the nature of the arrangement, and state whether such entity
or entities are affiliates of yours, in the sense defined in ~ 408, footnote 1263 ofthe Triennial
Review Order.
Request No.7: With respect to the voice-grade equivalent lines being provided to
(a) residential customers; (b) business customers to whom you provide between 1-3 voice-grade
equivalent lines at one location; (c) business customers to whom you provide between 4-24 voice
grade equivalent lines at one location; and (d) business customers to whom you provide 24 or more
1 Voice-grade equivalent lines would include DSO lines and, by the defmition in FCC Form 477 Instructions for the
Local Competition and Broadband Reporting From include traditional analog POTS lines, Centrex-CO extensions and
Centrex-CE trunks. Line counts are based on how they are charged to the customer rather than how they are physically
provisioned (e.g. 2-wire copper, VoIP, fiber).
FIRST PRODUCTION REQUEST
TO CLECS NOVEMBER 7, 2003
voice-grade equivalent lines (in one location), state the current average total monthly revenues
earned per line served in the state by LATA and by MSA and specify the source of those revenues
by service type.
Request No.8: For each switch (e.g. circuit, packet, soft switch, etc.) currently used, or
those that have been used, or that could be used to provide local service in the state (this would
include switches located in other states that provide or have the ability to provide local exchange
service in the state), state the initial cost of that switch, including installation and engineering costs
and the number of initial equipped lines.
Request No.9: Describe in detail any instances in which your company is using, through a
wholesale, lease, or resale arrangement, the switch of any entity other than and unaffiliated with an
ILEC (e., another competitive local exchange carrier) to provide local exchange service to end
users in the state. Include in your response the rates, terms, and conditions under which you are
obtaining switching on a wholesale, lease, or resale basis.
Request No. 10: State whether your company is providing, or plans to provide, through a
wholesale, lease or resale arrangement, capacity on any switches you own or operate in the state, or
that own or operate in another state and that you use to provide local service in the state, to an
unaffiliated entity. For any such instances, identify the rates, terms, and conditions under which you
are making that switch capacity available. For each switch on which you are currently leasing or
selling capacity to an unaffiliated entity, identify:
a. The make, model, age, and current software upgrades of each switch;
b. The geographic location of the switch;
c. The footprint or geographic area served by the switch, including a list of each
exchange served by the switch; the features and functions (including software
upgrades) available in the switch;
FIRST PRODUCTION REQUEST
TO CLECS NOVEMBER 7, 2003
d. Provide the capacity of each switch, including:
(i) percentage of switch capacity in use;
(ii) percentage of switch capacity reserved for your company s own use and future
use; and
(iii) percentage of current and future capacity of each switch that will be made
available for CLEC use.
e. For each switch identified, please state in detail:
(i) the anticipated service life of the switch; and
(ii) whether your company intends to utilize the identified switch for the full
anticipated service life.
Request No. 11: For each Qwest wire center in Idaho in which the CLEC provides retail
switched local exchange service, please report the number of switched voice-grade equivalent lines
in service per customer location that the CLEC serves. Please provide this information in the
following format: (total number of lines at locations with a single line at that location, number of
lines at locations with two lines at that location, etc.
WIRE CENTER:
QuantityofVGE
per Customer Location Residence Business
FIRST PRODUCTION REQUEST
TO CLECS NOVEMBER 7, 2003
24 or more
Request No. 12: For each switch the CLEC owns, operates, controls, maintains, or from
which you lease dial tone or trunking functionality/capacity within Idaho, please state whether the
local switching capacity of the switch can be expanded through modular software and hardware
additions. If you assert any obstacles to expansion, please identify and explain all such obstacles.
Request No. 13: Does the CLEC believe that there are costs associated with converting or
otherwise using a switch currently serving only enterprise customers to also serve mass-market
customers? If the CLEC believes that there are such switching costs, please identify all such costs
and explain why it would be necessary to incur them to begin serving mass-market customers.
Produce any documents or data that support your response.
Request No. 14: Please provide, a) on a statewide basis, and b) on a central office-specific
basis, monthly data for the past two years on customer "churn (i.percentage of your customers
lost to another carrier) on all of the following bases:
(a) number of customers by customer type (e.residential, business with one to
three lines; business with more than three lines);
(b) percentage of churn by customer type (e.residential, business with one to three
lines, business with more than three lines);
(c) number of customers by service type (i. e.local exchange voice service only,
long distance voice service only, bundled local exchange and long distance voice
services, and bundled local exchange, long distance, and DSL services);
(d) percentage of churn by service type (i.local exchange voice service only,
long distance voice service only, bundled local exchange and long distance voice
services, and bundled local exchange, long distance, and DSL services).
FIRST PRODUCTION REQUEST
TO CLECS NOVEMBER 7, 2003
Request No. 15: For customers that purchase up to 24 voice grade equivalent lines please
identify the types or categories of customer acquisition costs the CLEC incurred in Idaho in 2001
and 2002 to attract new customers, set up their accounts, and establish service to them. In addition
please provide the per line costs the CLEC incurred in 2001 and 2002 for both business and
residential customers for each of the types or categories of customer acquisition costs.
Request No. 16: For customers that purchase up to 24 voice grade equivalent lines please
identify the monthly churn rate the CLEC has experienced for local exchange customers in each
month in which it has provided local exchange service in the Idaho market. In answering this
request, calculate the churn rate based upon the number of lines lost each year divided by the
average number oflines in service that year. In calculating churn, do not include customers who
move but stay with the company. Please produce all documents that refer or relate to the
information you provide in response to this request.
Request No. 17: Please identify the percentage of customers that have left within one
month of signing up for service, within two months of signing up for service, within three months of
signing up for service, and within six months of signing up for service. Please provide this
information in connection with the CLEC's churn rates in Idaho for the most recent 24 months that
are available for local exchange customers that purchase up to 24 voice grade equivalent lines.
Please produce all documents that refer or relate to the information you provide in response to this
request.
Request No. 18: For customers that purchase up to 24 voice grade equivalent lines please
identify each rate plan that the CLEC offers to local exchange customers in Idaho. In addition
please identify the percentage of the CLEC's total local exchange customers in Idaho that subscribe
to each plan that you identify. Please produce all documents that reflect, refer or relate to the
information you provide in response to this request.
Request No. 19: For rate plans identified in B.13. that include a per minute of use
component, please provide the average long distance per minute usage in Idaho of the CLEC's local
FIRST PRODUCTION REQUEST
TO CLECS NOVEMBER 7 2003
exchange customers who subscribe to such plans for the most recent 24 months available. Please
produce all documents that reflect, refer, or relate to the information you provide in response to this
request.
Request No. 20: For customers that purchase up to 24 voice grade equivalent lines how
many CLEC-to-CLEC cross-connects has the CLEC performed in Idaho since June 2001? How
many CLEC-to-CLEC cross-connects does the CLEC maintain in Idaho at present?
The Development of an Efficient Loop Migration Process
Request No. 21: Describe the hot cut process currently used to transfer lines from the ILEC
switch to the CLEC facilities.
Request No. 22: List each task that is part of the current process. Provide the average time
it takes to complete the task, the typical occurrence of the task during the process, the labor rate for
the task, and the common overhead loading associated with the labor rate. Indicate the source of the
data, i.e. time/motion studies, SME analysis, etc.
Request No. 23: Describe a batch hot cut process that you would implement to meet the
FCC's requirement to establish a batch hot cut process. Include an estimate of the maximum
number of lines per batch.
Request No. 24: List each task that is part of the batch hot cut process described in the
answer to the preceding request. Provide the average time it takes to complete the task, the typical
occurrence of the task during the process, the labor rate for the task, and the common overhead
loading associated with the labor rate.
Request No. 25: IfUNE-P is no longer available, what monthly volumes of hot cuts would
be required: (a) to migrate existing UNE-P customers to another form of service and (b) to connect
new customers in the ordinary course of business. Provide supporting documentation for these
volume estimates.
FIRST PRODUCTION REQUEST
TO CLECS NOVEMBER 7 2003
fA--
DATED at Boise, Idaho, this -; day of November 2003.
Weldon B. Stutzman
Deputy Attorney General
Technical Staff:Wayne Hart
i:umisc/prodreq/gnrtO3.wsdc clec
FIRST PRODUCTION REQUEST
TO CLECS NOVEMBER 7, 2003
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 7TH DAY OF NOVEMBER 2003
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO COMPETITIVE LOCAL EXCHANGE CARRIERS, IN
CASE NO. GNR-03-, BY MAILING A COpy THEREOF, POSTAGE PREPAID
TO THE FOLLOWING:
DEAN J. MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE, ID 83701
CHARLES CARRA THERS
VERIZON NORTHWEST INC
1800 41 sT STREET
EVERETT, WA 98201
CONLEY E. WARD
GIVENS PURSLEY LLP
PO BOX 2720
BOISE, ID 83701
MARYB. TRIBBY
LETTY S.D. FRIESEN
AT &T COMMUNICATIONS OF THE
MOUNTAIN STATES INC
1875 LAWRENCE STREET, SUITE 1575
DENVER, CO 80202
SHARI' R. HARRIS
DIRECTOR OF OPERATIONS
BASICPHONE, INe.
PO BOX 220
ORANGE, TX 77631
CINDY LEE
MANAGER REGULATORY AFFAIRS
CCCID, INe.
124 WEST CAPITOL AVENUE SUITE 250
LITTLE ROCK, AR 72201
BRIAN THOMAS
TIME WARNER TELECOM
223 TAYLOR AVENUE NORTH
SEATTLE, WA 98109
ADAM L. SHERR
QWEST CORPORATION
1600 7TH AVENUE, ROOM 3206
SEATTLE, WA 98191
MARLIN D. ARD
ATTORNEY AT LAW
PO BOX 2190
SISTERS, OR 97759
CLAY R. STURGIS
MOSS ADAMS LLP
601 W. RIVERSIDE, SUITE 1800
SPOKANE, WA 99201-0663
ROBERT M. POMEROY, JR.
HOLLAND & HART
8390 E. CRESCENT PARKWAY
SUITE 400
GREENWOOD VILLAGE, CO 80111
RICHARD STEVENS
CENTEL COMMUNICATIONS, INC
1505 S. GRANT STREET
PO BOX 25
GOLDENDALE, W A 98620
CERTIFICATE OF SERVICE
MONIQUE BYRNES
Z- TEL COMMUNICATIONS, INe.
601 SOUTH HARBOUR ISLAND BLVD
SUITE 220
TAMPA, FL 33602
RICHARD WIGGINS
CTC TELECOM, INC.
130 SUPERIOR STREET
PO BOX 69
CAMBRIDGE, ID 83610
LANCE TADE
ELECTRIC LIGHTWAVE, INC.
4 TRIAD CENTER SUITE 200
SALT LAKE CITY, UTAH 84180
BECKY GIPSON
EXCEL TELECOMMUNICATIONS, INC.
PO BOX 223766
1600 VICEROY DRIVE
DALLAS, TX 75285
DONNA MOZINA
ICG TELECOM GROUP, INC.
161 INVERNESS DRIVE WEST
ENGLEWOOD, CO 80112
KAREN MAHURIN
REGULATORYMGR
IONEX TELECOMMUNICATIONS, INe.
FKA FIRS TEL
15305 DALLAS PARKWAY, SUITE 1500
ADDISON, TX 75001
JOE VELASQUEZ
THE LOCAL CONNECTION
TELEPHONE CO
1003 IDAHO STREET SUITE #5
ELKO, NV 89801
LANCE TADE
FRONTIER COMMUNICATIONS OF
AMERICA
4 TRIAD CENTER SUITE 200
SALT LAKE CITY, UTAH 84180
DAVID PIKOFF, VP
D PI - TELECONNECT, LLC
2997 LBJ FRWY SUITE 225
DALLAS, TX 75234
GARTH MORRISETTE
ESCHELON TELECOM, INC.
730 SECOND AVE SOUTH, SUITE 1200
MINNEAPOLIS, MN 55402
JAMES BAUCHMAN
FRETEL COMMUNICATIONS, LLC
110 E. MAIN
ST. ANTHONY, ID 83445
MARSHA POKORNEY
INTELLICAL OPERATOR SERVICES
INC. DBA ILD TELECOMMUNICATIONS
5000 SA WGRASS VILLAGE CIRCLE
SUITE 30
PENTE VEDRA BEACH, FL 32082
WILLIAM HUNT III
LEVEL 3 COMMUNICATIONS, LLC
1025 ELDORADO BLVD
BROOMFIELD, CO 80021
SUSAN TRAVIS
MCIMETRO ACCESS TRANSMISSION
SERVICES LLC
707 17TH STREET, SUITE 4200
DENVER, CO 80202
CERTIFICATE OF SERVICE
SUSAN TRAVIS
MCI WORLDCOM COMMUNICATIONS
INC.
707 17TH STREET, SUITE 4200
DENVER, CO 80202
R. SCOTT SWEAB, VP-REG AFFAIRS
NOW COMMUNICATIONS, INC.
711 S. TEJON ST STE 201
COLORADO SPRINGS, CO 80903
CHRISTINA CROWE
REG COMPLIANCE MGR
P AC- WEST TELECOMM, INe.
1776 W. MARCH LANE SUITE 250
STOCKTON, CA 95207
JEFFREY G. RICHARDS
QUANTUMSHIFT COMMUNICATIONS
100 ROWLAND WAY SUITE 145
NOVATO, CA 94945
DONALD O. TAYLOR
REG. COMPLIANCE CONSULTANT
TEL WEST COMMUNICATIONS LLC
% TAYLOR TELECOM CONSULTING
SERVICE
24428 145 TH PLACE SE
KENT, W A 98042
TIMOTHY TAYLOR
WESTCOM LLC
1488 E. BLUE TICK ST.
MERIDIAN, ID 83642
DAVID LAFRANCE
MANAGER-REGULATORY &
EXTERNAL AFFAIRS
XO IDAHO, INC.
1330 N. WASHINGTON SUITE 5000
SPOKANE, WA 99201
STEVE SAGER
REGIONAL COUNSEL
MCLEODUSA TELECOMMUNICATIONS
SERVICES, INC.
PO BOX 410460
SALT LAKE CITY, UT 84141-0460
WILLIAM BRAUN
800-RECONEX, INC
PO BOX 9
2500 INDUSTRIAL AVE
HUBBARD, OR 97032-0009
MARY S. HOBSON
QCC
STOEL RIVES LLP
101 S. CAPITOL BLVD STE 1900
BOISE, ID 83702
LANE WILLIAMS
RURAL NETWORK SERVICES
PO BOX 217
MIDV ALE, ID 83645
BECKY GIPSON
DIRECTOR OF REGULATORY AFFAIRS
VARTEC TELECOM, INC.
PO BOX 223766 (75222-3766)
1600 VICEROY DRIVE
DALLAS, TX 75235
...
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SECRETARY
CERTIFICATE OF SERVICE