200311071st Request of Staff to Verizon.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3283
RECEIVED illFILED 0
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UTIU iES COf'\r'iISSION
Street Address for Express Mail:
472 W WASHINGTON
BOISE ID 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
NINE-MONTH REVIEW ON ECONOMIC
AND OPERATIONAL IMPAIRMENT
REGARDING ACCESS TO SPECIFIC UNES.
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO VERIZON NORTHWEST INC.
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).
CASE NO. GNR-03-
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record
Weldon Stutzman, Deputy Attorney General, requests that Verizon Northwest Inc. (Verizon;
Company) 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 IDAPA 31.01.01.228.
This Production Request is to be considered as continuing, and Verizon 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 VERIZON 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 (ID AP 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: For each wire center in your territory in Idaho , please provide the number
of business voice-grade equivalent lines that you directly serve.
Request No.2: For each wire center in your territory in Idaho, please provide the number
of business voice-grade equivalent lines that CLECs are serving through resale.
Request No.3: For each wire center in your territory in Idaho, please provide the number
of business voice-grade equivalent lines that CLECs are serving through UNE-
Request No.4: For each wire center in your territory in Idaho, please provide the number
of business voice-grade equivalent lines that CLECs are serving through the CLEC's own
facilities.
Request No.5: For each wire center in your territory in Idaho, please provide the number
of residential voice-grade equivalent lines that you directly serve.
FIRST PRODUCTION REQUEST
TO VERIZON NOVEMBER 7, 2003
Request No.6: For each wire center in your territory in Idaho, please provide the number
of residential voice-grade equivalent lines that CLECs are serving through resale.
Request No.7: For each wire center in your territory in Idaho, please provide the number
of residential voice-grade equivalent lines that CLECs are serving through UNE- P.
Request No.8: For each wire center in your territory in Idaho, please provide the
estimated number of residential lines that CLECs are serving through their own facilities (complete
bypass).
Request No.9: For each wire center in your territory in Idaho, please provide the number
of in-service collocation arrangements that you have, and for each collocation arrangement, please
indicate the type of collocation that you are providing.
Request No. 10: For each wire center in your territory in Idaho, please provide the number
of provisioned collocation arrangements that you have in place that have yet to be activated, and
for each collocation arrangement, please indicate the type of collocation.
Request No. 11: For each wire center in your territory in Idaho, please provide the number
of pending collocation arrangements that you have, and for each collocation arrangement, please
indicate the type of collocation.
Request No. 12: For each wire center in your territory in Idaho, please provide a list of
restrictions on equipment, cross-connects between CLEC collocation cages, or other restrictions or
limitations that you place on a CLECs use of collocation space.
Request No. 13: For each wire center in your territory in Idaho, please identify whether or
not collocation space is currently available to CLECs. For each wire center where collocation
space is currently not available to CLECs, please include an explanation of why space is not
available in those wire centers.
FIRST PRODUCTION REQUEST
TO VERIZON NOVEMBER 7, 2003
Switching
Request No. 14: 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
voice-grade equivalent lines (in one location), state the current average total monthly revenues
earned per line served in Idaho by LATA and by MSA and specify the source of those revenues by
service type.
Request No. 15: For each switch (e., circuit, packet, soft switch, etc.) currently used, or
those that have been used, or that could be used to provide local service in Idaho (this would
include switches located in other states that provide or have the ability to provide local exchange
service in Idaho), state the initial cost of that switch, including installation and engineering costs
and the number of initial equipped lines.
Request No. 16: Describe in detail any instances in which your company is using, through
a wholesale, lease, or resale arrangement, the switch of any entity unaffiliated with Verizon (e.
another competitive local exchange carrier) to provide local exchange service to end users in
Idaho. Include in your response the rates, terms, and conditions under which you are obtaining
switching on a wholesale, lease, or resale basis.
Request No. 17: 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 Idaho, or
that you own or operate in another state and that you use to provide local service in Idaho, 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;
FIRST PRODUCTION REQUEST
TO VERIZON NOVEMBER 7, 2003
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;
d. Provide the capacity of each switch, including:
(i)
(ii)
percentage of switch capacity in use;
percentage of switch capacity reserved for your company s own use and
(iii)
future use; and
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)
(ii)
the anticipated service life of the switch; and
whether your company intends to utilize the identified switch for the full
anticipated service life.
Development of an Efficient Loop Migration Process
Request No. 18: Provide, in an electronic format, on a monthly basis, the number ofUNE-
P lines at the beginning of the month, added during the month, disconnected during the month and
at the end of the month. Provide this information for the most recent 12-month period for which
data is available. Provide the information on a region-wide (all areas using the same OSS system)
basis in addition to Idaho specific data.
Request No. 19: Provide, in an electronic format, on a monthly basis for every wire center
the number ofUNE-L lines at the beginning of the month, added during the month, disconnected
during the month and at the end of the month. Provide this information for the most recent 12
month period for which data is available. Provide the information on a region-wide basis in
addition to Idaho specific data.
Request No. 20: Describe the hot cut process currently used to transfer lines from the
ILEC switch to the CLEC facilities.
FIRST PRODUCTION REQUEST
TO VERIZON NOVEMBER 7, 2003
Request No. 21: 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
sources of the data, i., time/motion studies, SME analysis, etc.
Request No. 22: Describe a batch hot cut process that Verizon would implement to meet
the FCC's requirement to establish a batch hot cut process. Include an estimate of number oflines
per batch.
Request No. 23: List each task that is part of the batch hot cut process described in the
answer to the above question regarding a batch 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
, time/motion studies, SME analysis, etc.
Request No. 24: List each task that is part of the batch hot cut process that is not included
in the current hot cut process.
Request No. 25: List each task that is part of the current hot cut process that is not
included in the batch hot cut process.
Request No. 26: On a monthly basis, provide the total number of residential lines served
and the number of residential lines served using integrated digital line carriers. Provide separately
for every wire center the number of Verizon retail residential lines, UNE served residential lines
and Wholesale served residential lines. Provide this information for the most recent 12-month
period for which data is available. Provide the information on a region-wide basis in addition
Idaho specific data.
Request No. 27: For each wire center, on a monthly basis, provide the total number of
business mass-market lines served and the number of business mass-market lines served using
FIRST PRODUCTION REQUEST
TO VERIZON NOVEMBER 7, 2003
integrated digital line carriers. Provide separately for every wire center the number of Verizon
retail business mass-market lines, UNE served business mass-market lines, and wholesale served
business mass-market lines. Explain how Verizon determined which business lines were mass-
market lines and which are enterprise lines. Provide this information for the most recent 12-month
period for which data is available. Provide the information on a region-wide basis in addition to
Idaho specific data.
Request No. 28: If the tasks related to the hot cut process for lines served using integrated
digital line carriers differs from the process used for other lines, discuss how the process is
different and list the tasks that must be added specifically for the lines served using integrated
digital line carriers. Include the time required to accomplish those tasks.
Request No. 29: On a monthly basis, provide the average time a customer s service was
disconnected due to the hot cut process. Provide this information for the most recent 12-month
period for which data is available. Provide the information on a region-wide basis in addition to
Idaho specific data.
Request No. 30: On a monthly basis, provide the number of technicians during each
month who have transferred a line from an ILEC switch to the CLEC facility as part of the hot cut
process. Count only those employees who perform the manual process. Provide this information
for the most recent 12-month period for which data is available. Provide the information on a
region-wide basis in addition to Idaho specific data.
Request No. 31: On a monthly basis, provide the number of technicians trained and
capable of transferring a line from an ILEC switch to the CLEC facility as part of the hot cut
process. Count only those employees who can perform the manual process. Do not include
management or supervisory personnel who can perform these tasks but do not do so as part of their
regular work effort. Provide this information for the most recent 12-month period for which data
is available. Provide the information on a region-wide basis in addition to Idaho specific data.
FIRST PRODUCTION REQUEST
TO VERIZON NOVEMBER 7, 2003
Request No. 32: On a monthly basis for every wire center, provide, in an electronic
format, the number of hot cuts performed. Provide this information for the most recent 12-month
period for which data is available. Provide the information on a region-wide basis in addition to
Idaho specific data.
Request No. 33: Provide a list of all carriers with which Verizon has an interconnection
agreement for the provision of local service in Idaho.
Request No. 34: Provide a list of all carriers to which Verizon has sold collocation
services in Idaho. For each carrier, list the wire centers where the carrier is collocated.
Request No. 35: Provide a list ofVerizon wire centers with indicators that identify
whether the office is unstaffed, has a technician on duty but the technician cannot perform hot cuts
or has a technician on duty and the technician can perform hot cuts. For unstaffed offices and
offices where the technician cannot perform hot cuts, specify the number of miles that the
technician must drive and driving time to reach that office from the closest office where a
technician who can perform hot cuts is normally on duty.
Request No. 36: If a batch cut process is developed, does that make it more or less likely
that an electronic loop provisioning process will be implemented?
Request No. 37: For each technician identified as trained in the hot cut process, when did
that training occur?
Request No. 38: For each technician identified as trained in the hot cut process, is that
training documented or posted? If so, where is that training documented or posted?
Request No. 39: For each technician identified as trained in the hot cut process, how often
does that technician get trained in the hot cut process?
FIRST PRODUCTION REQUEST
TO VERIZON NOVEMBER 7, 2003
Request No. 40: For each technician identified as trained in the hot cut process, is there a
refresher course for that technician? If so, how often is the refresher course offered?
Request No. 41: For each technician identified as trained in the hot cut process, is the
technician required to take the refresher course if one is offered?
Request No. 42: Does Verizon s UNE-L loop always provide CLECs with DSO capacity?
Request No. 43: IfVerizon s UNE-L loop does not always provide CLECs with DSO
capacity, identify by customer and wire center all instances where it does not provide DSO
capacity.
Request No. 44: For each Verizon central office or wire center at which loops and
transport are connected at collocation arrangements to form EELs, please provide the following
information:
(a) the CLLI code, street address, and V&H coordinates of the Verizon central
office or wire center where such EELs are created;
(b) the CLLI code, street address, V&H coordinates, and owner(s) of the switch(es)
to which such EELs are connected;
(c) number of such EELs that comprise DS-O/voice grade transport connected to
DS-O/voice grade loops;
(d) number of such EELs that comprise DS-1 transport connected to multiplexed
DS-O/voice grade loops;
( e) number of such EELs that comprise DS-1 transport connected to multiplexed
and concentrated DS-O/voice grade loops, and the loop-to-transport concentration
ratio;
(f) number of such EELs that comprise DS-3 transport connected to multiplexed
DS-O/voice grade loops;
FIRST PRODUCTION REQUEST
TO VERIZON NOVEMBER 7, 2003
(g) number of such EELs that comprise DS-3 transport connected to multiplexed
and concentrated DS-O/voice grade loops, and the loop-to-transport concentration
ratio;
(h) number of such EELs that comprise DS-1 transport connected to DS-1 loops;
(i) number of such EELs that comprise DS-3 transport connected to multiplexed
DS-1 loops;
(j) number of such EELs that comprise DS-3 transport connected to multiplexed and
concentrated DS-1loops, and the loop-to-transport concentration ratio.
Request No. 45: For each Verizon central office or wire center at which loops and
transport are connected to form EELs without using collocation, please provide the following
information
(a) the CLLI code, street address, and V &H coordinates of the Verizon central
office or wire center where such EELs are created;
(b) the CLLI code, street address, V &H coordinates, and owner( s) of the switch( es)
to which such EELs are connected;
(c) number of such EELs that comprise DS-O/voice grade transport connected to
DS-O/voice grade loops;
(d) number of such EELs that comprise DS-l transport connected to multiplexed
DS-O/voice grade loops;
( e) number of such EELs that comprise DS-1 transport connected to multiplexed
and concentrated DS-O/voice grade loops, and the loop-to-transport concentration
ratio;
(f) number of such EELs that comprise DS-3 transport connected to multiplexed
DS-O/voice grade loops;
(g) number of such EELs that comprise DS-3 transport connected to multiplexed
and concentrated DS-O/voice grade loops, and the loop-to-transport concentration
ratio;
(h) number of such EELs that comprise DS-1 transport connected to DS-1 loops;
FIRST PRODUCTION REQUEST
TO VERIZON NOVEMBER 7, 2003
(i) number of such EELs that comprise DS-3 transport connected to multiplexed
DS-1 loops;
(j) number of such EELs that comprise DS-3 transport connected to multiplexed and
concentrated DS-1 loops, and the loop-to-transport concentration ratio.
Request No. 46: For each CLEC and other carrier collocation arrangement in each
Verizon central office or wire center in Idaho, please provide the following information, reported
by CLLI code and street address:
(a) name ofCLEC or other carrier;
(b) type of collocation arrangement (e.g. caged, cageless, virtual, etc.
(c) size of collocation arrangement;
(d) amount of power (including both "A" and "B" DC feeds and AC power)
supplied to the collocation arrangement;
(e) number of 2-wire cross connects currently provisioned from the MDF to the
collocation arrangement;
(f) number of 4-wire cross connects currently provisioned from the MDF to the
collocation arrangement;
(g) all equipment installed in the collocation arrangement, including make, model
and total installed capacity for each piece of equipment;
(h) type(s) ofVerizon transport connected to the collocation arrangement (e.
special access, UNE transport, etc.
(i) capacity(ies) ofVerizon transport connected to the collocation arrangement (e.
DS-, DS-, OC-, etc., and number of circuits at each level of capacity);
(j) all non-recurring and recurring charges for the collocation arrangement;
(k) name(s) of other collocating carrieres) to which this collocation arrangement is
connected in this central office or wire center.
FIRST PRODUCTION REQUEST
TO VERIZON NOVEMBER 7, 2003
Request No. 47: For each Verizon central office or wire center in Idaho , please identify
the amount of available unused collocation space, in terms of total square feet of space and type(
of collocation for which available space can be used. Please identify each central office in which
collocation space has been exhausted, or for which collocation space exhaustion is anticipated in
the next 3 years, including the date of exhaust or expected exhaust.
Request No. 48: Please explain whether you currently have in place electronic systems
that can accomplish each of the following migration types on a automated, flow-through basis
(i., no human or other manual intervention is required for completion ofthe migration):
(a) from UNE-P voice only, or UNE-P voice plus data, to CLEC switch-based voice
only;
(b) from UNE-P voice only, or UNE-P voice plus data, to Verizon voice only;
(c) from UNE-P voice only, or UNE-P voice plus data, to Verizon voice plus
data;
(d) from UNE-P voice only, or UNE-P voice plus data, to one CLEC line splitting;
(e) from UNE-P voice only, or UNE-P voice plus data, to two CLEC line splitting;
(f) from UNE-, or UNE-P voice plus data, to CLEC line sharing with CLEC
splitter;
(g) from UNE-, or UNE-P voice plus data, to CLEC line sharing with Verizon
splitter;
(h) from CLEC switch-based voice to any of the above;
(i) from one and two CLEC line splitting to any of the above;
(j) from one and two CLEC line sharing to any of the above.
DATED at Boise, Idaho, this l-fvt... day of November 2003.
cZJz 2-
- -~ =
Weldon B. Stutzman
Deputy Attorney General
Technical Staff: Wayne Hart
i:umisc/prodreq/gnrtO3.23wsdc qwe
FIRST PRODUCTION REQUEST
TO VERIZON 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 VERIZON NORTHWEST INc., 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, W A 98201
CONLEY E. WARD
GIVENS PURSLEY LLP
PO BOX 2720
BOISE, ID 83701
MARY B. 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, INc.
PO BOX 220
ORANGE, TX 77631
CINDY LEE
MANAGER REGULATORY AFFAIRS
CCCID, INc.
124 WEST CAPITOL AVENUE SUITE 250
LITTLE ROCK, AR 72201
BRIAN THOMAS
TIME WARNER TELECOM
223 T AYLOR AVENUE NORTH
SEATTLE, W A 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 P ARKW A Y
SUITE 400
GREENWOOD VILLAGE, CO 80111
RICHARD STEVENS
CENTEL COMMUNICATIONS , INC
1505 S. GRANT STREET
PO BOX 25
GOLD END ALE, W A 98620
CERTIFICATE OF SERVICE
MONIQUE BYRNES
Z- TEL COMMUNICATIONS, INc.
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
REGULATORY MGR
IONEX TELECOMMUNICATIONS , INc.
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
DPI- 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
PAC-WEST TELECOMM, INC.
1776 W. MARCH LANE SUITE 250
STOCKTON, CA 95207
JEFFREY G. RICHARDS
QUANTUMSHIFT COMMUNICATIONS
100 ROWLAND WAY SUITE 145
NOV A TO, CA 94945
DONALD O. TAYLOR
REG. COMPLIANCE CONSULTANT
TEL WEST COMMUNICATIONS LLC
% TAYLOR TELECOM CONSULTING
SERVICE
24428 145 TH PLACE SE
KENT, WA 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, W A 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
V ARTEC TELECOM, INC.
PO BOX 223766 (75222-3766)
1600 VICEROY DRIVE
DALLAS, TX 75235
ill
CERTIFICATE OF SERVICE