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Home My WebLink About200311121st Request of Staff to Wireless Companies.pdfWELDON B. STUTZMAN DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0318 IDAHO BAR NO. 3283 Street Address for Express Mail: 472 WWASHINGTON BOISE ID 83702-5983 Attorney for the Commission Staff "',.- e"r-IVEDf-, ; ,. ,... , . ',,-VL " rn en" ILLLI 1003 ,JOV I 2 PM 3: 4 I U (U UTILITIES COt.1tiISSION 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- T -03- FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO WIRELESS COMPANIES The Staff of the Idaho Public Utilities Commission, by and through its attorney of record Weldon Stutzman, Deputy Attorney General, requests that Active Electronics, AT&T Wireless Services ofldaho, Consumer Cellular, Clark Communications, Cricket Communications, CTC Telecom, Edge Wireless, Inland Cellular, Nextel Partners, Inc., Nextel West Corporation, Project Mutual Telephone, Sprint PCS, TW Wireless LLC, United States Cellular, Verizon Wireless Voicestream Wireless, Western Wireless, Cleartalk-NTCH-Idaho, Inc. and Farmers Mutual Telephone Company provide the following documents and information on or before WEDNESDAY, NOVEMBER 26,2003. FIRST PRODUCTION REQUEST TO WIRELESS COMPANIES NOVEMBER 12, 2003 Each 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 Company 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. 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: 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 FIRST PRODUCTION REQUEST TO WIRELESS COMPANIES NOVEMBER 12, 2003 of the switches identified in your response to Request No.1. Wire centers should be identified by providing their name, address, and CLLI code. Request No.3: For each ILEC wire center identified in response to Request No., identify the total number of voice-grade equivalent lines 1 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 of the term. Request No.4: For each switch identified in response to Request No., 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 of the 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 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 WIRELESS COMPANIES NOVEMBER 12, 2003 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 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 WIRELESS COMPANIES NOVEMBER 12, 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 oflines 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 WIRELESS COMPANIES NOVEMBER 12, 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 chum by customer type (e. g., 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. 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). FIRST PRODUCTION REQUEST TO WIRELESS COMPANIES NOVEMBER 12, 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 of lines 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. FIRST PRODUCTION REQUEST TO WIRELESS COMPANIES NOVEMBER 12, 2003 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 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. FIRST PRODUCTION REQUEST TO WIRELESS COMPANIES NOVEMBER 12 , 2003 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. DATED at Boise, Idaho, this IA~dayof November 2003. Weldon B. Stutzman Deputy Attorney General Technical Staff:Wayne Hart i:umisc/prodreq/gnrtO3, wsdc wireless FIRST PRODUCTION REQUEST TO WIRELESS COMPANIES NOVEMBER 12, 2003 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 12TH DAY OF NOVEMBER 2003 SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO WIRELESS COMPANIES, IN CASE NO. GNR-03- BY MAILING A COpy THEREOF POSTAGE PREPAID, TO THE FOLLOWING: ACTIVE ELECTRONICS 422 EAST MULLAN OSBURN ID 83849 AT&T WIRELESS SERVICES OF IDAHO 11760 US HWY 1 WEST TOWER NORTH PALM BEACH FL 33408 CONSUMER CELLULAR C/O TAX PARTNERS, LLC 3100 CUMBERLAND BLVD STE 900 ATLANTA GA 30339 CLARK COMMUNICATIONS O. BOX 1183 LEWISTON ID 83501 CRICKET COMMUNICATIONS 10307 PACIFIC CENTER COURT SAN DIEGO CA 92121 CTC TELECOM PO BOX 86 CAMBRIDGE ID 83610-0086 EDGE WIRELESS 600 SW COLUMBIA SUITE 7200 BEND OR 97702 INLAND CELLULAR O. BOX 688 ROSLYNWA 98941-0688 NEXTEL PARTNERS, INC. 4500 CARILLON POINT KIRKLAND W A 98033 NEXTEL WEST CORP. 2001 EDMUND HALLEY DRIVE RESTONVA 20191 PROJECT MUTUAL TELEPHONE O. BOX 366 RUPERT ID 83350 SPRINT PCS 6500 SPRINT PKWY MAILSTOP HL-5ATTX OVERLAND PARKKS 66251-5555 TW WIRELESS , LLC C/O TAX PARTNERS LLC 3100 CUMBERLAND BLVD STE 900 ATLANTA GA 30339 UNITED STATES CELLULAR 8410 W BRYN MAWR AVE STE 700 CHICAGO IL 60631-3486 VERIZON WIRELESS 1 VERIZON PLACE BUILDING ALPHARETTAGA 30004 VOICESTREAM WIRELESS 12920 SE 38TH STREET BELLEVUE W A 98006 CERTIFICATE OF SERVICE WESTERN WIRELESS 3650 131 ST AVENUE SE STE 400 BELLEVUE W A 98006 FARMERS MUTUAL TELEPHONE CO PO BOX 346 FRUITLAND ID 83619-0346 CLEARTALK-NTCH-IDAHO, INC. 233 NORTH MAIN POCATELLO ID 83204 SECRETARY CERTIFICATE OF SERVICE