200311211st Request of Qwest to AT&T of Mtn. States.pdf

Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ID 83702
Telephone: [phone]
Facsimile: [phone]
mshobson(q),stoel. com
nECEIVED
FILED
2003 NOV 21 Pl1 4: 00
i~;i\i;;J .J LiC
UTILITIES COl~H~lISSION
Adam L. Sherr (WSBA #25291)
Qwest
1600 ih Avenue - Room 3206
Seattle, WA 98191
Telephone: [phone]
Facsimile: [phone]
adam. sherr(q),qwest. com
Attorneys for Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IPUC RESPONSE TO
FCC ORDER ON REVIEW OF SECTION 251
UNBUNDLING OBLIGATIONS OF
INCUMBENT LOCAL EXCHANGE
CARRIERS (CC DOCKET NO. 01-338)
Case No. GNR-03-
NINE-MONTH REVIEW OF ECONOMIC
AND OPERATIONAL IMPAIRMENT
REGARDING ACCESS TO SPECIFIC UNES
FIRST PRODUCTION REQUEST OF
QWEST CORPORATION TO AT&T
COMMUNICATIONS OF THE
MOUNTAIN STATES, INc.
Qwest Corporation ("Qwest") pursuant to Rule 225 of the Rules of Procedure of the
Idaho Public Utilities Commission and Idaho Rules of Civil Procedure 33 and 34 hereby submits
the following Requests for Production of Documents to AT&T Communications of the Mountain
States, Inc. ("AT&T"). AT&T is requested to answer the following Requests in writing and
under oath by December 18 2003.
FIRST PRODUCTION REQUEST OF QWEST CORPORATION TO AT&T - Page
Boise-I64690.10029164-00097
These Requests shall be deemed continuing, and if AT&T its consultants or its attorneys
discover additional information and facts related to the matters inquired of between the time
answers are made and the time of the hearing in this matter, supplemental answers shall be made
informing Qwest and Qwest's attorneys as to said newly discovered information as far in
advance of the hearing as possible.
DEFINITIONS
The term "AT&T"
, "
you" or "your" refers to AT&T Communications of the
Mountain States, Inc., and its agents, consultants and representatives including its attorneys or
any employee, agent, investigator or representative of its attorneys.
The term "Qwest" refers to and shall mean Qwest Corporation.
The terms "relating
, "
related", or "which relates to" means constitutes, refers to
contains, embodies, evidences, reflects, contradicts, refutes, identifies, states, deals with, bears
upon, or is in any way logically or factually connected with any matter described.
The word "person" means any individual, corporation, joint venture, limited
partnership, association, group or entity of any kind.
The terms "document" or "statement" refer to and shall mean and include any
written, typed, printed, recorded or computer-produced or graphic matter of every type and
description, however and by whomever prepared, produced, reproduced, disseminated or made
including, but not limited to, reports, letters , correspondence, memoranda, records, summaries
analyses, results or reports of investigations, recommendations, diaries, books, messages
electronic mail (whether in hard copy form or as stored on disc or computer hard drive), notes
tapes, drawings, graphs, photographs , microfilms, telegrams, periodical articles, computer
printouts and any other writing, drawing, or records.
FIRST PRODUCTION REQUEST OF QWEST CORPORATION TO AT&T - Page 2
Boise-164690.10029164-00097
Terms in the plural include the singular, and terms in the singular include the
plural.
INSTRUCTIONS
If you object to any Request for Production, set forth all reasons for the objection.
If you claim privilege as a basis for not complying with any Interrogatory or Request for
Production, in full or in part, describe the factual basis for the claim of privilege in detail
sufficient to permit the Commission to rule upon the validity of the claim. If you object to any
part of any Interrogatory or Request for Production, answer the remaining partes) completely.
If any information called for by an Interrogatory or Request for Production is
unknown to you, so state and then state all remaining information that is known to you.
REQUEST NO.Please state whether the information in the LERG is current and
accurate for the switches that AT&T owns, operates, controls, maintains in Idaho, or from which
you lease dial tone or trunking functionality/capacity. If any of the information is not accurate
please identify the inaccurate information and provide corrected information, including any
additions, deletions or changes. As part of your review of the information in the LERG, please
state whether the CLLI code is accurate for each switch that AT&T owns, operates, controls
maintains, or from which you lease dial tone or trunking functionality/capacity. In addition
please state whether the LERG definition of the function of each switch (i., tandem, end office
etc.) is accurate.
REQUEST NO.For each switch owned or controlled by AT&T that is being used
Idaho to provide service to customers, please provide the capacity of the switch, with
capacity" defined as: (1) the number of lines installed; (2) the number of lines currently in use;
(3) the number of trunks currently installed; and (4) the number of trunks currently in use.
FIRST PRODUCTION REQUEST OF QWEST CORPORATION TO AT&T - Page 3
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addition, for each such switch that you identify, please provide the generic (feature package)
loaded in the switch.
REQUEST NO.Please provide the average total revenue per line that AT&T
received from its residential customers within Idaho in 2001 and 2002. The average revenue
per line should include revenues associated with the basic retail price charged to residential
customers, vertical features, universal service payments, interstate access charges, intrastate
access charges, subscriber line charges, toll, long distance, local number portability, and line
revenues derived from any other sources. Please provide both the total average revenue per line
and a breakdown of the amount of revenue for each category of revenue that comprises the total.
Please produce all documents that reflect, refer or relate to the information provided in your
response to this request.
REQUEST NO.Please provide the average total revenue per line that AT&T has
received from its business customers within Idaho in 2001 and 2002. The average revenue per
line should include revenues associated with the basic retail price charged to business customers
vertical features, universal service payments, interstate access charges, intrastate access charges
subscriber line charges, toll, long distance, local number portability, and line revenues derived
from any other sources. Please provide both the total average revenue per line and a breakdown
of the amount of revenue for each category of revenue that comprises the total. If revenues differ
depending on the type of business customer (small vs. large), please provide the total revenues
and the breakdown of revenues by type of business customer. Please provide the information by
POTS, DSO, DSI , DS3 , OC-, OC-, OC-, and any other relevant categories. Please produce
all documents that reflect, refer or relate to the information provided in your response to this
request.
FIRST PRODUCTION REQUEST OF QWEST CORPORATION TO AT&T - Page 4
Boise-164690.1 0029164-00097
REQUEST NO.Please explain how AT&T defines its business customer segments
and provide any documents that reflect this definition or the criteria AT&T uses to segment or
classify business customers into distinct customer groups. Please produce all documents that
reflect, refer or relate to the information provided in your response to this request.
REQUEST NO.Please provide the average total cost per line that AT&T incurred
in 2001 and 2002 for lines used to serve residential customers within Idaho. These costs should
include costs associated with switching; loops; collocation; transport; hot cuts; operational
support systems ("OSS"); signaling; customer acquisitions; backhauling traffic to AT&T's
switches; maintenance, operations, and other administrative activities; and capital costs.
available, please provide a breakdown of this information for the following categories: (1)
service provided by UNE-, (2) service provided by UNE-, and (3) service provided using
AT&T's own facilities. In addition, please provide any available breakdowns of each cost
component that is part of the average total cost per line, identifying the type and amount of each
cost. Please produce all documents that reflect, refer or relate to the information provided in
your response to this request.
REQUEST NO.Please provide the average total cost per line that AT&T incurred
in 2001 and 2002 for lines used to serve business customers within Idaho. These costs should
include costs associated with switching; loops; collocation; transport; hot cuts; ass; signaling;
customer acquisitions; backhauling traffic to AT&T's switches; maintenance, operations, and
other administrative activities; and capital costs. In addition to a total average cost, please
provide separate averages for service provided through UNE-, UNE-, and with AT&T's own
facilities. Please provide a breakdown of each cost component that is part of the average total
cost per line, identifying the type and amount of each cost. If costs differ depending on the type
of business customer (small vs. large), please provide the total cost and the breakdown of costs
FIRST PRODUCTION REQUEST OF QWEST CORPORATION TO AT&T - Page 5
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by type of business customer. Please produce all documents that reflect, refer or relate to the
information provided in your response to this request.
REQUEST NO.To the extent not provided in response to Request Nos. 6 and 7
please identify the types or categories of customer acquisition costs AT&T incurred in Idaho in
2001 and 2002 to attract new customers, set up their accounts, and establish service to them.
addition, to the extent not provided in response to Request Nos. 5 and 6, please provide the per
line costs AT&T incurred in 2001 and 2002 for both business and residential customers for
each of the types or categories of customer acquisition costs.
Respectfully submitted this 21 sl day of November, 2003.
Qwest Corporation
II-oh-
Mary S. bson
Stoel Rives LLP
Adam L. Sherr
Qwest
Attorneys for Qwest Corporation
FIRST PRODUCTION REQUEST OF QWEST CORPORATION TO AT&T - Page 6
Boise-I64690.10029164-00097
CERTIFICATE OF SERVICE
I hereby certify that on this 21 sl day of November, 2003, I served FIRST
PRODUCTION REQUEST OF QWEST CORPORATION TO AT&T as follows:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ID 83720-0074
Phone: [phone]
Fax: [phone]
i i ewell(q),puc.state.id. us
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U. S. Mail
Overnight Delivery
Facsimile
Email
Wayne Hart
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ill 83720-0074
Phone: [phone]
Fax: [phone]
whart(q),puc. state.id. us
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Weldon Stutzman, Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ID 83720-0074
Phone: [phone]
Fax: [phone]
wstutzm(q),puc.state.id. us
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Marlin D. Ard, Esq.
O. Box 2190
Sisters, OR 97759
Telephone: [phone]
Facsimile: [phone]
Marattv(q),qwest.net
Attorney for Verizon
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FIRST PRODUCTION REQUEST OF QWEST CORPORATION TO AT&T - Page 7
Boise-164690.1 0029164-00097
Charles Carrathers
Verizon Northwest Inc.
1800 41 sl Street
Everett, W A 98201
Telephone: [phone]
Facsimile: [phone]
chuck. carrathers(q),verizon. com
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Dean 1. Miller
McDevitt & Miller LLP
420 West Bannock Street
O. Box 2564 (83701)
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
i oe(q),mcdevi tt - miller. com
Attorney for MCImetro, Time Warner
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Robert M. Pomeroy, Jr.
Holland & Hart
8390 East Crescent Parkway - Suite 400
Greenwood Village, CO 80111
Telephone: [phone]
Facsimile: [phone]
bpomero v(q),ho llandhart. com
Attorney for AT&T
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Adam L. Sherr
Qwest
1600 ih Avenue - Room 3206
Seattle, WA 98191
Telephone: [phone]
Facsimile: [phone]
asherr(q),qwest. com
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Clay R. Sturgis
Moss Adams LLP
601 West Riverside - Suite 1800
Spokane, W A 99201-0663
Telephone: [phone]
Facsimile: [phone]
cia VS (q),moss adams. com
Attorney for ITA
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FIRST PRODUCTION REQUEST OF QWEST CORPORATION TO AT&T - Page 8
Boise-I 64690.! 0029164-00097
Brian Thomas
Time Warner Telecom
223 Taylor Avenue North
Seattle, WA 98109
Brian. Thomas((/),twtelecom.com
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Mary B. Tribby
Letty S. D. Friesen
AT&T Communications of the Mountain States, Inc.
1875 Lawrence Street - Suite 1575
Denver, CO 80202
Telephone: [phone]
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lsfriesen(q),att.com
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Conley E. Ward
Givens Pursley LLP
277 North 61h Street - Suite 200
O. Box 2720
Boise, ill 83701
Telephone: [phone]
Facsimile: [phone]
cew(Q),gi venspursley .com
Attorney for ITA
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/5uw; tV c$~
Brandi L. Gearhart, PLS
Legal Secretary to Mary S. Hobson
Stoel Rives LLP
FIRST PRODUCTION REQUEST OF QWEST CORPORATION TO AT&T - Page 9
Boise-I64690.1 0029164-00097