200311211st Request of Qwest to Time Warner Telecom.pdf

Mary S. Hobson (ISB #2142)
Stoe1 Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ID 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoel.com
RECEIVED
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Adam L. Sherr (WSBA #25291)
Qwest
1600 ih Avenue - Room 3206
Seattle, W A 98191
Telephone: [phone]
Facsimile: [phone]
adam.sherr~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-
FIRST PRODUCTION REQUEST OF
QWEST CORPORATION TO TIME
WARNER TELECOM OF IDAHO LLC
NINE-MONTH REVIEW OF ECONOMIC
AND OPERATIONAL IMPAIRMENT
REGARDING ACCESS TO SPECIFIC UNES
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 Time Warner Telecom ofIdaho LLC
Time Wamer ). Time W aIDer is requested to answer the following Requests in writing and
under oath by December 18, 2003.
FIRST PRODUCTION REQUEST OF QWEST CORPORATION TO Time Warner - Page
Boise-164691.1 0029164-00097
These Requests shall be deemed continuing, and if Time Warner 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 "Time Warner
, "
you" or "your" refers to Time Warner Telecom of
Idaho LLC , 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 Time Warner - Page 2
Boise-164691.10029164-00097
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 Time Warner 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 Time Warner 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 Time Warner that is being
used in 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 Time Warner - Page 3
Boise-I64691.1 0029164-00097
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 Time Warner
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 Time Warner
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, DS1 , 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 Time Warner - Page 4
Boise-I64691.1 0029164-00097
REQUEST NO.Please explain how Time Warner defines its business customer
segments and provide any documents that reflect this definition or the criteria Time Warner 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 Time Warner
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
Time Warner s switches; maintenance, operations, and other administrative activities; and capital
costs. If 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
Time Warner 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 Time Warner
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 Time Warner 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
Time Warner 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
FIRST PRODUCTION REQUEST OF QWEST CORPORATION TO Time Warner - Page 5
Boise-I64691.1 0029164-00097
depending on the type of business customer (small vs. large), please provide the total cost and
the breakdown of costs 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 Time Warner incurred in
Idaho in 2001 and 2002 to attract new customers, set up their accounts, and establish service to
them. In addition, to the extent not provided in response to Request Nos. 5 and 6, please provide
the per line costs Time Warner 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 st day of November, 2003.
Qwest Corporation
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Mary S. Ho
Stoel Rives LLP
Adam L. Sherr
Qwest
Attorneys for Qwest Corporation
FIRST PRODUCTION REQUEST OF QWEST CORPORATION TO Time Warner - Page 6
Boise-164691.1 0029164-00097
CERTIFICATE OF SERVICE
I hereby certify that on this 21st day of November, 2003 , I served FIRST
PRODUCTION REQUEST OF QWEST CORPORATION TO Time Warner 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]
wha1i~puc.state.id.
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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~puc.state.id. us
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Marlin D. Ard, Esq.
O. Box 2190
Sisters, OR 97759
Telephone: [phone]
Facsimile: [phone]
Maratty~qwest.net
Attorney for Verizon
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U. S. Mail
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Email
FIRST PRODUCTION REQUEST OF QWEST CORPORATION TO Time Warner - Page 7
Boise-I64691.1 0029164-00097
Charles Carrathers
Verizon Northwest Inc.
1800 41 st Street
Everett, W A 98201
Telephone: [phone]
Facsimile: [phone]
chuck. carrathers~verizon. com
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Dean J. Miller
McDevitt & Miller LLP
420 West Bannock Street
O. Box 2564 (83701)
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
i oe~mcdevitt - mi Her. com
Attorney for MCImetro, Time Warner
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~ U.Mail
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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, W A 98191
Telephone: [phone]
Facsimile: [phone]
asherr~qwest.com
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U. S. Mail
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Clay R. Sturgis
Moss Adams LLP
601 West Riverside - Suite 1800
Spokane, W A 99201-0663
Telephone: [phone]
Facsimile: [phone]
clays~mossadams.com
Attorney for ITA
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FIRST PRODUCTION REQUEST OF QWEST CORPORATION TO Time Warner - Page 8
Boise-164691.1 0029164-00097
Brian Thomas
Time Warner Telecom
223 Taylor Avenue North
Seattle, W A 98109
Brian. Thomas(q)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]
Facsimile: [phone]
lsfriesen(q)att.com
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Conley E. Ward
Givens Pursley LLP
277 North 6th Street - Suite 200
O. Box 2720
Boise, ill 83701
Telephone: [phone]
Facsimile: [phone]
cew~givenspursley.com
Attorney for ITA
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~tb
Brandi L. Gearhart, PLS
Legal Secretary to Mary S. Hobson
Stoel Rives LLP
FIRST PRODUCTION REQUEST OF QWEST CORPORATION TO Time Warner - Page 9
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