20031124Discovery Requests of MCI to ATT.pdf

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Dean J. Miller (ISE No. 1968)
McDEVITT & MILLER LLP
420 West Bannock Street
O. Box 2565-83701
Boise, Idaho 83702
Tel: [phone]
Fax: [phone]
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UTILI TIES Cui");')ISSION
Attorneysfor MCImetro Access Transmission Services LLC
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-
MCl's DISCOVERY REQUESTS
) TO AT&T COMMUNICA nONS OF
THE MOUNTAIN STATES, INc.
NINE-MONTH REVIEW OF ECONOMIC AND
OPERATIONAL IMPAIRMENT REGARDING
ACCESS TO SPECIFIC UNES
YOU WILL PLEASE TAKE NOTICE that MCImetro Access Transmission Services
LLC ("MCI") requests that AT&T Communications of the Mountain States, Inc. ("AT&T"
answer the following Discovery Requests in accordance with the Idaho Public Utilities
Commission s Rules of Procedure.
INSTRUCTIONS
Please answer each question separately and in the order that it is asked. The numbers of
the answers should correspond to the numbers of the data requests being answered. Please copy
each question immediately before the answer. Following each answer, please identify the person
or persons responsible for the answer and indicate what person or witness provided responsive
information or documents, and where applicable, what witness will sponsor each answer in
testimony.
MCI'S DATA REQUESTS ToAT&T-
In response to data requests seeking the production of documents, please produce all
responsive documents for inspection and copying unaltered and/or unredacted as they are kept in
the usual course of business and organize and label them to correspond to the categories in this
request. If the requested documents are kept in an electronic format, you shall produce the
requested document in such format. If any part of a document is responsive to any request , the
whole document is to be produced. If there has been any alteration, modification or addition to a
document (whether in paper form or electronic), including any marginal notes, handwritten
notes, underlining, date stamps, received stamps, attachments, distribution lists, drafts, revisions
or redlines, each such alteration, modification or addition is to be considered as a separate
document and it must be produced.
In response to Interrogatories requesting you to identify documents or other items
information or materials for disclosure, please identify the document(s) or other item(s),
information or material(s) in sufficient detail so that they can be produced in response to a
separate Request for Production. Such identification shall contain the number (and subpart, if
applicable) of the Interrogatory requesting the identification and the page count or description of
the document or item. Additionally, to the extent known, the listing shall include the author
publisher, title, date, and any "Bates" or other sequential production numbering for the document
or item. When responding to the Request for Production, please produce copies of all
documents, other items, information or materials that were identified in response to a request or
directive to "identify for disclosure" in MCI's Interrogatories. For each document or other item
please identify by number (including subpart, if any) the interrogatory which caused the
identification for disclosure
Please produce the requested information at the most granular level you possess. If a data
request seeks information at a level more granular than you possess, please do not object or
MCI's DATA REQUESTS ToAT&T-
decline to answer or produce on that basis, but rather state that you do not possess information at
that level and produce the information requested at the most granular level that you possess. MCI
is not asking for the creation of new data, but is seeking all available data for the specific
categories and sub-categories described.
Please produce all information requested on any table by filling in the table provided in
these data requests. If additional explanation is required, please copy the question and provide
your response below.
If you are unable to respond fully and completely to a document request, explain the
reasons why you are unable to do so. The terms defined herein and the individual data requests
should be construed broadly to the fullest extent of their meaning, in a good faith effort to
comply with all applicable rules, including without limitation the Procedural Rules of the Idaho
Public Utilities Commission.
This request is directed to all documents and information in your possession, custody or
control. A document is deemed to be in your possession, custody or control if you have
possession of the document, have the right to secure such document or communication from
another person having possession thereof, or the document or communication is reasonably
available to you (including those documents or communications in the custody or control of your
company s present employees, attorneys, agents, or other persons acting on its behalf and its
affiliates. In response to requests for production of documents contained in these data requests
you shall produce the documents, including all appendices, exhibits, schedules, and attachments
that are most relevant to the request.
If you are unable to produce a document or information based on a claim that the
document is not in your possession, custody or control, state the whereabouts of such document
or information when it was last in your possession, custody or control, and provide a detailed
MCI's DATA REQUESTS ToAT&T-
description of the reason the document is no longer in your possession, custody or control, and
the manner in which it was removed from your possession, custody or control.
These data requests are continuing in nature , and should there be a change in
circumstances which would modify or change an answer you have supplied, then in such case
you should change or modify such answer and submit such changes answer as a supplement to
the original answer. Further, should a subsequent version(s) of a document be created or exist
after the date of this data requests, such version(s) must be produced. Where prior versions or
drafts of documents exist, please produce all such documents in your possession, custody or
control.
MCI requests that you answer these data requests under oath or stipulate in writing that
your data requests responses can be treated exactly as if they were filed under oath.
If you claim a privilege, or otherwise decline to produce or provide, any document or
information responsive to one or more data requests, then in addition to, and not in lieu of, any
procedure that you must follow under law to preserve your objection(s) and/or privilege(s), the
attorney asserting the privilege shall:
identify in the objection to the request for information, or sub-part thereof
detailed reasons for your claim of privilege or other basis for protecting the
document or information from disclosure; and the nature of the privilege
(including work product) that is being claimed; and
provide the following information in the objection, unless divulgence of such
information would cause disclosure of the allegedly privileged information:
(i)for documents : (1) the type of document; (2) subject matter of the
document; (3) the date of the document; (4) the number of pages in the document;
(5) the location or custodian of the document; (6) such other information as is
MCI's DATA REQUESTS ToAT&T-4
sufficient to identify the document for a subpoena duces tecum including, where
available, the names(s), addressees) and telephone number of the author(s) of the
document and all recipient(s), and, where not apparent, the relationship of the
author and addressee to each other;
(ii)for oral communications: (1) the name(s), addressees) and phone
number(s) of the person making the communication and the name(s), addressees)
and phone number(s) of the persons present while the communication was made;
(2) the relationship of the person(s) present to the person(s) making the
communication; (3) the date and place of each communication; (4) the general
subject matter of the communication.
In the event that any requested information is considered by you to be confidential, the
attorney asserting such confidential status shall inform MCI of this designation as soon as he or
she becomes aware of it, but in any event, prior to the time the responses to the data requests are
due to discuss or attempt to negotiate a compromise. However, the confidential documents
should be produced pursuant to the protective order(s) and/or non-disclosure agreement(s)
executed in this proceeding.
MCI's DATA REQUESTS TOAT&T-
DEFINITIONS
1. The term "analog" refers to electrical signals representing sound or data which are
transmitted in a linear, non-digital format.
2. The terms "and" and "" as used herein shall be construed as both conjunctive and
disjunctive.
3. The term "any" shall be construed to include "all " and "all" shall be construed to include
any.
4. The terms "batch cut" and "batch hot cut" refer to a process by which the incumbent LEC
simultaneously migrates two or more loops from one carrier s local circuit switch to
another carrier s local circuit switch.
5. The term "bundled service" refers to a package offering to an end user customer that
includes at least two different services for a single, often discounted price, whether flat-
rate or charged on a per-unit basis. An example would be the offering of local and long
distance service to an end user customer for a price that is less than the standard retail
charges that would be assessed for each service individually.
6. The term "business end user" refers to an end user customer entity that purchases voice
or data services , typically supported on multiple loops, to support a commercial
enterprise. To the extent that your own tariff and/or business practices define this term
differently, please use this definition in your response.
7. The acronym "CLEC" refers to competitive local exchange carriers.
8. The acronym "CLLI" refers to common language location identifier, a multi-character
code generally composed of numerals and letters that provides a unique identifier for
circuit switches used by ILECs and CLECs.
9. The acronym "CO" refers to central office, the single physical ILEC building that houses
one or more Class 5/end office ILEC switch(es), and in which end user customers' loops
are cross connected to ILEC switching equipment or CLEC collocation arrangements.
10. The term "communication" includes, without limitation of its generality, correspondence
email, statements, agreements, contracts, reports, white papers, users guides, job aids
discussions, conversations, speeches, meetings, remarks, questions, answers, panel
discussions and symposia, whether written or oral. The term includes, without limitation
of its generality, both communications and statements which are face-to-face and those
which are transmitted by documents or by media such as intercoms, telephones
television, radio, electronic mail or the Internet.
11. The terms "cost study,
" "
cost studies
" "
cost model" and "cost analyses" means the
detailed development of a rate element or of rate elements through a methodology based
upon engineering, operational, economic, accounting, or financial inputs, plus support for
the sources of the inputs or support for the derivations of the inputs, that enables a person
MCI's DATA REQUESTS ToAT&T-
using the study, studies, model or analyses to start with the support for each input and to
then trace the support to the input, and to then be able to trace the input through the
methodology to the resulting cost and then to the resulting rate element.
12. The term "cross connect/jumper" refers to a copper pair that connects at the vertical and
horizontal sides of the ILEC MDF.
13. The term "customer location" refers to a building or set of connected, contiguous, or
adjacent buildings in a common area, used by residential, commercial, and/or
governmental customers that share a primary street address or group of street addresses.
It includes multi-unit residential, commercial, and/or governmental premises.
14. The term "customer premises" refers to the physical point at which the end user customer
assumes responsibility for telecommunications wiring (i., the network interface device
NID") for single unit dwellings, and the individual point of demarcation at the end user
customer unit for multi-unit buildings such as office buildings and apartment
buildings).
15. The term "digital" refers to electrical or optical signals representing sound or data which
are transmitted in a binary, discontinuous, non-linear format.
16. The term "DLC" refers to Digital Loop Carrier and includes UDLC, IDLC, and NGLDC.
17. The term "document " as used herein, shall have the same meaning and scope as
contained in Rule 34 of the Federal Rules of Civil Procedure, and shall include, without
limitation, all written, reported, recorded, magnetic, graphic, photographic matter
however produced or reproduced, which is now, or was at any time, in the possession
custody, or control of your company and its affiliates including, but not limited to, all
reports, memoranda, notes (including reports, memoranda, notes of telephone, email or
oral conversations and conferences), financial reports, data records, letters, envelopes
telegrams, messages electronic mail (e-mail), studies, analyses, books, articles
magazines, newspapers, booklets, circulars, bulletins , notices, instructions, accounts
pamphlets, pictures, films, maps, work papers, arithmetical computations, minutes of all
communications of any type (including inter- and intra-office communications), purchase
orders, invoices, statements of account, questionnaires, surveys, graphs, recordings, video
or audio tapes, punch cards, magnetic tapes, discs, data cells, drums, printouts, records of
any sort of meeting, invoices, diaries, and other data compilations from which
information can be obtained, including drafts of the foregoing items and copies or
reproductions of the foregoing upon which notations and writings have been made which
do not appear on the originals.
18. The term "DS-O" refers to a loop or circuit operating at Digital Signal Level Zero, and
capable of transmitting information at 64 kilo bits per second.
19. The term "DS-O/voice grade" includes all loops or circuits normally used for the
provision of a service to transmit human voice alone. In particular, it includes analog
circuits and digital circuits capable of transmitting at levels greater than 2400 baud, up to
and including 64 kilobits per second.
MCI's DATA REQUESTS TO A T& T-
20. The term "DS-l" refers to Digital Signal Level 1 , which has a transport speed of
544Mbps, and can be either unchannelized or channelized into 24 voice grade channels.
21. The term "hot cut" refers to an individual coordinated simultaneous transfer of a DS-
O/voice grade loop with live customers ' service transferred.
22. The term "identify" or "identifying" means:
(a) When used in reference to natural persons: (1) full name; (2) last known address
and telephone number; (3) whether the person is currently employed by, associated or
affiliated with SWBT; (4) that person s current or former position; and (5) dates of
employment, association or affiliation.(b) When used in reference to a document: (1) its author; (2) actual or intended
recipient(s); (3) date of creation; and (4) brief description of its contents.(c) When used in reference to a communication: (1) whether the communication was
oral or written; (2) the identity of the communicator; (3) the person receiving the
communication; and (4) the location of the communicator and the person receiving the
information, if the communication was oral.
23. The acronym "IDF" refers to an intermediate distribution frame, a physical frame located
between an MDF and (1) an ILEC switch in a central office or wire center over which
end user customer loops are transited for connection to the ILEC switch, or (2) a CLEC
collocation arrangement.
24. The term "ILEC" refers to an incumbent local exchange carrier, and includes the ILEC'
parent or any subsidiary or affiliate, and all current or former officers, directors
employees, agents, representatives, contractors or consultants of ILEC, as well as any
persons or other entities who have acted or purported to act on its behalf.
25. The term "LATA" means "Local Access and Transport Area" as that term is defined in
the Modification of Final Judgment, United States v. Western Elec. Co.5 52F. Supp. 131
(D.C. 1982), aff'd sub nom., Marylandv. United States 460 u.s. 1001 (1983).
26. The term "MSA" refers to a Metropolitan Statistical Area as defined by the US Census
Bureau and the Office of Management and Budget.
27. The term "qualifying service" refers to all telecommunications services, whether voice or
data, and whether analog or digital, that have ever been offered or provided by an ILEC
pursuant to tariff or an interconnection agreement.
28. The acronym "MDF" refers to main distribution frame, a physical frame located in a
central office or wire center that connects loops coming from an end user customer
premises to (1) an ILEC switch located in the central office or wire center, and (2)
facilities leading to a CLEC collocation arrangement.
29. The past tense includes the present tense and vice-versa.
MCI's DATA REQUESTS TO AT&T-8
30. "Relate, mention, reference , or pertain shall be used to mean documents or
communications containing, showing, relating, mentioning, referring or pertaining in any
way, directly, or indirectly to, or in legal, logical or factual way connection with, a
document request, and includes documents underlying, supporting, now or previously
attached or appended to , or used in the preparation of any document called for by such
request.
31. The singular form of a word shall be interpreted to include the plural, and the plural form
of a word shall be interpreted to include the singular whenever appropriate.
32. The term "residential end user" refers to an end user customer, typically an individual or
family, who purchases voice or data services at his, her or their place of residence, or
household. To the extent that your own tariff and/or business practices define this term
differently, please use this definition in your response.
33. The term "Telcordia" refers to Telcordia Technologies, Inc. and its parent(s), current and
former affiliates or subsidiaries, and all current or former officers, directors, employees
agents, representatives, contractors or consultants, as well as any persons or other entities
who have acted or purported to act on its behalf.
34. The term "wire center" is synonymous with the term "central office " and refers to the
single physical building that houses one or more Class 5/end office ILEC switch(es) and
in which end user customer s loops are cross connected to the Class 5/end office ILEC
switch( es).
35. The term "you
" "
your
" "
yours " or "your company refers to AT&T and its
predecessors, parents, successors, subsidiaries, divisions and related or affiliated
organizations.
CLEC HOT CUT/CUSTOMER MIGRATION ISSUES
Please provide, a) on a statewide basis, b) on a CLEC switch CLLI-code-
specific basis, and c) on a Qwest 8-digit (wire center) CLLI-code-specific
basis, monthly data for each month since July 1 , 2001 for your retail customer
chum (i.customer change from one carrier to another) on all ofthe
following bases. If you provide local service via both UNE-P and UNE loops
please provide the requested information separately for each of these serving
modes if available. If you provide local service via only one of these serving
modes , please state which one.
(a) number of customers changing carriers, and percentage of then-current
customers changing carriers, by customer type (e.
g.,
residential, business with
one to three DS-O/voice grade lines to a single customer premises; business
with more than three DS-O/voice grade lines to a single customer premises);
(b) number of customers changing carriers, and percentage of then-current
customers changing carriers, by service type (i. local exchange voice
service only; long distance voice service only; bundled local exchange and
long distance voice services; bundled local exchange and DSL; and bundled
local exchange, long distance, and DSL services);
MCI's DATA REQUESTS ToAT&T-
MCIC-265
MCIC-266
MCIC-267
MCIC-268
MCIC-269
(c) number of customers changing carriers, and percentage of then-current
customers changing carriers, by customer type (e. g., residential, business with
one to three DS-O/voice grade lines to a single customer premises; business
with more than three DS-O/voice grade lines to a single customer premises) by
the following customer ages: l) churn within the first three months after the
customer s service is provisioned, and 2) churn within the first six months
after the customer s service is provisioned.
Please provide, a) on a statewide basis, b) on a CLEC switch CLLI-code-
specific basis, and c) on an ILEC 8-digit (wire center) CLLI-code-specific basis
monthly data for each month since July 1 , 2001 for your retail customer "churn
(i.the number of customers changing from one carrier to another) for
residential local exchange customers between each of the following service
configurations: 1) Qwest voice only 2) Qwest voice plus DSL; 3) Qwest DSL
only; 4) CLEC UNE-P voice only; 5) CLEC switch-based voice only; 6) CLEC
line sharing; 7) CLEC line splitting; 8) CLEC DSL only (e., Qwest voice only
to CLEC UNE-P voice only; CLEC A switch-based voice only to CLEC B
switch-based voice only J.
Please provide, a) on a statewide basis, b) on a CLEC switch CLLI-code-
specific basis, and c) on a Qwest 8-digit (wire center) CLLI-code-specific basis
monthly data for each month since July 1 , 2001 for your retail customer "churn
(i.the number of customers changing from one carrier to another) for business
local exchange voice customers with one to three lines between each of the
following service configurations: 1) Qwest voice only 2) Qwest voice plus DSL;
3) Qwest DSL only; 4) CLEC UNE-P voice only; 5) CLEC switch-based voice
only; 6) CLEC line sharing; 7) CLEC line splitting; 8) CLEC DSL only (e.
Qwest voice only to CLEC UNE-P voice only; CLEC A switch-based voice only
to CLEC B switch-based voice only
Please provide, a) on a statewide basis, b) on a CLEC switch CLLI-code-
specific basis, and c) on a Qwest 8-digit (wire center) CLLI-code-specific basis
monthly data for each month since July 1 , 2001 for your retail customer "churn
(i. the number of customers changing from one carrier to another) for business
local exchange voice customers with more than three lines between each of the
following service configurations: 1) Qwest voice only 2) Qwest voice plus DSL;
3) Qwest DSL only; 4) CLEC UNE-P voice only; 5) CLEC switch-based voice
only; 6) CLEC line sharing; 7) CLEC line splitting; 8) CLEC DSL only (e.
Qwest voice only to CLEC UNE-P voice only; CLEC A switch-based voice only
to CLEC B switch-based voice only
Please provide, a) on a statewide basis, b) on a CLEC switch CLLI-code-
specific basis, and c) on a Qwest 8-digit (wire center) CLLI-code-specific basis
monthly data for each month since July 1 , 2001 on the number of UNE loops that
Qwest has migrated for you through hot cuts (i., individual coordinated
simultaneous transfer of DS-O/voice grade loops with live customers' service
transferred) that involved manual frame (MDF and/or IDF) jumper work.
MCI's DATA REQUESTS ToAT&T-
MCIC-270
MCIC-271
MCIC-272
MCIC-273
MCIC-274
MCIC-275
MCIC-276
With respect to your response to MCIC-269268, please specify the percentage
of hot cuts that were performed within the agreed-upon time frame (i., as of the
deadline set pursuant to an interconnection agreement or otherwise agreed to with
Qwest or pursuant to other state requirements).
With respect to the hot cuts identified in response to MCIC-269268 , please
provide a detailed description of the work efforts your personnel had to perform
as part of the hot cut process , the costs you incurred (including non-recurring
charges imposed by Qwest), and the maximum daily number of hot cuts that
Qwest has accomplished for you per Qwest 8-digit (wire center) CLLI code since
July 1 , 2001.
With respect to your response to MCIC-269268, please state whether the
existing customer loop was used for each of the migrations identified. If the loop
was not re-used, please provide a detailed explanation ofthe reasons why it was
not re-used, and any consequence of not being able to reuse the loop (i., delayed
installation interval, loss of customer telephone number, need for rewiring at
customer NID, etc.
Please provide, a) on a statewide basis, b) on a CLEC switch CLLI-code-
specific basis, and c) on a Qwest 8-digit (wire center) CLLI-code-specific basis
the number of UNE loop orders that your end user customers cancelled prior to
conversion from another carrier, for each month since July 1 , 2001. If you know
the reason(s) for such cancellation(s), please provide a detailed description of the
reason(s) for the cancellation(s) and any difficulties that arose during the
converSIOn process.
Please state the number of loops that you believe is appropriate to include in a
single "batch " as the FCC uses that terminology and concept in ~ 489 ofthe
Triennial Review Order and provide the basis for your belief and all
documentation that supports your belief.
Please explain whether you currently have in place electronic systems that can
accomplish, on an automated, flow-through basis (i., no manual intervention is
required for completion of the migration), migrations between each of the
following service configurations: 1) Qwest voice only 2) Qwest voice plus DSL;
3) Qwest DSL only; 4) CLEC UNE-P voice only; 5) CLEC switch-based voice
only; 6) CLEC line sharing; 7) CLEC line splitting; 8) CLEC DSL only (e.
Qwest voice only to CLEC UNE-P voice only; CLEC A switch-based voice only
to CLEC B switch-based voice only J.
With respect to your response to MCIC-275 , please indicate whether your
electronic systems can accomplish each migration type on each of the following
bases:
(a) automated flow-through batch cuts (please indicate the maximum number of
simultaneous loop migrations that you can support);
(b) automated flow-through individual loop hot cuts;
MCI's DATA REQUESTS ToAT&T-
MCIC-277
MCIC-278
MCIC-279
MCIC-280
MCIC-281
MCIC-282
MCIC-283
MCIC-284
(c) manual batch cuts (please indicate the maximum number of simultaneous loop
migrations that you can support
(d) manual individual loop hot cuts.
Please provide, a) on a statewide basis , and b) on a Qwest 8-digit (wire
center) CLLI-code-specific basis, the number of your UNE-P orders in Idaho that
were fulfilled each month since July 1 , 200 l.
Please explain whether you have always been able to obtain a customer
service record ("CSR") from Qwest and/or other CLECs for the provision of 1)
local exchange voice service on UNE-P; 2) local exchange voice service on UNE
loop. If not, please provide a detailed explanation of the reason( s) you did not
obtain the CSR.
For all instances in which you receive a CSR from Qwest or other CLECs
please provide a detailed explanation of the manner (e.g. fax, email, EDI , third
party gateway, etc.) in which you obtain the CSR and whether you retain the CSR
or the information in it (e.g. circuit ID, address, service features) for the duration
of your service to each customer.
Please provide a detailed explanation of the manner (e., fax, email, EDI
third party gateway, etc.) in which you provide the CSR or the information in it
(e.g. circuit ID , address, service features) to other carriers (ILEC or CLECs) to
migrate and provision new service for the customer.
Please explain whether you currently use an electronic automated (i., not
requiring any manual intervention prior to completion of task) method to interface
with Qwest to send or receive each of the following: a) pre-order inquiries; b)
orders (including placing the order, firm order confirmations, jeopardy notices
etc); c) provisioning (including the exchange of information for changes to 911
local number portability, and other databases); d) maintenance and repair; e)
billing.
Please provide a detailed explanation of the electronic method (e.g. EDI
CORBA, etc.) that you currently use to send to or receive from ILECs and/or
CLECs each of the following: a) pre-order inquiries; b) orders (including placing
the order, firm order confirmations, jeopardy notices, etc.); c) provisioning
(including the exchange of information for changes to 91l , local number
portability, and other databases); d) maintenance and repair; e) billing.
Please explain whether you currently have in place and use electronic
automated systems to process orders placed by customers whose service will be
provisioned using your own switches. If your ordering systems are only partially
electronic and automated, please identify specifically which portions are
electronic and which are manual, and provide a detailed explanation of the
limitations created by the manual portions when processing customer orders.
With respect to your response to MCIC-283 , if you use existing electronic
MCI's DATA REQUESTSTOAT&T-
MCIC-285
MCIC-286
MCIC-287
MCIC-288
MCIC-289
MCIC-290
automated systems to process orders place by customers whose service will be
provisioned using your own switches, please explain whether those electronic
automated systems have the capacity and capability to be used to process orders
of mass market customers whose service will be provisioned via your own
switches using UNE loops rather than UNE-
With respect to your response to MCIC-283282, if you cannot use your
existing electronic automated systems to process orders placed by mass market
customers whose service will be provisioned using your own switches using UNE
loops rather than UNE-, please provide a detailed explanation of every
modification or component replacement that you would have to make so that you
could use your existing electronic systems to process orders for such customers.
Please provide the estimated cost and time required to make such modifications or
replacements.
Please explain whether you currently have in place and use electronic
automated systems to provision service for customers using your own switches.
If your provisioning systems are only partially electronic and automated, please
identify specifically which portions are electronic and which are manual, and
provide a detailed explanation of the limitations created by the manual portions
when provisioning customer orders.
With respect to your response to MCIC-286, if you use existing electronic
automated systems to provision service for customers using your own switches
please explain whether those electronic automated systems have the capacity and
capability to be used to provision service for mass market customers whose
service will be provisioned via your own switches using UNE loops rather than
UNE-
With respect to your response to MCIC-286, if you cannot use your existing
electronic automated systems to provision service for mass market customers
whose service will be provisioned via your own switches using UNE loops rather
than UNE- P, please provide a detailed explanation of every modification or
component replacement that you would have to make so that you could use your
existing electronic systems to provision orders for such customers. Please provide
the estimated cost and time required to make such modifications or replacements.
Please explain whether you currently have in place and use electronic
automated systems to maintain and repair service for customers whose service is
provisioned using your own switches. If your maintenance and repair systems are
only partially electronic, please identify specifically which portions are electronic
and which are manual, and provide a detailed explanation of the limitations
created by the manual portions for maintenance and repair of customer services.
With respect to your response to MCIC-289, if you use existing electronic
automated systems to maintain and repair service for customers whose service is
provisioned using your own switches, please explain whether those electronic
automated systems have the capacity and capability to be used to maintain and
MCI's DATA REQUESTS TO A T& T -
MCIC-291
MCIC-292
MCIC-293
MCIC-294
MCIC-295
MCIC-296
MCIC-297
repair service for mass market customers whose service will be provisioned via
your own switches using UNE loops rather than UNE-
With respect to your response to MCIC-289 , if you cannot use your existing
electronic automated systems to maintain and repair services and facilities for
mass market customers whose service will be provisioned on your own switches
using UNE loops rather than UNE-, please provide a detailed explanation of
every modification or component replacement that you would have to make so
that you could use your existing electronic systems to maintain and repair service
for such customers. Please provide the estimated cost and time required to make
such modifications or replacements.
Please explain whether you have adequate access to Qwest facilities to
conduct trouble isolation and repair for customer services provisioned via your
own switches using UNE loops. If your response is anything other than an
unequivocal yes, please explain in detail the reason that you do not have such
access.
With respect to your response to MCIC-292, please explain whether such
access is adequate for you to perform trouble isolation and repair for mass market
customers whose service is provisioned via your own switches using UNE loops
rather than UNE-P. If your current access is not adequate from a technical or
economic perspective, please provide a detailed explanation of every reason why
it is inadequate, and identify what changes (e., technical, logistical, economic
etc.) must be implemented to make your access adequate. Please provide the
estimated cost and time required to make such changes.
Please explain whether you have adequate access to Qwest facilities to
conduct testing for customer services provisioned via your own switches using
UNE loops.
With respect to your response to MCIC-294, please explain whether such
access is adequate for you to conduct testing for mass market customers whose
service is provisioned via your own switches using UNE loops rather than UNE-
P. If your current access is not adequate from a technical or economic
perspective, please provide a detailed explanation of every reason why it is
inadequate, and identify what changes (e., technical, logistical, economic, etc.
must be implemented to make your access adequate. Please provide the estimated
cost and time required to make such changes.
Please explain whether you currently have in place and use electronic
automated systems to bill customers whose services are provisioned using your
own switches. If your billing systems are only partially electronic, please identify
specifically which portions are electronic, and which are manual, and provide a
detailed explanation of the limitations created by the manual portions when
billing customers.
With respect to your response to MCIC-296, please explain whether your
MCI's DATA REQUESTS ToAT&T-
MCIC-298
MCIC-299
MCIC-300
existing electronic automated systems have the capacity and capability to be used
to bill mass market customers for services provisioned via your own switches
using UNE loops rather than UNE-
With respect to your response to MCIC-296, if you cannot use your existing
electronic automated systems to bill services for mass market customers whose
service will be provisioned via your own switches using UNE loops rather than
UNE- P, please provide a detailed explanation of every modification or component
replacement that you would have to make so that you could use your existing
electronic systems to bill services to such customers. Please provide the
estimated cost and time required to make such modifications or replacements.
CLEC MASS MARKET UNE SWITCHING TRIGGER ISSUES
Please state whether you are you an incumbent local exchange provider
ILEC") or are an affiliate of an ILEC. If you are an affiliate of an ILEC, please
identify the ILEC and describe the affiliation. For purposes of these Requests
affiliate" shall be as defined in the Communications Act of 1934. Section 3
the Act defines the term "affiliate" as "a person that (directly or indirectly) owns
or controls, is owned or controlled by, or is under common ownership or control
with, another person. For the purposes of this paragraph, the term 'own' means to
own an equity interest (or the equivalent thereof) of more than 10 percent." 47
C. ~ 153(1)
For each switch you use to provide local exchange service to Idaho customers
please provide the following information for the switch and/or the switch
location:
(a) the 8-digit common language location identifier ("CLLI") code as it appears
in the Local Exchange Routing Guide ("LERG"
(b) V &H coordinates;
(c) street address, city and zip code;
(d) switch manufacturer, model, and date of installation;
(e) currently loaded version of switch software;
(f) currently equipped line side capacity in (1) DS-O/voice grade circuits and (2)
DS-l circuits;
(g) currently utilized line side capacity in (1) DS-O/voice grade circuits and (2)
DS-1 circuits;
(h) current switch processor capacity in CCS;
(i) busy hour and busy season utilized switch processor capacity in CCS;
G) function of the switch (e., stand-alone, host, or remote , other (e.g. DLC node
with no intelligence and/or no or limited switching capability J);
(k) the initial cost of the switch, including equipment, software, and EF&I
engineered, furnished and installed") costs;
(1) number of (1) DS-O/voice grade circuits and (2) DS-1 circuits equipped at the
time of installation;
(m)any ILEC wire center subtending areas currently served by your switch for
which you are currently considering discontinuing service for any reason
within the next 12 months.
MCI's DATA REQUESTS ToAT&T-
MCl's DATA REQUESTS TO AT&T -
MCIC-301 For each switch identified in your response to MCIC-300, please provide the
information requested in TABLE
TABLE 1
CLEC Number Of Number of Type of End-Number of Number of Number of
Switch Loops Per Local User Voice Only DSL Only Line
CLL!End-User Service End-Customer End User End User Shared/Line
Customer User Customers Customers Split DSL End
Premises Customers User
Customers
ABC g. 10 155 Residential g. 10 000 g. 5 g. 100
g. 5 300 Business g. 5 000 g. 100 g. 100
Residential
Business
Residential
Business
. . . (continue pattern as above)
Residential
Business
19-Residential
19-Business
one DS-Residential
one DS-Business
more than Business
one DS-
MCIC-302
MCIC-303
For each switch identified in your response to MCIC-300 that is not physically
located in Colorado, please state whether such switch also provides service to
customers in the state in which the switch is located. Ifthe answer is affirmative
please describe the manner in which the switch's capacity is divided or allocated
between the two states.
For each switch identified in your response to MCIC-300, please provide a list
of all the Qwest wire centers in Idaho for which you are currently using that
switch to provide local exchange service to one or more customers. Ifthere are
any limitations on the number of customers in that wire center that can be served
from your switch (e., the switch is a remote device capable of serving only
customers in a single building), please so state and provide a detailed description
of the limitation.
This category includes loops used for fax and/or modem-only traffic.
This category includes voice and DSL on the same wire pair (i., line sharing and line splitting).
MCI's DATA REQUESTS ToAT&T-
MCIC-304
MCIC-305
MCIC-306
For each switch identified in your response to MCIC-300 other than circuit
switches, please provide the following for each switch:
(a) any differences in quality of service compared to local exchange service
provided on circuit switches (e., reliability, throughput, ubiquity, outages
mean time to repair, availability of E911 service, lack of line-powered local
telephone service);
(b) the date(s) on which you installed the switch and began providing local
exchange service on the switch;
(c) the geographic area served by the switch compared to the geographic area
served by any circuit switches you use to provide local exchange service;
(d) any differences in the technical or operational requirements for the customer
to obtain local exchange service from the switch, including customer premises
equipment or software (e., specialized phone set; availability of computer
cable modem, set top box, need for customer premises battery backup for
telephone service), access method (e., DSL, cable television, satellite
service), provisioning interval;
(e) any Qwest central office or wire center subtending areas currently served by
your switch for which you are considering discontinuing service for any
reason within the next 12 months.
For each switch identified in your response to MCIC-300, please state whether
you own the switch, or instead whether you have leased the switching capacity or
otherwise obtained the right to use the switch on some non-ownership basis
(including wholesale and/or resale). If you do not own the switch
(a) state whether the entity owning the switch is an affiliate of yours;
(b) identify the entity owning the switch, and (if different) the entity with which
you entered into an arrangement to obtain switching capacity;
(c) identify the nature of the arrangement through which you obtained switching
capacity;
(d) provide a copy of the agreement (e.g. Interconnection Agreement, contract
lease, etc.) specifying the rates, terms and conditions through which you are
currently obtaining switching capacity.
For each switch you own or control and from which you offer or provide
wholesale local switching capacity (wholesale local switching capacity on a
standalone basis, or combined with loops and/or transport) to carriers that are not
affiliated with you, to use to serve Idaho customers, please provide the following
information for the switch and/or the switch location:
(a) the 8-digit common language location identifier ("CLLI") code as it appears
in the Local Exchange Routing Guide ("LERG"
(b) V &H coordinates;
(c) street address, city and zip code;
(d) the footprint or geographic area served by the switch, including each Qwest
wire center service by the switch;
MCI's DATA REQUESTS ToAT&T-
MCIC-307
(e) the features and functions of the switch available in each footprint or
geographic area and an identification of any features or functions that the
Qwest switch in that area can provide or support that your switch cannot
support;
(f) switch manufacturer, model and date of installation;
(g) currently loaded version of switch software;
(h) currently equipped line side capacity in (1) DS-O/voice grade circuits and (2)
DS-1 circuits;
(i) currently utilized line side capacity in (1) DS-O/voice grade circuits and (2)
DS-1 circuits;
U) current switch processor capacity in CCS;
(k) busy hour and busy season utilized switch processor capacity in CCS;
(1) percentage of line side or processor capacity reserved for your own current or
future use;
(m)percentage of line side and processor capacity that you currently make
available, or that you plan to make available, on a wholesale basis to other
CLECs;
(n) the expected useful service life of the switch;
(0) whether your company intends to utilize the switch for its full expected useful
service life;
(p) the serving platform (e., wholesale switching for local exchange service on a
standalone basis , or combined with loops and/or transport);
(q) the rates, terms and conditions under which you provide wholesale switching
for local exchange service, and/or loops and transport provided in conjunction
with wholesale switching (if rates, terms and conditions are not currently
available, please state when they will be available);
(r) a copy of the methods and procedures document, or other documents or
information, detailing the technical specifications for the provision of
wholesale switching, including interface requirements, signaling capabilities
service quality parameters (including procedures to minimize service
degradation, delay, echo return, and/or loss attenuation), and service
procedures;
(s) any Qwest central office or wire center subtending areas currently served by
your switch for which you are considering discontinuing service for any
reason within the next 12 months.
For each switch identified in your response to MCIC-306, please provide the
information requested in TABLE 2:
MCI's DATA REQUESTS ToAT&T-
TABLE 2
CLEC Number Of Number of Type of End-Number of Number of Number of
Switch Loops Per Local User Voice Only DSL OnIy Line
CLL!End-User Service End-Customer End-User End-User Shared/Line
Customer User Customers Customers Split DSL End
Premises Customers User
Customers
ABC g. 10 155 Residential g. 10 000 g. 5 g. 100
g. 5 300 Business g. 5,000 g. 100 g. 100
Residential
Business
Residential
Business
. . . (continue pattern as above)
Residential
Business
19-Residential
19-Business
one DS-Residential
one DS-Business
more than Business
one DS-
MCIC-308
MCIC-309
For each switch identified in your response to MCIC-306, please provide the
following information:
(a) whether you are willing to expand your switch capacity to meet increased
demand for wholesale switching from other CLECs;
(b) your existing plans and/or procedures for ordering and implementing software
upgrades for the switch;
(c) terms and conditions (including forecasts) you require or expect to require
from other CLECs in order to expand the capacity of your switch for the
provision of wholesale switching;
(d) rates, deposits or other financial information you require or expect to require
from other CLECs in order to expand the capacity of your switch for the
provision of wholesale switching;
(e) whether you now have, or intend to implement, a process or procedure to
ensure that your switch can provide the same features and functions as those
available from Qwest switches.
For each collocation arrangement in each Qwest central office or wire center
in Colorado, please provide the following information, reported by Qwest 8-digit
(wire center) CLLI code and street address:
(a) type of collocation arrangement (e.g. caged, cageless, virtual, etc.
(b) size of collocation arrangement;
(c) amount of power (including both "A" and "B" DC feeds and AC power)
supplied to the collocation arrangement;
This category includes loops used for fax and/or modem-only traffic.
This category includes voice and DSL on the same wire pair (i., line sharing and line splitting).
MCl's DATA REQUESTS TOAT&T-
(d) all equipment in the collocation arrangement, including make, model, EF&I
cost, total installed capacity, and total capacity currently in use;
(e) amount of unused space in the collocation arrangement that could be used for
placing additional equipment;
(f) number of2-wire cross connects currently provisioned from the MDF to the
collocation arrangement;
(g) number of 4-wire cross connects currently provisioned from the MDF to the
collocation arrangement; .
(h) number of 2-wire cross connects currently provisioned from the MDF to the
collocation arrangement that are currently used to provide service to
customers;
(i) number of 4-wire cross connects currently provisioned from the MDF to the
collocation arrangement that are currently used to provide service to
customers;
G) type(s) of Qwest transport connected to the collocation arrangement (e.
special access, UNE transport, etc.
(k) capacity(ies) of Qwest transport connected to the collocation arrangement
(e., DS-, DS-, OC-, etc.), and number of circuits at each level of
capacity;
(1) capacity(ies) of your own transport connected to the collocation arrangement
(e., DS-, DS-, OC-, etc.), and number of circuits at each level of
capacity;
(m)capacity(ies) ofthird party transport connected to the collocation arrangement
(e., DS-, DS-, OC-, etc.), and number of circuits at each level of
capacity;
(n) copy of tariff, contract, lease, IRU, or other document controlling the terms
and conditions for third party transport;
(0) if the collocation arrangement is connected via transport to any switch used by
CLEC to offer local service in Colorado, the CLLI code, city, street address
zip code, V &H coordinates, and owner of that switch;
(P) all non-recurring and monthly recurring charges for the collocation
arrangement;
(q) name(s) of other collocating carrieres) to which this collocation arrangement is
connected in this Qwest central office or wire center;
(r) name(s) of other collocating carrieres) that are sharing this collocation
arrangement (if collocation sharing is permitted by Qwest);
(s) the approximate number of days between the date collocation space was
ordered and the date on which collocation space was turned over to you by
Qwest;
(t) the approximate number of days between the date collocation space was
turned over to you by Qwest and the date equipment in the collocation space
was first used to provide local exchange service. If you have not used the
collocation space to provide local exchange service, or no longer use the
collocation space to provide local exchange service, please so state, and
indicate what steps and the approximate amount of time that would be
required for you to be able to use the collocation space to provide local
exchange service.
MCl's DATA REQUESTS TO A T& T -
MCIC-310
MCIC-3l1
With regard to all CLEC-to-CLEC cross connections you have purchased
please identify the following, reported by Qwest central office or wire center:
(a) number of such cross connections that you have had provisioned;
(b) the identity of the other CLEC with whom you provisioned the cross connect
(c) the type of collocation arrangement of both CLECs;
(d) the minimum, maximum and average provisioning time for CLEC-to-CLEC
cross connections;
( e) the identity of the entity or personnel who performs the cross connect (e.
ILEC central office technician, certified CLEC technician, etc.
For each collocation arrangement identified in your response to MCIC-309
please provide the information in TABLE 3.
TABLE 3
Qwest Number Of Number of Type of End-Number of Number of Number of
Digit Loops Per Local User Voice Only DSL Only Line
Wire End-User Service End-Customer End-User End-User Shared/Line
Center Customer User Customers Customers Split DSL End
CLL!Premises Customers User
Customers
ABC g. 1 017 Residential g. 1 000 g. 2 g. 10
g. 540 Business g. 500 g. 10 g. 10
Residential
Business
Residential
Business
. . . (continue pattern as above)
Residential
Business
19-Residential
19-Business
one DS-Residential
one DS-Business
more than Business
one DS-
MCIC-312 For each of the collocation arrangements identified in your response to MCIC-
309 that is connected via transport to a switch used by you to provide local
service in Colorado, please provide the following information concerning that
transport:
(a) the CLLI code , street address, V&H coordinates, and owner of the switch to
which the collocation arrangement is connected;
(b) number(s) and routing of transport circuits;
(c) type of physical facility used for transport (e.g. copper, fiber);
(d) type(s) of Qwest transport (e., special access, UNE transport, etc.
(e) identification of and capacity(ies) of Qwest transport (e., DS-, DS-, OC-
etc.), and number of circuits at each level of capacity;
This category includes loops used for fax and/or modem-only traffic.
This category includes voice and DSL on the same wire pair (i., line sharing and line splitting).
MCI's DATA REQUESTS TOAT&T-
MCIC-313
MCIC-314
(f) identification of and capacity(ies) of your own transport (e., DS-, DS-
OC-, etc.), and number of circuits at each level of capacity;
(g) identification of and capacity(ies) of third party transport (e., DS-, DS-
OC-, etc.), and number of circuits at each level of capacity;
(h) for all transport that is not owned by you, a description and copy ofthe
arrangement under which the transport is obtained (e., tariff, contract, lease
IRU, etc.
(i) all recurring and non-recurring costs and/or charges for transport.
For each of the collocation arrangements identified in your response to MCIC-
309 that is connected via EELs to a switch you use to provide local service in
Colorado, please provide the following information:
(a) the CLLI code, street address, zip code, V &H coordinates, and owner ofthe
switch to which the collocation arrangement is connected;
(b) number of such EELs that comprise DS-O/voice grade transport connected to
DS-O/voice grade loops;
( c) number of such EELs that comprise DS-l transport connected to multiplexed
DS-O/voice grade loops;
(d) number of such EELs that comprise DS-l transport connected to multiplexed
and concentrated DS-O/voice grade loops, and the loop-to-transport
concentration ratio;
(e) number of such EELs that comprise DS-3 transport connected to multiplexed
DS-O/voice grade loops;
(f) 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;
(g) number of such EELs that comprise DS-1 transport connected to DS-1 loops;
(h) number of such EELs that comprise DS-3 transport connected to multiplexed
DS-1loops;
(i) number of such EELs that comprise DS-3 transport connected to multiplexed
and concentrated DS-l loops, and the loop-to-transport concentration ratio.
Do you use EELs that comprise loops and transport without using collocation
arrangements? If the answer is affirmative, please provide the following
information:
(a) the CLLI code, street address, zip code, V&H coordinates , and owner of the
central office or other location where the loop and transport are connected to
form an EEL;
(b) number of such EELs that comprise DS-O/voice grade transport connected to
DS-O/voice grade loops;
(c) number of such EELs that comprise DS-1 transport connected to multiplexed
DS-O/voice grade loops;
(d) number of such EELs that comprise DS-l transport connected to multiplexed
and concentrated DS-O/voice grade loops, and the loop-to-transport
concentration ratio;
( e) number of such EELs that comprise DS-3 transport connected to multiplexed
DS-O/voice grade loops;
(f) number of such EELs that comprise DS-3 transport connected to multiplexed
MCI's DATA REQUESTS TO A T& T -
MCIC-315
MCIC-316
MCIC-317
and concentrated DS-O/voice grade loops, and the loop-to-transport
concentration ratio;
(g) number of such EELs that comprise DS-l transport connected to DS-l loops;
(h) number of such EELs that comprise DS-3 transport connected to multiplexed
DS-1 loops;
(i) number of such EELs that comprise DS-3 transport connected to multiplexed
and concentrated DS-l loops, and the loop-to-transport concentration ratio.
For each collocation arrangement in a non-Qwest central office or wire center
in Idaho (e., carrier hotels), please provide the following information:
(a) type of collocation arrangement (e.g. caged, cageless, virtual, etc.
(b) size of collocation arrangement;
(c) all equipment in the collocation arrangement, including make, model, cost
total installed capacity, total capacity currently in use, and number and type
(e., residential, business) of customer served by each piece of equipment, as
of the date of this Request;
(d) type(s) of transport connecting the collocation arrangement to your switch or
other non-ILEC switch (e., special access, UNE transport, self provisioned
third party provisioned)
(e) capacity(ies) of transport connected to the collocation arrangement (e., DS-
, DS-, DS-, OC-, etc., and number of each type);
(f) ifthe collocation arrangement is connected via transport to any switch you use
to offer local service in Colorado, the CLLI code, street address, zip code
V &H coordinates, and owner of that switch;
(g) all non-recurring and recurring charges for the collocation arrangement;
(h) name(s) of other collocating carrieres) to which this collocation arrangement is
connected in this central office or wire center;
(i) name(s) of other collocating carrieres) that are sharing this collocation
arrangement (if collocation sharing is permitted by owner)
For each Qwest central office or wire center subtending area in Idaho that you
do not serve with your own switch, please provide a detailed explanation of the
reason you do not serve that area (e., too few customers to achieve economies of
scale; high churn rates that preclude recovery of non-recurring costs and charges
etc.
Please provide a detailed explanation of each task you would have to
undertake to provide local exchange service to mass market customers via UNE
loops using your own switches, rather than via UNE-, including but not limited
to the following: implement new or modify business and operational plans to use
UNE loops; hire and train loop provisioning technicians; hire and train switch
technicians; establish collocation arrangements in Qwest central offices or wire
centers; purchase and install equipment in collocation arrangement; hire and train
new, or increase existing, customer service personnel; hire and train new, or
increase existing, trouble maintenance personnel; add new or revise OSS for
preordering, ordering, provisioning, repair and/or billing; develop capabilities for
E911 service; develop capabilities for number portability. Please provide an
estimate of the time and cost for each task identified.
MCI'S DATA REQUESTS TO AT&T -
MCIC-318
MCIC-319
MCIC-320
MCIC-321
MCIC-322
MCIC-323
MCIC-324
MCIC-325
Please provide the definition you use internally for business purposes for the
following terms: (l) "mass market customer" and (2) "enterprise customer " in
terms of type of customer (e., residential vs. business), number of lines per
customer, use of DS-O/voice grade loop facilities vs. DS-l s, or any other basis
you use to distinguish these terms.
Please state whether you view a crossover point between mass market
customers and enterprise customers set at 4 DS-O/voice grade lines per single
customer premises to have any economic, engineering, operational, or business
basis from the perspective of your non-regulatory business purposes. If your
response is not an unqualified "" please explain such basis in detail and
provide supporting documentation.
Please provide your calculation, estimate, or view of the economic crossover
point , in terms of number of DS-O/voice grade lines to a single customer
premises, at which you offer service at a DS-l level rather than using a number of
analog lines, and provide the basis for that crossover point (e., equivalency point
of analog service rates and DS-1 service rates, consideration of whether the
customer premises equipment can accept a DS-1 interface, etc.
With respect to each of the two customer categories identified in your
response to MCIC-318 , please provide the following information:
(a) what switching arrangement you use to serve the customer category (e., self-
provisioned CLEC switch, ILEC switch, purchase wholesale switching from
another CLEC, purchase switching from a third party other than a CLEC);
(b) the number of customers in each customer category, reported by Qwest central
office or wire center for each month since July 1 2001;
(c) the percentage of your total customer base in Idaho in each of the two
categories;
(d) whether you target your business plans, sales or marketing to particular
subsets of customers within each of the two customer categories.
If you do not currently offer service to residential customers in Colorado
please list and describe your reasons for not doing so.
If you do not currently offer service to business customers in Idaho below the
DS-1level (i., DS-O/voice grade loops), please list and describe your reasons for
not doing so.
If you currently offer service to business customer in Idaho below the DS-
level (i., DS-O/voice grade loops), but do not offer and/or market service to such
customers unless they have or need a certain minimum number of loops to their
premises, please state that minimum number, and list and describe your reasons
for not offering and/or marketing service below that level.
Please state the rates you charge for flat and measured local exchange service
for all 1) residential and 2) business customers in Colorado, and if the rate varies
MCI's DATA REQUESTS ToAT&T-
MCIC-326
MCIC-327
MCIC-328
by location, please identify the geographic coverage of the area to which the rate
applies (e., wire center, rate zone, etc.) and the statewide average rate you
charge for each category. If the rates you charge vary by central office, please
identify the rate that applies to each central office by CLLI code, and the rate zone
applicable to each central office.
Please identify the average monthly revenue per line in Idaho that you
consider to constitute low revenue, average revenue and high revenue for 1)
residential customers and 2) business customers below the DS-1 level. Please
provide a detailed explanation of whether high revenue customers typically
purchase a single service, or a bundle of services, and if they purchase a bundle
which services, features or functions are included in the bundle.
Please identify, by CLLI code, all central offices or wire centers in Idaho for
which you receive universal service fund subsidies and provide the following
information for each:
(a) whether the subsidy is from federal or state sources
(b) the amount of the subsidy on a per loop or per customer basis
(c) whether the subsidy applies to all customers served by the central office/wire
center, or only a portion thereof;
(d) if the subsidy applies only to a portion of the customers, please provide the
number of customers and the percentage of those customers to the total
number of customers served in the central office or wire center.
Please provide your current average monthly revenues per line per customer
in Colorado , stated separately for (1) residential customers served via UNE-P; (2)
residential customers served via UNE loops; (3) business customers served via
UNE-P; (4) business customers served via DS-O/voice grade UNE loops; and (5)
business customers served via DS-1 UNE loops. Please provide the requested
information at the most granular level available (e., per-ILEC-digit-CLLI
serving area, per-CLEC-switch serving area, statewide, etc.). Please identify the
source ofthe reported revenues by service and/or feature type (i., local voice
only, local voice plus vertical features, long distance only, DSL only, bundles of
any of the above, and/or other services or features). If you do not track revenues
differentially for UNE-P vs. UNE loop configurations for residential and/or
business customers, please so state, and provide combined numbers. For all
revenues provided, exclude taxes, regulatory assessments and surcharges, and
other payments made to governmental units. If it is not possible to exclude such
payments, please so state.
For each switch identified in your response to MCIC-304, please provide the
following for each switch:
(a) all categories and amounts of costs arising from the provision oflocal
exchange service using the switch (including the recurring and non-recurring
charges for the switch, software, installation, maintenance, loops, collocation
transmission/concentration equipment, etc.
(b) the average total monthly revenues earned per line per customer in Idaho for
1) residential customers, and 2) business customers taking service below the
MCI's DATA REQUESTS ToAT&T-
MCIC-329
MCIC-330
MCIC-331
MCIC-332
MCIC-333
DS-1 or equivalent level, since July l , 2001 , reported by CLLI code, MSA
and LATA. Please identify the source of those revenues by service and/or
feature type (i., local voice only, local voice plus vertical features, long
distance only, DSL only, bundles of any of the above, and/or other services or
features). For all revenues provided, exclude taxes, regulatory assessments
and surcharges, and other payments made to governmental units. If it is not
possible to exclude such payments, please so state.
With respect to each of the two customer categories identified in response to
MCIC-318, please provide the following:
(a) all categories and amounts of costs arising from the provision of local
exchange service to each customer category (including the recurring and non-
recurring charges for the switch, software, installation, maintenance, loops
collocation, transmission/concentration equipment, transport, hot cuts, OSS
signaling, etc.
(b) the average total monthly revenues earned per line since July 1 , 2001 for each
customer category, reported by CLLI code, LATA and MSA. Please identify
the source of those revenues by service and/or feature type (i., local voice
only, local voice plus vertical features, long distance only, DSL only, bundles
of any ofthe above, and/or other services or features). For all revenues
provided, exclude taxes, regulatory assessments and surcharges, and other
payments made to governmental units. If it is not possible to exclude such
payments, please so state.
If you currently offer service to residential customers, please provide your
variable costs per residential customer.
Do you currently have access to external sources of capital for the purpose of
expanding your operations by making new capital investments? If so , please list
and describe all such sources , and state the quoted or estimated interest rate for
each such source.
Please provide a copy of all business cases, business analysis, cost studies, or
other analyses or evaluations concerning whether entry into the mass market is
economically feasible without access to Qwest s switches, including but not
limited to those analyses and studies that were submitted to the FCC, performed
but not submitted to the FCC, and performed since February 22 2003. Provide
all supporting documentation and work papers, in electronic format if available.
MCI's DATA REQUESTS ToAT&T-
Dated thi h day of November 2003.
MCI's DATA REQUESTS TO AT&T-
~~~ \J\
ean . Ml ler
McDEVITT & MILLER LLP
420 West Bannock Street
Boise, Idaho 83702
Attorneys for MC!
Certificate of Service
I hereby certify that on the 24th day of November, 2003, I caused to be served by the methodes) indicated
below, the foregoing document upon:
Charles Carrathers
VERlZON NORTHWEST INC.
1800 41st Street
Everett, Washington 98201
Tel:
Fax:
ch lick. carrat hers(i!Jverizo n. co m
Marlin D. Ard
ATIORNEY AT LAw
O. Box 2190
Sisters, Oregon 977 59
Tel: [phone]
Fax: [phone]
maratty(i!Jqwest.net
Mary B. Tribby
Letty S.D. Friesen
AT&T COMMUNICATIONS OF TIlE MOUNTAIN STATES
1875 Lawrence Street, Suite 1575
Denver, Idaho 80202
Tel: [phone]
Fax: [phone]
lsfriesen(i!Jatt.com
Robert M. Pomeroy, Jr.
HOLLAND & HART
8390 East Crescent Parkway, Suite 400
Greenwood Village, Idaho 80111
Tel: [phone]
Fax: [phone]
bpomeroy(i!J ho lIandandhart. co m
Brian Thomas
TIME WARNER TELECOM
223 Taylor Avenue North
Seattle, Washington 98109
Tel: [phone]
Fax: [phone]
Brian. Thomas(i!Jt\vtelecom. com
Mary S. Hobson
STOEL RIvEs LLP
101 So. Capitol Blvd., Suite 1900
Boise, Idaho 83702
Tel: [phone]
Fax: [phone]
mshobson(i!Jstoel.com
MCI's DATA REQUESTS TOAT&T-
Hand Delivered
S. Mail
Fax
Fed. Express
Email
Hand Delivered
S. Mail
Fax
Fed. Express
Email
Hand Delivered
S. Mail
Fax
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Email
Hand Delivered
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Fax
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Email
Hand Delivered
S. Mail
Fax
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Hand Delivered
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Fax
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Email
IiI
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Certificate of Service
continued
Adam L. Sherr
QWEST
1600 7th Avenue, Room 3206
Seattle, Washington 98191
Tel: [phone]
Fax: [phone]
asherr(gJqwest.com
ConleyE. Ward
GIVENS PURSLEY, LLP
277 North 6th Street, Suite 200
O. Box 2720
Boise, Idaho 83701
Tel: [phone]
Fax: [phone]
cew(gJgi vensp ursley. com
Clay R. Sturgis
Moss ADAMS LLP
601 West Riverside, Suite 1800
Spokane, Washington 99201-0663
Tel: [phone]
Fax: [phone]
clay.s turgis(gJmossadams. com
~~ f'
MCI's DATA REQUESTS TO AT&T-
Hand Delivered
S. Mail
Fax
Fed. Express
Email
Hand Delivered
S. Mail
Fax
Fed. Express
Email
Hand Delivered
S. Mail
Fax
Fed. Express
Email