20031124Discovery Requests of MCI to Qwest.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
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Attorneys for MC/metro Access Transmission Services LLC
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
Case No. GNR-03-
MCl's DISCOVERY REQUESTS
) TO QWEST
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)
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 Qwest Corporation ("Qwest" or "QWEST") 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.
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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
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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.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
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information when it was last in your possessIOn, custody or control, and provide a detailed
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;
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(5) the location or custodian of the document; (6) such other information as is
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.
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DEFINITIONS
l. 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 incumbent local exchange carriers ("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.
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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
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 s 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 kilobits per second.
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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.
20. The term "DS-1 " refers to Digital Signal Levell , 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 Qwest; (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 afFinal Judgment, United States v. Western Elec. Co.552F. 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.
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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.
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 Qwest Corporation and its
predecessors, parents, successors, subsidiaries, divisions and related or affiliated
organizations.
QWEST HOT CUT/CUSTOMER MIGRATION ISSUES
MCI-Please provide, a) on a Idaho-statewide basis, and b) on a CLLI-code-specific basis
monthly data for each month since July 1 2001 for your retail customer "churn
(i.customer change from one carrier to another) on each of the following bases:(a) number of customers changing carriers, and percentage of then-current
customers changing carriers, by customer type (e.
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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);
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(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);
(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: 1) churn within the first three months after the
customer s service is provisioned 2) churn within the first six months after the
customer s service is provisioned.
Please provide, a) on a Idaho-statewide basis, and b) on a 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-
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 Idaho-statewide basis, and b) on a 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 Idaho-statewide basis, and b) on a 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, on a CLLI -code-specific basis, the number of loops that Qwest has
migrated through hot cuts (i., individual coordinated simultaneous transfer of DS-
a/voice grade loops with live customers' service transferred) since July 1 2001 that
involved manual frame (MDF and/or IDF) jumper work, reported on a daily,
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weekly and monthly basis, from each of the following: 1) Qwest retail analog
services; 2) CLEC UNE loops. Please provide all supporting documents or
information regarding such provisioning volumes.
F or each CLLI code in Idaho, please provide the number of individual cross
connects/jumper jobs performed on (1) the MDF, and (2) any IDF(s), during each
month since July 1 2001.
Please provide the actual (i., unadjusted and not subjected to performance measure
metrics) minimum, maximum, and mean provisioning intervals for Qwest
provisioning ofUNE loops for each month since July 1 2001 , reported on a CLLI
code basis.
For each CLLI code, and on a statewide basis in Idaho, please provide the number of
UNE-P orders that were fulfilled each month since July 1 2001 in Idaho.
With regard to your response to MCI-, please provide on a CLLI code-specific basis
the number oftrouble reports within the first five days after the hot cut.
With regard to your response to MCI-, please specify the percentage of hot cuts that
were performed within the agreed-upon time frame (e.
g.,
as of the deadline set
pursuant to an interconnection agreement or otherwise agreed to with the other
carrier or pursuant to other state requirements). Please report this information on
the same daily, weekly and monthly basis as in MCI-
With regard to your response to MCI-, please state whether the existing customer loop
was re-used for each of the migrations identified. If the loop was not re-used
please provide a detailed explanation of the 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 remote
terminal/FDI/customer NID, etc.
With respect to the hot cuts identified in response to MCI-, please provide a detailed
description of each work effort your personnel had to perform, the costs you
incurred, and the maximum number of hot cuts that you have accomplished per day
per CLLI code since July 1 , 2001.
For each CLLI in Idaho, provide the maximum number of hot cuts that can be
performed per day, week and month with current workforce levels for (a) loops
carrying voice only; and (b) loops carrying voice plus DSL. State the basis for the
maximum number (e., methods and procedures, union work rules, informal
guidelines, Qwest policy, etc.
State and describe in detail any plans to increase workforce levels in the next 12
months for job classifications that perform hot cuts, state whether such plans have
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received budgetary approval and funding, and provide a copy of the approved and
funded budget and related documentation.
Please state whether you agree that a proper hot cut process requires Qwest to re-use
the existing loop for the following migration types: a) UNE-P to UNE DS-O/voice
grade loops; b) line sharing over UNE-P when the DSL service is removed; c) line
sharing over UNE-P migrated to line split UNE loop. If you agree, do you always
perform hot cuts for the listed migration types in this manner? If not, why not? If
you disagree, please state concisely your reasons for disagreement.
On a Idaho-statewide basis and for each CLLI code, please identify all service
disruptions of the type referenced in paragraphs 421 , 422 and 459 of the Triennial
Review Order that have occurred each month since July 1 2001 during your hot cut
process, and provide a detailed explanation of the cause of the service disruption.
As part of your response, please quantify the subset of service disruptions where
customers were unable to place or receive calls and/or data for a period of greater
than five minutes.
On a Idaho-statewide basis and for each CLLI code, reported monthly for each month
since July 1 , 2001 , please provide a detailed description of UNE loop orders
cancelled prior to customer migration. Your response should include the number
and percentage of such order cancellations compared to the total number of UNE
loop orders; a detailed description of the number and percentage of trouble reports
during the hot cut process; and a detailed description of the reason the customer
cancelled the order prior to migration.
On a Idaho-statewide basis and for each CLLI code, reported monthly for each month
since July 1 2001 , please provide the percentage of hot cuts that were successfully
completed and tested consistent with the time intervals specified in Qwest's
Methods and Procedures or other guidelines or work rules.
Please provide the name(s) of the work group(s) whose members routinely perform
cross connects/jumper jobs in Qwest central offices, and provide the following
information for each:
(a) a list and description of every job classification (e.g. frame technician) within
such work group(s);
(b) whether each job classification is staffed by members of a union, and whether
non-union employees may perform the same job function;
(c) for each job classification, the minimum job requirements, including training,
job experience, education, etc;
(d) a description of all on-the-job training required or provided for each job
classification once in the position;
(e) a copy of the methods and procedures or similar documents that contain any
kind of instructions specifying the steps, processes, techniques, tasks , materials
etc. for performing cross connects/jumper jobs.
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Please 1) state whether Qwest s methods, procedures, scheduling, and/or completion
intervals are different in any way, 2) provide a detailed explanation of all such
differences, and 3) provide all Methods and Procedures and other documents that
describe the work effort required for the following types of cross connects/jumper
jobs:
(a) new retail service installation to a premises with no previous telephone service;
(b) adding a second line to a premises with existing service;
(c) performing a line and station transfer ("LST") that involves cross
connects/jumper jobs at the MDF on a loop with live traffic;
(d) changing loops with live traffic from one type of retail service to another (e.
POTS to ISDN);
(e) changing loops with live traffic from one type of provider to another (e.
UNE-P to UNE loop; one CLEC UNE loop to another CLEC UNE loop)
(f) changing loops with live traffic from one service on a loop to two services on a
loop (e., line shared DSL and voice; line split DSL and voice);
(g) any other type of cross connect/jumper job in the Qwest central office not
covered by (a) through (f) above.
For each type of cross connect/jumper job identified in response to MCI-, please
identify each step or task in the process (e., obtain work order for frame wiring,
review work order, travel to central office (if required), travel to remote
terminal/FDI/customer premises serving terminal (if required), locate binder posts
for service to be installed, locate binder posts for service to be removed (if any),
remove oldjumper(s), install new jumper(s), test for dial tone/connectivity,
troubleshoot lack of dial tone/connectivity, enter job completion in work force
administration system and/or other record(s), etc.
On a Idaho-statewide basis and for each CLLI code, for each type of cross
connect/jumper job identified in response to MCI-, please identify the minimum
maximum and average actual work time(s) for 1) the total work effort and 2) each
step or task in the work effort identified in response to MCI-, reported monthly
for each month since July 1 , 2001.
On a Idaho-statewide basis and for each CLLI code, for each type of cross
connect/jumper job identified in response to MCI-, please identify the minimum
maximum and average work time(s) for 1) the total work effort and 2) each step or
task in the work effort identified in response to MCI -, specified in: a) Qwest
union contracts covering workers who routinely perform cross connect/jumper jobs
in the Qwest central offices; b) Qwest methods and procedures, guidelines, rules
regulations, specifications or any other written directive; c) employee performance
evaluation criteria.
On a Idaho-statewide basis and for each CLLI code, for each type of cross
connect/jumper job identified in response to MCI-, and for cross connect/jumper
jobs in general, please identify the minimum, maximum and average number of
such jobs that must be performed by each individual employee or worker during the
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time interval specified in Qwest employee performance requirements and/or union
contracts (i., the number of cross connect/jumper jobs that must be performed per
hour, day, shift, or other time interval).
Please state whether cross connect/jumper job performance has ever been the subject of
litigation, arbitration, mediation, labor negotiations, formal labor disputes, informal
labor disputes, or evaluation by any third party (e.g. federal or state agencies, etc.
If the answer is anything other than an unqualified no, please provide supporting
details and documentation.
Please describe how you prioritize cross connects/jumper jobs during normal working
conditions (e., first come first served, by service type, etc.) and state whether
those priorities change during strikes and other labor related work disruptions.
the priorities change, please provide a detailed description of the manner in which
they change.
Please provide all time and motion studies, special studies, or other evaluations of cross
connect/jumper job work times and processes.
Please provide the studies, analyses, and/or calculations of cross connect/jumper job
work times and loaded labor costs from the most recent non-recurring cost study
submitted by Qwest to Idaho Public Utilities Commission.
For each central office in Idaho, for each month since July 1 2001 , please state:
(a) whether the central office was staffed with one or more resident frame
technician(s) (or other job classification(s) that routinely perform cross
connect/jumper jobs);
(b) for each central office that was so staffed, the hours during which it was staffed;
(c) for each central office that was so staffed, the number of person hours per day
or per week devoted to cross connect/jumper jobs;
(d) for each central office that was not staffed, the number of person hours per day
or per week devoted to cross connect/jumper jobs.
Please provide a list, detailed description, method of sampling, method of calculation
and monetary penalty for all UNE performance measures or metrics applicable in
Idaho. State which of these measurements or metrics you assert is relevant to the
issues in this proceeding.
Please provide all UNE performance measure or metric reports applicable in Idaho
including a report of any penalties paid, for each month since July 1 , 2001.
Please provide all third party evaluations and/or reports addressing and/or assessing
Qwest performance under the UNE performance measures or metrics applicable in
Idaho.
MCI's DISCOVERY REQUESTS TO QWEST-
MCI-
MCI-
MCI-
MCI-
MCI-
MCI-
MCI-
Please list, define and describe each type of migration of service from one carrier to
another in Idaho for which you have current methods and procedures (e., hot cut
coordinated hot Gut bulk hot cut, frame due time, project managed cutover, loop
conversion, line and station transfer, etc.), and provide a copy of the business rules
and methods and procedures for each such migration type.
For each type of service migration in Idaho listed in your response to MCI-, please:
(a) provide the current total non-recurring charge(s);
(b) separately state the service ordering chargee s), the provisioning (cross
connect/jumper job) charge(s), and any other charge(s);
(c) list and describe any current volume discounts applicable to non-recurring
charges;
(d) list any changes in non-recurring charges and/or volume discounts planned or
expected in the next 12 months.
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 of the Triennial
Review Order and provide the basis for your belief and all documentation that
supports your belief.
Please provide a detailed description of the current QWEST OSS capabilities to
support automated, flow-through processes for Pre-ordering for DS-voice-grade
UNE loops on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC
and c) hybrid fiber-copper facilities using UDLC or NGDLC. Please provide a
copy of all documents describing these processes, including but not limited to
Te1cordia documents, Qwest Methods and Procedures, Workgroup User Manuals
Guidelines, Bulletins, etc.
Please provide a detailed description of the current QWEST OSS capabilities to
support automated, flow-through processes for Ordering for DS-voice-grade
UNE loops on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC
and c) hybrid fiber-copper facilities using UDLC or NGDLC. Please provide a
copy of all documents describing these processes, including but not limited to
T elcordia documents, Qwest Methods and Procedures, Workgroup User Manuals
Guidelines, Bulletins, etc.
Please provide a detailed description of the current QWEST OSS capabilities to
support automated, flow-through processes for Provisioning for DS-voice-grade
UNE loops on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC
and c) hybrid fiber-copper facilities using UDLC or NGDLC. Please provide a
copy of all documents describing these processes, including but not limited to
Telcordia documents, Qwest Methods and Procedures, Workgroup User Manuals
Guidelines, Bulletins, etc.
Please provide a detailed description of the current QWEST OSS capabilities to
support automated, flow-through processes for Maintenance/Repair for DS-
MCl's DISCOVERY REQUESTS TO QWEST-
MCI-
MCI-
MCI-
MCI-
MCI-
voice-grade UNE loops on a) all-copper facilities; b) hybrid fiber-copper facilities
using IDLC and c) hybrid fiber-copper facilities using UDLC or NGDLC. Please
provide a copy of all documents describing these processes, including but not
limited to Telcordia documents, Qwest Methods and Procedures, Workgroup User
Manuals, Guidelines, Bulletins, etc.
Please provide a detailed description of the current QWEST OSS capabilities to
support automated, flow-through processes for Billing for DS-voice-grade UNE
loops on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC and c)
hybrid fiber-copper facilities using UDLC or NGDLC. Please provide a copy of all
documents describing these processes, including but not limited to Telcordia
documents, Qwest Methods and Procedures, Workgroup User Manuals, Guidelines
Bulletins, etc.
Please provide a detailed description of the current QWEST OSS capabilities to
support automated, flow-through processes for Pre-ordering for DSL-capable UNE
loops on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC and c)
hybrid fiber-copper facilities using UDLC or NGDLc. Please provide a copy of all
documents describing these processes, including but not limited to Telcordia
documents, Qwest Methods and Procedures , Workgroup User Manuals, Guidelines
Bulletins, etc.
Please provide a detailed description of the current QWEST OSS capabilities to
support automated, flow-through processes for Ordering for DSL-capable UNE
loops on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC and c)
hybrid fiber-copper facilities using UDLC or NGDLC. Please provide a copy of all
documents describing these processes, including but not limited to Telcordia
documents, Qwest Methods and Procedures, Workgroup User Manuals, Guidelines
Bulletins, etc.
Please provide a detailed description of the current QWEST OSS capabilities to
support automated, flow-through processes for Provisioning for DSL-capable UNE
loops on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC and c)
hybrid fiber-copper facilities using UDLC or NGDLC. Please provide a copy of all
documents describing these processes, including but not limited to Telcordia
documents, Qwest Methods and Procedures, Workgroup User Manuals, Guidelines
Bulletins, etc.
Please provide a detailed description of the current QWEST OSS capabilities to
support automated, flow-through processes for Maintenance/Repair for DSL-
capable UNE loops on a) all-copper facilities; b) hybrid fiber-copper facilities using
IDLC and c) hybrid fiber-copper facilities using UDLC or NGDLC. Please provide
a copy of all documents describing these processes, including but not limited to
Telcordia documents, Qwest Methods and Procedures, Workgroup User Manuals
Guidelines, Bulletins, etc.
MCI's DISCOVERY REQUESTS TO QWEST -
MCI-
MCI-
MCI-
MCI-
MCI-
MCI-
Please provide a detailed description of the current QWEST OSS capabilities to
support automated, flow-through processes for Billing for DSL-capable UNE loops
on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC and c)
hybrid fiber-copper facilities using UDLC or NGDLC. Please provide a copy of all
documents describing these processes, including but not limited to Telcordia
documents, Qwest Methods and Procedures , Workgroup User Manuals , Guidelines
Bulletins, etc.
Please provide a detailed description of the current QWEST OSS capabilities to
support automated, flow-through processes for Pre-ordering for UNE loops capable
of supporting line splitting (i. e. voice service and DSL service carried on a single
wire pair entering the customer s premises) on a) all-copper facilities; b) hybrid
fiber-copper facilities using IDLC and c) hybrid fiber-copper facilities using UDLC
or NGDLC. Please provide a copy of all documents describing these processes
including but not limited to Telcordia documents, Qwest Methods and Procedures
Workgroup User Manuals, Guidelines, Bulletins, etc.
Please provide a detailed description of the current QWEST OSS capabilities to
support automated, flow-through processes for Ordering for UNE loops capable of
supporting line splitting (i. e. voice service and DSL service carried on a single wire
pair entering the customer s premises) on a) all-copper facilities; b) hybrid fiber-
copper facilities using IDLC and c) hybrid fiber-copper facilities using UDLC or
NGDLC. Please provide a copy of all documents describing these processes
including but not limited to Telcordia documents, Qwest Methods and Procedures
Workgroup User Manuals, Guidelines, Bulletins, etc.
Please provide a detailed description of the current QWEST OSS capabilities to
support automated, flow-through processes for Provisioning for UNE loops capable
of supporting line splitting (i. e. voice service and DSL service carried on a single
wire pair entering the customer s premises) on a) all-copper facilities; b) hybrid
fiber-copper facilities using IDLC and c) hybrid fiber-copper facilities using UDLC
or NGDLC. Please provide a copy of all documents describing these processes
including but not limited to Telcordia documents, Qwest Methods and Procedures
Workgroup User Manuals, Guidelines, Bulletins, etc.
Please provide a detailed description of the current QWEST OSS capabilities to
support automated, flow-through processes for MaintenancelRepair for UNE loops
capable of supporting line splitting (i. e. voice service and DSL service carried on a
single wire pair entering the customer s premises) on a) all-copper facilities; b)
hybrid fiber-copper facilities using IDLC and c) hybrid fiber-copper facilities using
UDLC or NGDLc. Please provide a copy of all documents describing these
processes, including but not limited to Telcordia documents, Qwest Methods and
Procedures, Workgroup User Manuals, Guidelines, Bulletins, etc.
Please provide a detailed description of the current QWEST OSS capabilities to
support automated, flow-through processes for Billing for UNE loops capable of
MCI'S DISCOVERY REQUESTS TO QWEST -
MCI-
MCI-
MCI-
MCI-
MCI-
MCI-
supporting line splitting (i. e. voice service and DSL service carried on a single wire
pair entering the customer s premises) on a) all-copper facilities; b) hybrid fiber-
copper facilities using IDLC and c) hybrid fiber-copper facilities using UDLC or
NGDLC. Please provide a copy of all documents describing these processes
including but not limited to Telcordia documents, Qwest Methods and Procedures
Workgroup User Manuals, Guidelines, Bulletins, etc.
To the extent that Qwest's responses to MCI-36 to MCI-50 assert that Qwest has in
place OSS capabilities to support automated, flow-through processes, please
provide for each response to Data Request MCI-36 to MCI-, the statewide
volumes that have been supported on an automated flow-through basis for each
month since July 1 , 2001.
To the extent that Qwest s responses to MCI-36 to MCI-50 assert that Qwest has in
place ass capabilities to support automated, flow-through processes, please
provide for each Data Request MCI-36 to MCI-50 the monthly fall-out rates (i.
percentage of transactions that were designed to flow through but did not) since
July 1 , 2001.
To the extent that Qwest s responses to MCI-36 to MCI-50 assert that Qwest has in
place OSS capabilities to support automated, flow-through processes, please
provide for each response to Data Request MCI-36 to MCI-50 the maximum daily,
weekly and monthly volumes that can currently be supported.
To the extent that Qwest s responses to MCI-36 to MCI-50 state that Qwest does not
have in place OSS capabilities to support automated, flow-through processes
please provide for each response to Data Request MCI-36 to MCI-50 a detailed
estimate of the costs, work effort and timeframes associated with any ass
modification or upgrade necessary to convert Qwest's manual and/or semi-
mechanized process to an automated, flow-through process for each of the OSS
functions and each of the service types in MCI-36 to MCI-50. Please provide a
copy of all documents describing these modifications or upgrades, including but
not limited to documents sent to or received from Telcordia, Qwest Methods and
Procedures, Workgroup User Manuals, Guidelines, Bulletins, etc.
To the extent that Qwest's responses to MCI-36 to MCI-50 state that Qwest does not
have in place OSS capabilities to support automated, flow-through processes
please provide a detailed description of the current manual and/or semi-mechanized
QWEST OSS processes for each of the OSS functions and each of the service types
in MCI-36 to MCI-50. Please provide a copy of all documents describing these
processes, including but not limited to documents sent to or received from
Telcordia, Qwest Methods and Procedures, Workgroup User Manuals, Guidelines
Bulletins, etc.
Please provide a detailed description of the planned QWEST OSS capabilities to
support automated, flow-through processes for Pre-ordering for DS-O/voice-grade
MCI's DISCOVERY REQUESTS TO QWEST-
MCI-
MCI-
MCI-
MCI-
MCI-
UNE loops on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC
and c) hybrid fiber-copper facilities using UDLC or NGDLC. Please provide a
copy of all documents describing these processes, including but not limited to
documents sent to or received from Telcordia, Qwest Methods and Procedures
Workgroup User Manuals, Guidelines, Bulletins, etc.
Please provide a detailed description of the planned QWEST OSS capabilities to
support automated, flow-through processes for Ordering for DS-O/voice-grade
UNE loops on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC
and c) hybrid fiber-copper facilities using UDLC or NGDLc. Please provide a
copy of all documents describing these processes, including but not limited to
documents sent to or received from Telcordia, Qwest Methods and Procedures
Workgroup User Manuals, Guidelines, Bulletins, etc.
Please provide a detailed description of the planned QWEST OSS capabilities to
support automated, flow-through processes for Provisioning for DS-O/voice-grade
UNE loops on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC
and c) hybrid fiber-copper facilities using UDLC or NGDLC. Please provide a
copy of all documents describing these processes, including but not limited to
documents sent to or received from Telcordia, Qwest Methods and Procedures
Workgroup User Manuals, Guidelines, Bulletins, etc.
Please provide a detailed description of the planned QWEST OSS capabilities to
support automated, flow-through processes for Maintenance/Repair for DS-
O/voice-grade UNE loops on a) all-copper facilities; b) hybrid fiber-copper facilities
using IDLC and c) hybrid fiber-copper facilities using UDLC or NGDLC. Please
provide a copy of all documents describing these processes, including but not
limited to documents sent to or received from Telcordia, Qwest Methods and
Procedures, Workgroup User Manuals, Guidelines, Bulletins, etc.
Please provide a detailed description of the planned QWEST OSS capabilities to
support automated, flow-through processes for Billing for DS-O/voice-grade UNE
loops on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC and c)
hybrid fiber-copper facilities using UDLC or NGDLC. Please provide a copy of all
documents describing these processes, including but not limited to documents sent
to or received from Telcordia, Qwest Methods and Procedures, Workgroup User
Manuals, Guidelines, Bulletins, etc.
Please provide a detailed description of the planned QWEST OSS capabilities to
support automated, flow-through processes for Pre-ordering for DSL-capable UNE
loops on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC and c)
hybrid fiber-copper facilities using UDLC or NGDLC. Please provide a copy of all
documents describing these processes, including but not limited to documents sent
to or received from Telcordia, Qwest Methods and Procedures, Workgroup User
Manuals, Guidelines, Bulletins, etc.
MCI's DISCOVERY REQUESTS TO QWEST -
MCI-
MCI-
MCI-
MCI-
MCI-
MCI-
Please provide a detailed description of the planned QWEST ass capabilities to
support automated, flow-through processes for Ordering for DSL-capable UNE
loops on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC and c)
hybrid fiber-copper facilities using UDLC or NGDLC. Please provide a copy of all
documents describing these processes, including but not limited to documents sent
to or received from Telcordia, Qwest Methods and Procedures, Workgroup User
Manuals, Guidelines, Bulletins, etc.
Please provide a detailed description of the planned QWEST ass capabilities to
support automated, flow-through processes for Provisioning for DSL-capable UNE
loops on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC and c)
hybrid fiber-copper facilities using UDLC or NGDLC. Please provide a copy of all
documents describing these processes , including but not limited to documents sent
to or received from Telcordia, Qwest Methods and Procedures, Workgroup User
Manuals, Guidelines, Bulletins, etc.
Please provide a detailed description of the planned QWEST OSS capabilities to
support automated, flow-through processes for Maintenance/Repair for DSL-
capable UNE loops on a) all-copper facilities; b) hybrid fiber-copper facilities using
IDLC and c) hybrid fiber-copper facilities using UDLC or NGDLC. Please provide
a copy of all documents describing these processes, including but not limited to
documents sent to or received from Telcordia, Qwest Methods and Procedures
Workgroup User Manuals, Guidelines, Bulletins, etc.
Please provide a detailed description ofthe planned QWEST OSS capabilities to
support automated, flow-through processes for Billing for DSL-capable UNE loops
on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC and c)
hybrid fiber-copper facilities using UDLC or NGDLC. Please provide a copy of all
documents describing these processes, including but not limited to documents sent
to or received from Telcordia, Qwest Methods and Procedures, Workgroup User
Manuals, Guidelines, Bulletins, etc.
Please provide a detailed description of the planned QWEST OSS capabilities to
support automated, flow-through processes for Pre-ordering for UNE loops capable
of supporting line splitting (i.e. voice service and DSL service carried on a single
wire pair entering the customer s premises) on a) all-copper facilities; b) hybrid
fiber-copper facilities using IDLC and c) hybrid fiber-copper facilities using UDLC
or NGDLC. Please provide a copy of all documents describing these processes
including but not limited to documents sent to or received from Telcordia, Qwest
Methods and Procedures , Workgroup User Manuals, Guidelines, Bulletins, etc.
Please provide a detailed description of the planned QWEST ass capabilities to
support automated, flow-through processes for Ordering for UNE loops capable of
supporting line splitting (i. e. voice service and DSL service carried on a single wire
pair entering the customer s premises) on a) all-copper facilities; b) hybrid fiber-
copper facilities using IDLC and c) hybrid fiber-copper facilities using UDLC or
MCI's DISCOVERY REQUESTS TO QWEST -
MCI-
MCI-
MCI-
MCI-
MCI-
NGDLC. Please provide a copy of all documents describing these processes
including but not limited to documents sent to or received from Telcordia, Qwest
Methods and Procedures, Workgroup User Manuals, Guidelines, Bulletins, etc.
Please provide a detailed description of the planned QWEST ass capabilities to
support automated, flow-through processes for Provisioning for UNE loops capable
of supporting line splitting (i. e. voice service and DSL service carried on a single
wire pair entering the customer s premises) on a) all-copper facilities; b) hybrid
fiber-copper facilities using IDLC and c) hybrid fiber-copper facilities using UDLC
or NGDLC. Please provide a copy of all documents describing these processes
including but not limited to documents sent to or received from Telcordia, Qwest
Methods and Procedures, Workgroup User Manuals, Guidelines, Bulletins, etc.
Please provide a detailed description of the planned QWEST ass capabilities to
support automated, flow-through processes for Maintenance/Repair for UNE loops
capable of supporting line splitting (i. e. voice service and DSL service carried on a
single wire pair entering the customer s premises) on a) all-copper facilities; b)
hybrid fiber-copper facilities using IDLC and c) hybrid fiber-copper facilities using
UDLC or NGDLC. Please provide a copy of all documents describing these
processes, including but not limited to documents sent to or received from
Telcordia, Qwest Methods and Procedures, Workgroup User Manuals, Guidelines
Bulletins, etc.
Please provide a detailed description of the planned QWEST OSS capabilities to
support automated, flow-through processes for Billing for UNE loops capable of
supporting line splitting (i. e. voice service and DSL service carried on a single wire
pair entering the customer s premises) on a) all-copper facilities; b) hybrid fiber-
copper facilities using IDLC and c) hybrid fiber-copper facilities using UDLC or
NGDLC. Please provide a copy of all documents describing these processes
including but not limited to documents sent to or received from Telcordia, Qwest
Methods and Procedures, Workgroup User Manuals, Guidelines, Bulletins, etc.
To the extent that Qwest's responses to MCI-56 to MCI-70 assert that Qwest plans to
deploy OSS capabilities to support automated, flow-through processes, please
provide for each Data Request MCI-56 to MCI-70 the maximum daily, weekly and
monthly volumes that could be supported.
Please provide a detailed description of current and planned Qwest OSS capabilities to
support automated, flow-through single-order migration between each of the
following service configurations: 1) Qwest voice only 2) Qwest voice plus data; 3)
Qwest data only; 4) CLEC UNE-P voice only; 5) CLEC switch-based voice only;
6) CLEC line sharing; 7) CLEC line splitting; 8) CLEC data only (e., Qwest
voice only to CLEC UNE-P voice only; CLEC A switch-based voice only to CLEC
B switch-based voice only).
MCI's DISCOVERY REQUESTS TO QWEST -
MCI-
MCI-
MCI-
MCI-
MCI-
MCI-
MCI-
MCI -
Please provide a detailed description of current and planned Qwest OSS capabilities to
support automated, flow-through single-order migration from 1) Qwest to CLEC;
2) CLEC to CLEC and 3) CLEC to Qwest, for each of the following: a) adding or
dropping local exchange voice service from line shared or line split DSL; b) adding
or dropping DSL service from line shared or line split local exchange voice service.
Please state whether Qwest provides CLECs with real-time, read-only access to all data
in all Qwest OSS (including what some QWEST'S have called back-office
systems) related to loop and transport facilities.
To the extent that the response to MCI-74 indicates that CLECs have real time, read-
only access to the described data, please provide a detailed description of the
manner in which CLECs may access and use all data in Qwest OSS related to loop
and transport facilities on a real-time, read-only basis.
Please provide a list of all ass used by Qwest for pre-ordering, ordering, provisioning,
maintenance and repair and billing for Qwest retail services, including all of the
following: 1) full name of system; 2) acronym for system (if any); 3) detailed
description of capabilities and function of system; 4) whether system was
developed and is maintained by Qwest or by third party (and name of third party).
Please provide a list of all OSS used by Qwest for pre-ordering, ordering, provisioning,
maintenance and repair and billing for services offered by a Qwest subsidiary or
affiliate, including all of the following: 1) full name of system; 2) acronym for
system (if any); 3) detailed description of capabilities and function of system; 4)
whether system was developed and is maintained by Qwest or by third party (and
name of third party).
Please provide a list of all ass used by Qwest for pre-ordering, ordering, provisioning,
maintenance and repair and billing for CLEC UNE-including all of the following:
1) full name of system; 2) acronym for system (if any); 3) detailed description of
capabilities and function of system; 4) whether system was developed and is
maintained by Qwest or by third party (and name of third party).
Please provide a list of all OSS used by Qwest for pre-ordering, ordering, provisioning,
maintenance and repair and billing for UNE loop and transport facilities, including
all of the following: 1) full name of system; 2) acronym for system (if any); 3)
detailed description of capabilities and function of system; 4) whether system was
developed and is maintained by Qwest or by third party (and name of third party).
Please provide a schematic drawing showing the interrelationships between all OSS
used by Qwest for pre-ordering, ordering, provisioning, maintenance and repair and
billing for Qwest retail services, including but not limited to the following: 1) full
name of system; 2) acronym for system (if any).
MCI's DISCOVERY REQUESTS TO QWEST -
MCI-
MCI-
MCI-
MCI-
MCI-
MCI-
MCI -
MCI-
MCI-
Please provide a schematic drawing showing the interrelationships between all ass
used by Qwest for pre-ordering, ordering, provisioning, maintenance and repair and
billing for services offered by a Qwest subsidiary or affiliate, including but not
limited to the following: 1) full name of system; 2) acronym for system (if any).
Please provide a schematic drawing showing the interrelationships between all OSS
used by Qwest for pre-ordering, ordering, provisioning, maintenance and repair and
billing for CLEC UNE-including but not limited to the following: 1) full name of
system; 2) acronym for system (if any).
Please provide a schematic drawing showing the interrelationships between all OSS
used by Qwest for pre-ordering, ordering, provisioning, maintenance and repair and
billing for UNE loop and transport facilities, including but not limited to the
following: 1) full name of system; 2) acronym for system (if any).
Please provide a detailed process flow chart for all OSS used by Qwest for pre-
ordering, ordering, provisioning, maintenance and repair and billing for Qwest
retail services, including but not limited to the following: 1) full name of system; 2)
acronym for system (if any).
Please provide a detailed process flow chart for all OSS used by Qwest for pre-
ordering, ordering, provisioning, maintenance and repair and billing for services
offered by a Qwest subsidiary or affiliate, including but not limited to the
following: 1) full name of system; 2) acronym for system (if any).
Please provide a detailed process flow chart for all OSS used by Qwest for pre-
ordering, ordering, provisioning, maintenance and repair and billing for CLEC
UNE-including but not limited to the following: 1) full name of system; 2)
acronym for system (if any).
Please provide a detailed process flow chart for all ass used by Qwest for pre-
ordering, ordering, provisioning, maintenance and repair and billing for UNE loop
and transport facilities, including but not limited to the following: 1) full name of
system; 2) acronym for system (if any).
Please provide a complete set of the current business rules for all OSS used by Qwest
for pre-ordering, ordering, provisioning, maintenance and repair and billing for
Qwest retail services, including but not limited to the following: 1) full name of
system; 2) acronym for system (if any).
Please provide a complete set of the current business rules for all OSS used by Qwest
for pre-ordering, ordering, provisioning, maintenance and repair and billing for
services offered by a Qwest subsidiary or affiliate, including but not limited to the
following: 1) full name of system; 2) acronym for system (if any).
MCI's DISCOVERY REQUESTS TO QWEST -
MCI-
MCI-
MCI-
MCI-
MCI-
MCI-
MCI-
Please provide a complete set of the current business rules for all OSS used by Qwest
for pre-ordering, ordering, provisioning, maintenance and repair and billing for
CLEC UNE-including but not limited to the following: 1) full name of system; 2)
acronym for system (if any).
Please provide a complete set of the current business rules for all OSS used by Qwest
for pre-ordering, ordering, provisioning, maintenance and repair and billing for
UNE loop and transport facilities, including but not limited to the following: 1) full
name of system; 2) acronym for system (if any).
Please provide a detailed description of any current Qwest processes that you claim
will support batch cuts (as defined in Rule 51.319(d)(2)(ii)) 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).
With regard to your response to MCI-, please indicate whether your electronic back
end 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;
(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 detailed description of any current Qwest processes to support
individual loop hot cuts between each of the following service configurations: 1)
Qwest voice only 2) Qwest voice plus DSL; 3) Qwest DSL only; 4) CLEC UNE-
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 copy of all documents or information describing or discussing such
processes.
Please provide a detailed description of any planned Qwest processes to support batch
cuts 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 copy of all
documents or information describing or discussing such processes.
Please provide a detailed description of any planned Qwest processes to support
individual customer hot cuts between each of the following service configurations:
MCI's DISCOVERY REQUESTS TO QWEST -
MCI-
MCI-
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 copy of all documents or information describing or discussing
such processes.
QWEST MASS MARKET UNE SWITCHING TRIGGER ISSUES
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 and model;
( e) currently loaded version of switch software;
(f) currently equipped line side capacity in (1) DS-O/voice grade circuits and (2)
DS-1 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;
U) 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));
(k) the initial cost of the switch, including equipment, software, and EF &1
engineered, furnished and installed") costs;
(1) number of (1) DS-O/voice grade circuits and (2) DS-l circuits equipped at the
time of installation;
(m)any central offices or wire centers 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 response to MCI-97 above, please provide the information
requested in TABLE 1:
MCI's DISCOVERY REQUESTS TO QWEST -
TABLE
Qwest Number Number of Type of Number of Number of Number of
Switch Of Loops Local End-User Voice Only DSL Only Line
CLLI Per End-Service Customer End User End User SharedN oice
User End-User Customers Plus DSLCustomers
Customer Customers End User
Premises 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-
MCI-For each switch you own or control and from which you offer or provide wholesale
local switching capacity via UNE-P to carriers that are not affiliated with you
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 and model;
(e) current 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 processor capacity in CCS;
G) percentage of line side or processor capacity reserved for your own current or
future use;
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 QWEST voice plus DSL).
MCl's DISCOVERY REQUESTS TO QWEST -
(k) 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;
(1) the expected useful service life of each switch;
(m)whether your company intends to utilize the switch for the full expected useful
service life;
(n) 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);
(0) any wire center subtending areas currently served by your switch for which you
are considering discontinuing wholesale local switching for any reason within
the next 12 months.
MCI-I00 For each switch identified in response to MCI-99 above, please provide the
information requested in TABLE 2:
TABLE 2
Qwest Number Number of Type of Number of Number of
Switch Of Loops Local End-User Voice Only Line Split
CLLI Per End-Service Customer End User End User
User End-User Customers Customers
Customer Customers
Premises
ABC g. 10 155 Residential g. 10 000 g. 100
g. 5 300 Business g. 5 000 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-
MCI-101 Please provide the following information regarding (1) the Class 5 (end office) circuit
switch most recently installed in Idaho by Qwest, and (2) any planned new
This category includes loops used for fax and/or modem-only traffic.
This category includes UNE-P voice and CLEC DSL on the same wire pair.
MCI's DISCOVERY REQUESTS TO QWEST -
MCI-I02
MCI-I03
installations of a Class 5 (end office) circuit switch in Idaho by Qwest: a)
manufacturer, b) model, c) date to be placed in service, d) location (street address
city, and zip code), e )CLLI code and f) V &H coordinates.
For each switch identified in your response to MCI-97 above other than circuit
switches, please provide the following:
(a) any differences in quality of service compared to local exchange service
provided on circuit switches (i., reliability, throughput, ubiquity, outages
mean time to repair, etc.
a. 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 (i., specialized phone set; availability of computer
cable modem, set top box), access method (i., DSL, cable television, satellite
service), provisioning interval;
(e) any central offices or wire centers currently served by your switch for which
you are considering discontinuing service for any reason within the next 12
months.
Please identify all switches, other than circuit switches, currently in use by cable
operators to provide local exchange voice service in Idaho or regionwide (Qwest 14
states (AZ, CO, ID, lA, MN, MT, NE, ND, NM, OR, SD, UT, WA, WY)))) if
Qwest is unable to provide Idaho-specific data, or at any geographic level, if Qwest
cannot provide either Idaho-specific or regionwide data, stated separately for
residential and business customers, and provide the following information:
(a) the identity of the cable operator;
(b) the number of units passed (reported separately by residential and business units)
by the portion of the cable operator s network capable of supporting local exchange
VOice service;
(c) the number of residential units passed by the cable operator s network that are
subscribing to cable (video) services;
(d) the number of residential units passed by the cable operator s network that are
subscribing to broadband data services;
(e) the number of residential units subscribing to cable (video) services that also obtain
local exchange voice service from the cable operator;
(f) the date on which the cable operator first began providing local exchange voice
service;
(g) the price of local exchange voice service provided by the cable operator;
(h) service quality of local exchange service provided by CMRS operators compared
to local exchange service provided by Qwest (e., service outages, dropped calls;
E911 , etc.
(i) maps of the cable operator s serving territories with locations of QWEST central
offices or wire centers identified;
MCI'S DISCOVERY REQUESTS TO QWEST -
MCI-I04
MCI-105
U) any business cases, analysis, or projections for entry of cable companies into the
broadband data and/or local exchange voice markets (whether the information or
documents were prepared by you, on your behalf, or by a third party).
Please identify all switches, other than circuit switches, currently in use by CMRS
operators to provide local exchange voice service in Idaho or regionwide (Qwest 14
states (AZ, CO, ID, lA, MN, MT, NE, ND, NM, OR, SD, UT, W A, WY)) )) if
Qwest is unable to provide Idaho-specific data, or at any geographic level, if Qwest
cannot provide either Idaho-specific or regionwide data, stated separately for
residential and business customers, and provide the following information:
(a) the identity of the CMRS operator;
(b) the number of customers of the CMRS operator who are subscribing to local
exchange voice services;
(c) the number of customers of the CMRS operator who are subscribing to
broadband data services;
(d) the minimum, maximum and average throughput rate for the CMRS operator
broadband data services each month for the last 12 months;
(e) the date on which the CMRS operator first began providing local exchange
VOIce servIce;
(f) the price of local exchange voice service provided by the CMRS operator;
(g) the service quality of local exchange service provided by the CMRS operator
compared to local exchange service provided by Qwest (e., service outages
dropped calls. etc.
(h) a description of the entire service territory the CMRS operator can reach;
(i) the percentage of Qwest' s serving territory (by central office or wire center)
that the CMRS operator can reach;
U) the percentage of Qwest' s serving territory (by central office or wire center) to
which the CMRS operator is providing local exchange voice service;
(k) the percentage of Qwest' s serving territory (by central office or wire center) to
which the CMRS operator is providing broadband data service;
(1) any business cases, analysis, or projections for entry of CMRS operators into
the broadband data and/or local exchange voice markets (whether the
information or documents were prepared by you, on your behalf, or by a third
party).
For each CLEC or other carrier collocation arrangement in each Qwest wire center in
Idaho, please provide the following information, reported by CLLI code, street
address and zip code:
(a) name of CLEC or other carrier;
(b) type of collocation arrangement (e.g. caged, cageless, virtual, etc.
( c) size of collocation arrangement;
(d) amount of power (including both "A" and "B" DC feeds and AC power)
supplied to the collocation arrangement;
(e) number of2-wire cross connects currently provisioned from the MDF to the
collocation arrangement;
MCI's DISCOVERY REQUESTS TO QWEST -
MCI-106
MCI-107
MCI-I08
(f) number of 4-wire cross connects currently provisioned from the MDF to the
collocation arrangement;
(g) all equipment installed in the collocation arrangement, including make, model
and total installed capacity for each piece of equipment;
(h) type(s) of Qwest transport connected to the collocation arrangement (e.
special access, UNE transport, etc.
(i) capacity(ies) of Qwest transport connected to the collocation arrangement (e.
DS-, DS-, OC-, etc.), and number of circuits at each level of capacity.
For each Qwest wire center in Idaho, please identify the amount of available unused
collocation space, in terms oftotal square feet of space and type(s) of collocation
for which available space can be used. Please identify all wire centers that you
previously listed as out of space for collocation that now have space available.
Please provide a detailed explanation of what was done to free up space, and
identify for disclosure of all documents on which you relied for your response, or
that are relevant to this request.
With regard to all CLEC to CLEC cross connections you have provisioned, please
identify the following, reported by wire center:
(a) number of such cross connections that you have provisioned;
(b) the identity of both CLECs for 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.
QWEST central office technician, certified CLEC technician, etc.
For each Qwest central office or wire center at which loops and transport are connected
at collocation arrangements to form EELs in Idaho or regionwide (Qwest 14 states
(AZ, CO, ID, lA, MN, MT, NE, ND, NM, OR, SD, UT, WA, WY)) if Qwest is
unable to provide Idaho-specific data, please provide the following information:
(a) the CLLI code, street address, zip code, and V &H coordinates of the Qwest
central office or wire center where such EELs are created;
(b) the CLLI code, street address, zip code, V &H coordinates, and owner( s) of the
switch(es) to which such EELs are connected;
(c) number of such EELs that comprise DS-O/voice grade transport connected to
DS-O/voice grade loops;
(d) number of such EELs that comprise DS-l transport connected to multiplexed
DS-O/voice grade loops;
(e) number of such EELs that comprise DS-1 transport connected to multiplexed
and concentrated DS-O/voice grade loops, and the loop-to-transport
concentration ratio;
(f) number of such EELs that comprise DS-3 transport connected to multiplexed
DS-O/voice grade loops;
MCI's DISCOVERY REQUESTS TO QWEST -
MCI-109
MCI-IIO
(g) number of such EELs that comprise DS-3 transport connected to multiplexed
and concentrated DS-O/voice grade loops, and the loop-to-transport
concentration ratio;
(h) number of such EELs that comprise DS-l transport connected to DS-lloops;
(i) number of such EELs that comprise DS-3 transport connected to multiplexed
DS-1 loops;
G) number of such EELs that comprise DS-3 transport connected to multiplexed
and concentrated DS-l loops, and the loop-to-transport concentration ratio;
(k) what equipment is required to deploy EELs;
(1) whether collocation is required for CLECs to utilize EELs;
(m)the concentration ratio allowed for EELs.
For each Qwest central office or wire center at which loops and transport are connected
to form EELs without using collocation in Idaho or regionwide (Qwest 14 states
(AZ, CO , ID, lA, MN, MT, NE, ND, NM, OR, SD, UT, WA, WY)) if Qwest is
unable to provide Idaho-specific data, please provide the following information:
(a) the CLLI code, street address, zip code, and V &H coordinates of the Qwest
central office or wire center where such EELs are created;
(b) the CLLI code, street address , zip code, V &H coordinates, and owner( s) of the
switch(es) to which such EELs are connected;
(c) number of such EELs that comprise DS-O/voice grade transport connected to
DS-O/voice grade loops;
(d) number of such EELs that comprise DS-1 transport connected to multiplexed
DS-O/voice grade loops;
(e) number of such EELs that comprise DS-1 transport connected to multiplexed
and concentrated DS-O/voice grade loops, and the loop-to-transport
concentration ratio;
(f) number of such EELs that comprise DS-3 transport connected to multiplexed
DS-O/voice grade loops;
(g) number of such EELs that comprise DS-3 transport connected to multiplexed
and concentrated DS-O/voice grade loops, and the loop-to-transport
concentration ratio;
(h) number of such EELs that comprise DS-1 transport connected to DS-1 loops;
(i) number of such EELs that comprise DS-3 transport connected to multiplexed
DS-l loops;
G) number of such EELs that comprise DS-3 transport connected to multiplexed
and concentrated DS-l loops, and the loop-to-transport concentration ratio.
Please provide the definition you use internally for business purposes for the following
terms: (1) "mass market customer" and (2) "enterprise customer " in terms of type
of customer (e., residential vs. business), number of lines per customer, use of
analog loop facilities vs. DS-1 s, or any other basis you use to distinguish these
terms.
MCI-lll 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
MCl's DISCOVERY REQUESTS TO QWEST -
MCI-112
MCI-I13
MCI-114
MCI-115
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-l service rates, consideration of whether the customer premises
equipment can accept a DS-l interface , etc.
With respect to each of the two customer categories identified in response to MCI -110
please provide the following information:
(a) the number of customers in each category, reported by central office/wire center
for each month since July 1 , 2001;
(b) the percentage of your total customer base in Idaho in each of the two categories;
(c) whether you target your business plans or marketing to particular sub-sets of
customers within each of the two categories identified in response to MCI-l10.
Please identify, by CLLI code, city, street address and zip code, all switches you have
deployed in Idaho in density zone 1 of the top 50 largest Metropolitan Statistical
Areas (MSAs), and whether each of those switches is subject to the FCC'
unbundled switching "carve out."
Please state the technical characteristics and capabilities of all loops that you consider
to be a DS-O and/or voice grade loop, and provide any relevant public and/or
confidential technical publications and any other documents that describe these
characteristics and capabilities.
MCI -116 Please state the technical characteristics and capabilities of a DSL-capable loop, and
provide any relevant public and/or confidential technical publications and any other
documents that describe these characteristics and capabilities.
MCI-117
MCI-118
Please state the technical characteristics and capabilities of loops capable of supporting
1) line sharing and 2) line splitting (i.e. voice service and DSL service carried on a
single wire pair entering the customer s premises), and provide any relevant public
and/or confidential technical publications and any other documents that describe
these characteristics and capabilities.
Please provide, a) on a Idaho-statewide basis, and b) on a CLLI-code-specific basis
monthly data for each month since July 1 , 2001 on the number of loops carrying
DS-O/voice grade service on all of the following bases: 1) total loops in service 2)
residential loops in service; 3) business loops for business with 1-3 loops in service
to a single customer premises; 4) business loops for businesses with more than 3
loops in service to a single customer premises; 5) UNE loops.
MCI's DISCOVERY REQUESTS TO QWEST -
MCI-119
MCI-120
MCI-121
MCI-122
MCI-123
MCI-124
Please provide, a) on a Idaho-statewide basis, and b) on a CLLI-code-specific basis
monthly data for each month since July 1 , 2001 on the number of loops carrying
standalone DSL service on all of the following bases: 1) total loops in service 2)
residential loops in service; 3) business loops for business with 1-3 loops in service
to a single customer premises; 4) business loops for businesses with more than 3
loops in service to a single customer premises; 5) UNE loops.
Please provide, a) on a Idaho-statewide basis, and b) on a CLLI-code-specific basis
monthly data for each month since July 1 2001 on the number ofloops carrying
line shared Qwest voice plus CLEC DSL service on all of the following bases: 1)
total loops in service 2) residential loops in service; 3) business loops for business
with 1-3 loops in service to a single customer premises; 4) business loops for
businesses with more than 3 loops in service to a single customer premises; 5) UNE
loops.
Please provide, a) on a Idaho-statewide basis, and b) on a CLLI-code-specific basis
monthly data for each month since July 1 2001 on the number ofloops carrying
line split voice plus DSL service on all of the following bases: 1) total loops in
service 2) residential loops in service; 3) business loops for business with 1-3 loops
in service to a single customer premises; 4) business loops for businesses with more
than 3 loops in service to a single customer premises; 5) UNE loops.
Please provide, a) on a Idaho-statewide basis, and b) on a CLLI-code-specific basis
monthly data for each month since July 1 , 2001 on the number of loops carrying
Qwest voice plus Qwest/Qwest affiliate DSL service on all of the following bases:
1) total loops in service 2) residential loops in service; 3) business loops for
business with 1-3 loops in service to a single customer premises; 4) business loops
for businesses with more than 3 loops in service to a single customer premises.
Please provide, a) on a Idaho-statewide basis, and b) on a CLLI-code-specific basis
monthly data for each month since July 1 2001 on the number ofloops that are
provisioned using: 1) all-copper facilities; 2) hybrid fiber/copper facilities; 3) all-
fiber facilities; 4) IDLC; 5) UDLC; 6) NGDLC; 7) DAML.
Please state whether you currently provision in Idaho UNE loops over loops
provisioned using 1) IDLC and 2) NGDLC. Please provide a copy of any methods
and procedures, technical service descriptions, and other technical documents that
describe the service arrangement and/or identify the supported features, functions
and supported throughput rates.
MCI-125 Please provide, on a CLLI-code-specific basis for Idaho, detailed information
concerning copper feeder plant that 1) has been retired since January 1 , 2000 or 2)
Qwest plans to or is considering retiring in the next three years.
MCI's DISCOVERY REQUESTS TO QWEST -
MCI-126
MCI-127
MCI-128
Please provide, on a CLLI-code-specific basis, detailed information concerning
Qwest's plans for Idaho over the next three years to use copper feeder plant that has
been replaced with fiber-feeder plant, for reinforcement to meet growth needs on
shorter all-copper feeder routes.
Please provide a detailed description of Qwest' s current policy for Idaho regarding
maintenance of copper outside plant facilities once those facilities have been
retired. Please provide a copy of all documents, including Methods and
Procedures, guidelines, bulletins, business rules and/or business analysis on which
you relied, or that are relevant to this Request. Also please state whether Qwest is
considering revising this policy, and if so, when such revision is anticipated.
Please provide detailed information, including supporting and related documents
regarding Qwest's plans, incentives, justification, benefits and/or analysis of
upgrading its loop plant in Idaho by installing additional 1) hybrid copper/fiber
loops; 2) all-fiber loops.
MCI-129 Please provide , on a wire center basis , detailed information concerning dark fiber in the
loop plant that is currently available in Idaho for use by CLECs.
MCI-130
MCI-131
On a statewide and CLLI -code-specific basis in Idaho, please state the percentage of
working loops used or available to support Qwest retail services that are configured
as "connect through"warm line" (i., loops that have electrical continuity
between the customer premises and the Qwest switch, and over which a person at
the customer premises can call 911 and Qwest repair service).
Please state whether collocation rates, terms and conditions in Qwest's service territory
in Idaho are controlled by tariff, interconnection agreements, documents controlled
by Qwest (e., CLEC handbook) or a combination of these documents. Please
provide a complete copy (including attachments or amendments) of each such
document.
MCI-132 With respect to MCI -131 , ifthe collocation rates, terms and/or conditions vary among
interconnection agreements, please provide a copy of each different collocation
section.
MCI-133 With respect to MCI -131 , please state whether Qwest is considering changing the type
of document that controls collocation rates, terms and conditions (e.g. using tariffs
instead of interconnection agreements). If Qwest is considering such change
please provide all documents that address such change.
MCI-134 Please list and describe all types of physical collocation offered by Qwest in Idaho.
MCI-135 Please provide the non-recurring (including EF&I ("engineered, furnished and
installed") charges) and monthly recurring charges that Qwest charges for all
elements of all types of collocation in Idaho.
MCI's DISCOVERY REQUESTS TO QWEST -
MCI-136 Please list and describe all restrictions on the types and/or quantities of equipment or
facilities that may be placed in Qwest collocation space in Idaho. For each such
restriction, please provide the rationale for the restriction and the basis for the
restriction (e.g. QWEST business decision, FCC order, Idaho PUC order, etc.
MCI-137 With respect to MCI-136 , please provide all documents that support or address the
restriction or the basis for the restriction.
MCI-138
MCI-139
On an individual wire center basis, please provide the following for Qwest in Idaho:
(a) total collocation space (used and unused space stated in square feet) for each
type of collocation you offer;
(b) total collocation space currently occupied by carriers (in square feet; for caged
collocation, state the number of cages);
( c) names of carriers currently occupying collocation space;
(d) collocation space (stated in square feet) held by carriers who are currently in
bankruptcy proceedings;
(e) collocation space (stated in square feet) occupied by CLECs no longer
operating;
(f) total unoccupied collocation space (stated in square feet) available for carriers;
and
(g) total non-collocation space available or suitable for conversion to collocation
space.
Please list, by CLLI code and street address, the central offices in Idaho where
collocation space of any type has been exhausted, or for which collocation space
exhaustion is anticipated in the next 3 years, including the date of exhaust or
expected exhaust.
MCI-140 For cross-connects between CLEC collocation arrangements in your central offices in
Idaho, please provide:
MCI-141
(a) your Methods and Procedures, guidelines, and practices relevant to, or
describing cross-connects between CLEC collocation arrangements;
(b) non-recurring charges;
(c) monthly recurring charges;
(d) applicable performance measures and penalties;
(e) complaints from CLECs regarding any aspect of such cross-connects (e., cost
timeliness, etc.
(f) your response to and resolution of any such complaints.
Please state the rates you charge for flat and measured local exchange service for all 1)
residential and 2) business customers in Idaho, and if the rate varies 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
MCI's DISCOVERY REQUESTS TO QWEST -
MCI-142
MCI-143
MCI-144
MCI-145
MCI-146
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 that you consider to constitute low
revenue, average revenue and high revenue for 1) residential customers and 2)
business customers. Please provide a detailed explanation of whether 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 and the
average monthly revenue for each type of bundle.
Please identify, by CLLI code, all wire centers 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/wire center.
With respect to any subsidies that you contend are implicit and/or explicit in your
Idaho retail rates for any service, please:
(a) identify and describe the service;
(b) state separately the amount ofthe subsidy you contend is implicit and/or
explicit in the non-recurring and monthly recurring rates for the service;
(c) provide all cost studies, calculations, and other materials that directly support
your contention that the service is implicitly and/or explicitly being subsidized.
With respect to each of the rows of Table 1 identified in response to MCI-98 above
please state the average total monthly revenues earned each month per line in Idaho
since July 1 2001 by wire center, MSA and LATA. Also please identify the source
of those revenues by service and/or feature type (i., local voice only, local voice
plus vertical features, local long distance only, DSL only, bundles of any of the
above, and/or other services or features).
For each switch identified in your response to MCI-97 above other than circuit
switches, please provide the following for each switch:
(a) all costs arising from the provision of local 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 in Idaho since July 1 , 2001
reported by wire center, MSA and LATA. Also please identify the source of
those revenues by service and/or feature type (i., local voice only, local voice
plus vertical features, local long distance only, DSL only, bundles of any of the
above, and/or other services or features);
MCI's DISCOVERY REQUESTS TO QWEST -
MCI-147 With respect to each of the two customer categories identified in response to MCI-110
please provide the following:
(a) all categories and amounts of costs arising from providing 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 , ass , signaling, etc.
(b) the average total monthly revenues earned per line since July 1 , 2001 for each
customer category, reported by wire center, MSA and LATA.
(c) the source of all revenues derived from each category loop identified in subpart
(b) by service and/or feature type (i., local voice only, local voice plus vertical
features, local long distance only, DSL only, bundles of any of the above
and/or other services or features).
MCI-148 For each type of digital loop carrier ("DLC") equipment deployed by Qwest, please
state the minimum and maximum configuration deployed in Idaho, in terms of
number of lines supported.
MCI-149 For each type of digital loop carrier ("DLC") equipment deployed by Qwest in Idaho
please provide Qwest's equipment capital costs for minimum , average and
maximum configurations, in terms of number of lines supported.
MCI -150 For each type of digital loop carrier ("DLC") equipment deployed by Qwest in Idaho
please provide Qwest's Engineered , Furnished and Installed ("EF &1") costs for
minimum, average and maximum configurations, in terms of number of lines
supported.
MCI-151
MCI-152
MCI-153
Please provide all non-recurring and recurring rates and charges applicable in Idaho for
UNE loops of all types as found in:
(a) intrastate tariffs
(b) interstate tariffs
(c) currently effective Interconnection Agreement(s) with CLEC(s)
(d) your Statement of Generally Available Terms ("SGA T"
Please provide all non-recurring and recurring rates and charges applicable in Idaho for
UNE transport of all types as found in:
(a) intrastate tariffs
(b) interstate tariffs
(c) currently effective Interconnection Agreement(s) with CLEC(s)
(d) your Statement of Generally Available Terms ("SGA T"
Please provide a copy of all business cases, business analysis, cost studies, or other
analyses or evaluations concerning whether entry into the mass market in Idaho, or
regionwide (Qwest 14 states (AZ, CO, ID, lA, MN, MT, NE, ND , NM, OR, SD
, W A, WY)) )) if Qwest is unable to provide Idaho-specific data, is
economically feasible without access to Qwest's switches , including those analyses
MCI's DISCOVERY REQUESTS TO QWEST -
MCI-154
MCI-155
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.
Please state whether you have deployed facilities of any type (e.g. switches, loops
transport, DLC , DSLAMs, splitters, etc.) to provide local services as a CLEC in
any state or other geographic area outside your QWEST serving territory. If so
please provide all of the following:
(a) all states, cities or other geographic area in which you have deployed facilities;
(b) a detailed description of the facilities for each geographic region;
(c) a detailed description of the criteria you used to choose the geographic areas in
which you would deploy facilities;
(d) a copy of all business cases, business analysis, cost studies, or other analyses or
evaluations (whether created by you or on your behalf) regarding competitive
entry into the geographic area outside your QWEST serving territory;
( e) the date on which you first began providing competitive local services using
your own facilities in each state, city or other geographic region outside your
QWEST serving territory;
(f) the number of 1) residential and 2) business customers at the most granular
level for which data has been retained (e., QWEST wire center, city, state
etc.) for your operations outside your QWEST serving territory for each month
since such operations began;
(g) all categories and amounts of costs arising from providing competitive local
services in each state, city or other geographic region outside your QWEST
serving territory (including the recurring and non-recurring charges for the
switch, software, installation, maintenance, loops, collocation
transmission/concentration equipment, transport, hot cuts, ass, signaling, etc.
(h) the average total monthly revenues earned per customer for each customer type
(e., residential, small business, enterprise) served in each state , city or other
geographic region outside your QWEST serving territory, reported by CLLI
LATA, MSA;
(i) the source of all revenues derived from each customer type identified in your
response to subpart (h) by service and/or feature type (i., local voice only,
local voice plus vertical features, local long distance only, DSL only, bundles of
any of the above, and/or other services or features).
Please state whether you have ever offered, or are currently offering, local services via
UNE-P as a CLEC in any state or other geographic area outside your QWEST
serving territory. If so, please provide'all of the following:
(a) all states, cities or other geographic area in which you have, or are, offering
local services;
(b) a detailed description of the criteria you used to choose the geographic areas in
which you would offer local services;
(c) a copy of all business cases, business analysis, cost studies, or other analyses or
evaluations (whether created by you or on your behalf) regarding competitive
entry into the geographic area outside your QWEST serving territory;
MCI's DISCOVERY REQUESTS TO QWEST -
MCI-156
(d) the date on which you first began providing competitive local services using
UNE-P in each state, city or other geographic region outside your QWEST
serving territory;
(e) the number of 1) residential and 2) business customers at the most granular
level for which data has been retained (e., QWEST wire center, city, state
etc.) for your operations outside your QWEST serving territory for each month
since such operations began;
(f) all categories and amounts of costs arising from providing competitive local
services in each state, city or other geographic region outside your QWEST
serving territory;
(g) the average total monthly revenues earned per customer for each customer type
(e., residential , small business, enterprise) served in each state, city or other
geographic region outside your QWEST serving territory, reported by CLLI
LATA and MSA;
(h) the source of all revenues derived from each customer type identified in subpart
(g) by service and/or feature type (i., local voice only, local voice plus vertical
features, local long distance only, DSL only, bundles of any of the above
and/or other services or features).
Please state whether you have ever offered, or are currently offering, local services via
resale as a CLEC in any state or other geographic area outside your QWEST
serving territory. If so, please provide all of the following:
(a) all states, cities or other geographic area in which you have, or are, offeringlocal services;
(b) a detailed description of the criteria you used to choose the geographic areas in
which you would offer local services;
(c) a copy of all business cases, business analysis, cost studies, or other analyses or
evaluations (whether created by you or on your behalf) regarding competitive
entry into the geographic area outside your QWEST serving territory;
(d) the date on which you first began providing competitive local services using
resale in each state, city or other geographic region outside your QWEST
serving territory;
(e) the number of 1) residential and 2) business customers at the most granular
level for which data has been retained (e., QWEST wire center, city, state
etc.) for your operations outside your QWEST serving territory for each month
since such operations began;
(f) all categories and amounts of costs arising from providing competitive local
services in each state, city or other geographic region outside your QWEST
serving territory;
(g) the average total monthly revenues earned per customer for each customer type
(e., residential, small business, enterprise) served in each state, city or other
geographic region outside your QWEST serving territory, reported by CLLI
LATA, and MSA;
(h) the source of all revenues derived from each customer type identified in subpart
(g) by service and/or feature type (i.e., local voice only, local voice plus vertical
MCI's DISCOVERY REQUESTS TO QWEST -
MCI-157
MCI-158
MCI-159
MCI-160
MCI-161
MCI-162
MCI-163
features, local long distance only, DSL only, bundles of any of the above
and/or other services or features).
Please provide all documents addressing Qwest currently offered bundles of the
following: a) business local exchange and long distance services, b) residential
local exchange and long distance services, c) business local exchange, long
distance and broadband/DSL services, d) residential local exchange, long distance
and broadband/DSL services; e) residential local exchange and DSL; and f)
business local exchange and DSL.
Please provide all documents addressing Qwest planned bundling of the following: a)
business local exchange and long distance services, b) residential local exchange
and long distance services , c) business local exchange, long distance and
broadband/DSL services, d) residential local exchange, long distance and
broadband/DSL services; e) residential local exchange and DSL; and f) business
local exchange and DSL.
On a CLLI -code-specific basis in Idaho, please provide all forecasts of Qwest' s
expected, estimated or forecasted demand growth or decline for each of the next
five years for circuit switched voice grade services, stated on all available bases
(e., number oflines, minutes of use, processor utilization CCS, etc.
On a CLLI-code-specific basis in Idaho, please provide Qwest's current capacity
utilization for each Class 5 circuit switch for the major switch components (e.
processor, line cards, trunk cards, etc.
On a CLLI-code-specific basis in Idaho, please provide the Qwest's demand growth or
decline for circuit switched voice grade services for each of the last three years
stated on all available bases (e., number oflines, minutes of use, processor
utilization CCS, etc.
On a CLLI-code-specific basis in Idaho, please provide the Qwest's demand growth or
decline for each of the last three years for each of the following Qwest retail
services: primary business voice lines, primary residential voice lines, additional
business voice lines, additional residential voice lines, standalone DSL lines, Qwest
DSL service provisioned in the high frequency portion of a loop that also supports
Qwest narrowband analog voice service, CLEC DSL service provisioned in the
high frequency portion of a loop that also supports Qwest narrowband analog voice
service, and CLEC DSL service provisioned in the high frequency portion of a loop
that also supports (CLEC) narrowband analog voice service.
On a CLLI -code-specific basis in Idaho, please provide Qwest's current in-service
quantities for each of the following Qwest retail services: primary business voice
lines, primary residential voice lines, additional business voice lines, additional
residential voice lines, standalone DSL lines, Qwest DSL service provisioned in the
high frequency portion of a loop that also supports Qwest narrowband analog voice
service, CLEC DSL service provisioned in the high frequency portion of a loop that
MCI's DISCOVERY REQUESTS TO QWEST-40
MCI-l64
MCI-165
MCI-166
MCI-167
also supports Qwest narrowband analog voice service, and CLEC DSL service
provisioned in the high frequency portion of a loop that also supports (CLEC)
narrowband analog voice service.
On a CLLI-code-specific basis in Idaho, please provide Qwest s expected, estimated or
forecasted demand growth or decline for each of the next three years for each of the
following Qwest retail services: primary business voice lines, primary residential
voice lines, additional business voice lines , additional residential voice lines
standalone DSL lines, Qwest DSL service provisioned in the high frequency
portion of a loop that also supports Qwest narrowband analog voice service, CLEC
DSL service provisioned in the high frequency portion of a loop that also supports
Qwest narrowband analog voice service , and CLEC DSL service provisioned in the
high frequency portion of a loop that also supports (CLEC) narrowband analog
VOIce servIce.
On a CLLI -code-specific basis in Idaho , please provide the Qwest's demand growth or
decline for each of the last three years for each of the following: a) UNE loops
used for circuit switched voice service, b) UNE loops used for DSL service
(including line split configurations), c) UNE-P residential local exchange service
d) UNE-P business local exchange service, e) resold QWEST business local
exchange service and f) resold QWEST residential local exchange service.
On a CLLI -code-specific basis in Idaho, please provide the Qwest's current in-service
quantities for each of the following: a) UNE loops used for circuit switched voice
service, b) UNE loops used for DSL service (including line split configurations), c)
UNE-P residential local exchange service, d) UNE-P business local exchange
service, e) resold QWEST business local exchange service and f) resold QWEST
residential local exchange service.
On a CLLI -code-specific basis in Idaho, please provide the Qwest's expected
estimated or forecasted demand growth or decline for each of the next three years
for each of the following: a) UNE loops used for circuit switched voice service, b)
UNE loops used for DSL service (including line split configurations), c) UNE-
residential local exchange service, d) UNE-P business local exchange service, e)
resold QWEST business local exchange service and f) resold QWEST residential
local exchange service.
MCI-168 Please provide all documents that address or assess the risk of stranded capacity on all
or any portion of Qwest' s existing network in Idaho.
MCI-169 Please provide all calculations and/or estimates in Qwest s custody or control of the
market demand elasticity for local exchange service in Idaho or regionwide (Qwest
14 states (AZ, CO, ID, lA, MN, MT, NE, ND, NM, OR, SD, UT, W A, WY)) )) if
Qwest is unable to provide Idaho-specific data, or at any geographic level , if Qwest
cannot provide either Idaho-specific or regionwide data, stated separately for
residential and business customers, if such separate calculations and/or estimates
MCI's DISCOVERY REQUESTS TO QWEST-41
MCI-170
MCI-171
MCI-172
MCI-I73
MCI-174
exist. Please provide all supporting documentation for such calculations and/or
estimates.
Please provide all calculations and/or estimates in Qwest's custody or control of the
market demand elasticity for long distance service in Idaho or regionwide (Qwest
14 states (AZ, CO, ID, lA, MN, MT, NE, ND , NM, OR, SD, UT, WA, WY)J)J if
Qwest is unable to provide Idaho-specific data, or at any geographic level , if Qwest
cannot provide either Idaho-specific or regionwide data, stated separately for
residential and business customers, if such separate calculations and/or estimates
exist. Please provide all supporting documentation for such calculations and/or
estimates.
Please provide all calculations and/or estimates in Qwest's custody or control of the
market demand elasticity for broadband service (i., DSL) in Idaho or regionwide
(Qwest 14 states (AZ, CO, ID, lA, MN, MT, NE, ND , NM, OR, SD, UT, W A
WY)) )J if Qwest is unable to provide Idaho-specific data, or at any geographic
level, if Qwest cannot provide either Idaho-specific or regionwide data, stated
separately for residential and business customers, if such separate calculations
and/or estimates exist. Please provide all supporting documentation for such
calculations and/or estimates.
Please provide all calculations and/or estimates in Qwest's custody or control of the
market demand elasticity for bundled local and long distance service in Idaho or
regionwide (Qwest 14 states (AZ, CO, ID, lA, MN, MT, NE, ND, NM, OR, SD
, W A, WY)J )) if Qwest is unable to provide Idaho-specific data, or at any
geographic level, if Qwest cannot provide either Idaho-specific or regionwide data
stated separately for residential and business customers, if such separate
calculations and/or estimates exist. Please provide all supporting documentation
for such calculations and/or estimates.
Please provide all calculations and/or estimates in Qwest's custody or control of the
market demand elasticity for bundled local, long distance, and broadband service
(i., DSL) in Idaho or regionwide (Qwest 14 states (AZ, CO, ID, lA, MN, MT
, ND, NM, OR, SD, UT, W A, WY)) )) if Qwest is unable to provide Idaho-
specific data, or at any geographic level, if Qwest cannot provide either Idaho-
specific or regionwide data, stated separately for residential and business
customers, if such separate calculations and/or estimates exist. Please provide all
supporting documentation for such calculations and/or estimates.
Please define the following terms, as Qwest understands and uses them in Idaho, and
whether Qwest's definition these terms is the same as those found in the Idaho
PUC's Costing and Pricing Rules found at 4 CCR 723-30 and the Idaho PUC'
decisions in Docket Nos. 96A-331 T and 97 A-577T defining total element long run
incremental costs ("TELRIC") and distinguish each defined term from all of the
others on this list:
(a) variable cost
MCI's DISCOVERY REQUESTS TO QWEST-42
MCI-175
MCI-176
MCI-l77
MCI-178
MCI-179
(b) sunk cost
( c) marginal cost
(d) incremental service incremental cost
(e) Total Service Long Run Incremental Costs ("TSLRIC"
(f) TELRIC.
Please provide Qwest's calculation and/or estimate of its variable costs for providing
local exchange service in Idaho or regionwide (Qwest 14 states (AZ, CO, ID , lA
, MT, NE, ND, NM, OR, SD, UT, W A, WY)J if Qwest is unable to provide
Idaho-specific data, stated separately for residential and business customers, if such
separate calculations and/or estimates exist. Please provide all supporting
documentation for such calculations and/or estimates.
Please provide Qwest s calculation and/or estimate of its marginal costs for providing
local exchange service in Idaho or regionwide (Qwest 14 states (AZ, CO, ID, lA
, MT, NE, ND, NM, OR, SD , UT, WA, WY)) if Qwest is unable to provide
Idaho-specific data, stated separately for residential and business customers, if such
separate calculations and/or estimates exist. Please provide all supporting
documentation for such calculations and/or estimates.
Please provide Qwest s calculation and/or estimate of its variable costs for providing
long distance service in Idaho or regionwide (Qwest 14 states (AZ, CO, ID , lA
, MT, NE, ND , NM, OR, SD, UT, WA, WY)) if Qwest is unable to provide
Idaho-specific data, stated separately for residential and business customers, if such
separate calculations and/or estimates exist. Please provide all supporting
documentation for such calculations and/or estimates.
Please provide Qwest's calculation and/or estimate of its marginal costs for providing
long distance service in Idaho or regionwide (Qwest 14 states (AZ, CO , ID, lA
, MT, NE, ND, NM, OR, SD, UT, W A, WY)J if Qwest is unable to provide
Idaho-specific data, stated separately for residential and business customers, if such
separate calculations and/or estimates exist. Please provide all supporting
documentation for such calculations and/or estimates.
Please provide Qwest's calculation and/or estimate of its variable costs for providing
broadband service (i.e. DSL) in Idaho or regionwide (Qwest 14 states (AZ, CO , ID
, MN, MT, NE, ND, NM, OR, SD, UT, WA, WY)) if Qwest is unable to provide
Idaho-specific data, stated separately for residential and business customers, if such
separate calculations and/or estimates exist. Please provide all supporting
documentation for such calculations and/or estimates.
MCI-180 Please provide Qwest's calculation and/or estimate of its marginal costs for providing
broadband service (i.e. DSL) in Idaho or regionwide (Qwest 14 states (AZ, CO, ID
, MN, MT, NE, ND, NM, OR, SD, UT, W A, WY)) if Qwest is unable to provide
Idaho-specific data, stated separately for residential and business customers, if such
MCI's DISCOVERY REQUESTS TO QWEST-43
MCI-181
MCI-182
MCI-183
MCI-184
MCI-185
separate calculations and/or estimates exist. Please provide all supporting
documentation for such calculations and/or estimates.
Please provide Qwest s calculation and/or estimate of its variable costs for providing
bundled local exchange and long distance service in Idaho or regionwide (Qwest 14
states (AZ, CO, ID, lA, MN, MT, NE, ND , NM, OR, SD, UT, WA, WY)) if Qwest
is unable to provide Idaho-specific data, stated separately for residential and
business customers, if such separate calculations and/or estimates exist. Please
provide all supporting documentation for such calculations and/or estimates.
Please provide Qwest s calculation and/or estimate of its marginal costs for providing
bundled local exchange and long distance service in Idaho or regionwide (Qwest 14
states (AZ, CO, ID, lA, MN, MT, NE, ND, NM, OR, SD, UT, W A, WY)) if Qwest
is unable to provide Idaho-specific data, stated separately for residential and
business customers , if such separate calculations and/or estimates exist. Please
provide all supporting documentation for such calculations and/or estimates.
Please provide Qwest's calculation and/or estimate of its variable costs for providing
bundled local exchange, long distance and broadband service in Idaho or
regionwide (Qwest 14 states (AZ, CO, ID, lA, MN, MT, NE, ND, NM, OR, SD
, W A, WY)) if Qwest is unable to provide Idaho-specific data, stated separately
for residential and business customers, if such separate calculations and/or
estimates exist. Please provide all supporting documentation for such calculations
and/or estimates.
Please provide Qwest's calculation and/or estimate of its marginal costs for providing
bundled local exchange, long distance and broadband service in Idaho or
regionwide (Qwest 14 states (AZ, CO, ID , lA, MN, MT, NE, ND , NM, OR, SD
, W A, WY)) if Qwest is unable to provide Idaho-specific data, stated separately
for residential and business customers, if such separate calculations and/or
estimates exist. Please provide all supporting documentation for such calculations
and/or estimates.
Please state whether Qwest has any affiliates or subsidiaries that provide local
exchange voice services, long distance voice services and/or DSL services in Idaho.
If the response for any of these services is affirmative, please provide the full name
ofthe affiliate or subsidiary and a list ofthe service(s) provided by the affiliate or
subsidiary .
MCI-186 Please provide a copy of each executed contract (including attachments and/or
amendments) between Qwest and a long distance carrier that Qwest uses to provide
inter-LATA toll services and/or facilities.
MCI-187 With respect to each contract requested in MCI-186, please provide the total minutes of
use, and/or total transport capacity purchased, as well as the total dollar amount
MCl's DISCOVERY REQUESTS TO QWEST-44
MCI-188
MCI-189
MCI-190
MCI-191
MCI-192
paid for such minutes of use and/or transport capacity, stated on a quarterly basis
for the past three years.
Please provide all calculations or estimates in Qwest' s custody or control of Qwest' s
current total and component (e., debt, preferred stock, equity, etc.) cost of capital
in Idaho or regionwide (Qwest 14 states (AZ, CO, ID , lA, MN , MT, NE, ND, NM
, SD, UT, W A, WY)) if Qwest is unable to provide Idaho-specific data, based
on each ofthe following: a) market capital structure, b) book capital structure, and
c) target capital structure. Please provide supporting documentation, including the
documents relied upon to answer this question.
With respect to the cost of capital calculations or estimates requested in MCI -188
please provide such calculations or estimates for Qwest's major types of service , at
the most granular level available, including the following: a) residential local
exchange service, b) business local exchange service, c) long distance service, d)
DSL service and e) unbundled network elements (UNEs). Please provide
supporting documentation, including the documents relied upon to answer this
question.
Please describe in detail the approach and manner in which Qwest segments its sales
and marketing efforts and personnel on the basis of customer size, type (e.
residential, small business, medium business, large business), monthly level of
revenues , and/or service(s) taken by customer (individually or as part of a bundle),
and provide the basis on which such segmentation is made.
Please describe in detail any legal, regulatory or other constraints on Qwest's ability to
target price reductions 1) to specific geographic areas , and 2) to types of customers
(including individual customers), for each of the following: a) business local
exchange service, b) residential local exchange service, c) long distance service and
d) DSL service.
Please describe in detail any price floors imposed by any law, regulation, Idaho PUC
orders or rulings that constrain Qwest's ability to reduce prices for each of the
following: a) business local exchange service, b) residential local exchange
service, c) long distance service and d) DSL service. For each such price floor
provide the basis for the calculation for the price floor (e., price freeze, cost-based
calculation, etc.
MCI -193 Please provide average total revenue for each Qwest wire center in Idaho.
MCI-194 For each CLLI code in Idaho, please provide for the most recent period available (1)
the underlying data Qwest used to provide the Idaho-statewide data found in Table
II and Table III of the most recently filed FCC ARMIS Report 43-08; (2) the
number of switched DS-1 lines/loops in service when Qwest filed its most recently
filed FCC ARMIS Report 43-08; (2) the number of non-switched DS-llines/loops
in service when Qwest filed its most recently filed FCC ARMIS Report 43-08; and
MCI's DISCOVERY REQUESTS TO QWEST-45
MCI-195
(4) the number ofDS-3 lines/loops in service when Qwest filed its most recently
filed FCC ARMIS Report 43-08.
F or each CLLI code in Idaho, please provide the most current monthly average
revenues per line for (1) residential voice-only customers; (2) residential voice plus
DSL customers; (3) business DS-O/voice grade customers; (4) business DS-
customers; for local service, vertical features, and voice mail. For customers in
each of these four categories who also subscribe to Qwest long distance service
provide the current monthly average long distance revenues per line.
MCI's DISCOVERY REQUESTS TO QWEST-46
QWEST UNE TRANSPORT IMPAIRMENT ISSUES
MCI 195A Does Qwest intend to present a case to remove any transport routes that it
contends should be removed from the list of available DS-l UNEs pursuant to
FCC Rules ~51.319(e)(1)(ii) (existence of competitive wholesale facilities)?
the answer to Question 195A is ", do not respond to Questions MCI-196
through MCI-231 , and skip to Question MCI-231A.
MCI-196 Please list each and every transport route which you contend should be removed from
the list of available DS-l UNEs pursuant to FCC Rules ~51.319( e)(1 )(ii) (existence
of competitive wholesale facilities.) For each listed route, please list: a) the CLLI
code identifications of the endpoints; b) the identities of each claimed alternative
competitive provider.
MCI-197 For each alternative competitive provider listed in your response to MCI -196, indicate
whether it is an "affiliate" (as defined in 47 USC ~153(1)) of Qwest or of any other
listed alternative competitive provider.
MCI-198 For each route listed in your response to MCI-196 , please provide the following
information:
(a) The type of terminating facility (e., collocation) used at each end of the route
and a copy of the authority by which that facility is governed (i., tariff pages
collocation contract, or interconnection agreement.)
(b) The exact route of each claimed alternative facility, including the owner of each
facility segment, its date of installation and date of initial operation, the nature
of the alternative competitive provider s ownership/occupancy rights (i.
, "
fee
simple ownership
, "
IRU", etc.), and the identity of any underlying owners or
interest holders in the facility.
(c) Any and all documents you have that state that each claimed alternative
competitive provider is willing immediately to provide, on a widely available
basis, dedicated DS 1 transport along the particular route.
(d) The terms, including copies of any governing documents, by which requesting
telecommunications carriers are able to obtain reasonable and
nondiscriminatory access through cross connection to the facilities of the
alternative competitive provider.
MCI-199 Please list each and every transport route which you contend should be removed from
the list of available DS-3 UNEs pursuant to FCC Rules ~51.319(e)(2)(i)(A)
(existence of alternative self-provisioned facilities.) For each listed route, please
list: a) the CLLI code identifications of the endpoints; b) the identities of each
claimed alternative competitive provider.
MCI'S DISCOVERY REQUESTS TO QWEST-47
MCI-200 For each alternative competitive provider listed in your response to MCI-199, indicate
whether it is an "affiliate" (as defined in 47 USC 9153(1)) of Qwest or of any other
listed alternative competitive provider.
MCI-201
MCI-202
For each route listed in your response to MCI-199, please provide the following
information:
(a) The type of terminating facility (i., collocation) used at each end and a copy
of the authority by which that facility is governed (i., tariff pages, collocation
contract, or interconnection agreement.)
(b) The exact route of each claimed alternative facility, including the owner of each
facility segment, its date of installation and date of initial operation, the nature
of the alternative competitive provider s ownership/occupancy rights (i.
, "
fee
simple ownership
, "
IRU", etc.), and the identity of any underlying owners or
interest holders in the facility.
(c) Any and all documents you have that state that each claimed alternative
competitive provider is operationally ready to use the listed transport facilities
to provide dedicated DS-3 transport along the particular route.
Please list each and every transport route which you contend should be removed from
the list of available DS-3 UNEs pursuant to FCC Rules 951.319(e)(2)(i)(B)
(existence of competitive wholesale facilities.) For each listed route, please list: a)
the CLLI code identifications of the endpoints; b) the identities of each claimed
alternative competitive provider.
MCI-203 For each alternative competitive provider listed in your response to MCI-202, indicate
whether it is an "affiliate" (as defined in 47 USC 9153(1)) of Qwest or of any other
listed alternative competitive provider.
MCI-204 For each route listed in your response to MCI-202, please provide the following
information:
(a) The type of terminating facility (i., collocation) used at each end and a copy
of the authority by which that facility is governed (i., tariff pages, collocation
contract, or interconnection agreement.)
(b) The exact route of each claimed alternative facility, including the owner of each
facility segment, its date of installation and date of initial operation, the nature
of the alternative competitive provider s ownership/occupancy rights (i.e.
, "
fee
simple ownership
, "
IRU", etc.), and the identity of any underlying owners or
interest holders in the facility.
(c) Any and all documents you have that state that each claimed alternative
competitive provider is willing immediately to provide, on a widely available
basis, dedicated DS-3 transport along the particular route.
(d) The terms, including copies of any governing documents, by which requesting
telecommunications carriers are able to obtain reasonable and
nondiscriminatory access through cross connection to the facilities of the
alternative competitive provider.
MCI's DISCOVERY REQUESTS TO QWEST-48
MCI-205
MCI-206
Please list each and every transport route which you contend should be removed from
the list of available DS-3 UNEs pursuant to FCC Rules 951.319( e )(2)(ii) (potential
deployment of alternative facilities.) For each listed route, please list: a) the CLLI
code identifications of the endpoints; b) the identities of any identified alternative
competitive provider.
For each route listed in your response to MCI-205 , please provide copies of all
information in your possession relating to:
(a) local engineering costs of building and utilizing transmission facilities
(b) the cost of underground or aerial laying of fiber or copper;
(c) the cost of equipment needed for transmission; installation and other necessary
costs involved in setting up service;
(d) relevant local topography such as hills and rivers;
(e) availability of reasonable access to rights-of-way;
(f) availability/feasibility of similar quality/reliability alternative transmission
technologies along the particular route;
(g) customer density and addressable market; and
(h) existing facilities-based competition.
MCI-207 For each alternative competitive provider listed in your response to MCI-205 and for
each provider of any existing facilities-based competition listed in your response to
MCI-206(h), indicate whether it is an "affiliate" (as defined in 47 USC 9153(1)) of
Qwest or of any other listed alternative competitive provider.
MCI-208 Please list each and every transport route which you contend should be removed from
the list of available Dark Fiber UNEs pursuant to FCC Rules 951.319( e )(3)(i)(A)
(existence of alternative self-provisioned facilities.) For each listed route, please
list: a) the CLLI code identifications ofthe endpoints; b) the identities of each
claimed alternative competitive provider.
MCI-209 For each alternative competitive provider listed in your response to MCI-208, indicate
whether it is an "affiliate" (as defined in 47 USC 9153(1)) of Qwest or of any other
listed alternative competitive provider.
MCI-210 For each route listed in your response to MCI-208, please provide the following
information:
(a) The type of terminating facility (i., collocation) used at each end and a copy
of the authority by which that facility is governed (i., tariff pages, collocation
contract, or interconnection agreement.
(b) The exact route of each claimed alternative facility, including the owner of each
facility segment, its date of installation and date of initial operation, the nature
of the alternative competitive provider s ownership/occupancy rights (Le.
, "
fee
simple ownership
, "
IRU", etc.), and the identity of any underlying owners or
interest holders in the facility.
MCI's DISCOVERY REQUESTS TO QWEST-49
MCI-211
(c) Any and all documents you have that state that each claimed alternative
competitive provider is operationally ready to use the listed transport facilities
to provide dedicated Dark Fiber transport along the particular route.
Please list each and every transport route which you contend should be removed from
the list of available Dark Fiber UNEs pursuant to FCC Rules ~51.319(e)(3)(i)(B)
(existence of competitive wholesale facilities.) For each listed route, please list: a)
the CLLI code identifications of the endpoints; b) the identities of each claimed
alternative competitive provider.
MCI-212 For each alternative competitive provider listed in your response to MCI-211 , indicate
whether it is an "affiliate" (as defined in 47 USC ~153(1)) of Qwest or of any other
listed alternative competitive provider.
MCI-213
MCI-214
MCI-215
For each route listed in your response to MCI-211 , please provide the following
information:
(a) The type of terminating facility (i., collocation) used at each end and a copy of
the authority by which that facility is governed (i., tariff pages, collocation
contract, or interconnection agreement.)
(b) The exact route of each claimed alternative facility, including the owner of each
facility segment, its date of installation and date of initial operation, the nature of
the alternative competitive provider s ownership/occupancy rights (i.
, "
fee simple
ownership
, "
IRU", etc.), and the identity of any underlying owners or interest
holders in the facility.
(c) Any and all documents you have that state that each claimed alternative
competitive provider is willing immediately to provide, on a widely available
basis, dedicated Dark Fiber transport along the particular route.
(d) The terms, including copies of any governing documents, by which requesting
telecommunications carriers are able to obtain reasonable and
nondiscriminatory access through cross connection to the facilities of the
alternative competitive provider.
Please list each and every transport route which you contend should be removed from
the list of available Dark Fiber UNEs pursuant to FCC Rules ~51.319(e)(3)(ii)
(potential deployment of alternative facilities.) For each listed route, please list: a)
the CLLI code identifications of the endpoints; b) the identities of any identified
alternative competitive provider.
For each route listed in your response to MCI-214, please provide copies of all
information in your possession relating to:
(a) local engineering costs of building and utilizing transmission facilities;
(b) the cost of underground or aerial laying of fiber or copper;
(c) the cost of equipment needed for transmission; installation and other necessary
costs involved in setting up service;
(d) relevant local topography such as hills and rivers;
(e) availability of reasonable access to rights-of-way;
MCl's DISCOVERY REQUESTS TO QWEST -
MCI-216
MCI-217
MCI-218
MCI-219
(f) availability/feasibility of similar quality/reliability alternative transmission
technologies along the particular route;
(g) customer density and addressable market; and
(h) existing facilities-based competition.
For each alternative competitive provider listed in your response to MCI-214 and for
each provider of any existing facilities-based competition listed in your response to
MCI-215(h), indicate whether it is an "affiliate" (as defined in 47 USC 9153(1)) of
Qwest or of any other listed alternative competitive provider.
Please describe and provide supporting documents for any state or locally enacted or
enforced barriers to entry by competing providers of DS-, DS- 3 , OC-n, or Dark
Fiber transport, including, but not limited to, any moratoria or restrictions on
construction or access to rights of way. Include all relevant legal provisions and a
description of any Qwest deployment or construction projects which have been
undertaken since the enactment of the restriction or moratoria. Describe the steps
taken or qualifications met in order for the identified Qwest projects to either
comply with or avoid the effects of the restriction or moratoria.
For each route identified in your responses to MCI-196 through MCI-214, please
provide the following information:
(a) All forecasts of Qwest expected, estimated , anticipated, or forecasted demand
growth or decline for all classes of transport service. To the extent you have
information disaggregated by type of customer or demand (e.
, "
business
, "
data
ONE"
, "
special access , or other categories) please provide such disaggregated
figures. To the extent different documents may provide differing figures
estimates, or forecasts based upon the impact or implementation of any regulatory
or judicial action (including, but not limited to, the Triennial Review Order and
related proceedings) provide all such figures, estimates, and forecasts, identifying
which relate to which different regulatory or judicial outcomes;
(b) Qwest's current transport capacity utilization , including total number and type of
fibers or copper cabling
(c) number of "unlit" or "dark" fibers;
(d) number of "lit" fibers with the current operational level implemented for each (i.
which OC level);
(e) current utilization of copper wire, if any, including identification and capacity of
implemented digital and analog transmission capability
(f) identification of unused copper facilities, ifany.
Please provide the following information for each fiber or conduit deployment project
by Qwest in Idaho since January 1 2000:
(a) type, size, and capacity of conduit installed along all or any separate portion of
the route;
(b) type and number of fibers initially installed along all or any separate portion of
the route
MCI's DISCOVERY REQUESTS TO QWEST -
MCI-220
MCI-221
(c) type and number of fibers for each and every subsequent installation along all
or any portion of the route;
(d) all available budgetary and actual cost data for both initial and any subsequent
installations, including all costs for permits, authority, ROW, lobbying, public
policy, excavation, trenching, boring, backfill, surface repair, remediation, vault
construction, termination, payments-in-kind, related usage rights, materials
(including conduit and cabling), and any other expenses necessary to the
project.
Please provide the following information for each planned fiber or conduit deployment
project by Qwest in Idaho for the next 3 years: (Include in this response any
current projects not included in MCI-219, as well as future projects.
(a) type, size , and capacity of conduit to be installed along all or any separate portion
of the route;
(b) type and number of fibers to be initially installed along all or any separate portion
of the route
(c) type and number of fibers for each and every planned subsequent installation along
all or any portion of the route;
(d) all available budgetary cost data and estimates for both initial and any subsequent
installations, including all costs and estimates for permits, authority, ROW
lobbying, public policy, excavation, trenching, boring, backfill, surface repair
remediation, vault construction, termination, payments-in-kind, related usage
rights, materials (including conduit and cabling), and any other expenses necessary
to the project.
Please provide copies of contracts, agreements, tariffs, or other governing documents
by which Qwest:
(a) sells, rents, leases, or otherwise provides telecommunications transport services
between its switches and/or wire centers to others in Idaho;
(b) buys, rents, leases, or otherwise acquires telecommunications transport services
between its switches and/or wire centers from others in Idaho.
MCI-222 With respect to all documents identified in your response to (d), please provide
quarterly totals for the last 3 years of the amount of transport capacity provided or
acquired, identifying the quantity, route, and opposite party for each segment.
MCI-223 Please describe in detail any price floors or other limitation imposed by any law
regulation, Idaho PUC orders or rulings that constrain Qwest's ability to reduce
prices for each of the following: a) dark fiber service, b) OC-n level service , c) DS-
3 service and d) DS-1 service. For each such price floor or other limitation
provide the basis for the calculation for the price floor or other limitation (e.
price freeze, cost-based calculation, etc.
MCI's DISCOVERY REQUESTS TO QWEST -
MCI-224 Please provide a description and supporting documentation for all Qwest currently
offered bundles and volume discounts involving the following: a) dark fiber
service, b) OC-n level service, c) DS-3 service and d) DS-1 service.
MCI-225 Please provide a description and supporting documentation for all Qwest planned or
contemplated bundles and volume discounts involving the following: a) dark fiber
service, b) OC-n level service, c) DS-3 service and d) DS-1 service.
MCI-226 Please provide all documents that address or assess the risk of stranded transport
capacity on all or any portion of Qwest's existing network in Idaho.
MCI-227
MCI-228
MCI-229
MCI-230
For this and the immediately following four questions, the phrase "lit enterprise
circuit(s)" means one or more circuits at the DS-, DS-3, or OC-x capacity levels.
Please describe all your current procedures for moving portions of lit enterprise
circuits from your own network to a CLEC or IXC network. Include all procedures
for circuits which serve multiple end-users by virtue of connection to multiple
Qwest "tail circuits" or "loops" via Qwest provided MUX or DACS equipment.
When a lit enterprise circuit provided by Qwest under UNE procedures or Special
Access tariffs serves multiple end-user customers through Qwest provided MUX or
DACS equipment, will Qwest perform a "hot cut" of all or part ofthe lit enterprise
circuit portion to non-Qwest provided transport?
(a) Ifno, why not?
(b) If yes, will Qwest perform this function based on a single Access Service Request
ASR") submission by the carrier customer or does Qwest require multiple ASRs?
If the answer is that a single ASR is acceptable, please identify any prior periods
when multiple ASRs were required.
As part of any required transition from UNE enterprise circuit transport to non-Qwest
transport, will Qwest perform a "hot cut" of all or part of any lit enterprise circuit
portion to non-Qwest provided transport?
(a) Ifno, why not?
(b) If yes, will Qwest perform this function based on a single service request, or
will Qwest require separate requests for each end-user circuit?
Has Qwest ever imposed restrictions on the number of lit enterprise circuits it would
transition from the Qwest network to the networks of others? If yes, state all such
restrictions imposed and all terms of such restrictions (i., any specifics as to
numbers of such transitions within a specific time and/or region; conditions as to
time "out of service ; any required impositions of unfavorable customer conditions;
any mandatory classification of any such transition as "project work" (or other non-
standard undertaking) thereby changing or avoiding any otherwise applicable
MCI's DISCOVERY REQUESTS TO QWEST -
MCI-231
MCI231A
service guarantees, performance standards, or terms ensuring quality of service
etc.
Please produce all internal methods & procedures, business rules, memoranda
communications, e-mail, reports, etc. which describe in any way issues related to
the migration of lit enterprise circuits or circuit portions from the Qwest network to
any non-Qwest network. In addition, if not already encompassed in the prior
sentence, include all such documents which discuss any potential means of
discouraging such moves, or any complaints or comments received relating to
procedures used to undertake such moves, or any refusals of such moves.
QWEST ENTERPRISE UNE LOOP IMPAIRMENT ISSUES
Does Qwest intend to present a case to remove any customer location which it
contends should be removed from the list of available DS-l UNE loop
destinations pursuant to FCC Rules ~51.319(a)(4)(ii) (existence of competitive
wholesale facilities)? If the answer to Question 231A is ", do not respond
to Questions MCI-232 through MCI-263.
MCI-232 Please state the proportion of "unlit" or "dark" fiber in loop feeder and distribution
plant a) for each of the last 3 years; b) currently; and c) all projections for the next 3
years.
MCI-233
MCI-234
MCI-235
Please state the "OCn" level(s) at which fiber in the loop feeder and distribution plant
has been, is being, or will be operated:
(a) for each of the last 3 years;
(b) currently; and
(c) all projections for the next 3 years.
Please describe and supply supporting documentation for any change in the last three
years, and any change currently in progress , in deployment plans or schedules
which would tend to either a) lower or reduce the future transmission ("OCn ) level
of any fiber in the loop feeder and/or distribution plant; b) reduce any expected
anticipated, or planned increases in the future transmission ("OCn ) level of any
fiber in the loop feeder and/or distribution plant; c) increase the number of fibers
used at any point in the loop feeder and/or distribution plant; or d) reduce the
number of "unlit" fibers available for provision of "dark fiber" to others.
Please define "customer location" and "customer premises" in the context of enterprise
UNE loop impairment analyses. Are these terms synonymous in your view?
not, please describe in detail your view of the differences in these terms with
respect to DS-, DS-, and Dark Fiber UNE loops.
MCI-236 Please list each and every customer location which you contend should be removed
from the list of available DS-1 UNE loop destinations pursuant to FCC Rules
MCI's DISCOVERY REQUESTS TO QWEST -
~51.319( a)( 4)(ii) (existence of competitive wholesale facilities.) For each listed
location, please list:
(a) the CLLI code identification of the network endpoint;
(b) the identities of each claimed alternative competitive provider;
(c) the exact location of the customer endpoint;
(d) all persons owning an interest in or controlling access to the customer location;
( e) whether the location is a single-tenant or multi-tenant facility;
(f) all documents or information in your possession, custody or control regarding
any and all rights of access either you or any other telecommunications carrier
may have within the location;
(g) whether you claim ownership or control over any intra-building wire, fiber
cabling, or right of access;
(h) whether you are willing to make available any intra-building wire, fiber
cabling or right of access you may have to other telecommunications carriers at
no cost;
(i) whether you are willing to make available any intra-building wire, fiber
cabling, or right of access you may have to other telecommunications carriers
for consideration, including the amounts and all terms of that consideration;
G) what other means, if any, you are aware of that could be used by other
telecommunications carriers to access tenants within the location.
MCI-237 For each alternative competitive provider listed in your response to MCI-236, indicate
whether it is an "affiliate" (as defined in 47 USC ~153(1)) of Qwest or of any other
listed alternative competitive provider.
MCI-238
MCI-239
For each location listed in your response to MCI-236 , please provide the following
information:
(a) The type of alternative loop provisioned and made available.
(b) The exact location of each claimed alternative facility, including the owner of
each facility segment, its date of installation and date of initial operation, the
nature of the alternative competitive provider s ownership/occupancy rights
(i.
, "
fee simple ownership
, "
IRU", etc.), and the identity of any underlying
owners or interest holders in the facility.
(c) Any and all documents in your possession, custody or control that state that
each claimed alternative competitive provider is willing immediately to
provide, on a widely available basis, dedicated DS 1 loop facilities at the
specified location.
(d) The terms, including copies of any governing documents, by which requesting
. telecommunications carriers are able to obtain reasonable and
nondiscriminatory access to the facilities of the alternative competitive
provider.
Please list each and every customer location which you contend should be removed
from the list of available DS-3 UNE loop destinations pursuant to FCC Rules
~51.319(a)(5)(i)(A) (existence of alternative self-provisioned facilities.) For each
listed location, please list:
MCI's DISCOVERY REQUESTS TO QWEST -
(a) the CLLI code identification of the network endpoint;
(b) the identities of each claimed alternative competitive provider;
(c) the exact location of the customer endpoint;
(d) all persons owning an interest in or controlling access to the customer location;
(e) whether the location is a single-tenant or multi-tenant facility;
(f) all documents or information in your possession, custody or control regarding
any and all rights of access either you or any other telecommunications carrier
may have within the location;
(g) whether you claim ownership or control over any intra-building wire, fiber
cabling, or right of access;
(h) whether you are willing to make available any intra-building wire, fiber
cabling or right of access you may have to other telecommunications carriers at
no cost;
(i) whether you are willing to make available any intra-building wire, fiber
cabling, or right of access you may have to other telecommunications carriers
for consideration, including the amounts and all terms of that consideration;
(j) what other means, if any, you are aware of that could be used by other
telecommunications carriers to access tenants within the location.
MCI-240 For each alternative competitive provider listed in your response to MCI-239, indicate
whether it is an "affiliate" (as defined in 47 USC 9153(1)) of Qwest or of any other
listed alternative competitive provider.
MCI-241
MCI-242
For each location listed in your response to MCI-239, please provide the following
information:
(a) The type of alternative loop provisioned and made available.
(b) The exact route of each claimed alternative facility, including the owner of each
facility segment, its date of installation and date of initial operation, the nature
of the alternative competitive provider s ownership/occupancy rights (i.
, "
fee
simple ownership
, "
IRU", etc.), and the identity of any underlying owners or
interest holders in the facility.
(c) Any and all documents in your possession, custody or control that state that
each claimed alternative competitive provider is operationally ready to use the
listed loop facilities to provide dedicated DS-3 loop facilities at the specified
location.
Please list each and every customer location which you contend should be removed
from the list of available DS-3 UNE loop destinations pursuant to FCC Rules
951.319(a)(5)(i)(B) (existence of competitive wholesale facilities.) For each listed
location, please list:
(a) the CLLI code identification of the network endpoint;
(b) the identities of each claimed alternative competitive provider;
(c) the exact location of the customer endpoint;
(d) all persons owning an interest in or controlling access to the customer location;
(e) whether the location is a single-tenant or multi-tenant facility;
MCl's DISCOVERY REQUESTS TO QWEST -
(f) all documents or information in your possession, custody or control regarding
any and all rights of access either you or any other telecommunications carrier
may have within the location;
(g) whether you claim ownership or control over any intra-building wire, fiber
cabling, or right of access;
(h) whether you are willing to make available any intra-building wire , fiber
cabling or right of access you may have to other telecommunications carriers at
no cost;
(i) whether you are willing to make available any intra-building wire, fiber
cabling, or right of access you may have to other telecommunications carriers
for consideration, including the amounts and all terms of that consideration;
U) what other means, if any, you are aware of that could be used by other
telecommunications carriers to access tenants within the location.
MCI-243 For each alternative competitive provider listed in your response to MCI-242, indicate
whether it is an "affiliate" (as defined in 47 USC 9153(1)) of Qwest or of any other
listed alternative competitive provider.
MCI-244
MCI-245
For each location listed in your response to MCI-242, please provide the following
information:
(a) The type alternative loop provisioned and made available.
(b) The exact route of each claimed alternative facility, including the owner of each
facility segment, its date of installation and date of initial operation, the nature
of the alternative competitive provider s ownership/occupancy rights (i.
, "
fee
simple ownership
, "
IRU", etc.), and the identity of any underlying owners or
interest holders in the facility.
(c) Any and all documents in your possession, custody or control that state that
each claimed alternative competitive provider is willing immediately to
provide, on a widely available basis, dedicated DS-3 loop facilities at the
specified location.
(d) The terms, including copies of any governing documents, by which requesting
telecommunications carriers are able to obtain reasonable and
nondiscriminatory access through cross connection to the facilities of the
alternative competitive provider.
Please list each and every customer location which you contend should be removed
from the list of available DS-3 UNE loop destinations pursuant to FCC Rules
951.319(a)(5)(ii) (potential deployment of alternative facilities.) For each listed
location, please list:
(a) the CLLI code identification of the network endpoint;
(b) the identities of any identified alternative competitive provider;
(c) the exact location of the customer endpoint;
(d) all persons owning an interest in or controlling access to the customer location;
(e) whether the location is a single-tenant or multi-tenant facility;
MCl's DISCOVERY REQUESTS TO QWEST -
MCI-246
MCI-247
MCI-248
(f) all documents or information in your possession, custody or control regarding
any and all rights of access either you or any other telecommunications carrier
may have within the location;
(g) whether you claim ownership or control over any intra-building wire, fiber
cabling, or right of access;
(h) whether you are willing to make available any intra-building wire, fiber
cabling or right of access you may have to other telecommunications carriers at
no cost;
(i) whether you are willing to make available any intra-building wire, fiber
cabling, or right of access you may have to other telecommunications carriers
for consideration, including the amounts and all terms of that consideration;
G) what other means, if any, you are aware of that could be used by other
telecommunications carriers to access tenants within the location.
For each location listed in your response to MCI-245 , please provide copies of all
documents and information in your possession, custody or control relating to:
(a) local engineering costs of building and utilizing loop facilities;
(b) the cost of underground or aerial laying of fiber or copper;
(c) the cost of equipment needed for loop facilities; installation and other necessary
costs involved in setting up service;
(d) relevant local topography such as hills and rivers;
(e) availability of reasonable access to rights-of-way;
(f) availability/feasibility of similar quality/reliability alternative loop technologies
along the particular route;
(g) customer density and addressable market; and
(h) existing facilities-based competition.
For each alternative competitive provider listed in your response to MCI-245 and for
each provider of any existing facilities-based competition listed in your response to
MCI-246(h), indicate whether it is an "affiliate" (as defined in 47 USC 9153(1)) of
Qwest or of any other listed alternative competitive provider.
Please list each and every customer location which you contend should be removed
from the list of available Dark Fiber UNEs pursuant to FCC Rules ~51.319(a)(6)(i)
(existence of alternative self-provisioned facilities.) For each listed location, please
list:
(a) the CLLI code identification of the network endpoint;
(b) the identities of each claimed alternative competitive provider;
(c) the exact location of the customer endpoint;
(d) all persons owning an interest in or controlling access to the customer location;
(e) whether the location is a single-tenant or multi-tenant facility;
(f) all documents or information in your possession, custody or control regarding
any and all rights of access either you or any other telecommunications carrier
may have within the location;
(g) whether you claim ownership or control over any intra-building wire, fiber
cabling, or right of access;
MCI's DISCOVERY REQUESTS TO QWEST -
(h) whether you are willing to make available any intra-building wire, fiber
cabling or right of access you may have to other telecommunications carriers at
no cost;
(i) whether you are willing to make available any intra-building wire, fiber
cabling, or right of access you may have to other telecommunications carriers
for consideration, including the amounts and all terms of that consideration;
G) what other means, if any, you are aware of that could be used by other
telecommunications carriers to access tenants within the location.
MCI-249 For each alternative competitive provider listed in your response to MCI-248, indicate
whether it is an "affiliate" (as defined in 47 USC 9153(1)) of Qwest or of any other
listed alternative competitive provider.
MCI-250
MCI-251
For each location listed in your response to MCI-248, please provide the following
information:
(a) The type of alternative loop provisioned and made available.
(b) The exact route of each claimed alternative facility, including the owner of each
facility segment, its date of installation and date of initial operation, the nature
of the alternative competitive provider s ownership/occupancy rights (i.
, "
fee
simple ownership
, "
IRU", etc.), and the identity of any underlying owners or
interest holders in the facility.
(c) Any and all documents in your possession, custody or control that state that
each claimed alternative competitive provider is operationally ready to use the
listed loop facilities to provide dedicated Dark Fiber loop facilities at the
specified location.
Please list each and every customer location which you contend should be removed
from the list of available Dark Fiber UNEs pursuant to FCC Rules 951.319(a)(6)(ii)
(potential deployment of alternative facilities.) For each listed location, please list:
(a) the CLLI code identification of the network endpoint;
(b) the identities of each claimed alternative competitive provider;
(c) the exact location of the customer endpoint;
(d) all persons owning an interest in or controlling access to the customer location;
(e) whether the location is a single-tenant or multi-tenant facility;
(t) all documents or information in your possession, custody or control regarding
any and all rights of access either you or any other telecommunications carrier
may have within the location;
(g) whether you claim ownership or control over any intra-building wire, fiber
cabling, or right of access;
(h) whether you are willing to make available any intra-building wire, fiber
cabling or right of access you may have to other telecommunications carriers at
no cost;
(i) whether you are willing to make available any intra-building wire, fiber
cabling, or right of access you may have to other telecommunications carriers
for consideration, including- the amounts and all terms of that consideration;
MCI's DISCOVERY REQUESTS TO QWEST -
MCI-252
MCI-253
MCI-254
MCI-255
U) what other means, if any, you are aware of that could be used by other
telecommunications carriers to access tenants within the location.
For each location listed in your response to MCI-251 , please provide copies of all
documents and information in your possession, custody or control relating to:
(a) local engineering costs of building and utilizing loop facilities;
(b) the cost of underground or aerial laying of fiber or copper;
(c) the cost of equipment needed for loop facilities; installation and other necessary
costs involved in setting up service;
(d) relevant local topography such as hills and rivers;
(e) availability of reasonable access to rights-of-way;
(t) availability/feasibility of similar quality/reliability alternative
(g) loop technologies along the particular route;
(h) customer density and addressable market; and
(i) existing facilities-based competition.
For each alternative competitive provider listed in your response to MCI-251 and for
each provider of any existing facilities-based competition listed in your response to
MCI-252(h), indicate whether it is an "affiliate" (as defined in 47 USC 9153(1)) of
Qwest or of any other listed alternative competitive provider.
Please describe and provide supporting documents for any state or locally enacted or
enforced limitations on or barriers to entry by competing providers ofDS-, DS-
OC-n, or Dark Fiber loop, including, but not limited to, any moratoria or
restrictions on construction or access to rights of way. Include all relevant legal
provisions and a description of any Qwest deployment or construction projects
which have been undertaken since the enactment of the restriction or moratoria.
Describe the steps taken or qualifications met in order for the identified Qwest
projects to either comply with or avoid the effects of the restriction or moratoria.
For each location identified in your responses to MCI-236 through MCI-251 , please
provide the following information:
(a) All forecasts of Qwest expected, estimated, anticipated, or forecasted demand
growth or decline for all classes of loop facilities. To the extent you have
information disaggregated by type of customer or demand (e.
, "
business
data
, "
UNE"
, "
special access , or other categories) please provide such
disaggregated figures. To the extent different documents may provide differing
figures, estimates, or forecasts based upon the impact or implementation of any
regulatory or judicial action (including, but not limited to, the Triennial Review
Order and related proceedings) provide all such figures, estimates, and
forecasts, identifying which relate to which different regulatory or judicial
outcomes;
MCI's DISCOVERY REQUESTS TO QWEST-60
MCI-256
MCI-257
(b) Qwest's current loop capacity utilization , including total number and type of
fibers or copper cabling;
(c) number of "unlit" or "dark" fibers;
(d) number of "lit" fibers with the current transmission level implemented for each
(i., which OCn level);
(e) current utilization of copper wire, if any, including identification and capacity
of implemented digital and analog loop capability;
(f) identification of unused copper facilities, if any.
Please provide the following information for each fiber or conduit deployment project
by Qwest in Idaho since January 1 , 2000:
(a) type, size, and capacity of conduit installed along all or any separate portion of
the route;
(b) type and number of fibers initially installed along all or any separate portion of
the route
(c) type and number of fibers for each and every subsequent installation along all
or any portion of the route;
(d) all available budgetary and actual cost data for both initial and any subsequent
installations, including all costs for permits, authority, ROW, lobbying, public
policy, excavation, trenching, boring, backfill, surface repair, remediation, vault
construction, termination, payments-in-kind, related usage rights, materials
(including conduit and cabling), and any other expenses necessary to the
project.
Please provide the following information for each planned fiber or conduit deployment
project by Qwest in Idaho for the next 3 years: (Include in this response any
current projects not included in MCI-256, as well as future projects.
(a) type, size, and capacity of conduit to be installed along all or any separate
portion of the route;
(b) type and number of fibers to be initially installed along all or any separate
portion of the route
(c) type and number of fibers for each and every planned subsequent installation
along all or any portion of the route;
(d) all available budgetary cost data and estimates for both initial and any
subsequent installations, including all costs and estimates for permits, authority,
ROW, lobbying, public policy, excavation, trenching, boring, backfill, surface
repair, remediation, vault construction, termination, payments-in-kind, related
usage rights, materials (including conduit and cabling), and any other expenses
necessary to the project.
MCI-258 Please provide copies of all contracts, agreements, tariffs, or other governing
documents by which Qwest:
MCI's DISCOVERY REQUESTS TO QWEST -
(a) sells, rents, leases, or otherwise provides telecommunications loop facilities to
others in Idaho;
(b) buys, rents, leases, or otherwise acquires loop facilities from others in Idaho.
MCI-259 With respect to all documents identified in your response to MCI-258 , please provide
quarterly totals since January 1 2000 of the amount of loop capacity provided or
acquired, identifying the quantity, route , and opposite party for each segment.
MCI-260 Please describe in detail any price floor(s) or other limitation(s) imposed by any law
regulation, Idaho PUC orders or rulings that constrain Qwest's ability to reduce
prices for each of the following:
(a) dark fiber loop service
(b) OC-n level loop service
(c) DS-3 loop service and
(d) DS-1100p service. For each such price floor or other limitation, provide the
basis for the calculation for the price floor or other limitation (e., price freeze
cost-based calculation, etc.
MCI-261 Please provide a description and supporting documentation for all Qwest currently
offered bundles and volume discounts involving the following: a) dark fiber loop
service, b) OC-n level loop service, c) DS-3 loop service and d) DS-1loop service.
MCI-262 Please provide a description and supporting documentation for all Qwest planned or
contemplated bundles and volume discounts involving the following: a) dark fiber
loop service, b) OC-n level loop service, c) DS-3 loop service and d) DS-l100p
servIce.
MCI-263 Please provide all documents in your possession, custody or control that address or
assess the risk of stranded loop capacity on all or any portion of Qwest' s existing
network in Idaho.
MCI-264 Please provide a copy of your responses to all audit and data requests that you have
received in this proceeding to date and to any audit and data requests you receive in
the future from other parties in this proceeding.
MCI's DISCOVERY REQUESTS TO QWEST -
Dated this _th day of November, 2003.
MCI's DISCOVERY REQUESTS TO QWEST-63
~i~L~
Dean 1. Miller
McDEVITT & MILLER LLP
420 West Bannock Street
Boise, Idaho 83702
Attorneys for MC/
Certificate of Service
I hereby certify that on the 241h day of November, 2003, I caused to be served by the methodes) indicated
below, the foregoing document upon:
Charles Carrathers
VERIZON NORTHWEST INC.
1800 41st Street
Everett, Washington 98201
Tel:
Fax:
ch uck. carra the rs (iWerizo n. co m
Marlin D. Ard
ATIORNEY AT LAw
O. Box 2190
Sisters, Oregon 977 59
Tel: [phone]
Fax: [phone]
marattv(!Yqwest.net
Mary B. Tribby
Letty S.D. Friesen
AT&T COMMUNICATIONS OF THE MOUNTAIN STATES
1875 Lawrence Street, Suite 1575
Denver, Idaho 80202
Tel: [phone]
Fax: [phone]
lsfriesen(!Yatt.com
Robert M. Pomeroy, Jr.
HOLLAND & HART
8390 East Crescent Parkway, Suite 400
Greenwood Village, Idaho 80111
Tel: [phone]
Fax: [phone]
bpomeroy(!Y h 0 llandandhart. co m
Brian Thomas
TIME WARNER TELECOM
223 Taylor Avenue North
Seattle, Washington 98109
Tel: [phone]
Fax: [phone]
Brian. Thomas(!Ytwtelecom.com
Mary S. Hobson
STOEL RIVES LLP
101 So. Capitol Blvd., Suite 1900
Boise, Idaho 83702
Tel: [phone]
Fax: [phone]
mshobson(!Ystoel.com
MCI's DISCOVERY REQUESTS TO QWEST -
Hand Delivered
S. Mail
Fax
Fed. Express
Email
Hand Delivered
S. Mail
Fax
Fed. Express
Email
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
S. Mail
Fax
Fed. Express
Email
Ii'!
Ii'!
Ii'!
Ii:!
Ii'!
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Certificate of Service
continued
Adam L. Sherr
QWEST
1600 7ili Avenue, Room 3206
Seattle, Washington 98191
Tel: [phone]
Fax: [phone]
asherr(g)qwest.com
Conley E. Ward
GIVENS PuRSLEY, LLP
277 North 6ili Street, Suite 200
O. Box 2720
Boise, Idaho 83701
Tel: [phone]
Fax: [phone]
cew(g)giyensp urs ley. com
Clay R. Sturgis
Moss ADAMS LLP
601 West Riverside, Suite 1800
Spokane, Washington 99201-D663
Tel: [phone]
Fax: [phone]
clay.sturgis(g)mossadams.com
7~'. ftf tt-""
MCI's DISCOVERY REQUESTS TO QWEST -
Hand Delivered
S. Mail
Fax
Fed. Express
Email
Hand Delivered
S. Mail
Fax
Fed. Express
Email
Hand Delivered
S. Mail
Fax
Fed. Express
Email