HomeMy WebLinkAbout200311251st Request of ATT to Qwest.pdf" "
Mary B. Tribby
Letty S.D. Friesen
AT&T Communications of the
Mountain States, Inc.
1875 Lawrence Street, Suite 1575
Denver, Colorado 80202
(303) 298-6475 (phone)
(303) 298-6301 (Fax)
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Robert M. Pomeroy Jr.
Holland & Hart LLP
8390 E. Crescent Parkway, Suite 400
Greenwood Village, CO 80111-2800
Telephone: (303) 290-1622
Facsimile: (303) 290-1606
Attorneys for AT&T
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IPUC RESPONSE TO
FCC ORDER ON REVIEW OF SECTION 251
UNBUNDLING OBLIGATIONS OF
INCUMBENT LOCAL EXCHANGE
CARRIERS (CC DOCKET NO. 01-338
CASE NO. GNR-03-
NINE-MONTH REVIEW ON ECONOMIC
AND OPERATIONAL IMPAIRMENT
REGARDING ACCESS TO SPECIFIC UNES
AT&T COMMUNICATIONS OF THE MOUNTAIN STATES, INC.S FffiST SET
OF DISCOVERY REQUESTS TO QWEST CORPORATION
AT&T Communications of the Mountain States, Inc. ("AT&T") hereby submit
this First Set of Discovery Requests to Qwest Corporation ("Qwest
.,.
INSTRUCTIONS
These data requests shall be deemed to be continuing. You are obliged to
change, supplement, and correct all answers to interrogatories and responses to the
production request to conform to available information, including such information as
first becomes available to you after the answers and production of documents hereto are
filed and made, should additional information become known or should information
supplied in the answers or documents prove to be incorrect or incomplete.
The Response to each data request provided should first restate the
question asked and also identify the person(s) supplying the information.
In answering these data requests, furnish all information that is available
to Qwest or may be reasonably ascertained by Qwest, or otherwise subject to Qwest's
knowledge, possession, custody or control.
If Qwest objects to any part of a request, answer all parts of such requests
to which Qwest does not object, and as to each part to which Qwest does object
separately set forth the specific basis for the objection.
If Qwest claims any form of privilege or other protection from disclosure
as a ground for withholding information responsive to a request, contained in a
document, set forth with respect to the document:
(i)the date and number of pages of the document;
(ii)the identity of the author(s) and/or preparer(s);
(iii)the identity of the addressee, if any;
(iv)the title;
(v)the type of tangible thing (e.letter, memorandum, telegram
chart, report, recording disc);
(vi)the subject matter (without revealing the information as to which
privilege or protection from non-disclosure is claimed);
(vii)the identity of each person who has received the document or to
whom knowledge of the contents of the document was communicated;
(viii) the identity of the present custodian(s);
(ix)the nature of your claim of non-discover ability (e.
g.,
attorney-
client privilege); and
(x)each and every fact on which you rest your claim of privilege or
other protection from disclosure, stated with sufficient specificity to permit
AT &T to make a full determination as to whether the claim is valid.
Please provide your objections in written form no later than fourteen (14)
days from the date of service and your responses in written form no later than twenty-
eight (28) days from the date of service to:
Letty S.D. Friesen
AT &T Law Department
1875 Lawrence Street, Suite 1575
Denver, CO 80202
(303) 298-6301 facsimile
lsfriesen~att. com
Thorvald A. Nelson
Holland & Hart LLP
8390 E. Crescent Parkway, Suite 400
Greenwood Village, CO 80111
303-290-1606 facsimile
tnelson~hollandhart. com
DEFINITIONS
As used herein, the term or terms "document, documentation, data
material and information" shall include, but are not limited to, the following-regardless
of format (e.electronic, paper copy or other form of audio, electronic or visual
recording)-items: correspondence, memoranda, financial data, reports, investigations
studies, plans, communications, notes, notebooks, marginalia, telephone logs, recordings
opinions, decisions, photographs, drawings, sketches, graphic renderings, bulletins
pamphlets, circulars, articles, press releases, video tapes, data compilations, drafts
brochures, and other documents or tangible things of whatever description that may
constitute or contain information within the scope of the data requests, which are in the
possession, custody and control ofthe respondent-including without limitation, any
officers, directors, employees, agents, attorneys or other representatives.
The term or terms "Company, you, your, Qwest or Qwest Corporation
refer to the above captioned entity, Qwest Corporation and its affiliates.
Identify, identity or identification" when used in herein shall mean
provide the full name, title, business address and telephone number of any relevant
individuals or, when used in reference to documentation, shall mean to state the type of
document (e.letter, memorandum, policy, circular, book, etc.) and the location of such
documentation by business address.
Describe" when used with respect to an occurrence, event, activity, or
any transaction, means to provide a complete and detailed list of its nature, its time and
place and to identify the persons present and involved. The term "describe" when used
with respect to a document, means to provide a complete and detailed description of its
nature and content. The term "describe " when used with respect to a communication
other than a document, means to provide a complete and detailed description of its nature
and content.
AT&T 001
DISCOVERY REQUESTS
Re:Switch Triggers - Competitive Wholesale Facilities
Please identify any telecommunications carriers (including Independent Local Exchange
Companies ("ILECs ) or Competitive Local Exchange Companies ("CLECs )) that you
have identified as being willing to provide, intending to provide, or currently making
available, wholesale unbundled local switching used in combination with unbundled
analog loops obtained from the ILEC to CLECs. Additionally, please:
AT&T 002
Produce any documents substantiating any assertion that an unaffiliated
competitive switch provider qualifies as a wholesale provider and
identifying the product, customer and geographic market served by such
wholesale provider.
Identify by wire center each wholesale alternative to ILEC circuit
switching and provide the basis upon which you believe such entity
qualifies as a wholesale provider.
Produce any documents substantiating any assertion that a non-ILEC
wholesale circuit switching provider is operationally ready to provide
wholesale switching and that such provider and the ILEC have procedures
in place to enable a carrier purchasing an ILEC analog loop to provide
service of equivalent quality using another non- ILEC carrier s switch.
Produce any documents, information, notes, work papers, or
communications from the identified company in your possession or
control relating to the identified company s ability, intent, desire, or
willingness to provide or to make available wholesale unbundled local
switching to CLECs.
Identify any other companies, other than telecommunications carriers, that
are willing to offer wholesale unbundled switching to CLECs. Please
provide the name, address, and telephone number of each identified
companIes.
Re:Switch Triggers - Competitive Wholesale Facilities
For each carrier listed in AT&T 001 , please provide for each switch you claim provides a
wholesale alternative:
The II-digit CLLI code of the switch as it appears in the LERG, the V &H
coordinates of the switch from the LERG, and claimed function of the
switch (e.
g.,
stand-alone, host, or remote);
For each applicable CLLI code: the associated LATA number; MSA
number (if applicable); the V &H coordinates; the latitude and longitude
(L&L) coordinates; the UNE loop rate zone; the special access density
AT&T 003
zone and whether interstate special access pricing flexibility is applicable
for that end office;
The location of each collocation arrangement that you claim is
interconnected to the switch;
The number ofloops, by type (i.analog UNE, DS-1 UNE, analog
special access, DS-1 Special Access, etc.) provisioned to each collocation:(i) Within the last 3 months;(ii) Within the last 6 months; and
(iii) Within the past year; and
(iv) The number of loops, by type (i.analog UNE, DS-
UNE, analog special access, DS-1 Special Access, etc.) in-
service at each collocation as of September 30, 2003.
Re:Switch Triggers - Self Provisioning
Identify by wire center each unaffiliated competitive switch provider that you assert
qualifies as a retail self provider and detail the basis upon which you believe such entity
qualifies as a self provider, including the geographic markets within which each
unaffiliated competitive switch provider is providing service and the product and
customer markets reached by each unaffiliated competitive switch provider.
AT&T 004
Produce any documents substantiating any assertion that an unaffiliated
competitive switch provider qualifies as a self provider and include the
product, customer and geographic market served by such self provider;
Identify by wire center each wholesale alternative to ILEC circuit
switching and provide the basis upon which you believe such entity
qualifies as a self-provider; and
Produce any documents, information, notes, work papers, or
communications from the identified company in your possession or
control relating to the identified company s ability, intent, desire, or
willingness to provide or to make available wholesale unbundled local
switching to CLECs.
Re:Switch Triggers - Self Provisioning
For each carrier listed in the previous question, please provide for each switch you claim
is used for self provisioning:
The II-digit CLLI code of the switch as it appears in the LERG, the V &H
coordinates of the switch from the LERG, and claimed function of the
switch (e., stand-alone, host, or remote);
For each applicable CLLI code: the associated LATA number; MSA
number (if applicable); the V&H coordinates; the L&L coordinates; the
UNE loop rate zone; the special access density zone and whether interstate
special access pricing flexibility is applicable for that end office;
The location of each collocation arrangement that you claim is
interconnected to the switch;
AT&T 005
The number of loops, by type (i. e.analog UNE, DS-1 UNE, analog
special access, DS-1 Special Access, etc.) provisioned to each collocation:(i) Within the last 3 months(ii) Within the last 6 months
(iii) Within the past year; and
(iv) The number of loops, by type (i.analog UNE, DS-1 UNE
analog special access, DS-1 Special Access, etc.) in-service at each
collocation as of September 30, 2003.
Re:Network and Market Demand - Switch Information
For each switch (e.
g.
circuit, packet, soft switch, etc.) that you have used or could use to
provide local service in Idaho (this would include switches located in other states that
provide or have the ability to provide local exchange service in Idaho) please provide the
following information for the switch and/or the switch location:
AT&T 006
the physical location of each switch (i.the street address);
the area the switch serves (by wire center);
the services provided by the switch;
the utilized trunk line, trunk and processor capacity;
the potential line, trunk and processor capacity;
Re:Network and Market Demand - Switch Information
For each switch identified in AT&T 005 , provide the following information:
AT&T 007
the total number of voice-grade equivalent lines served by the switch (by
wire center)
the number of voice-grade equivalent lines being provided to business
customers
the number ofDSO voice-grade equivalent lines being provided to
business customers
the number of voice-grade equivalent lines being provided to residential
customers
the switch type (e.
g.,
Lucent 5ESS);
Re:Network and Market Demand - Switch Information
For each switch identified in AT&T 005, provide the following information:
the II-digit Common Language Location ("CLLI") code of the switch;
the vertical and horizontal ("V &H") coordinates of the switch;
function of the switch (e.
g.,
stand-alone, host, or remote); and
whether each CLLI offers International Direct Distant Dialing ("IDDD"
AT&T 008 Re:Network and Market Demand - Switch Information; Out of
Region
For each switch (e.
g.,
circuit, packet, soft switch, etc.) that you have used or could use to
provide local service outside of the territory for which you are an incumbent please
provide the following information for the switch and/or the switch location:
AT&T 009
the physical location of each switch (i.the street address);
the area the switch serves (by wire center);
the services provided by the switch;
the utilized trunk line, trunk and processor capacity; and
the potential line, trunk and processor capacity;
Re:Network and Market Demand - Switch Information; Out of
Region
For each switch identified in AT&T 008, provide the following information:
AT&T 010
the total number of voice-grade equivalent lines served by the switch (by
wire center);
the number of voice-grade equivalent lines being provided to business
customers;
the number ofDSO voice-grade equivalent lines being provided to
business customers;
the number of voice-grade equivalent lines being provided to residential
customers; and
the switch type (e.
g.,
Lucent 5ESS);
Re:Network and Market Demand - Switch Information; Out of
Region
For each switch identified in AT&T 008, provide the following information:
AT&T 011
the II-digit CLLI code of the switch;
the vertical and horizontal V &H coordinates of the switch;
function of the switch (e.stand-alone, host, or remote); and
whether each CLLI offers IDDD.
Re:Network and Market Demand - Switches, Upgrades
During the past 5 years, have you ever added processor capacity or peripheral equipment
to one or more of your local switches due to:
Increased usage; or
Exhaust of the number of end-user lines that could be connected to the
switch.
AT&T 012 Re:Network and Market Demand - Switches, Upgrades
If the answer to either part of AT&T 011 is yes, please identify each instance and:
AT&T 013
The nature of the upgrade performed.
Whether you had other end-office switches within a 15-mile radius with
capacity to handle additional lines.
If the answer to b. is yes, whether you considered off-loading subscriber
lines from the switch requiring the upgrade, and serving those lines from a
different local switch. If you did not consider doing so, why not?
If the answer to c. above is yes, produce any documents that refer, relate
, or discuss your consideration of off-loading such lines to a different
local switch.
Re:Network and Market Demand - Switches
What engineering guidelines and/or standards do you use to determine when, if ever, to
serve customer lines from a switch other than the switch located at the customer s serving
wire center?
AT&T 014
Under what conditions, if any, would you consider serving lines from a
switch other than the one located in the customer s serving wire center?
Please produce a copy of your switch engineering guidelines.
Re:Network and Market Demand - Switches, Foreign Exchange
Do you currently provide any customers local exchange service, other than for foreign
exchange service, from a switch located at a place other than the customer s serving wire
center? If yes, identify:
AT&T 015
The wire centers and the number of affected lines at each of those wire
centers;
The circumstances that caused you to offer service in this manner; and
Any additional charges imposed on the customer for this serving
configuration.
Re:Network and Market Demand - Loops
Provide the number of loops, by Central Office (by applicable CLLI code), in Idaho that
are currently served by each of the following:
IDLC arrangements;
NGDLC arrangements;
UDLC arrangements; and
Of the IDLC loops, please state how many loops are transferable to
universal digital loop carrier (UDLC) without additional construction.
AT&T 016 Re:Network and Market Demand - Loops
Provide a forecast for the next five years, or the longest available forecast if a five-year
forecast is not available, identifying the number ofloops in Idaho that you intend to serve
VIa:
AT&T 017
IDLC loop arrangements; and
NGDLC loop arrangements.
Re:Network and Market Demand - Loops
Are there any customers being served via UNE-P today that could not be served via
UNE-L (for example, ifthere were no copper to replace UDLC, etc.)? If so, please
provide in detail the reasons why such customers could not be served via UNE-
including the number of such customers by wire center or by CLLI code.
AT&T 018 Re:Network and Market Demand - NGDLC
Have you considered deploying NGDLC arrangements that packetize both the voice and
data services? If so, please describe any such alternatives considered and produce any
documents that refer, relate to or discuss your deployment ofNGDLC arrangements that
packetize both the voice and data services.
AT&T 019 Re:Network and Market Demand - DSL Capable Loops
By wire center, please provide the percentage of copper loops that are located within
000 feet of Qwest' s Central Offices.
AT&T 020 Re:Network and Market Demand - Loops, Line Splitting
Identify the overall number and percentage of loops in Qwest territory in Idaho that are
currently provisioned on:
AT&T 021
All-copper loop facilities without pair-gain devices of any type (e.
g.,
analog pair gain, DAMLs, etc.
All-copper loop facilities with pair gain devices.
All-copper loop facilities less than 18K feet in length.
All-copper loop facilities greater than 18K feet in length.
Re:Network and Market Demand - Loops, Line Splitting
Identify the overall number and percentage of loops in Qwest territory in Idaho that are
currently provisioned on:
Fiber-fed DLC facilities that do not support DSL.
Fiber-fed DLC facilities that do or will support DSL.
AT&T 022 Re:Network and Market Demand - Copper Loops, DLC
Please provide the number of lines served by DLC for which alternative copper loop
facilities are currently not available.
AT&T 023 Re:Network and Market Demand - Copper Loops, Retirement
Describe with specificity your plans to retire any copper loop plant in Idaho.
AT&T 024 Re:Network and Market Demand - Copper Loops, Retirement
Please provide a copy of any studies, reports, memorandum, email or documents
describing your plans to retire any copper loop plant in Idaho.
AT&T 025 Re:Network and Market Demand - Copper Loops, Retirement
Please describe with specificity the process you use in retiring a copper loop plant.
Please specifically include in your answer the notice you provide to CLECs who have
customers that provide service using the plant and what options will be available to
CLECs providing voice and/or DSL service to customers served by the copper loop plant
you plan to retire.
AT&T 026 Re:Network and Market Demand - Availability, TIs
For each month beginning in January 2000 and extending to the most recent month for
which data is available, provide the following information:
a. The total number of orders for T -1 exchange access linesltrunks that were
rejected due to a determination by you that facilities were not available;
b. The total number of orders for T-1 intraLATA Special Access lines that
were rejected due to a determination by you that facilities were not
available; and
c. The total number of orders for T -1 UNEs that were rejected due to a
determination by you that facilities were not available.
AT&T 027 Re:Network and Market Demand - Availability, TIs
Please provide any written practice(s) or, if no such practice exists, provide a narrative
explaining your practices and policies relative to the rearrangement and reuse of existing
facilities when facilities are initially unavailable at a particular customer location to fulfill
an order for a service requiring a T -1 facility. Indicate whether the same or different
practices apply in the case of retail service orders placed by end users, orders for special
access placed by carriers, or orders for T -1 UNEs placed by carriers, including
IntraLATA Special Access T-, and UNE T-1. In your response, please address the
following circumstances:
The T-1 common equipment has no spare ports/slots, but one or more of
the ports/slots is assigned to a circuit that is no longer in use because
AT&T 028
service has been discontinued. Under your applicable policies and
procedures, could the technician reuse such a port/slot in order to fulfill
the new order? Describe any differences that might occur as between
orders for IntraLATA Special Access T-, and UNE T-
There is no unassigned T -1 copper or fiber distribution facility available to
fulfill the order, but one or more T -1 distribution facilities along the route
passing the customer location is assigned to a circuit that formerly served
a customer at a nearby location, but is no longer in use because that
service had been discontinued. Under your applicable policies and
procedures, could the technician reuse such a distribution facility in order
to fulfill the new order? Describe any differences that might occur as
between orders for IntraLATA Special Access T-, and UNE T-
Re:Network and Market Demand - Interoffice Traffic
In Idaho, please identify, by name and location, each of your Central Offices that do not
have fiber connectivity for purposes of interoffice transport.
AT&T 029 Re:Network and Market Demand - Remote Terminals
In Idaho, please provide your current total number of Remote Terminals.
AT&T 030 Re:Network and Market Demand - CLEC Resale Lines
For each of the serving methods listed below, provide the total number ofDS-O (or voice
grade analog) lines in each wire center being served by CLECs:
AT&T 031
Resale Residential; and
Resale Business;
Re:Network and Market Demand - CLEC UNE-L Lines
For each of the serving methods listed below, provide the total number ofDS-O (or voice
grade analog) lines in each wire center being served by CLECs:
AT&T 032
UNE-L Residential; and
UNE-L Business;
Re:Network and Market Demand - CLEC UNE-P Lines
For each of the serving methods listed below, provide the total number ofDS-O (or voice
grade analog) lines in each wire center being served by CLECs:
UNE-P Residential; and
UNE-P Business
AT&T 033 Re:Network and Market Demand - Request for Interconnection
Identify any instances where you initiated a request for interconnection with a CLEc.
F or each such instance, provide the identity of the CLEC, the date at which such request
was first made to the CLEC, the date at which the CLEC responded with a draft or
template interconnection agreement, the date at which you provided your responsive
comments/red-lines to the draft or template agreement, whether and the date at which an
interconnection agreement was successfully negotiated between you and the CLEc.
the event that no such successful negotiation took place, indicate what subsequent actions
or initiatives were taken by you (e.mediation, arbitration) to secure an agreement, and
the current status of the agreement or lack thereof.
AT&T 034 Re:Network and Market Demand - Business Customers
With regard to business customer locations that you serve using 24 or fewer analog lines
for the most recent quarter available, delineate, by wire center, the business customers by
the number of such analog lines, through and including those business premises with 24
analog lines (i.identify those with a single line, two analog lines, three analog lines
etc. through 24 analog lines). Also, with regard to business customer locations using
more than 24 analog lines, for the most recent quarter available, delineate, by wire center
the number of business customer locations and the average total lines in those locations.
AT&T 035 Re:Network and Market Demand - Number of Residential and
Business Lines
Provide separately the number of primary and secondary residential and DSO-equivalent
business switched exchange access lines for end of year 1996 through 2002 and for year
2003 through September 30 2003.
AT&T 036 Re:Network and Market Demand - Number of Access Lines
Specify by wire center and, within each wire center, by UNE and retail rate zone, if
applicable, the number of primary, secondary and total switched exchange access lines
disaggregated by month from January 1999 to present.
AT&T 037 Re:Network and Market Demand - Residential Access Lines
Provide, by wire center and by exchange:
AT&T 038
the total residential access lines subscribed to each category of local
exchange service (i.message rate, flat rate, etc.), by Rate Group;
the total access lines subscribed to Lifeline service;
The average monthly minutes for use of subscribers to Flat Rate service
by Rate Group;
Re:Network and Market Demand - Residential Access Lines
Provide, by wire center and by exchange:
AT&T 039
The average monthly number of message units for subscribers to Message
Rate service, by Rate Group;
The total residential access lines by wire center not subscribed to an
optional local calling package plan; and
The average monthly billed amount to those residential access lines not
subscribed to an optional calling plan.
Re:Network and Market Demand - Minutes of use per Line
Please provide the current average total monthly minutes of use separately for business
and residential lines by wire center and provide a complete breakdown of each category
of usage by type (e.
g.,
local, intraLATA intrastate, intraLATA interstate, interLATA
intrastate, interLATA interstate, international, 800 service, etc.
AT&T 040 Re:Network and Market Demand - Number of Residential and
Business Lines
Please provide the current average number of voice grade equivalent lines you provide
per residential and business customer in Idaho.
AT&T 041 Re:Network and Market Demand
Please provide a copy of the completed Part II (Wireline and Fixed Wireless Local
Telephone) to the FCC's Form 477 (Local Competition and Broadband Reporting Data
Request) with data as of June 2003 for Idaho.
AT&T 042 Re:Network and Market Demand
Please provide a copy of the completed Part II (Wireline and Fixed Wireless Local
Telephone) to the FCC's Form 477 (Local Competition and Broadband Reporting Data
Request) with data as of June 2003 for Idaho.
AT&T 043 Re:Customer and Economic Market Forces - Average Residential
Revenue
For each year 1996 inclusive through 2002, and for 2003 through September 30 2003
please provide the following average revenue, per residential customer and per residential
line identified in response to AT&T 035 , received by you and/or your corporate
predecessor, by wire center separately for:
Local exchange service;
Discretionary services, including vertical services;
IntraLA T A toll revenues;
Intrastate switched access revenues, identifying separately intraLA T
access revenues from interLAT A access revenues; and
AT&T 044
Interstate switched access revenues, identifying separately intraLAT A
access revenues from interLAT A access revenues.
Nonregulated services furnished in connection with, and billed to, the
subscriber access line (e.
g.,
voice mail, inside wire maintenance, OS/DA).
Reciprocal compensation;
Data services, and
DSL
Re:Customer and Economic Market Forces Average Business
Revenue
For each year 1996 inclusive through 2002, and for 2003 through September 30 2003
please provide the following average revenue, per business customer and per business
line identified in response to AT&T 035 , received by you and/or your corporate
predecessor, by wire center separately for:
AT&T 045
Local exchange service;
Discretionary services, including vertical services;
IntraLAT A toll revenues;
Intrastate switched access revenues, identifying separately intraLAT A
access revenues from interLAT A access revenues; and
Interstate switched access revenues, identifying separately intraLAT A
access revenues from interLAT A access revenues.
Nonregulated services furnished in connection with, and billed to, the
subscriber access line (e.voice mail, inside wire maintenance, OS/DA).
Reciprocal compensation;
Data services, and
DSL
Re:Customer and Economic Market Forces - "Take Rates
Please provide the average "take rate " by wire center, for intraLATA toll, interLATA
toll, vertical features (by feature), inside wire maintenance, voice mail and DSL service
AT&T 046 Re:Customer and Economic Market Forces - IntraLATA toll
usage, Residential
By wire center, provide the total number of your intraLATA toll residential customers
with average intraLA T A toll usage of:
Less than 30 minutes per month;
30 to 60 minutes per month;
60 to 120 minutes per month;
AT&T 047
120 to 180 minutes per month; and
More than 180 minutes per month.
Re:Customer and Economic Market Forces - IntraLA TA toll
usage, Business
By wire center, provide the total number of your intraLATA toll business DSO loop
customers with average intraLA T A toll usage of:
AT&T 048
Less than 30 minutes per month;
30 to 60 minutes per month;
60 to 120 minutes per month;
120 to 180 minutes per month; and
More than 180 minutes per month.
Re:Customer and Economic Market Forces - InterLATA toll
usage, Residential
By wire center (or other disaggregated geographic breakout) provide the total number of
your long distance affiliates' interLAT A residential customers with average interLAT A
usage of:
AT&T 049
AT&T 050
Less than 30 minutes per month;
30 to 60 minutes per month;
60 to 120 minutes per month;
120 to 180 minutes per month; and
More than 180 minutes per month.
Re:Customer and Economic Market Forces - InterLATA toll
usage, Business
By wire center (or other disaggregated geographic breakout) provide the total
number of your long distance affiliates ' interLATA business DSO loop customers
with average interLATA usage of:
Less than 30 minutes per month;
30 to 60 minutes per month;
60 to 120 minutes per month;
120 to 180 minutes per month; and
More than 180 minutes per month.
Re:Customer and Economic Market Forces - InterLATA toll
revenues
Provide the average interLATA and intraLATA revenue per subscriber for your long
distance affiliates, by wire center.
for residential customers;
for business DSO loop customers.
AT&T 051 Re:Customer and Economic Market Forces - Switched Access
Identify any local exchange carriers in Idaho other than you from which any of your long
distance affiliates intend to or already have agreed to purchase switched carrier access
services, and specify precisely what types of switched access services will be purchased
from each such carrier.
AT&T 052 Re:Customer and Economic Market Forces - Qwest Toll Services
Does Qwest or any of its long distance affiliates provide interLATA and intraLATA
services in Idaho to customers served by other local exchange carriers? If so, indicate
which other LEC customers will be able to obtain intraLATA and interLATA long
distance services from Qwest or its long distance affiliates.
AT&T 053 Re:Competitive and Economic Market Forces - Switching
Have you ever considered leasing switching capacity from a third party to provide retail
servIces:
Within your certificated incumbent territory (i. e.in-region)?
Outside your certificated incumbent territory (i.out-of-region)?
AT&T 054 Re:Competitive and Economic Market Forces- Substitutable
Services
For each mass market service you offer, identify every provider that actively offers
services that you consider substitutes, excluding wireless providers and services. For
each competitive service identified, provide your exchanges and/or wire centers where
the substitute is currently being offered.
AT&T 055 Re:Competitive and Economic Market Forces - Substitutable
Services
For each business service you offer, identify every provider that actively offers services
that you consider substitutes, excluding wireless providers and services. For each service
identified, provide your exchanges and/or wire centers where the substitute is currently
being offered.
AT&T 056 Re:Competitive and Economic Market Forces - Fixed Wireless
Do you contend that all of the business services you now provide can be provided over
fixed wireless in Idaho? If so, do you contend that fixed wireless facilities are available
to provide commercial volumes of business services in Idaho?
AT&T 057 Re:Competitive and Economic Market Forces - Winback
What period oftime do you use to define a winback (and therefore churn)? How many
mass-market local winbacks have you achieved in Idaho by quarter since 1999? What
percentage of those customers receive a bundle of services that include interLA T A long
distance service?
AT&T 058 Re:Competitive and Economic Market Forces - OSS
Do you have pre-ordering and ordering processes that allow a CLEC to use one
wholesale provider for switching and another for the loop, or otherwise use multiple
vendors in its service arrangement? If so, please provide a copy of any documents
describing the processes identified.
AT&T 059 Re:Competitive and Economic Market Forces - Costs
Please provide your variable costs and marginal costs for local, long distance and
broadband services individually and as part of a bundled offering.
AT&T 060 Re:Customer and Economic Market Forces - Cost of Basic
Exchange Service
Do you contend that your current rates for any basic exchange service in any area is
below your cost to provide that service? If so, please identify each such scenario
location and the price that you would need to charge to recover your costs. Please also
provide the basis for this analysis.
AT&T 061 Re:Network and Market Demand - Average Cost Per Line
Provide the average total cost per line for each of the past two years that Qwest has
incurred to install and maintain lines used to serve mass market customers (residential
customers and business customers that are served by 1-3 voice-grade equivalent lines at
one location, or are otherwise included in the definition of mass market customer as
determined by the Idaho Commission. Provide a breakdown of each cost component
(e.investment-related costs, network operations, maintenance, and SG&L) that is part
of the average total cost per line, identifying the type and amount of each cost. Produce
all documents that reflect, refer or relate to the information provided in your response to
this request.
AT&T 062 Re:Competitive and Economic Market Forces - Costs, Transport
For each of the last 10 new interoffice fiber facilities that you have constructed in Idaho
please provide:
The initial project business case;
Any requests for bids and all responsive documents;
A complete description ofthe project including routes and materials
requirements; and
AT&T 063
Final "actual" booked costs for the project.
Re:Competitive and Economic Market Forces - Price Reductions
Identify and describe any constraints (if any) on your ability to:
AT&T 064
Reduce prices in relation to some measure of cost (e.price floor based
on TELRIC);
Target price reductions to geographic areas; and
Target price reductions to types of customers (including individual
customers).
Re:Competitive and Economic Market Forces - Competitive
Responses
Produce any documents referring or relating to any pricing offers, advertising campaigns
packaged offerings, waiver of fees, term contract offerings, marketing strategies you have
evaluated or implemented in consideration of one or more CLEC's planned or actual
entry into a local service market.
AT&T 065 Re:Competitive and Economic Market Forces - Line Growth
On an individual Central Office, end office, and serving wire center basis, please provide
the recent history of line growth/line loss for:
AT&T 066
Primary voice lines;
Additional voice lines; and
Broadband/data lines.
Re:Competitive and Economic Market Forces - Financial
Information by Services
For each year 1996 through 2002 inclusive, and for this year through September 30
2003 , please provide the following financial information: (i) total operating revenues; (ii)
total operating expenses; (iii) average Telephone Plant in Service (TPIS); (iv) average net
investment/net telephone plant; (v) realized return on investment as well as return on
equity for you and/or for your corporate predecessor, separately, for total company all
services (regulated and nonregulated).
AT&T 067 Re:Competitive and Economic Market Forces - Financial
Information by Services
For each year 1996 through 2002 inclusive, and for this year through September 30
2003, please provide the following financial information: (i) total operating revenues; (ii)
total operating expenses; (iii) average Telephone Plant in Service (TPIS); (iv) average net
investment/net telephone plant; (v) realized return on investment as well as return on
equity for you and/or for your corporate predecessor, separately, for jurisdictionally
intrastate regulated services.
AT&T 068 Re:Competitive and Economic Market Forces - Financial
Information by Services
For each year 1996 through 2002 inclusive, and for this year through September 30
2003, please provide the following financial information: (i) total operating revenues; (ii)
total operating expenses; (iii) average Telephone Plant in Service (TPIS); (iv) average net
investment/net telephone plant; (v) realized return on investment as well as return on
equity for you and/or for your corporate predecessor, separately, for jurisdictionally
interstate regulated services.
AT&T 069 Re:Competitive and Economic Market Forces - Financial
Information by Services
For each year 1996 through 2002 inclusive, and for this year through September 30
2003, please provide the following financial information: (i) total operating revenues; (ii)
total operating expenses; (iii) average Telephone Plant in Service (TPIS); (iv) average net
investment/net telephone plant; (v) realized return on investment as well as return on
equity for you and/or for your corporate predecessor, separately, for total company
regulated services.
AT&T 070 Re:Competitive and Economic Market Forces - Financial
Information by Services
For each year 1996 through 2002 inclusive, and for this year through September 30
2003, please provide the following financial information: (i) total operating revenues; (ii)
total operating expenses; (iii) average Telephone Plant in Service (TPIS); (iv) average net
investment/net telephone plant; (v) realized return on investment as well as return on
equity for you and/or for your corporate predecessor, separately, for services classified as
Non-Regulated per 47 C.R. 64.901.
AT&T 071 Re:Competitive and Economic Market Forces - Financial
Information by Services
For each year 1996 through 2002 inclusive, and for this year through September 30
2003, please provide the following financial information: (i) total operating revenues; (ii)
total operating expenses; (iii) average Telephone Plant in Service (TPIS); (iv) average net
investment/net telephone plant; (v) realized return on investment as well as return on
equity for you and/or for your corporate predecessor, separately, for services classified as
Non-Regulated by the Idaho commission.
AT&T 072 Re:Competitive and Economic Market Factors - Out-of-Region
Wholesale Switching
Provide any documents that refer, relate to, or discuss the examination or consideration
by you of offering wholesale switching in any out-of-region local market.
AT&T 073 Re:Mass Market - Identification
Identify any and all purposes for which you use each of the following operational
economic, or marketing differentiations:
AT&T 074
LATA;
Wire center;
MSA;
Disaggregated geographic area for performance measurement data
collection and reporting;
Entire state;
Re:Network and Market Demand - Mass Market - Identification
Identify any and all purposes for which you use each of the following operational
economic, or marketing differentiations:
AT&T 075
Entire service area; and
Other level of differentiation (specify).
Re:Mass Market - Identification
Indicate whether local or state governmental agencies, such as Idaho state offices
universities and/or university housing are considered residential customers or mass
market business customers.
AT&T 076 Re:Mass Market - Market Share
Will you rely on any market share studies in Idaho or your territory to contest the FCC'
finding of impairment for mass market switching? If yes, provide the studies.
AT&T 077 Re:Mass Market - Reports and Studies
Will you rely on any third party reports, studies or articles regarding the market presence
of CLEC UNE or facilities-based providers? If yes, provide the reports, studies or
articles.
AT&T 078 Re:Mass Market - Switching, Delisted UNEs
What is the "market rate" that you propose to charge other carriers for access to de-listed
local switching functionality?
Explain the basis for determining the "market rate " including a
description of the market, and any competitors to your switching
functionality.
Explain the source of each difference between the proposed just and
reasonable rate for de-listed local switching and the approved TELRIC
rate.
AT&T 079
Provide the new return-on-equity achieved by the proposed just and
reasonable rate for de-listed local switching.
Re:Mass Market - DSL, UNE -
Please describe with specificity the process by which CLECs offering voice service to a
mass-market customer utilizing unbundled local switching could provide xDSL service
using UNE-L. Please also provide the following information regarding the process:
AT&T 080
Please state whether the process is mechanized or manual. If the process
is mechanized, please state whether the service orders flow through.
orders do flow through, please state the percentage of the service orders
that flow through to completion;
Please list the recurring and nonrecurring charges the CLEC would incur;
Please provide the average service outage experienced by the end user
customer;
Please state whether the loop and switch port would be reused or whether
new facilities would be provisioned; and
Please state whether information in downstream databases, including 911
LIDB and directory listings would be impacted. If your answer is yes
please explain any such effects in detail.
Re:Mass Market - DSL, EELs
Please describe with specificity the process by which CLECs offering voice service to a
mass-market customer utilizing unbundled local switching could provide xDSL service
using EELs. Please also provide the following information regarding the process:
a. Please state whether the process is mechanized or manual. If the process is
mechanized, please state whether the service orders flow through. If orders do
flow through, please state the percentage of the service orders that flow through to
completion;
b. Please list the recurring and nonrecurring charges the CLEC would incur;
c. Please provide the average service outage experienced by the end user customer;
d. Please state whether the loop and switch port would be reused or whether new
facilities would be provisioned; and
e. Please state whether information in downstream databases, including 911 , LIDB
and directory listings would be impacted. If your answer is yes, please explain
any such effects in detail.
AT&T 081 Re:Mass Market - DSL, UNE- L
Please describe with specificity the process by which CLECs offering voice service to a
mass market customer utilizing its own switches could provide xDSL service using UNE-
L. Please also provide the following information regarding the process:
Please state whether the process is mechanized or manual. If the process
is mechanized, please state whether the service orders flow through.
AT&T 082
orders do flow through, please state the percentage of the service orders
that flow through to completion;
Please list the recurring and nonrecurring charges the CLEC would incur;
Please provide the average service outage experienced by the end user
customer;
Please state whether the loop would be reused or whether new facilities
would be provisioned; and
Please state whether information in downstream databases, including 911
LIDB and directory listings would be impacted. If your answer is yes
please explain any such effects in detail.
Re:Mass Market - DSL, EELs
Please describe with specificity the process by which CLECs offering voice service to a
mass market customer utilizing its own switches could provide xDSL service using
EELs. Please also provide the following information regarding the process:
a. Please state whether the process is mechanized or manual. If the process is
mechanized, please state whether the service orders flow through. If orders do
flow through, please state the percentage of the service orders that flow through to
completion;
b. Please list the recurring and nonrecurring charges the CLEC would incur;
c. Please provide the average service outage experienced by the end user customer;
d. Please state whether the loop would be reused or whether new facilities would be
provisioned; and
e. Please state whether information in downstream databases, including 911 , LIDB
and directory listings would be impacted. If your answer is yes, please explain
any such effects in detail.
AT&T 083 Re:Mass Market - DSL
Please describe with specificity the process by which CLECs providing voice and xDSL
service to a mass-market customer utilizing unbundled local switching for the voice
service could perform the following activities:
AT&T 084
Disconnect the data service, but retain the voice service;
Migrate the data service to another provider, but retain the voice service;
Migrate the voice service to another provider, but retain the data service;
and
Disconnect the voice service, but retain the data service.
Re:Mass Market - DSL
For each scenario described in AT&T 083, please also provide the following information:
Please state whether the process is mechanized or manual. If the process
is mechanized, please state whether the service orders flow through.
AT&T 085
orders do flow through, please state the percentage of the service orders
that flow through to completion;
Please list the recurring and nonrecurring charges the CLEC would incur;
Please provide the average service outage experienced by the end user
customer;
Please state whether the loop and switch port would be reused or whether
new facilities would be provisioned; and
Please state whether information in downstream databases, including 911
LIDB and directory listings would be impacted. If your answer is yes
please explain any such effects in detail.
Re:Mass Market - DSL
Please describe with specificity the process by which CLECs providing voice and xDSL
service to a mass-market customer utilizing their own switches and a UNE loop could
perform the following activities:
AT&T 086
Disconnect the data service, but retain the voice service;
Migrate the data service to another provider, but retain the voice service;
Migrate the voice service to another provider, but retain the data service;
and
Disconnect the voice service, but retain the data service.
Re:Mass Market - DSL
For each scenario described in AT&T 085, please also provide the following information:
AT&T 087
Please state whether the process is mechanized or manual. If the process
is mechanized, please state whether the service orders flow through.
orders do flow through, please state the percentage of the service orders
that flow through to completion;
Please list the recurring and nonrecurring charges the CLEC would incur;
Please provide the average service outage experienced by the end user
customer;
Please state whether the loop would be reused or whether new facilities
would be provisioned; and
Please state whether information in downstream databases, including 911
LIDB and directory listings would be impacted. If your answer is yes
please explain any such effects in detail.
Re:Collocation - Experience and History
Provide the following data for each of your Central Offices and Remote Terminals in
which one or more CLECs maintains a collocation presence:
Identification of the wire center (CLLI code);
The area served by the Central Office or Remote Terminal;
AT&T 088
The total number of switched exchange access lines currently being served
at retail by you;
The total amount of space currently being used by collocators; and
The total amount of space available for use by collocators (which does not
include space reserved for you or your affiliates).
Re:Collocation - Experience and History
Provide the following data for each of your Central Offices and Remote Terminals in
which one or more CLECs maintains a collocation presence:
AT&T 089
The number of CLECs collocated in the wire center;
The name(s) of any CLECs collocated in the wire center and the date of
occupancy;
The types of service( s) being offered by each of the collocated CLECs to
their customers (retail local residential, retail local mass market (small)
business, retail data services, retail enterprise services, or wholesale
services (specify nature)); and
The number of residential and business lines that each CLEC serves out of
its collocation space, via UNE-
Specify your policy with respect to disconnecting collocation
arrangements for non-payment.
Re:Collocation - Experience and History
Provide the following data for each of your Central Offices and Remote Terminals in
which one or more CLECs maintains a collocation presence:
AT&T 090
Indicate the number of pending disconnect orders for collocation
arrangements;
Collocation space occupied by CLECs who are no longer operating.
Whether the Central Office is manned or unmanned;
The number of cross-connects in service to the wire center; and
The number ofUNE loops provisioned to each collocating carrier in the
past 3 months.
Re:Collocation - Experience and History
Identify the number of your Central Offices in Idaho in which there are no current
collocation arrangements provided to CLECs. For each identified Central Office, please
identify the name and location of the Central Office, and state whether each such Central
Office is manned or unmanned.
AT&T 091 Re:Collocation - Experience and History
Identify the number of your Central Offices in which more than one CLEC was
collocated in Idaho as of:
AT&T 092
December 31 , 1996;
December 31 , 2000; and
March 31 2003.
Re:Collocation - Availability
What is the maximum number of collocators you can accommodate at each Central
Office and each Remote Terminal in Idaho? If you have not developed this information
what are the variables you would need to consider to make this determination?
AT&T 093 Re:Collocation - Availability
Do you have space for additional physical collocators in every wire center? List those
wire centers in which you cannot accommodate at least 3 more collocators (assuming that
each collocator will require at least a lOx 10 foot cage).
AT&T 094 Re:Collocation - Experience and History
Identify any cases where you have refused collocation requests since January 1 , 2001.
Indicate the ultimate resolution of the dispute.
AT&T 095 Re:Collocation - Use Restrictions
Please describe with specificity any restrictions on the type of equipment that CLECs can
place in a collocation space obtained from Qwest. If restrictions vary by type of
collocation space, please identify such restrictions by type of collocation space.
AT&T 096 Re:Hot Cuts - Historical Quantities
Please provide UNE Loop quantities provisioned for each quarter from January 2001 to
the present, stating for each quarter and each wire center the:
AT&T 097
Average number oflines provisioned on a daily basis;
Fewest number of lines provisioned in a work day; and
Maximum number of lines provisioned in a work day.
Re:Hot Cuts - Quantities and Charges
For UNE Loop lines provisioned for CLECs, identify separately the quantities of
business and residential lines, and the hot cut charges (average per line and total) on a
monthly basis from January 2001 to present, distinguishing between provisioning done
on a project or negotiated basis and those lines not provisioned on a project or negotiated
basis and between those processed as coordinated installation with cooperative testing
versus coordinated installation without cooperative testing.
AT&T 098 Re:Hot Cuts - Capacity
On an individual wire center basis, identify the current total number ofUNE loops per
day that can be provisioned by you, where "provisioned" includes migration of customers
from ILEC-to-CLEC, from CLEC-to-CLEC, and from CLEC-to-ILEC. Identify how the
maximum quantities of lines that may be provisioned mayor may not be dependent on:
(i) how many different CLECs
' "
hot cut" requests are being provisioned on a given day,
(ii) whether requests are being handled on a coordinated installation with cooperative
testing, coordinated installation without cooperative testing, or project/negotiated basis
(iii) how many Central Offices in Idaho have scheduled cutovers on the same day, (iii)
whether you also are processing "winbacks" of customers currently served by CLECs
using UNE-, (iv) whether any of the "hot cuts" are CLEC-to-CLEC migrations, and (v)
any other relevant factors (describe).
AT&T 099 Re:Hot Cuts - Plans to Increase Capacity
Detail any plans to increase current capacity to provision UNE loops. Provide any testing
performed or planned and any studies done or planned (including their underlying
assumptions and supporting data) to determine work force, process and system scalability
to meet an increasing demand for UNE-L provisioning.
AT&T 100 Re:Hot Cuts - Capability
Has Qwest ever communicated to any CLEC the total number of unbundled loop
cutovers Qwest is capable of performing per central office per day? Or in any specific
geographic area per day? If yes, provide the substance of those communications
including all documents relating to limitations on the number of hot cuts that can be
performed. If there are differences in the maximum number of cutovers that can be
performed in a Central Office or geographic area, explain the reasons for the differences.
AT&T 101 Re:Hot Cuts - OSS
Describe current process flows supporting "hot cuts" on a coordinated installation with
cooperative testing, coordinated installation without cooperative testing, and
project/negotiated basis. The description should include any variations that exist when
the customer is served over all-copper facilities, hybrid fiber-copper facilities using
IDLC, and hybrid fiber-copper facilities using UDLC or NGDLC. The description
should include any variations in the process flows depending on whether the provisioning
is a transition of a CLEC customer currently served on UNE-P (same CLEC, a migration
ofa UNE-L served customer to another CLEC's switch (CLEC to CLEC), a transition of
an ILEC customer to CLEC's UNE-L based service (ILEC to CLEC), or a "winback" of
a currently served CLEC UNE-L customer to the ILEC (CLEC to ILEC)).
AT&T 102 Re:Hot Cuts - OSS, Process Improvements
Describe any proposed improvements to your current process flows for "hot cut"
provisioning, including any proposed plans for a batch hot cut process, and the dates by
which such improvements are planned to be proposed and implemented. Described
improvements should cover the scenarios identified in AT&T 113, and specifically
include the TELRIC rate for the process as revised, and a description of the applicable
performance measurement standards.
AT&T 103 Re:Hot Cuts - OSS
Describe and document current and planned OSS functionality and requirements to
support Pre-ordering, Ordering, Provisioning/Status Inquiry and Communication
Maintenance/Repair and Billing for voice-grade, DSL capable, and line-split UNE loops
on all-copper facilities, hybrid fiber-copper facilities using IDLC, and hybrid fiber-copper
facilities using UDLC or NGDLc. Your response should include process flows
requirements, and business rules (identifying data characteristics associated with each
combination ofreq type/activity code) for:
AT&T 104
transitioning an existing customer s service to UNE-L (ILEC to CLEC),
transitioning a customer served on UNE-L by one CLEC to another CLEC
serving a customer using UNE-L (CLEC to CLEC), and
transitioning your existing UNE-P customer to service as a UNE-
customer (same CLEC).
Re:Hot Cuts - OSS, LSR
For your responses to AT&T 115 , detail which Local Service Requests ("LSRs
associated with each scenario will be handled on a fully automated, flow-through basis.
Identify any limitations on the number of lines that can be included on a single UNE-
LSR, and your anticipated proposals for changing such limitations.
AT&T 105 Re:Hot Cuts - OSS, LSR
Does ILEC have in place a single LSR process to migrate UNE loops from ILEC to
CLEC, CLEC to ILEC and CLEC to CLEC for each of the following?
AT&T 106
Voice service;
Data service; and
Voice and data service.
Re:Hot Cuts - OSS, LSR
If Qwest has a single LSR process to migrate UNE loops, state whether the process
provides flow through capability, and provide:
The capacity of each process in terms of number ofUNE loops per day
that can be migrated; and
State the percentage of the service orders that flow through to completion.
AT&T 107 Re:Hot Cuts - OSS, LSR
Does Qwest have plans to increase its capacity to perform single LSR migrations? If so
provide the planned capacity for each type of migration and service.
AT&T 108 Re:Hot Cuts - OSS, LSR
To the extent that you do not today offer CLECs the ability to submit one Local Services
Request (LSR) to support any of the CLEC-initiated scenarios described in AT&T 115
on a one-service order, fully-electronic basis, describe any planned improvements and
identify when you project delivering the new functionality. Include any requirement
changes that may be required, but for which OBF or other standards bodies have not yet
released guidelines, and which may be subject to change management plan requirements.
AT&T 109 Re:Hot Cuts - OSS, LSR
Provide any testing and studies of the scalability of end-to-end electronic systems and
manual OSS processes to migrate customers from one CLEC to another CLEC or to
migrate customers from UNE-P loops to UNE Loops.
AT&T 110 Re:Hot Cuts - OSS
IfUNE-P is unavailable, which ILEC and CLEC systems and processes need to be
established, altered or enhanced to accommodate facilities-based local
telecommunications competition, including but not limited to, updates/upgrades to
PSAP/E911 , NP AC/number portability, directory assistance, directory listings, white
pages, and electronic access to both ILEC and CLEC customer service records?
AT&T 111 Re:Hot Cuts - OSS
Please describe the impact on any of your systems and databases associated with
migrating a UNE Loop used in conjunction with unbundled switching to a UNE Loop
used in conjunction with CLEC provided switching. Please specifically state whether
circuits inventoried as UNE-P loops must be migrated to a different inventory system.
AT&T 112 Re:Hot Cuts - OSS
Is UNE-P treated as a designed or non-designed circuit in your inventory systems? Is
UNE-L treated as a designed or non-designed circuit in your inventory systems? Please
describe the impact of migrating a non-designed circuit to a designed circuit.
AT&T 113 Re:Hot Cuts - Loop Testing
Is MLT testing available with UNE-Loops? Ifnot, what type of testing is available to a
CLEC utilizing UNE-Loops? Must you install test access points for manual testing?
Must the CLEC install terminal equipment? Is there a capacity constraint on the test
access points that can be installed? If so, is the capacity constraint associated with the
manual testing?
AT&T 114 Re:Hot Cuts - OSS
For each month since January 1 , 2001 , provide the number of and the total charges
assessed for unbundled loop cutovers when the "CHC" field on the LSR form is
populated with a ", for existing customers by wire center, separated between each type
or classification of cutover provided by ILEC, including, but not limited to
, "
coordinated
installation with cooperative testing,
" "
coordinated installation without cooperative
testing,
" "
frame due time" or "project coordinated installation" cutovers.
AT&T 115 Re:Hot Cuts - Capability
State the highest number of unbundled loop cutovers, when the "CHC" field on the LSR
form is populated with a "" Qwest has ever performed in a single day for each Central
Office.
AT&T 116 Re:Hot Cuts - Capability
State, for the most recent 30, 60 and 90-day periods forwhich data are available, the
average number of lines Qwest processes on an order when the "CHC" field on the LSR
form is populated with a ". State the time period used to develop the averages
provided and the number of observations used to develop the average.
AT&T 117 Re:Hot Cuts - Personnel Time
Provide the average Qwest personnel time attributable to a single cutover on a single
unbundled loop order, separated between each type or classification of cutover provided
by ILEC, including, but not limited to
, "
coordinated installation with cooperative
testing,
" "
coordinated testing without cooperative testing,
" "
frame due time" or "project
coordinated installation" cutovers.
AT&T 118 Re:Hot Cuts - Personnel Time
Provide the average Qwest personnel time attributable to multiple cutovers contained on
a single unbundled loop order, separated between each type or classification of cutover
provided by ILEC, including, but not limited to
, "
coordinated installation with
cooperative testing,
" "
coordinated installation without cooperative testing,
" "
frame due
time" or "project coordinated installation" cutovers.
AT&T 119 Re:Hot Cuts - OSS
What processes do you have in place with regard to directory listings, E911 and LIDB
when a UNE-P loop is migrated to UNE-Loop? Are there capacity constraints? What is
the process for ensuring the accuracy ofthe records?
AT&T 120 Re:Hot Cuts - Restoration
Describe in detail any process Qwest has to restore service if an end-user experiences
problems resulting in loss of service during a hot cut.
AT&T 121 Re:Hot Cuts - OSS, Winback
Describe process flows supporting, and record and database changes associated with
your "winback" of a customer which had been served by a CLEC using UNE-L. For any
descriptions and documentation relating to "planned" as opposed to presently available
OSS, provide the planned or projected release date.
AT&T 122 Re:Hot Cuts - Winbacks
For each month since January 1999, please provide the number ofloop cutovers by wire
center that resulted in the loop being swung back to your switch, separated by those that
met the provisioning due date, the number within 10 days of the provisioning due date
and the number beyond 10 days of the provisioning due date.
AT&T 123 Re:Hot Cuts - CLEC Complaints
Provide documentation of any process or performance complaints from CLECs regarding
your hot cut procedures and any internal analysis of potential improvements to the hot cut
process you currently use, including any description of planned improvements to the
process.
AT&T 124 Re:Transport - Availability
Identify each instance in the last three years in which Qwest has denied a CLEC request
for UNE interoffice transport in Idaho on the basis of "no facilities available.
AT&T 125 Re:Transport - Availability
Specify the CLLI code for each pair of end offices (if any) between which the CLEC
requested UNE interoffice transport was denied due to "no facilities available." Provide
all documents, information or communications on which Qwest relies for its response to
this request.
AT&T 126 Re:Transport - Availability
Identify each instance in the last three years in which Qwest has delayed provisioning a
CLEC request for UNE interoffice transport on the basis of "no facilities available.
AT&T 127 Re:Transport - Availability
In each instance where provisioning of a CLEC's UNE interoffice transport was delayed
due to "no facilities available" at the time ofthe request, describe in detail why there
were no facilities available at the time ofthe request. How long was each such request
delayed before facilities became available? Provide all documents, information or
communications on which Qwest relies for its response to this request.
Respectfully submitted this 24th of November, 2003.
AT&T COMMUNICATIONS OF THE
MOUNTAIN STATES, INC.
By:
Mary B. Tribby
Letty S.D. Friesen
AT&T Communications of the
Mountain States, Inc.
1875 Lawrence Street, Suite 1575
Denver, Colorado 80202
Telephone: (303) 298-6475
Facsimile: (303) 298-6301
E-mail: 1~Jri~.~~.n..(ill_~1L~Qm
Robert M. Pomeroy Jr.
Holland & Hart LLP
8390 E. Crescent Parkway, Suite 400
Greenwood Village, CO 80111
Telephone: (303) 290-1622
Facsimile: (303) 290-1606
E-mail: rpomeroy~hollandhart. com
CERTIFICATE OF SERVICE
GNR- T -03-
I certify that the original and three copies of AT&T COMMUNICATIONS OF THE
MOUNTAIN STATES, INc.'S FIRST SET OF DISCOVERY REQUESTS TO
QWEST CORPORATION in Docket GNR-03-23 were sent by overnight delivery on
November 24 2003 to:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, ID 83702-5983
jj ewell~puc. state.id. us
And a true and correct copy was sent via overnight delivery on November 24 2003 to:
Brian Thomas
Time Warner Telecom
223 Taylor Ave North
Seattle, W A 98109
Marlin D. Ard
P. O. Box 2190
Sisters, OR 97759
Adam L. Sherr
Qwest
1600 7th Avenue, Room 3206
Seattle, WA 98191
asherr~qwest. com
Clay R. Sturgis
Moss Adams LLP
601 W. Riverside, Suite 1800
Spokane, WA 99201-0663
Dean J. Miller
McDevitt & Miller LLP
420 West Bannock Street
Boise, ID 83702
Charles Carrathers
Verizon Northwest, Inc.
1800 41 st Street
Everett, W A 98201
Mary S. Hobson
Stoel Rives LLP
101 S. Capitol Blvd., Ste 1900
Boise, ID 83702
mshobson~stoel.com
Conley E. Ward
Givins Pursley LLP
277 North 6th Street
Suite 200
Boise, ID 83701
3162033 l.DOC
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