200311261st Response of MCI to Staff.pdf

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Dean J. Miller (ISB No. 1968)
McDEVITT & MILLER LLP
420 West Bannock Street
O. Box 2565-83701
Boise, Idaho 83702
Tel: [phone]
Fax: [phone]
Attorneysfor WorldCom, Inc./MCI
RECEIVED
FilED
ZOO3 NOV 26 Pr1 3: 2 G
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UTlLITIES cm.1r'iJSSION
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)
NINE-MONTH REVIEW OF ECONOMIC AND
OPERATIONAL IMPAIRMENT REGARDING
ACCESS TO SPECIFIC UNES
Case No. GNR-03-
MCI'S RESPONSES TO THE
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
COMPETITIVE LOCAL
EXCHANGE CARRIERS
In accordance with the November 4, 2003 Order Establishing Procedural Schedule
Including Informal Batch Hot Cut Process, Order No. 29375, WorldCom, Inc., on behalf of its
regulated subsidiaries ("MCI"), submits these Responses to the First Request of the Commission
Staff (the "Staff') to Competitive Local Exchange Carriers (the "Staff Discovery ). MCI's
Responses to the Staff Discovery are made subject to, and without waiver of, the following
objections:
General Objections
MCI has interpreted the Staff Discovery to apply to MCI's regulated intrastate
operations in Idaho and will limit its responses accordingly. To the extent that the Staff Discovery is
intended to apply to matters that take place outside the state of Idaho and which are not related to
MCI'S RESPONSES TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL
EXCHANGE CARRIERS-
Idaho intrastate operations subject to the jurisdiction of the Idaho Public Utilities Commission (the
Commission ), MCI objects to such request as irrelevant, overly broad, unduly burdensome, and
oppressIVe.
MCI objects to the Staff Discovery to the extent that such discovery calls for
information which is exempt from discovery by virtue ofthe attorney-client privilege, work product
privilege, or other applicable privilege.
MCI objects to the Staff Discovery insofar as such discovery is vague, ambiguous
overly broad, imprecise, or utilizes terms that are subject to multiple interpretations but are not
properly defined or explained for purposes of these requests.
MCI objects to the Staff Discovery insofar as such discovery is not reasonably
calculated to lead to the discovery of admissible evidence and is not relevant to the subject matter of
this action.
MCI objects to the Staff Discovery insofar as it seeks information or documents, or
seeks to impose obligations on MCI which exceed the requirements of the FCC's TRO, the Idaho
Rules of Civil Procedure, Idaho law, the Commission s Rules of Practice and Procedure and other
Commission rules, or any other applicable laws, rules, or procedures.
MCI objects to the Staff Discovery to the extent that it seeks information that is
already in the public record before the Commission or which is already in the possession, custody, or
control of the Commission.
MCI objects to the Staff Discovery to the extent that it is overly broad, unduly
burdensome, expensive, oppressive, or excessively time consuming as written.
MCI objects to the Staff Discovery to the extent that the information requested
constitutes "trade secrets" which are privileged pursuant to the Idaho Trade Secrets Act, Idaho Code
MCI'S RESPONSES TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL
EXCHANGE CARRIERS-
948-801 et seq.(2003). To the extent that Staff Discovery seeks proprietary confidential or highly
confidential business information which is not the subject ofthe "trade secrets" privilege , MCI will
make such information available pursuant to the Protective Order No. 29384, issued November 21
2003.
MCI is a large corporation with employees located in many different locations in
Idaho and in other states. In the course of its business, MCI creates countless documents that are not
subject to the Commission s or FCC's retention of records requirements. These documents are kept
in numerous locations and are frequently moved from site to site as employees change jobs or as the
business is reorganized. Therefore, it is possible that not every document has been identified in
response to these requests. MCI will conduct a reasonable and diligent search of those files that are
reasonably expected to contain the requested information, and will supplement its discovery
responses if appropriate. To the extent that the Staff Discovery purports to require more, MCI
objects on the grounds that compliance would impose an undue burden or expense.
10.MCI objects to the Staff Discovery that seeks to obtain "all
" "
each " or "every
document, item, customer, or other such piece of information to the extent that such discovery is
overly broad and unduly burdensome.
11.MCI objects to the Staff Discovery to the extent such discovery seeks to have MCI
create documents not in existence at the time of the request.
12.MCI objects to the Staff Discovery to the extent that such discovery is not limited to
any stated period of time or relates to a stated period of time that is longer than is relevant for
purposes of the issues in this docket, as such discovery is overly broad and unduly burdensome.
13.In light of the short period of time MCI has been afforded to respond to the Staff
Discovery, the development ofMCI's positions and potentially responsive information to the Staff
MCI'S RESPONSES TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL
EXCHANGE CARRIERS-
Discovery is necessarily ongoing and continuing. MCI expressly reserves the right to supplement or
modify its discovery responses based on its ongoing inquiry.
14.MCI objects to the Staff Discovery to the extent it seeks information regarding so-
called "voice-grade equivalent lines
" ("
VGEs ) as this term is not used by MCI in the course of its
business, and MCI does not maintain information regarding "voice-grade equivalent lines" in the
ordinary course of business. Given MCI's business records , MCI will answer such discovery by
providing information regarding MCI's DSOs.
15.MCI objects to each and every request for information that seeks information
regarding non-switched services (e., services that do not depend on local Class 5 switches) except
for non-switched services (e., DSL) provided on loops that are also used to provide switched
services), as such discovery is irrelevant for purposes of this docket and is not reasonably calculated
to lead to the discovery of admissible evidence.
16.MCI objects to each and every request for information that seeks information
regarding MCI's operations in ILEC service areas other than the Qwest service area within the state
ofIdaho, as such information is irrelevant to Qwest's case in this docket and such discovery is overly
broad and unduly burdensome.
17.MCI objects to the definitions for "qualifying service" and "non-qualifying service
and each and every request for information that includes such terms, as MCI does not use such terms
in the ordinary course of business, does not maintain information regarding "qualifying service" and
non-qualifying service" in the ordinary course of business, and answering in these terms would
require MCI to provide a legal interpretation of the FCC's terms. With the exception of the specific
services the FCC has designated as qualifying or non-qualifying, the term is not clearly defined by
the FCC or by the Staff Discovery. For example, as the FCC stated in footnote 466 of the TRO
MCI'S RESPONSES TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL
EXCHANGE CARRIERS-4
Order (FCC 03-, released August 21 2003), "Our list is intended to identify general categories of
services that would qualify as eligible services. It is not intended to be an exhaustive list or to
identify services in a more particular manner." Thus, such discovery is vague.
18.MCI objects to each and every request for information that seeks information, to the
extent such is requested, regarding MCI's projections regarding future services , revenues, marketing,
strategies, equipment deployments, or other such future business plans as such requests are trade
secrets and, for purposes of this proceeding, would be highly speculative and irrelevant to the issues
to be decided in this docket. Moreover, MCI's future plans are irrelevant because the TRO concerns
a hypothetical CLEC.
19.MCI objects to the Staff Discovery to the extent it requests that MCI provide
information that MCI does not maintain in the ordinary course of business. This objection includes
but is not limited to , requests for information on "voice-grade equivalent lines." MCI does not
maintain data on "voice-grade equivalent lines" in the ordinary course of business. (See General
Objection 14).
20.MCI objects to the definitions for "hot cut
, "
batch hot cut " and "individual hot cut
and each and every request that includes such terms, as such definitions are vague in that it is not
clear whether or to what extent Qwest's practices are consistent with the FCC's use of such terms
however such terms may be defined by the FCC. Thus, such discovery is vague. MCI further
objects to the use of such terms as they apply to Qwest's individual hot cut process as MCI is not
privy to each and every process or procedure employed by Qwest in implementing such hot cuts.
21.MCI objects to the Staff Discovery to the extent it seeks information not within
MCI's possession , custody, or control.
MCI'S RESPONSES TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL
EXCHANGE CARRIERS-
Responses
Mass Market Switching
Request No.1: Provide a list of all switches that you currently use to provide a qualifying
service (as defined in 47 C.R. 9 51., as that section will be amended by the Final Rules issued by
the FCC pursuant to the Triennial Review Order) anywhere in the state, regardless of whether the
switch itself is located in the state. Do not include ILEC switches utilized by you on an unbundled
basis in the ILEC's service territory or through the resale of the incumbent's services at wholesale
rates.
MCl's RESPONSE : MCI incorporates its General Objections as if fully set forth herein
particularly General Objections 1 , 19, and 21. Subject to and without
waiving these objections and the notice of unavailability of data, MCI states that all of the switches
MCI uses to provide qualifying service (as defined in the question) are ILEC switches.
Request No.2: Identify each ILEC wire center district (i.the territory served by a wire
center of the ILEC) in which you provide qualifying service to any end user customers utilizing any
of the switches identified in your response to Request No.1. Wire centers should be identified by
providing their name, address, and CLLI code.
MCl's RESPONSE : MCI incorporates its General Objections as if fully set forth herein
particularly General Objections 1 , 10 , 11, 13, 19, and 21. Subjectto and without
waiving these objections and the notice of unavailability of data, MCI refers the PUC to MCI's
response to Request No.
MCI'S RESPONSES TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL
EXCHANGE CARRIERS-6
Request No.3: For each ILEC wire center identified in response to Request No., identify
the total number of voice-grade equivalent lines you are providing to customers in that wire center
from your switch( es) identified in response to Request No.1. For purposes of this request
, "
voice-
grade equivalent lines" should be defined consistent with the FCC's use of the term.
MCl's RESPONSE : MCI incorporates its General Objections as if fully set forth herein
particularly General Objections 1 , 7 , 8 , 10 , 11 , 13 , 14, 15, 19 , and 21. Subject to and
without waiving these objections and the notice of unavailability of data, MCI refers the PUC to
MCI's response to Request No.1 & No.
Request No.4: For each switch identified in response to Request No., identify the
approximate capacity of the switch - that is, the maximum number of voice-grade equivalent lines it
is capable of serving - based on that switch's existing configuration and component parts.
MCl's RESPONSE : MCI incorporates its General Objections as if fully set forth herein
particularly General Objections 1 , 7 , 13 , 14, 15 , 19, and 21. Subject to and
without waiving these objections and the notice of unavailability of data, MCI refers the PUC to
MCI's response to Request No.
Request No.5: With respect to the voice-grade equivalent lines identified in response to
Request No., separately indicate the number being provided to (a) residential customers; (b)
business customers to whom you provide only voice-grade or DSO lines.
MCI'S RESPONSES TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL
EXCHANGE CARRIERS-
MCl's RESPONSE : MCI incorporates its General Objections as if fully set forth herein
particularly General Objections 1 , 14, 19, and 21. Subject to and
without waiving these objections and the notice of unavailability of data, MCI refers the PUC to
MCI's response to Request No. I & No.
Request No.6: For each of the switches identified in your response to Request No., state
whether the switch is owned by you, or whether you have leased the switching capacity or otherwise
obtained the right to use the switch on some non-ownership basis. If the facility is not owned by
you, identify the entity owning the switch and (if different) the entity with which you entered into the
lease or other arrangement, identify the nature of the arrangement, and state whether such entity or
entities are affiliates of yours, in the sense defined in ~ 408 , footnote 1263 of the Triennial Review
Order.
MCl's RESPONSE : MCI incorporates its General Objections as if fully set forth herein
particularly General Objections 1 , 5, 7, 8 , 10, 13 , 19, and 21. Subject to and without
waiving these objections and the notice of unavailability of data, MCI refers the PUC to MCI's
response to Request No.
Request No.7: With respect to the voice-grade equivalent lines being provided to (a)
residential customers; (b) business customers to whom you provide between 1-3 voice-grade
equivalent lines at one location; (c) business customers to whom you provide between 4-24 voice
grade equivalent lines at one location; and (d) business customers to whom you provide 24 or more
voice-grade equivalent lines (in one location), state the current average total monthly revenues
earned per line served in the state by LA T A and by MSA and specify the source of those revenues by
service type.
MCI'S RESPONSES TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL
EXCHANGE CARRIERS-8
MCl's RESPONSE: MCI incorporates its General Objections as if fully set forth herein
particularly General Objections 1 , 5 , 7, 8 , 9, 10, 11 , 13 , 14, 19, and 21. Subject to and
without waiving these objections and the notice of unavailability of data MCI states that this
question does not apply to MCI, because MCI does not provide local services in Idaho using its own
switches, nor does it lease capacity from any entity other than the ILEc.
Request No.8: For each switch (e.g. circuit, packet, soft switch, etc.) currently used, or
those that have been used, or that could be used to provide local service in the state (this would
include switches located in other states that provide or have the ability to provide local exchange
service in the state), state the initial cost of that switch, including installation and engineering costs
and the number of initial equipped lines.
MCl's RESPONSE : MCI incorporates its General Objections as if fully set forth herein
particularly General Objections 1 , 19, and 21. MCIfurtherobjectstothis
request to the extent it seeks information no longer maintained or possessed by MCI. MCI further
refers the PUC to MCI's response to Request No.
Request No.9: Describe in detail any instances in which your company is using, through a
wholesale, lease, or resale arrangement, the switch of any entity other than and unaffiliated with an
ILEC (e., another competitive local exchange carrier) to provide local exchange service to end
users in the state. Include in your response the rates, terms, and conditions under which you are
obtaining switching on a wholesale, lease, or resale basis.
MCl's RESPONSE : MCI incorporates its General Objections as if fully set forth herein
particularly General Objections 1 , 7 , 10, 11 , 13 , 19 , and 21. Subject to and without
waiving these objections and the notice of unavailability of data, MCI states that there are no
MCI'S RESPONSES TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL
EXCHANGE CARRIERS-
instances in which MCI is using, through a wholesale, lease, or resale arrangement, the switch of any
entity other than and unaffiliated with an ILEC (e., another competitive local exchange carrier) to
provide local exchange service to end users in Idaho.
Request No. 10: State whether your company is providing, or plans to provide, through a
wholesale, lease or resale arrangement, capacity on any switches you own or operate in the state, or
that own or operate in another state and that you use to provide local service in the state, to an
unaffiliated entity. For any such instances , identify the rates, terms, and conditions under which you
are making that switch capacity available. For each switch on which you are currently leasing or
selling capacity to an unaffiliated entity, identify:
a. The make, model, age, and current software upgrades of each switch;
b. The geographic location of the switch;
c. The footprint or geographic area served by the switch, including a list of each
exchange served by the switch; the features and functions (including software
upgrades) available in the switch;
d. Provide the capacity of each switch, including:
(i) percentage of switch capacity in use;
(ii) percentage of switch capacity reserved for your company s own use and
future use; and
(iii) percentage of current and future capacity of each switch that will be made
available for CLEC use.
e. For each switch identified, please state in detail:
(i) the anticipated service life ofthe switch; and
(ii) whether your company intends to utilize the identified switch for the full
anticipated service life.
MCI'S RESPONSES TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL
EXCHANGE CARRIERS-
MCl's RESPONSE : MCI incorporates its General Objections as if fully set forth herein
particularly General Objections 1 , 10, 11 , 13 , 18, 19, and 21. Subject to and without
waiving these objections and the notice of unavailability of data, MCI refers the PUC to MCI's
answer to request No.
Request No. 11: For each Qwest wire center in Idaho in which the CLEC provides retail
switched local exchange service, please report the number of switched voice-grade equivalent lines
in service per customer location that the CLEC serves. Please provide this information in the
following format: (total number of lines at locations with a single line at that location, number of
lines at locations with two lines at that location, etc.
WIRE CENTER:
QuantityofVGE
per Customer Location
24 or more
Residence Business
MCI'S RESPONSES TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL
EXCHANGE CARRIERS-
MCl's RESPONSE : MCI incorporates its General Objections as if fully set forth herein
particularly General Objections 1 , 10, 11 , 13, 14, 19 , and 21. Subject to and
without waiving these objections and the notice of unavailability of data, MCI states that this
question does not apply to MCI , because MCI does not provide local services in Idaho using its own
switches, nor does it lease capacity from any entity other than the ILEC.
Request No. 12: For each switch the CLEC owns, operates, controls, maintains , or from
which you lease dial tone or trunking functionality/capacity within Idaho, please state whether the
local switching capacity of the switch can be expanded through modular software and hardware
additions. If you assert any obstacles to expansion, please identify and explain all such obstacles.
MCl's RESPONSE : Subject to and without waiving its General Objections and the notice of
unavailability of data, M CI refers the PU C to M CI' s response to Request No.
Request No. 13: Does the CLEC believe that there are costs associated with converting or
otherwise using a switch currently serving only enterprise customers to also serve mass-market
customers? If the CLEC believes that there are such switching costs, please identify all such costs
and explain why it would be necessary to incur them to begin serving mass-market customers.
Produce any documents or data that support your response.
MCl's RESPONSE : Subject to and without waiving its General Objections and the notice of
unavailability of data, MCI refers the PUC to MCI's response to Request No.
Request No. 14: Please provide, a) on a statewide basis, and b) on a central office-specific
basis, monthly data for the past two years on customer "chum (i.percentage of your customers
lost to another carrier) on all of the following bases:
MCI'S RESPONSES TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL
EXCHANGE CARRIERS -
(a) number of customers by customer type (e.
g.,
residential, business with one to
three lines; business with more than three lines);
(b) percentage of churn by customer type (e. g. , residential, business with one to three
lines, business with more than three lines);
( c) number of customers by service type (i. e. , local exchange voice service only, long
distance voice service only, bundled local exchange and long distance voice services
and bundled local exchange, long distance, and DSL services);
(d) percentage of churn by service type (i. local exchange voice service only,
long distance voice service only, bundled local exchange and long distance voice
services, and bundled local exchange, long distance, and DSL services).
MCl's RESPONSE : Subject to and without waiving its General Objections and the notice of
unavailability of data, MCI states that it does not track or maintain this information in the manner
requested and cannot provide the information in the manner requested. Answering further, MCI
states that it is compiling certain confidential information regarding the churn rates for MCI's
residential customers, and will provide that information promptly once compiled. To the extent this
request seeks breakdown of churn rates on bases other than those that will be provided, MCI does
not maintain that information.
Request No. 15: For customers that purchase up to 24 voice grade equivalent lines please
identify the types or categories of customer acquisition costs the CLEC incurred in Idaho in 2001
and 2002 to attract new customers, set up their accounts, and establish service to them. In addition
please provide the per line costs the CLEC incurred in 2001 and 2002 for both business and
residential customers for each of the types or categories of customer acquisition costs.
MCl's RESPONSE:MCI incorporates its General Objections as if fully set forth herein
particularly General Objections 1 11,, 19, and 21. Subject to and
without waiving these objections and the notice of unavailability of data, MCI states that it does not
track or maintain this information in the manner requested and cannot provide the information in the
MCI'S RESPONSES TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL
EXCHANGE CARRIERS-
manner requested Answering further, MCI states that it is compiling certain confidential information
regarding certain acquisition costs associated with MCI's residential customers , and will provide that
information promptly once compiled. To the extent this request seeks other types of acquisition
costs, MCI does not maintain that information.
Request No. 16: For customers that purchase up to 24 voice grade equivalent lines please
identify the monthly churn rate the CLEC has experienced for local exchange customers in each
month in which it has provided local exchange service in the Idaho market. In answering this
request, calculate the churn rate based upon the number of lines lost each year divided by the average
number of lines in service that year. In calculating churn, do not include customers who move but
stay with the company. Please produce all documents that refer or relate to the information you
provide in response to this request.
MCl's RESPONSE:MCI incorporates its General Objections as if fully set forth herein
particularly General Objections 1 , 7 , 10, 11 , 12, 13 , 14, 19, and 21. Subject to and
without waiving these objections and the notice of unavailability of data, MCI states that it does not
track or maintain this information in the manner requested and cannot provide the information in the
manner requested. Answering further, MCI states that it is compiling certain confidential information
regarding the chum rates for MCI's residential customers , and will provide that information
promptly once compiled. To the extent this request seeks breakdown of churn rates on bases other
than those that will be provided, MCI does not maintain that information.
Request No. 17: Please identify the percentage of customers that have left within one month
of signing up for service, within two months of signing up for service, within three months of
signing up for service, and within six months of signing up for service. Please provide this
MCI'S RESPONSES TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL
EXCHANGE CARRIERS-
information in connection with the CLEC's churn rates in Idaho for the most recent 24 months that
are available for local exchange customers that purchase up to 24 voice grade equivalent lines.
Please produce all documents that refer or relate to the information you provide in response to this
request.
MCl's RESPONSE : MCI incorporates its General Objections as if fully set forth herein
particularly General Objections 1 , 7, 8 , 9 , 12, 13 , 14, 19, and 21. Subject to and
without waiving these objections and the notice of unavailability of data, MCI states that it does not
track or maintain this information in the manner requested and cannot provide the information in the
manner requested. Answering further, MCI states that it is compiling certain confidential information
regarding the chum rates for MCI's residential customers, and will provide that information
promptly once compiled. To the extent this request seeks breakdown of chum rates on bases other
than those that will be provided, MCI does not maintain that information.
Request No. 18: For customers that purchase up to 24 voice grade equivalent lines please
identify each rate plan that the CLEC offers to local exchange customers in Idaho. In addition, please
identify the percentage of the CLEC's total local exchange customers in Idaho that subscribe to each
plan that you identify. Please produce all documents that reflect, refer or relate to the information you
provide in response to this request.
MCl's RESPONSE : MCI incorporates its General Objections as if fully set forth herein
particularly General Objections 1 , and 21. Subject to and
without waiving these objections and the notice of unavailability of data, MCI states that it does not
. track or maintain this information in the manner requested and cannot provide the information in the
manner requested. Answering further, MCI states that it is compiling certain confidential information
MCI'S RESPONSES TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL
EXCHANGE CARRIERS-
regarding the rate plans MCI offers to residential customers, and the percentage of residential
customers that subscribe to each rate plan, and will provide that information promptly once
compiled. To the extent this request seeks additional rate plan information, MCI does not maintain
that information.
Request No. 19: For rate plans identified in B.13. that include a per minute of use
component, please provide the average long distance per minute usage in Idaho of the CLEC's local
exchange customers who subscribe to such plans for the most recent 24 months available. Please
produce all documents that reflect, refer, or relate to the information you provide in response to this
request.
MCl's RESPONSE : MCI incorporates its General Objections as if fully set forth herein
particularly General Objections 1 , 10, 11 , 12, 13, 14, 19, and 21. Subject to and
without waiving these objections and the notice of unavailability of data, MCI states that it cannot
ascertain what information this question is seeking, because the question is vague, and therefore
cannot provide a response to the question at this time.
Request No. 20: For customers that purchase up to 24 voice grade equivalent lines how
many CLEC-to-CLEC cross-connects has the CLEC performed in Idaho since June 2001? How
many CLEC-to-CLEC cross-connects does the CLEC maintain in Idaho at present?
MCl's RESPONSE : MCI incorporates its General Objections as if fully set forth herein,.
particularly General Objections 1 , 10, 11 , 12 , 13, 14, 19 , and 21. Subject to, and
without waiving its objections, MCI states that it has not performed any CLEC-to-CLEC cross-
connects in Idaho since June 2001.
MCI'S RESPONSES TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL
EXCHANGE CARRIERS-
The Development of an Efficient Loop Migration Process
Request No. 21: Describe the hot cut process currently used to transfer lines from the
ILEC switch to the CLEC facilities.
MCl's RESPONSE : MCI incorporates its General Objections as if fully set forth herein
particularly General Objections 1 , 7 , 10 , 12, 13 , and 21. Subject to and
without waiving these objections and the notice of unavailability of data, MCI respectfully refers the
Commission to MCI's Response to Qwest's Proposal for a Region-Wide Batch Loop Conversion
Process, filed on November 18 , 2003. That pleading explains MCI's understanding of and position
regarding an appropriate batch hot cut process.
Request No. 22: List each task that is part ofthe current process. Provide the average time
it takes to complete the task, the typical occurrence of the task during the process, the labor rate for
the task, and the common overhead loading associated with the labor rate. Indicate the source of the
data, i.e. time/motion studies, SME analysis, etc.
MCl's RESPONSE : MCI incorporates its General Objections as if fully set forth herein
particularly General Objections 1 , 7, 8,, 10, 11 , 12, 13 , and 21. Subject to and
without waiving these objections and the notice of unavailability of data, MCI respectfully refers the
Commission to MCI's response to Request No. 21 .
Request No. 23: Describe a batch hot cut process that you would implement to meet the
FCC's requirement to establish a batch hot cut process. Include an estimate of the maximum number
of lines per batch.
MCI'S RESPONSES TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL
EXCHANGE CARRIERS-
MCl's RESPONSE : MCI incorporates its General Objections as if fully set forth herein
particularly General Objections 1 , 10, 11 , 12, 13 , and 21. Subject to and
without waiving these objections and the notice of unavailability of data, MCI respectfully refers the
Commission to MCI's response to Request No. 21.
Request No. 24: List each task that is part of the batch hot cut process described in the
answer to the preceding request. Provide the average time it takes to complete the task, the typical
occurrence of the task during the process, the labor rate for the task, and the common overhead
loading associated with the labor rate.
MCl's RESPONSE : MCI incorporates its General Objections as if fully set forth herein
particularly General Objections 1 , 7 9, 10, 11 , 12 , 13 , and 21. Subject to and
without waiving these objections and the notice of unavailability of data, MCI respectfully refers the
Commission to M CI' s response to Request No. 21.
Request No. 25: IfUNE-P is no longer available, what monthly volumes of hot cuts would
be required: (a) to migrate existing UNE-P customers to another form of service and (b) to connect
new customers in the ordinary course of business. Provide supporting documentation for these
volume estimates.
MCl's RESPONSE : MCI incorporates its General Objections as if fully set forth herein
particularly General Objections 1 , 5, 6, 7, 8 , 9, 10, 11 , 12, 13 , and 21. Subject to and
without waiving these objections and the notice of unavailability of data, MCI respectfully refers the
Commission to MCI's response to Request No. 21.
MCI'S RESPONSES TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL
EXCHANGE CARRIERS -
Dated this 26th day of November, 2003.ORLDCOM INc.
Dean . Miller
McDEVITT & MILLER LLP
420 West Bannock Street
Boise, Idaho 83702
Attorneysfor WorldCom, lnc./MCI
MCI'S RESPONSES TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL
EXCHANGE CARRIERS -
Certificate of Service
I hereby certify that on the 26th day of November, 2003 , I caused to be served by the methodes) indicated
below, the foregoing document upon:
Charles Carrathers Hand Delivered
VERIZON NORTHWEST INC.S. Mail
180041" Street Fax
Everett, Washington 98201 Fed. Express
Tel:Email
Fax:
chuck. ca rrathe rs CiYverizo 11. co 111
Marlin D. Ard Hand Delivered
ATTORNEY AT LAw S. Mail
O. Box 2190 Fax
Sisters, Oregon 97759 Fed. Express
Tel: [phone] Email
Fax: [phone]
marattyCiYqwest.net
Mary B. Tribby Hand Delivered
Letty S.D. Friesen S. Mail
AT&T COMMUNICATIONS OF THE MOUNTAIN STATES Fax
1875 Lawrence Street, Suite 1575 Fed. Express
Denver, Idaho 80202 Email
Tel: [phone]
Fax: [phone]
IsfriesenCiYatt.com
Robert M. Pomeroy, Jr.Hand Delivered
HOLLAND & HART S. Mail
8390 East Crescent Parkway, Suite 400 Fax
Greenwood Village, Idaho 80111 Fed. Express
Tel: [phone] Email
Fax: [phone]
bp omeroyCiY ho llandandhart. com
Brian Thomas Hand Delivered
TIME WARNER TELECOM S. Mail
223 Taylor Avenue North Fax
Seattle, Washington 98109 Fed. Express
Tel: [phone] Email
Fax: [phone]
Brian. ThomasCiYtWtelecom.com
Mary S. Hobson Hand Delivered
STOEL RIVES LLP S. Mail
101 So. Capitol Blvd., Suite 1900 Fax
Boise, Idaho 83702 Fed. Express
Tel: [phone] Email
Fax: [phone]
ms ho bso n CiYs toel. com
MCI'S RESPONSES TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL
EXCHANGE CARRIERS -
Certificate of Service
continued
Adam 1. Sherr
QWEST
1600 7th Avenue, Room 3206
Seattle, Washington 98191
Tel: [phone]
Fax: [phone]
asherr(fj?qwesr.com
Hand Delivered
S. Mail
Fax
Fed. Express
Email
ConleyE. Ward
GIVENS PuRSLEY, LLP
277 North 6th Street, Suite 200
O. Box 2720
Boise, Idaho 83701
Tel: [phone]
Fax: [phone]
cew(fj?givenspursley.com
Hand Delivered
S. Mail
Fax
Fed. Express
Email
Clay R. Sturgis
Moss ADAMS LLP
601 West Riverside, Suite 1800
Spokane, Washington 99201.0663
Tel: [phone]
Fax: [phone]
clay .sturgis(fj?mossadams. com
Hand Delivered
S. Mail
Fax
Fed. Express
Email
'14.
MCI'S RESPONSES TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL
EXCHANGE CARRIERS -