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HomeMy WebLinkAbout200311261st Response of Z Tel.pdf'7. TEL'" HECEIVEOFILED 2003 NOV 2i AM 9: 54 601 South Harbour Island Boulevard Suite 220 ;id tUbLiC UTILITIES Cor'If1ISSlm~ Tampa, FL 33602 www,teLcom Overnight Delivery November 25, 2003 W elc';Jn B. Stutzman Deputy Attorney General Idaho Public Utilities Commission 472 vv Washington Boise, ill 83702-5983 Re:Case No. GNR-O3= Dear Mr. Stutzman: Attached are o~k and one original copy of Z- Tel Communications, Inc. 's responses to the Commission s First Production Request to Idaho CLECs in the above referenced Case. Thank you for your attention to this matter. Sinc relY' ""/:' -"-- Michael Reith Director, Industry Policy Z- Tel Communications, Inc. (813) 233-4531 Enclosures BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Tel Communications, Inc.s Responses to the FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL EXCHANGE CARRIERS Case No. GNR-03- 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. Mass Market S~nching Request No.Please provide a list of all switches that you currently use to provide a qualifying service (as defined in 47 C.R. ~ 51.5, 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. Response:Z- Tel believes the term "qualifying service" is ambiguous. Subject to that objection, Z- Tel states that it only provides local service in Idaho via UNE- Michael Strobl, Director - Strategic Planning November 25, 2003 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Tel Communications, Inc.s Responses to the FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL EXCHANGE CARRIERS Case No. GNR-03- 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. Request No.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. Response:Tel believes the term "qualifying service" is ambiguous. Subject to that objection, Z- Tel states that it only provides local service in Idaho via UNE- Michael Strobl, Director - Strategic Planning November 25 2003 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Tel Communications, Inc.s Responses to the FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL EXCHANGE CARRIERS Case No. GNR-03- 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. Request No.For each ILEC wire center identified in response to Request No. identify the total number of voice-grade equivalent lines you are providing to customer 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. Response:Not applicable. Michael Strobl, Director - Strategic Planning November 25 2003 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Tel Communications, Inc.s Responses to the FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL EXCHANGE CARRIERS Case No. GNR- T -03- 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. Request No.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. Response:Not applicable. Michael Strobl, Director - Strategic Planning November 25, 2003 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Tel Communications, Inc.s Responses to the FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL EXCHANGE CARRIERS Case No. GNR-03-23 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. Request No.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. Response:Not applicable. Michael Strobl, Director - Strategic Planning November 25 2003 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Tel Communications, Inc.s Responses to the FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL EXCHANGE CARRIERS Case No. GNR-03- 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. Request No.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,-r 408, footnote 1263 of the Triennial Review Order. Response:Not applicable. Michael Strobl, Director - Strategic Planning November 25 2003 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Tel Communications, Inc.s Responses to the FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL EXCHANGE CARRIERS Case No. GNR-03- 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. Request No.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; (d) business customers to whom you provide 24 or more voice-grade equivalent lines (in one location), state the current average monthly revenues earned per line served in the state by LATA and by MSA and specify the source of those revenues by service type. Response:Z- Tel objects to this Discovery Request on the grounds that inasmuch as the FCC ruled in the TRO that impairment analysis was not to be based on the business models of individual carriers the Discovery Request seeks irrelevant information and is not reasonably calculated to lead to the discovery of admissible evidence. Z-Tel further objects on the grounds that this Discovery Request seeks proprietary and confidential business information. Michael Strobl, Director - Strategic Planning November 25, 2003 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Tel Communications, Inc.s Responses to the FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL EXCHANGE CARRIERS Case No. GNR- T -03- 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. Request No.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 the switch including installation and engineering costs, and the number of initial equipped lines. Response:Not applicable. Michael Strobl, Director - Strategic Planning November 25, 2003 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Tel Communications, Inc.'s Responses to the FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL EXCHANGE CARRIERS Case No. GNR-03- 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. Request No.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. Response:Not applicable. Michael Strobl, Director - Strategic Planning November 25 2003 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Tel Communications, Inc.s Responses to the FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL EXCHANGE CARRIERS Case No. GNR-03- 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. 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 such instances, identify the rates terms, and conditions under which you are making the switch capacity available. For each switch on which you are currently leasing or selling capacity to an unaffiliated entity, indentify: a. The make, model, age, and current software upgrades of each switch; b. The geographic location ofthe switch; c. The footprint or geographic are 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 available for CLEC use. e. For each switch identified, please state in detail:(i) The anticipated service life of the switch; and Whether your company intends to utilize the identified switch for the full anticipated service life. (ii) Response:Not applicable. Michael Strobl, Director - Strategic Planning November 25 2003 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Tel Communications, Inc.s Responses to the FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL EXCHANGE CARRIERS Case No. GNR-03- IN THE MATTER OF IPUC RESPONSE TO FCC ORDER ON REVIEW OF SECTION 251 UNBUND LIN G 0 BLI GA TI 0 NS OF INCUMBENT LOCAL EXCHANGE CARRIERS (CC DOCKET NO. 01-338) NINE-MONTH REVIEW OF ECONOMIC AND OPERATIONAL IMPAIRMENT REGARDING ACCESS TO SPECIFIC UNES. Request No. 11:For each Qwest wire center in Idaho in which your company 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 oflines at locations with a single line at that location, number oflines at locations with two lines at that location, etc. Quantity ofVGE Lines per Customer Location WIRE CENTER: Residence Business Michael Strobl, Director - Strategic Planning November 25 2003 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Z- Tel Communications, Inc.'s Responses to the FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL EXCHANGE CARRIERS Case No. GNR-03- 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. 24 or more Response:Z- TEL objects on the grounds the request seeks information that comprises proprietary and confidential information. Notwithstanding this objection, Z. TEL will provide responsive information subject to a confidentiality agreement. Michael Strobl, Director - Strategic Planning November 25, 2003 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Z- Tel Communications, Inc.'s Responses to the FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL EXCHANGE CARRIERS Case No. GNR-03- 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. Request No. 12:For each switch the CLEC owns, operates, controls, maintains, or ttom 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. Response:Not applicable. Michael Strobl, Director - Strategic Planning November 25 2003 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Z- Tel Communications, Inc.'s Responses to the FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL EXCHANGE CARRIERS Case No. GNR-03- 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. 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 then to begin serving mass-market customers. Please produce any documents or data that support your response. Response:Z- Tel has developed no such cost information at this time. Michael Strobl, Director - Strategic Planning November 25 , 2003 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Tel Communications, Inc.'s Responses to the FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL EXCHANGE CARRIERS Case No. GNR-03- 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. Request No. 14: Response: Please provide, a) on a statewide basis, and b) on a central office- specific basis, monthly data for the past two years on customer churn (i.e. percentage of your customers lost to another carrier) on all ofthe following bases: (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.residential business with one to three lines, business with more than three lines); ( c) number of customers by service type (i. e.local exchange 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 chum by service type (i.local exchange service only, long distance voice service only, bundled local exchange and long distance voice services, and bundled local exchange, long distance, and DSL services). Z - T E G-objec t~do- this - Bi scovery- R-eq ue s t -on - the-groun d ~;-tha t inasmuch as the FCC ruled in the TRO that impairment analysis was not to be based on the business models of individual carriers the Discovery Request seeks irrelevant information and is not reasonably calculated to lead to the discovery of admissible evidence. Z-TEL further objects on the grounds that this Discovery Request seeks proprietary and confidential business information. Michael Strobl, Director - Strategic Planning November 25 2003 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Tel Communications, Inc.s Responses to the FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL EXCHANGE CARRIERS Case No. GNR-03- 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. Request No. 15:For customers that purchase up to 24 voice grade equivalent lines please identify the types of 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 acquisition costs. Response:Z- TEL objects to this Discovery Request on the grounds that inasmuch as the FCC ruled in the TRO that impairment analysis was not to be based on the business models of individual carriers the Discovery Request seeks irrelevant information and is not reasonably calculated to lead to the discovery of admissible evidence. Z-TEL further objects on the grounds that this Discovery Request seeks proprietary and confidential business information. Michael Strobl, Director - Strategic Planning November 25 2003 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Z- Tel Communications, Inc.'s Responses to the FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL EXCHANGE CARRIERS Case No. GNR-03- 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. 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. Response:TEL objects to this Discovery Request on the grounds that inasmuch as the FCC ruled in the TRO that impairment analysis was not to be based on the business models of individual carriers the Discovery Request seeks irrelevant information and is not reasonably calculated to lead to the discovery of admissible evidence. Z- TEL further objects on the grounds that this Discovery Request seeks proprietary and confidential businessinformation. Michael Strobl, Director - Strategic Planning November 25, 2003 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Z- Tel Communications, Inc.'s Responses to the FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL EXCHANGE CARRIERS Case No. GNR-03- 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. 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 information in connection with the CLEC's chum rate 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. Response:Z- TEL objects to this Discovery Request on the grounds that inasmuch as the FCC ruled in the TRO that impairment analysis was not to be based on the business models of individual carriers the Discovery Request seeks irrelevant information and is not reasonably calculated to lead to the discovery of admissible evidence. Z-TEL further objects on the grounds that this Discovery Request seeks proprietary and confidential business information. Michael Strobl, Director - Strategic Planning November 25 2003 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Tel Communications, Inc.'s Responses to the FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL EXCHANGE CARRIERS Case No. GNR-03- 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. 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 refer or relate to the information you provide in response to this request. Response:TEL objects to this Discovery Request on the grounds that inasmuch as the FCC ruled in the TRO that impairment analysis was not to be based on the business models of individual carriers the Discovery Request seeks irrelevant information and is not reasonably calculated to lead to the discovery of admissible evidence. Z- TEL further objects on the grounds that this Discovery Request seeks proprietary and confidential business information. Michael Strobl, Director - Strategic Planning November 25, 2003 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Tel Communications, Inc.'s Responses to the FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL EXCHANGE CARRIERS Case No. GNR-03- 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. 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 ofthe CLEC's local exchange customers who subscribe to such plans for the most recent 24 months available. Please produce all documents that refer or relate to the information you provide in response to this request. Response:Z- TEL objects to this Discovery Request on the grounds that inasmuch as the FCC ruled in the TRO that impairment analysis was not to be based on the business models of individual carriers the Discovery Request seeks irrelevant information and is not reasonably calculated to lead to the discovery of admissible evidence. Z-TEL further objects on the grounds that this Discovery Request seeks proprietary and confidential business information. Michael Strobl, Director - Strategic Planning November 25, 2003 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Z- Tel Communications, Inc.'s Responses to the FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL EXCHANGE CARRIERS Case No. GNR-03- 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. 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? Response:The answer to both questions is zero. Michael Strobl, Director - Strategic Planning November 25 2003 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Tel Communications, Inc.s Responses to the FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL EXCHANGE CARRIERS Case No. GNR-03- 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. The Development of an Efficient Loop Migration Process Request No. 21:Describe the hot cut process currently used to transfer lines ttom the ILEC switch to CLEC facilities. Response:Not applicable. Michael Strobl, Director - Strategic Planning November 25, 2003 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Z- Tel Communications, Inc.'s Responses to the FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL EXCHANGE CARRIERS Case No. GNR-03- 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. Request No. 22:List each task that is part of the 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 rates. Indicate the source of the data, i.e. time/motion studies, SME analysis, etc. Response:Not applicable. Michael Strobl, Director - Strategic Planning November 25, 2003 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Tel Communications, Inc.'s Responses to the FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL EXCHANGE CARRIERS Case No. GNR-O3- 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. 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. Response:To date, no incumbent ILEC has provided or offered Z- Tel a batch hot cut process that would meet the needs of serving "mass market" customers. Moreover, batch hot cut processes require entrants to "pay twice" for switching-payment for unbundled local switching while the entrant gathers enough customers to become a "batch". As a result, batch hot cut processes are inherently discriminatory and pose a barrier to entry, because it forces entrants to pay twice for switching, a cost incumbents do not face. Michael Strobl, Director - Strategic Planning November 25, 2003 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Z- Tel Communications, Inc.s Responses to the FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL EXCHANGE CARRIERS Case No. GNR-03- 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. 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 task. Response:Not applicable. Michael Strobl, Director - Strategic Planning November 25, 2003 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Tel Communications, Inc.'s Responses to the FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL EXCHANGE CARRIERS Case No. GNR-03- 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. 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. Response:Z- TEL has not developed any such projections at this time. Z- Tel notes that Qwest has an obligation under section 271 (c)(2)(B)(6) to provide unbundled access to switching at just and reasonable rate and the FCC recognized in the Triennial Review Order that this section 271 checklist obligation was independent of the section 251 obligation. As a result, Z- Tel believes that in the event the Idaho Commission is determined that unbundled mass-market switching was no longer available in the market pursuant to section 251 , it is likely that Z. Tel would transition ttom section 251 switching to wholesale access to Qwest's switching pursuant to section 271(c). Z-Tel expects that the Idaho Commission would analyze whether Qwest's offering of unbundled switching pursuant to its section 271 checklist obligations comply with applicable law. Michael Strobl, Director - Strategic Planning November 25 2003