200312011st Response of Qwest to Staff.pdf

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101 S. Capitol Boulevard. Suite 1900
Boise, Idaho 83702
main 208.389.90002003 NO\!
fax [phone]
ATTORNEYS AT LAW
U t'u8LJC
UTILITIES COMi'lISSION
www.sloel.com
November 26, 2003
MARY S. HOBSON
Direct [phone]
mshobson(fj)stoel.com
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, ID 83702-5983
RE:Docket No. GNR-O3-
Dear Ms. Jewell:
Enclosed for filing with this Commission is an original and three (3) copies of Qwest
Corporation s Responses to First Production Request of the Commission Staff in the above- ~
referenced matter.
" ,'.
Cf:)
:"
Attachment A to Response to Request No. 12 i~)10t c~nsidered confidential but is voluminous
and is therefore being provided on compact dIsc.
Attachments to Responses to Request Nos. 18 and 31 are considered confidential and proprietary
and are being filed under separate cover with this Commission. Copies of the confidential
attachment(s) will be provided to those individuals who execute Exhibit A to the Protective
Agreement.
Attachments to Responses to Request Nos. 1 , 15, 17 and 35 are considered Highly
Confidential and Use Restricted per Protective Order No. 29384 and are being filed under
separate cover with this Commission. Copies of these Highly Confidential attachments will be
provided to those individuals who execute Exhibit B to the Protective Agreement.
If you have any questions, please contact me. Thank you for your cooperation in this matter.
Very truly yours
Enclosurescc: Service List; Tina Colvin
0 reg 011
Washington
California
U I a h
Boise-I 64764.1 0029164-00097 Idaho
Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoel.com
OR' G H\lQL\L
RECEIVED
FiLED
II)
ZOU3 MOV 29 fM~: 23
.u LJ t,U8LiC
UTiliTIES CGr'iMISSIUN
Adam L. Sherr (WSBA #25291)
Qwest
1600 ih Avenue - Room 3206
Seattle, WA 98191
Telephone: [phone]
Facsimile: [phone]
adam.sherr~qwest.com
Attorneys for Qwest Corporation
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 (CCDOCKET NO. 01-338)
Case No. GNR-03-
QWEST CORPORATION'S RESPONSES
TO FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF
NINE-MONTH REVIEW OF ECONOMIC
AND OPERATIONAL IMPAIRMENT
REGARDING ACCESS TO SPECIFIC UNES
Qwest Corporation ("Qwest") pursuant to Rule 225 of the Rules of Procedure of the
Idaho Public Utilities Commission and Idaho Rule of Civil Procedure 34 hereby submits the
following responses to Staffs Request for Production.
QWEST CORPORATION'S RESPONSES TO FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - Page
Boise-164762,1 0029164-00097
Respectfully submitted this 26th day of November, 2003.
Qwest Corporation
Ho fa--.-
~ary S. H son
Stoel Rives LLP
Adam L. Sherr
Qwest
Attorneys for Qwest Corporation
QWEST CORPORATION'S RESPONSES TO FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - Page 2
Boise-I 64762,1 0029164-00097
CERTIFICATE OF SERVICE
I hereby certify that on this 26th day of November, 2003, I served QWEST
CORPORATION'S RESPONSES TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF as follows:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ill 83720-0074
Phone: [phone]
Fax: [phone]
i i ewell~puc. state.id. us
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Wayne Hart
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ill 83720-0074
Phone: [phone]
Fax: [phone]
whart~puc.state.id. us
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Weldon Stutzman, Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ill 83720-0074
Phone: [phone]
Fax: [phone]
wstutzm~puc.state.id.
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Marlin D. Ard, Esq.
O. Box 2190
Sisters, OR 97759
Telephone: [phone]
Facsimile: [phone]
Maratty~qwest.net
Attorney for Verizon
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
QWEST CORPORATION'S RESPONSES TO FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - Page 3
Boise-I 64762.1 0029164-00097
Charles Carrathers
Verizon Northwest Inc.
1800 41 st Street
Everett, W A 98201
Telephone: [phone]
Facsimile: [phone]
chuck. carrathers~verizon. com
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Dean J. Miller
McDevitt & Miller LLP
420 West Bannock Street
O. Box 2564 (83701)
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
i oe~mcdevitt -miller .com
Attorney for MCImetro, Time Warner
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Robert M. Pomeroy, Jr.
Holland & Hart
8390 East Crescent Parkway - Suite 400
Greenwood Village, CO 80111
Telephone: [phone]
Facsimile: [phone]
bpomeroy~ho llandhart. com
Attorney for AT&T
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Adam L. Sherr
Qwest
1600 ih Avenue - Room 3206
Seattle, W A 98191
Telephone: [phone]
Facsimile: [phone]
adam.sherr~qwest.com
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Clay R. Sturgis
Moss Adams LLP
601 West Riverside - Suite 1800
Spokane, W A 99201-0663
Telephone: [phone]
Facsimile: [phone]
c1ays~mossadams.com
Attorney for ITA
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
QWEST CORPORATION'S RESPONSES TO FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - Page 4
Boise-164762.10029164-00097
Brian Thomas
Time Warner Telecom
223 Taylor Avenue North
Seattle, W A 98109
Brian. Thomas~twtelecom.com
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Mary B. Tribby
Letty S. D. Friesen
AT&T Communications of the Mountain States, mc.
1875 Lawrence Street- Suite 1575
Denver, CO 80202
Telephone: [phone]
Facsimile: [phone]
lsfiiesen~att.com
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Conley E. Ward
Givens Pursley LLP
277 North 6th Street - Suite 200
O. Box 2720
Boise, ill 83701
Telephone: [phone]
Facsimile: [phone]
cew~gi venspursley .com
Attorney for ITA
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
At Iv yff I/o
t-z---
Mary S. Hfjson
QWEST CORPORATION'S RESPONSES TO FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - Page 5
Boise-164762,10029164-00097
Idaho
Case No. GNR-03-
STF 1-001
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:001
Mass Market Switching
For each wire center in your territory in Idaho , please provide the number of
business voice-grade equivalent lines that you directly serve.
RESPONSE:
Please see Highly Confidential Attachment "A" which contains the number of
business voice-grade equivalent lines served by Qwest by wire center.
Respondent:Maryann Klasinsi , Qwest Manager
Idaho
Case No. GNR-03-
STF 1-002
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:002
For each wire center in your territory in Idaho , please provide the number of
business voice-grade equivalent lines that CLECs are serving through resale.
RESPONSE:
Qwest has compiled the Idaho data in its possession that is responsive to
this request. However , this request seeks CLEC/carrier specific information
that may be protected under 47 U. S. C. 222 (a) ("Privacy of Customer
Information") and/or other federal privacy laws. Qwest will provide the
requested CLEC information to those that have signed Exhibit B of theProtective Order (Commission Order No. 29384) upon receiving either: (1) a
Commission order requiring production of the information; or 2) permission
from the CLEC to release the requested information.
Once Qwest has received a Commission Order or CLEC permission to release
information, see HIGHLY CONFIDENTIAL ATTACHMENT "A" for the number of
business voice-grade equivalent lines by wire center that CLECs are serving
through resale as of 9/30/03.
Respondent:Elaine Garley, Qwest Manager
Idaho
Case No. GNR-03-
STF 1-003
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:003
For each wire center in your territory in Idaho , please provide the number of
business voice-grade equivalent lines that CLECs are serving through UNE-
RESPONSE:
Qwest has compiled the Idaho data in its possession that is responsive to
this request. However , this request seeks CLEC/carrier specific information
that may be protected under 47 U. S. C. 222 (a) ("Privacy of Customer
Information") and/or other federal privacy laws. Qwest will provide the
requested CLEC information to those that have signed Exhibit B of the
Protective Order (Commission Order No. 29384) upon receiving either: (1) a
Commission order requiring production of the information; or 2) permission
from the CLEC to release the requested information.
Once Qwest has received a Commission Order or CLEC permission to release
information,
see HIGHLY CONFIDENTIAL ATTACHMENT "A" for the estimated number of business
voice-grade equivalent UNE-P lines in service as of 9/30/03 by wire center.Since Qwest cannot directly track the number of UNE-P lines CLECs are using
to serve business customers, Qwest has identified the quantity of UNE-
telephone numbers appearing in the residential section of the Qwest White
Pages database , and subtracted those quantities from the total UNE-
quantities in service. The remainder is identified for this purpose as being
business UNE-P lines in service. Since only a fraction of all business lines
in service actually appear in the White Pages, a simple reporting of UNE-
business listings understates the actual number of UNE-P lines being used for
business purposes.
Respondent: Elaine Garley, Qwest Manager
Idaho
Case No. GNR-03-
STF 1-004
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:004
For each wire center in your territory in Idaho, please provide the number of
business voice-grade equivalent lines that CLECs are serving through the
CLEC's own facilities.
RESPONSE:
Information regarding quantities of customers , by type of service, being
served by CLECs via CLEC-owned facilities is highly confidential information
that is proprietary to the CLECs. Qwest does not have access to these linecounts.
Respondent: Elaine Garley, Qwest Manager
Idaho
Case No. GNR-03-
STF 1-005
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:005
For each wire center in your terri tory in Idaho, please provide the number of
residential voice-grade equivalent lines that you directly serve.
RESPONSE:
Please see Highly Confidential Attachment "A" which contains the number of
residence voice-grade equivalent lines served by Qwest by wire center.
Respondent:Maryann Klasinski, Qwest Manager
Idaho
Case No. GNR-03-
STF 1-006
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:006
For each wire center in your territory in Idaho , please provide the number of
residential voice -grade equivalent lines that CLECs are serving throughresale.
RESPONSE:
Qwest has compiled the Idaho data in its possession that is responsive to
this request. However , this request seeks CLEC/carrier specific information
that may be protected under 47 U.C. 222(a) ("Privacy of Customer
Information") and/or other federal privacy laws. Qwest will provide the
requested CLEC information to those that have signed Exhibit B of the
Protective Order (Commission Order No. 29384) upon receiving either: (1) a
Commission order requiring production of the information; or 2) permission
from the CLEC to release the requested information.
Once Qwest has received
information , see HIGHLY
residential voice-grade
resale.
a Commission Order or CLEC permission to release
CONFIDENTIAL ATTACHMENT "A" for the number of
equivalent lines that CLECs are serving through
Respondent: Elaine Garley, Qwest Manager
Idaho
Case No. GNR-03 -
STF 1-007
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:007
For each wire center in your territory in Idaho, please provide the number of
residential voice-grade equivalent lines that CLECs are serving through
UNE - P .
RESPONSE:
Qwest has compiled the Idaho data in its possession that is responsive to
this request. However , this request seeks CLEC/carrier specific information
that may be protected under 47 U.C. 222(a) ("Privacy of Customer
Information") and/or other federal privacy laws. Qwest will provide the
requested CLEC information to those that have signed Exhibit B of theProtective Order (Commission Order No. 29384) upon receiving either: (1) a
Commission order requiring production of the information; or 2) permission
from the CLEC to release the requested information.
Once Qwest has received a Commission Order or CLEC permission to release
information, see HIGHLY CONFIDENTIAL ATTACHMENT "A" for the number of UNE-
lines Qwest believes are being used by CLECs to serve residential customers.
UNE-P is not identified in Qwest systems as being used for residential or
business purposes - these services are generic, wholesale services provide by
Qwest to CLECs. To estimate the number of residential UNE-P lines inservice, Qwest compared the telephone numbers associated with UNE-P lines in
service against the current White Pages listings database, and identified the
quantity of UNE-P telephone numbers shown in the residential section of thatdatabase. This is the only means Qwest has of approximating the number of
UNE-P residential lines in service, and the results of this analysis are
reflected in HIGHLY CONFIDENTIAL ATTACHMENT "
Respondent: Elaine Garley, Qwest Manager
Idaho
Case No. GNR-03-
STF 1-008
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:008
For each wire center in your territory in Idaho , please provide the estimated
number of residential lines that CLECs are serving through their ownfacilities (complete bypass) .
RESPONSE:
Information regarding quanti ties of customers , by type of service , being
served by CLECs via CLEC-owned facilities is highly confidential information
that is proprietary to the CLECs. Qwest does not have access to these line
counts.
Respondent: Elaine Garley, Qwest Manager
Idaho
Case No. GNR-03-
STF 1-009
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:009
For each wire center in your territory in Idaho, please provide the number of
in-service collocation arrangements that you have, and for each collocation
arrangement , please indicate the type of collocation that you are providing.
RESPONSE:
Qwest has compiled the Idaho data in its possession that is responsive to
this request. However , this request seeks CLEC/carrier specific information
that may be protected under 47 U.C. 222 (a) ("Privacy of Customer
Information ) and/or other federal privacy laws. Qwest will provide the
requested CLEC information to those that have signed Exhibit B of the
Protective Order (Commission Order No. 29384) upon receiving either: (1) a
Commission order requiring production of the information; or 2) permission
from the CLEC to release the requested information.
Once Qwest has received a Commission Order or CLEC permission to release
information , see HIGHLY CONFIDENTIAL ATTACHMENT "A" for the number of
in-service collocation arrangements for all collocation types by wire center.
Respondent:Elaine Garley, Qwest Manager
Idaho
Case No. GNR-03-
STF 1-010
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:010
For each wire center in your territory in Idaho, please provide the number of
provisioned collocation arrangements that you have in place that have yet to
be activated , and for each collocation arrangement , please indicate the type
of collocation.
RESPONSE:
Qwest does not monitor when a CLEC activates their facilities to provide
services to their customer and so Qwest has no knowledge regarding the
information sought in this request.
Respondent:Maryann Klasinski , Qwest Manager
Idaho
Case No. GNR-03-
STF 1- 011
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:011
For each wire center in your territory in Idaho , please provide the number of
pending collocation arrangements that you have , and for each collocation
arrangement, please indicate the type of collocation.
RESPONSE:
Qwest has compiled the Idaho data in its possession that is responsive to
this request. However , this request seeks CLEC/carrier specific information
that may be protected under 47 U. S. C. 222 (a) ("Privacy of Customer
Information ) and/or other federal privacy laws. Qwest will provide the
requested CLEC information to those that have signed Exhibit B of theProtective Order (Commission Order No. 29384) upon receiving either: (1) a
Commission order requiring production of the information; or 2) permission
from the CLEC to release the requested information.
Respondent:Maryann Klasinski, Qwest Manager
Idaho
Case No. GNR-03-
STF 1-012
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:012
For each wire center in your territory in Idaho, please provide a list of
restrictions on equipment, cross-connects between CLEC collocation cages, or
other restrictions or limitations that you place on a CLECs use of
collocation space.
RESPONSE:
The following language from applicable SGAT sections defines the type of
equipment that can be placed in collocation space:
Collocation of Switching Equipment. CLEC may collocate any
equipment that is necessary for Interconnection or access to Unbundled
Network Elements.
Digital Subscriber
meet this legal standard.
Line Access Multiplexers (DSLAMS)always
Asynchronous Transfer Mode (ATM) or Packet Switching also meets
this legal standard when used for Interconnection or access to Unbundled
Network Elements for purposes of providing Advanced Services such as xDSL.
Equipment used predominantly to support DSLAMs and ATMs, such as routers
and concentrators , as well as testing and network management equipment
also meet this legal standard. Before any equipment that includesswitching functionality is installed CLEC must provide a written
inventory to Qwest of all switching equipment and how it will be used for
Interconnection or access to Unbundled Network Elements. Once CLEC
establishes that it will use certain type of equipment for
Interconnection or access to Unbundled Network Elements, Qwest will allowfuture Collocations of similar equipment without requesting a written
justification unless and until Qwest can establish to the state Commission
that such equipment is not intended for Interconnection or access to
Unbundled Network Elements. However , Qwest will complete the Collocation
within the appropriate interval unless granted relief by the Commission.
1.2.Remote Switching Units (RSUs) also meet this legal standard
when used for Interconnection or access to Unbundled Network Elements for
purposes of providing Local Exchange Service.
Except as provided for in Sections 8.1 through 8.above, CLEC may not collocate equipment that is not necessary for
Interconnection or access to Unbundled Network Elements.
All equipment shall meet and be installed in accordance with
Network Equipment Building System (NEBS) Level l safety standards. Qwestshall provide standard Premises alarming pursuant to Qwest TechnicalPublication 77385. Qwest shall not impose safety or engineering
requirements on CLEC that are more stringent than the safety or
engineering requirements Qwest imposes on its own equipment located on its
Premises.
Also , Qwest Technical Publication 77386 addresses the type of
can be placed in collocation space. ATTACHMENT "A", provided
contains Technical Publication 77386. This document also can
following url: http:j jwww.qwest.comjtechpubj .
equipment that
on a CD
be found at the
Respondent:Maryann Klasinski , Qwest Manager
Idaho
Case No. GNR-O3-
STF 1-013
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:013
For each wire center in your territory in Idaho, please identify whether or
not collocation space is currently available to CLECs. For each wire center
where collocation space is currently not available to CLECs, please include
an explanation of why space is not available in those wire centers.
RESPONSE:
Please see ATTACHMENT "A" which lists the wire centers in Idaho indicating
whether space is available or not. This information is available at the
following url: http: / /www. qwest. com/wholesale/notices/ collo/ spaceAvail. html
A wire center is at exhaust when there is no space to place one standard bay
of equipment for cageless collocation.
Respondent:Maryann Klasinski, Qwest Manager
Idaho
Case No. GNR-03-
STF 1-014
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:014
Swi tching
With respect to the voice-grade equivalent lines being provided to (a)
residential customers; (b) business customers to whom you provide between 1-
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 equivalentlines (in one location), state the current average total monthly revenues
earned per line served in Idaho by LATA and by MSA and specify the source of
those revenues by service type.
RESPONSE:
Qwest is in the process of gathering the information necessary to respond to this
request and will supplement its response as it completes its review and analysis of thl
information.
Respondent:Qwest Legal Department
Idaho
Case No. GNR-03-
STF 1-015
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:015
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
Idaho (this would include switches located in other states that provide or
have the ability to provide local exchange service in Idaho), state the
initial cost of that switch, including installation and engineering costs,
and the number of initial equipped lines.
RESPONSE:
Please see Highly Confidential Attachment "A" which contains the Engineered,
Furnished and Installed (liE, F , and I ") cost for switches purchased in 1999
to present and the initial line counts for these switches. A special study
would be required to provide information for those switches purchased prior
to 1999.
Respondent:Maryann Klasinski , Qwest Manager
Idaho
Case No. GNR-03 -
STF 1-016
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:016
Describe in detail any instances in which your company is using, through a
wholesale, lease , or resale arrangement , the switch of any entity
unaffiliated with Qwest (e., another competitive local exchange carrier) to
provide local exchange service to end users in Idaho. Include in your
response the rates , terms, and conditions under which you are obtaining
swi tching on a wholesale , lease, or resale basis.
RESPONSE:
Qwest is not using, through a wholesale , lease, or resale arrangement, the
switch of any entity unaffiliated with Qwest (e.g., another competitive local
exchange carrier) to provide local exchange service to end users in Idaho.
Respondent:Maryann Klasinski , Qwest Manager
Idaho
Case No. GNR-03 -
STF 1-017
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:017
State whether your company is providing, or plans to provide , through a
wholesale, lease or resale arrangement, capacity on any swi tches you own or
operate in Idaho , or that you own or operate in another state and that you
use to provide local service in Idaho, 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)
(ii)
percentage of switch capacity in use;
percentage of switch capacity reserved for your company
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)
(ii)
the anticipated service life of the switch; and
whether your company intends to utilize the identified
switch for the full anticipated service life.
RESPONSE:
Qwest provides access to its facilities, including switches in accordance
with all state and federal statutes and to all entities as required by law.
Idaho
Case No. GNR-03-
STF 1-023
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:023
List each task that is part of the batch hot cut process described in the
answer to the above request regarding a batch 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.
RESPONSE:
Qwest is in the process of preparing a detailed overview of the new Batch Hot
Cut Process ("BHCP") in anticipation of a collaborative meeting with the
CLECs. The overview was filed with the Commission on November 12 , 2003 , with
the Joint Forum scheduled to take place on December 1st - 3rd. The
information provided at that time, as well as the information that will be
developed during the forum process will address the issues raised in this
data request.
Respondent:Maryann Klasinski , Qwest Manager
Idaho
Case No. GNR-03-
STF 1-024
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:024
List each task that is part of the batch hot cut process that is not included
in the current hot cut process.
RESPONSE:
Please see Qwest I s Response to Staff Set 1, Data Request No. 22.
Respondent:Maryann Klasinski , Qwest Manager
Idaho
Case No. GNR-03-
STF 1-025
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:025
List each task that is part of the current hot cut process that is not
included in the batch hot cut process.
RESPONSE:
Please see Qwest I s Response to Staff Set 1, Data Request No. 22. Tasks in
Qwest r s current hot cut process but not in Qwest I s proposed batch hot cut
process include, but are not limited to, the following:a. The Central Office Technician ("COT") performs the central office wiring
and appropriate tests on Design, Verify, and Assign date. The COT documents
the start time of the "lift" and the end of the "lay" process;
b. The COT notifies the Qwest Customer Care Center ("QCCC") that the work is
complete and provides , the QCCC with: the "lift" and "lay" time and the testresults;c. The QCCC documents the stop time of the cut and phones the CLEC that the
work is complete providing test results. If the CLEC has purchased
Cooperative or Performance Testing, the test results are also forwarded to
the CLEC via e-mail within two business days of order completion; and
d. CLEC does not accept the loop, the QCCC enters a jeopardy code on the order
and notifies the Service Delivery Coordinator ("SDC") and the Recent Change
Memory Administration Center ("RCMAC") that the order will not be completed
due to customer reasons.
Respondent:Maryann Klasinski , Qwest Manager
Idaho
Case No. GNR-03-
STF 1-026
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:026
On a monthly basis, provide the total number of residential lines served and
the number of residential lines served using integrated digital linecarriers. Provide separately for every wire center the number of Qwest
retail residential lines, UNE served residential lines, and Wholesale served
residential lines. Provide this information for the period of time since the
FCC approved Qwest' s Application for 271 authority in Idaho. Provide the
information on a region-wide basis in addition to Idaho specific data.
RESPONSE:
Qwest has compiled the Idaho data in its possession that is responsive to
this request. However , this request seeks CLEC/carrier specific information
that may be protected under 47 U.C. 222(a) ("Privacy of Customer
Information") and/or other federal privacy laws. Qwest will provide the
requested CLEC information to those that have signed Exhibit B of theProtective Order (Commission Order No. 29384) upon receiving either: (1) a
Commission order requiring production of the information; or 2) permission
from the CLEC to release the requested infor~ation.
Qwest has not compiled region-wide data , nor has it compiled the requested
data for all of the states in its 14-state region. Region-wide data is not
relevant to the mass market switching case in the nine-month proceeding, nor
does Qwest believe that region-wide data is necessary for the Commission
participation in the Batch Hot Cut forum.
Once Qwest has received a Commission Order or CLEC permission to release
information, see HIGHLY CONFIDENTIAL ATTACHMENT "A" for the number of
residential lines served by Qwest in Idaho and the percent of these
residential lines using integrated digital line carrier, HIGHLY CONFIDENTIAL
ATTACHMENT "B" for the total number of CLEC residential resold lines
(characterized in the request as "wholesale" served residential lines), and
HIGHLY CONFIDENTIAL ATTACHMENT "C" for the number of UNE-P lines Qwest
believes are being used by CLECs to serve residential customers. Neither
UNE-P nor UNE-L are identified in Qwest systems as being used for residential
or business purposes - these services are generic, wholesale services
provided by Qwest to CLECs. To estimate the number of residential UNE-
lines in service, Qwest compared the telephone numbers associated with UNE-
lines in service against the current White Pages listings database , and
identified the quantity of UNE-P telephone numbers shown in the residentialsection of that database. This is the only means Qwest has of approximating
the number of UNE-P residential lines in service. and the results of this
analysis are reflected in HIGHLY CONFIDENTIAL ATTACHMENT "C." Since UNE-L has
no associated telephone number in Qwest switches (the telephone numbers
associated with UNE-L lines are provisioned from CLEC switches) Qwest is
unable to compare UNE-L telephone numbers to the Qwest White Pages database.
In the Idaho Section 271 proceedings , Qwest attributed 100% of UNE-L lines in
service to business. For consistency, the same approach will be applied in
this proceeding in developing Qwest I s response to this discovery question.
To the extent CLECs provide information in their discovery responses showing
some proportion of their UNE-L lines are now being used to serve residential
customers, Qwest will reflect that information in its direct testimony.
Respondents: Elaine Garley, Qwest Manager
Maryann Klasinski , Qwest Manager
Idaho
Case No. GNR-03-
STF 1-027
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:027
For each wire center , on a monthly basis, provide the total number of
business mass-market lines served and the number of business mass-marketlines served using integrated digital line carriers. Provide separately for
every wire center the number of Qwest retail business mass-market lines, liNE
served business mass-market lines, and Wholesale served business mass-marketlines. Explain how Qwest determined which business lines were mass-market
lines and which are enterprise lines. Provide this information for the
period of time since the FCC approved Qwest' s Application for 271 authorityin Idaho. Provide the information on a region-wide basis in addition to
Idaho specific data.
RESPONSE:
Qwest has compiled the Idaho data in its possession that is responsive to
this request. However , this request seeks CLEC/carrier specific information
that may be protected under 47 U. S . C. 222 (a) ( "Privacy of Customer
Information") and/or other federal privacy laws. Qwest will provide the
requested CLEC information to those that have signed Exhibit B of the
Protective Order (Commission Order No. 29384) upon receiving either: (1) a
Commission order requiring production of the information; or 2) permission
from the CLEC to release the requested information.
Qwest has not compiled region-wide data, nor has it compiled the requesteddata for all of the states in its 14-state region. Region-wide data is not
relevant to the mass market switching case in the nine-month proceeding, nor
does Qwest believe that region-wide data is necessary for the Commission '
participation in the Batch Hot Cut forum.
Once Qwest has received a Commission Order or CLEC permission to release
information
see HIGHLY CONFIDENTIAL ATTACHMENT "A" for a report of all business access
lines served on a DSO level in each wire center in Idaho, and the percent of
these business lines served using integrated digital carrier. Qwest does not
track lines using integrated digital carrier by service; therefore, the
percent is the same for residence and for business.
Once Qwest has received a Commission Order or CLEC permission to release
information
see HIGHLY CONFIDENTIAL ATTACHMENT "B" for the number of resold DSO-Ievel
business lines in service (characterized in the above request as "wholesale"
served business lines) .
Once Qwest has received a Commission Order or CLEC permission to release
information , see HIGHLY CONFIDENTIAL ATTACHMENT "C" for the estimated number
of DSQ-level business UNE-P lines in service by wire center. Since Qwest
cannot directly track the number of UNE-P lines CLECs are using to serve
business customers, Qwest has identified the quantity of UNE-P telephone
numbers appearing in the residential section of the Qwest White Pages
database , and subtracted those quantities from the total UNE-P quantities in
service. The remainder is identified for this purpose as being business
UNE-P lines in service. Since only a fraction of all business lines in
service actually appear in the White Pages, a simple reporting of UNE-
business listings understates the actual number of UNE-P lines being used for
business purposes.
Once Qwest has received a Commission Order or CLEC permission to release
information, see HIGHLY CONFIDENTIAL ATTACHMENT "D" for a report by wire
center of all DSQ-level UNE-L lines in service. At this time, Qwest has no
way to differentiate whether UNE-L lines are used by CLECs to serve
residential or business customers , and represents for purposes of this
response that all UNE-L lines are being used to serve business customers.
However, as CLECs provide discovery responses in this proceeding identifying
the proportion of UNE-L lines actually used to serve business customers,
Qwest will reflect that information in its direct testimony to be filed in
December.
For purposes of this response, Qwest has defined all business lines served at
the DSQ level as "mass market" business lines. In fact, the FCC has directed
the state Commissions to determine the point at which CLECs can efficiently
and reasonably serve multi-line business customers with DSl loops , and the
Commission will base its findings in this regard on all evidence supplied by
the parties through discovery responses and direct testimony. Qwest does not
yet know where this "break" point is, but will submit its recommendation to
the Commission as to where it recommends the break point to be in its direct
testimony to be filed in December.
Respondents: Elaine Garley, Qwest Manager
Maryann Klasinski , Qwest Manager
Idaho
Case No. GNR-03-
STF 1-028
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:028
If the tasks related to the hot cut process for lines served using integrated
digi tal line carriers differs from the process used for other lines , discuss
how the process is different and list the tasks that must be added
specifically for the lines served using integrated digital line carriers.
Include the time required to accomplish those tasks.
RESPONSE:
If a UNE-P loop is currently provided over IDLC and the CLEC requests
conversion to an Unbundled Loop, Qwest will first look for an alternative
which could include, but is not limited to, metallic facilities (copper pair)
or a Universal Pair Gain. If neither of these alternatives is available as a
temporary solution , Qwest will hairpin the circuit and issue a job to
provision a Central Office Terminal (COT) and will convert the hairpin onto
the COT when it becomes available. Hairpins are dedicated time slots between
two DSO ports in the same Integrated Digital Carrier Unit (IDCU).
If a UNE-P line provided over IDLC is converted to a UNE-Loop using a hot cut
process, a new jumper must be run on the DSO distributing frames where the
OSP pair appears. The OSP pair is connected by jumpers to the CLEC switching
equipment. It may be necessary to place voltage protection coils or
continui ty coils at the OSP pair appearance or UDLC pair appearance. The
IDLC channel formerly used is modified by translations and then becomesavailable for reuse. The time needed to accomplish these tasks will vary,
based on the size of the office (number of floors, etc.) and the number and
location of distributing frames involved.
Respondent:Maryann Klasinski , Qwest Manager
Idaho
Case No. GNR-03-
STF 1-029
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:029
On a monthly basis, provide the average time a customer s service was
disconnected due to the hot cut process. Provide this information for the
period of time since the FCC approved Qwest' s Application for 271 authorityin Idaho. Provide the information on a region-wide basis in addition to
Idaho specific data.
RESPONSE:
Qwest does not track the exact data point identified in this request;
however, Qwest does track "the time actually involved in disconnecting the
loop from Qwest network and connecting/testing the loop.See Purpose of
Measure OP-7 available at the following URL:
http:\\www.qwest.com\wholesale\results\roc.html The audited data under PID
OP-7 shows that the amount of out of service time plus testing time is
approximately three minutes. However , the amount of time a customer is out
of service is only the time it takes Qwest to disconnect the loop from its
frame and reconnect it to the CLEC. While testing occurs thereafter, the
customer is almost always in service during the testing phase. While Qwest
does not track the true out of service time , Qwest estimates that this time
is almost always less than 30 seconds, and would average approximately 15
seconds.
Qwest has not compiled region-wide data, nor has it compiled the requested
data for all of the states in its 14-state region. Region-wide data is not
relevant to the mass market switching case in the nine -month proceeding, nor
does Qwest believe that region-wide data is necessary for the Commission '
participation in the Batch Hot Cut forum.
Respondent:Maryann Klasinski , Qwest Manager
Idaho
Case No. GNR-03-
STF 1-030
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:030
On a monthly basis , provide the number of technicians during each month who
have transferred a line from an ILEC switch to the CLEC facility as part of
the hot cut process. Count only those employees who perform the manualprocess. Provide this information for the period of time since the FCC
approved Qwest' s Application for 271 authority in Idaho. Provide the
information on a region-wide basis in addition to Idaho specific data.
RESPONSE:
Qwest does not track this information in Idaho or on a region-wide basis.
Respondent:Maryann Klasinski , Qwest Manager
Idaho
Case No. GNR-03-
STF 1-031
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:031
On a monthly basis , provide the number of technicians trained and capable of
transferring a line from an ILEC switch to the CLEC facility as part of the
hot cut process. Count only those employees who can perform the manual
process. Do not include management or supervisory personnel who can perform
these tasks but do not do so as part of their regular work effort. Provide
this information for the period of time since the FCC approved Qwest' s
Application for 271 authority in Idaho. Provide the information on a
region-wide basis in addition to Idaho specific data.
RESPONSE:
Qwest does not track this information on a monthly basis. However
Confidential Attachment "A" contains the number of technicians. trained
capable of transferring a line from a Qwest switch to CLEC facility as
of Qwest I s current hot cut process currently working in Idaho.
andpart
Qwest has not compiled region-wide data , nor has it compiled the requested
data for all of the states in its 14-state region. Region-wide data is not
relevant to the mass market switching case in the nine-month proceeding, nor
does Qwest believe that region-wide data is necessary for the Commission'
participation in the Batch Hot Cut forum.
Respondent:Maryann Klasinski, Qwest Manager
Idaho
Case No. GNR-03-
STF 1-032
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:032
On a monthly basis for every wire center , provide, in an electronic format
the number of hot cuts performed. Provide this information for the period of
time since the FCC approved Qwest' s Application for 271 authority in Idaho.
Provide the information on a region-wide basis in addition to Idaho specific
data.
RESPONSE:
Qwest has compiled the Idaho data in its possession that is responsive to
this request. However , this request seeks CLEC/carrier specific information
that may be protected under 47 U.C. 222 (a) ("Privacy of Customer
Information") and/or other federal privacy laws. Qwest will provide the
requested CLEC information to those that have signed Exhibit B of the
Protective Order (Commission Order No. 29384) upon receiving either: (1) a
Commission order requiring production of the information; or 2) permission
from the CLEC to release the requested information.
Qwest has not compiled region-wide data, nor has it compiled the requested
data for all of the states in its 14-state region. Region-wide data is not
relevant to the mass market switching case in the nine-month proceeding, nor
does Qwest believe that region-wide data is necessary for the Commission '
participation in the Batch Hot Cut forum.
Respondent:Maryann Klasinski , Qwest Manager
Idaho
Case No. GNR-03-
STF 1-033
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:033
Provide a list of all carriers with which Qwest has an interconnection
agreement for the provision of local service in Idaho.
RESPONSE:
See Attachment "A" for a list of all carriers with which Qwest has an
interconnection agreement for the provision of local service in Idaho.
Respondent:Susan Van Putten, Qwest Manager
Sam Radetsky, Qwest Manager
Idaho
Case No. GNR-03-
STF 1-034
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:034
Provide a list of all carriers to which Qwest has sold collocation services
in Idaho. For each carrier , list the wire centers where the carrier is
collocated.
RESPONSE:
Qwest has compiled the Idaho data in its possession that is responsive to
this request. However , this request seeks CLEC/carrier specific information
that may be protected under 47 U.C. 222 (a) ("Privacy of Customer
Information") and/or other federal privacy laws. Qwest will provide the
requested CLEC information to those that have signed Exhibit B of the
Protective Order (Commission Order No. 29384) upon receiving either: (1) a
Commission order requiring production of the information; or 2) permission
from the CLEC to release the requested information.
Once Qwest has received a Commission Order or CLEC permission to release
information , see HIGHLY CONFIDENTIAL ATTACHMENT "A" for a list of all
carriers that have active collocations as of 11/17/03.
Respondent: Elaine Garley, Qwest Manager
Idaho
Case No. GNR-03-
STF 1-035
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:035
Provide a list of Qwest wire centers with indicators that identify whether
the office is unstaffed, has a technician on duty but the technician cannot
perform hot cuts , or has a technician on duty and the technician can perform
hot cuts. For unstaffed offices and offices where the technician cannot
perform hot cuts, specify the number of miles that the technician must drive
and driving time to reach that office from the closest office where a
technician who can perform hot cuts is normally on duty.
RESPONSE:
Please see Highly Confidential Attachment "A" which lists the Qwest wire
centers in Idaho , whether there are technicians in the office who can perform
hot cuts, and , if the office is unstaffed , the nearest wire center with staff
and the distance from that wire center. Qwest did not provide the time
between offices due to factors such as weather , traffic, and workload that
could influence travel time.
Respondent:Maryann Klasinski, Qwest Manager
Idaho
Case No. GNR-03-
STF 1-036
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:036
If a batch cut process is developed , does that make it more or less likely
that an electronic loop provisioning process will be implemented?
RESPONSE:
Qwest does not intend to implement an electronic loop provisioning ("ELP"process.
The FCC recognized in the Triennial Review Order ("TRO") that an electronic
loop provisioning proposal would cost by one estimate "more than 100 billion
dollars"TRO at Para. 491.
Respondent:Maryann Klasinski , Qwest Manager
Idaho
Case No. GNR-03-
STF 1-037
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:037
For each technician identified as trained in the hot cut process , when did
that training occur?
RESPONSE:
On the job training was conducted in advance of the first live hot cut and
continues today in the form of weekly audi ts conducted by management
employees.
Respondent:Maryann Klasinski , Qwest Manager
Idaho
Case No. GNR-03 -
STF 1-038
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:038
For each technician identified as trained in the hot cut process, is that
training documented or posted? If so , where is that training documented or
posted?
RESPONSE:
The training is not documented or posted.
Respondent:Maryann Klasinski , Qwest Manager
Idaho
Case No. GNR-O3-
STF 1- 03
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:039
For each technician identified as trained in the hot cut process , how often
does that technician get trained in the hot cut process?
RESPONSE:
Hot cut training is provided as on the job training using Qwest Central
Office job aids. Qwest management employees audit non-management employees
on a weekly basis to ensure compliance to processes. Coaching sessions are
provided to bring employees back into compliance if necessary. Training is
an ongoing process.
Respondent:Maryann Klasinski , Qwest Manager
Idaho
Case No. GNR-03-
STF 1-040
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:040
For each technician identified as trained in the hot cut process , is there a
refresher course for that technician? If so, how often is the refresher
course offered?
RESPONSE:
Please see Qwest I s Response to Staff Set 1 , Data Request No.3 9.
Respondent:Maryann Klasinski , Qwest Manager
Idaho
Case No. GNR-03-
STF 1-041
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:041
For each technician identified as trained in the hot cut process, is the
technician required to take the refresher course if one is offered?
RESPONSE:
Each technician is required to attend refresher training.
Respondent:Maryann Klasinski , Qwest Manager
Idaho
Case No. GNR-03-
STF 1-042
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:042
Does Qwest I s UNE-L loop always provide CLECs with DSO capacity?
RESPONSE:
Qwest is in the process of gathering the information necessary to respond to this
request and will supplement its response as it completes its review and analysis of thE
information.
Respondent:Qwest Legal Department
Idaho
Case No. GNR-03-
STF 1-043
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:043
If Qwest I s UNE-L loop does not always provide CLECs with DSO capacity,
identify by customer and wire center all instances where it does not provide
DSO capacity.
RESPONSE:
Qwest is in the process of gathering the information necessary to respond to this
request and will supplement its response as it completes its review and analysis of the
information.
Respondent:Qwest Legal Department
Idaho
Case No. GNR-03-
STF 1- 044
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:044
For each Qwest central office or wire center at which loops and transport are
connected at collocation arrangements to form EELs, please provide the
following information:
(a) the CLLI code , street address , and V&H coordinates of the Qwest central
office or wire center where such EELs are created;
(b) the CLLI code, street address, V&H coordinates , and owner(s) of the
switch (es) to which such EELs are connected;
(c) number of such EELs that comprise DS-O/voice grade transport connected to
DS - O/voice grade loops;
(d) number of such EELs that comprise DS-1 transport connected to multiplexed
DS-O/voice grade loops;
(e) number of such EELs that comprise DS-1 transport connected to multiplexed
and concentrated DS-O/voice grade loops, and the loop-to-transportconcentration ratio;
(f) number of such EELs that comprise DS-3 transport connected to multiplexed
DS-O/voice grade loops;
(g) number of such EELs that comprise DS-3 transport connected to multiplexed
and concentrated DS-O/voice grade loops , and the loop-to-transportconcentration ratio;
(h)number such EELs that comprise DS-transport connected DS-loops;
(i)number such EELs that comprise DS-transport connected to multiplexed
DS-loops;
(j) number of such EELs that comprise DS-3 transport connected to multiplexed
and concentrated DS-1 loops, and the loop-to-transport concentration ratio.
RESPONSE:
Qwest has compiled the Idaho data in its possession that is responsive to
this request. However , this request seeks CLEC/ carrier specific information
that may be protected under 47 U. S . C. 222 (a) "Privacy of Customer
Information") and/or other federal privacy laws. Qwest will provide the
requested CLEC information to those that have signed Exhibit B of the
Protective Order (Commission Order No. 29384) upon receiving either: (1) a
Commission order requiring production of the information; or 2) permission
from the CLEC to release the requested information.
(a) Please see Highly Confidential Attachment "A" which contains the CLLI
code, street address , and V & H coordinates of the Qwest central offices that
have EELs.
(b) Qwest does track the information requested.
(c-j) Qwest does not track the information requested. Please see HIGHLY
CONFIDENTIAL ATTACHEMNT "B" for the EEL in service by wire center as of
9/30/03.
Respondent: Maryann Klasinski , Qwest Manager
Elaine Garley, Qwest Manager
Idaho
Case No. GNR-03-
STF 1-045
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:045
For each Qwest central office or wire center at which loops and transport are
connected to form EELs wi thout using collocation , please provide the
following information
(a) the CLLI code, street address, and V&H coordinates of the Qwest central
office or wire center where such EELs are created;
(b) the CLLI code , street address , V&H coordinates , and owner(s) of the
switch(es) to which such EELs are connected;
(c) number of such EELs that comprise DS-Ojvoice grade transport connected to
DS-Ojvoice grade loops;
(d) number of such EELs that comprise DS-1 transport connected to multiplexed
DS-Ojvoice grade loops;
(e) number of such EELs that comprise DS-1 transport connected to multiplexed
and concentrated DS-Ojvoice grade loops, and the loop-to-transportconcentration ratio;
(f) number of such EELs that comprise DS-3 transport connected to multiplexed
DS-Ojvoice grade loops;
(g) number of such EELs that comprise DS-3 transport connected to multiplexed
and concentrated DS-Ojvoice grade loops, and the loop-to-transportconcentration ratio;
(h)number such EELs that comprise DS-transport connected DS-loops;
(i)number such EELs that comprise DS-transport connected multiplexed
DS-loops;
(j) number of such EELs that comprise DS-3 transport connected to multiplexed
and concentrated DS-1 loops, and the loop-to-transport concentration ratio.
RESPONSE:
Qwest does not track if the EELs used by CLECs are used with or withoutcollocations.
Respondent: Elaine Garley, Qwest Manager
Idaho
Case No. GNR-03-
STF 1-046
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:046
For each CLEC and other carrier collocation arrangement in each Qwest central
office or wire center in Idaho, please provide the following information
reported by CLLI code and street address:
(a) name of CLEC or other carrier;
(b) type of collocation arrangement (e.g. caged , cageless , virtual , etc.
(c) size of collocation arrangement;
(d) amount of power (including both "A" and "B" DC feeds and AC power)
supplied to the collocation arrangement;
(e) number of 2-wire cross connects currently provisioned from the MDF to the
collocation arrangement;
(f) number of 4-wire cross connects currently provisioned from the MDF to the
collocation arrangement;
(g) all equipment installed in the collocation arrangement, including make,
model , and total installed capacity for each piece of equipment;
(h) type (s) of Qwest transport connected to the collocation arrangement
(e., special access , UNE transport , etc.
(i) capacity (ies) of Qwest transport connected to the collocation arrangement
(e., DS-, DS-3, OC-3, etc., and number of circuits at each level of
capaci ty) ;
(j) all non-recurring and recurring charges for the collocation arrangement;
(k) name (s) of other collocating carrier (s) to which this collocation
arrangement is connected in this central office or wire center.
RESPONSE:
with regard to subparts (a), (b), and (c), Qwest has compiled the Idaho data
in its possession that is responsive to this request. However , this request
seeks CLEC/carrier specific information that may be protected under 47 U. S. C.
222 (a) ("Privacy of Customer Information") and/or other federal privacy laws.
Qwest will provide the requested CLEC information to those that have signed
Exhibit B of the Protective Order (Commission Order No. 29384) upon receiving
either: (1) a Commission order requiring production of the information; or
permission from the CLEC to release the requested information.
(d)Qwest does not track this information.
(e)Qwest does not track this information.
(f)Qwest does not track this information.
(g)
Qwest does not track this information.
(h)Qwest does not track this information.
(i)Qwest does not track this inf orma t ion.
(j) Recurring and nonrecurring rates for collocation may be located in the
SGAT,
Exhibit A from the pull down menu at the following URL:
http://www.qwest.com/who1esa1e/c1ecs/sgatswire1ine.htm1
(k)Qwest does not track this information.
Respondent:Maryann Klasinski , Qwest Manager
Elaine Garley, Qwest Manager
Steve Nelson, Qwest Manager
Idaho
Case No. GNR-03-
STF 1-048
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:048
Please explain whether you currently have in place electronic systems that
can accomplish each of the following migration types on a automated
flow-through basis (i. e., no human or other manual intervention is required
for completion of the migration)
(a) from UNE-P voice only, or UNE-P voice plus data , to CLEC switch-based
voice only;
(b)from UNE - P voice only,or UNE-voice plus data,Qwest voice only;
(c)from UNE-voice only,or UNE-voice plus data,Qwest voice plus
data;
(d) from UNE-P voice only, or UNE-P voice plus data, to one CLEC linesplitting;
(e) from UNE-P voice only, or UNE-P voice plus data, to two CLEC line
splitting;
(f) from UNE-, or UNE-P voice plus data , to CLEC line sharing with CLECsplitter;
(g) from UNE-, or UNE-P voice plus data , to CLEC line sharing with Qwestsplitter;
(h) from CLEC switch-based voice to any of the above;
(i) from one and two CLEC line splitting to any of the above;
(j) from one and two CLEC line sharing to any of the above.
RESPONSE:
Qwest is in the process of gathering the information necessary to respond to this
request and will supplement its response as it completes its review and analysis of tht
information.
Respondent:Qwest Legal Department
GNR- T -03-
N ov. 26 , 2003
Attachment A to Response Request No. 12 is
voluminous - (3 copies of compact disc)
for case file / Legal / Wayne