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HomeMy WebLinkAbout200312031st Response of Electric Lightwave.pdfWJift,~:~c A. Citizens CommunicGtklns Company IT) 4 Triad Center, Suite 200 Salt Lake City, UT 84180 AM 9: Ii ILl r UBtlC unLIT IES COtviMISS1ON December 2, 2003 Mrs. Jean Jewell Commission Secretary Idaho Public Utilities Commission 472 W. Waslrington Street Boise, ID 83702-5983 Subject:Case No. GNR-O3023 First Production Request of Commission Staff Dear Mrs. Jewell: Electric Lightwave hereby submits both its redacted and highly confidential response to the First Production Request of the Commisison Staff to Competitive Local Exchange Carriers in the above referenced case. The highly confidential response is provided pursuant to the Protective Order in this case. If you have any questions or need additional information, please contact me at the above address or at (801) 924-6357. Sincerely, J' ---- Lance A. Tade Manager- State Government Affairs Enclosures BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATIER 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 ON ECONOMIC AND OP ARATION IMPAIRMENT REGARDING ACCESS TO SPECIFIC UNES. CASE NO. GNR-T-03-23 ELECTRIC LIGH1W AVE' REDACTED RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO COMPETITIVE LOCAL EXCHANGE CARRIERS Electric Lightwave hereby provides its redacted response as follows: 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. ~ 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: Boise - BOISIDPZDSo 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. Response: Electric Lightwave provides service in the following Qwest rate centers: Boise, Caldwell, Meridian, Nampa. Requested information regarding Qwest's wire centers within each identified rate center is not available. Request No.3: For each ILEC wire center identified in response to Request No. , identify the total number of voice-grade equivalent lines 1 you are providing to customers in that wire center from your switch(es) identified in response to Request No. 1. For purposed of this request , " voice-grade equivalent lines should be defined consistent with the FCC's use of the term. REDACTED RESPONSE: ELECTRIC LIGHTWAVE'S RESPONSE TO STAFF'S FIRST PRODUCTION REQUEST IN CASE NO. GNR-O3- The requested information is not available by Qwest wire center. As of October , 2003, Electric Lightwave had **REDACTED** voice-grade equivalent lines in Idaho. 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. REDACTED RESPONSE: The capacity of the switch identified in response to Request NO.1 is REDACTED** lines. Request No.5: With respect to the voice-grade equivalent lines identified in response to Request No.3, separately indicate the number being provided to (a) residential customers; (b) business customers to whom you provide only voice- grade or DSO lines. Response: 100% of the lines identified in response to Request No.3 are provided to business customers. 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. Response: The switch identified in response to Request NO.1 is owned by Electric Lightwave. 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 lATA and by MSA and specify the source of those revenues by service type. REDACTED RESPONSE: ELECTRIC LIGHTWAVE'S RESPONSE TO STAFF'S FIRST PRODUCTION REQUEST IN CASE NO. GNR-O3- The following table provides average monthly revenues per line for January through October 2003 at the level of detail available from Electric Lightwave accounting system. An extremely time consuming analysis of billing records would be required to provide accurate data at any other level. Revenue Category Local Toll Access Interconnection Private Line Data Collocation Average Monthly Revenue per Line """ REDACTED""" """ REDACTED""" """ REDACTED"" """ REDACTED""" """ REDACTED""" REDACTED""" """ REDACTED""" """ REDACTED"" 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. REDACTED RESPONSE: Initial cost - **REDACTED**; initial lines equipped - ** REDACTED** Request No.9: Describe in detail any instances in which you 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: None. 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: The make, model, age and current software upgrades of each switch; The geographic location of the switch; ELECTRIC LIGHTWAVE'S RESPONSE TO STAFF'S FIRST PRODUCTION REQUEST IN CASE NO. GNR-T -03- The footprint or geographic area service by the switch, including a list of each exchange service by the switch; the features and functions (including software upgrades) available in the switch; Provide the capacity of each switch, including; (i) percentage of switch capacity in use;(ii) percentage of switch capacity reserved for your company own use and future use; and(Hi) percentage of current and future capacity of each switch that will be made available for CLEC use. For each switch identified, please state in detail:(i) the anticipated service life of the switch; and (ii) whether your company intends to utilize the identified switch for the full anticipated service life Response: None. 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 services. 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: Quantity ofVGE Per Customer Location Residence Business ELECTRIC LIGHTWAVE'S RESPONSE TO STAFF'S FIRST PRODUCTION REQUEST IN CASE NO. GNR-O3- 24 or more Response: The requested information is not available. 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. Response: Yes, switching capacity can be expanded. Request No. 13: Does the CLEC believe that there are costs associated with converting or otherwise using a switch currently servicing only enterprise customers to also service 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. Response: Electric Lightwave does not serve mass-market customers and has not conducted a study of doing so. As such, no relevant data is available on this subject. 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.e.percentage f your customers lost to another carrier) on all of the following bases: (a) number of customers by customer type (e.residential, business with one to three lines; business with more than three lines); (b) percentage of chum 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., 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 chum 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 ELECTRIC LIGHTWAVE'S RESPONSE TO STAFF'S FIRST PRODUCTION REQUEST IN CASE NO. GNR-O3- DLS services). Response: The requested data is not available. 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. REDACTED RESPONSE: The following table provides expenses at the level of detail available from Electric Lightwave s accounting system. An extremely time consuming analysis of individual transactions would be required to provide accurate data at any other level. Cost of Goods Sold by Product Category Local Toll Interconnection Private Line Data Miscellaneous 2001 2002 10/03 YTD Average Monthly Cost per Line ** REDACTED 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 chum 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 no include customers who move but stay with the company. Please produce all documents that refer or relate to the information your provide in response to this request. REDACTED RESPONSE: Monthly churn rates are not available for the periods requested. Churn rates experienced in 2004 have been: **REDACTED** 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 ELECTRIC LIGHTWAVE'S RESPONSE TO STAFF'S FIRST PRODUCTION REQUEST IN CASE NO. GNR-O3- 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. REDACTED RESPONSE: Percent that left within one month - ** REDACTED** Percent that left within two months - **REDACTED** Percent that left within three months - ** REDACTED** Percent that left within six months - ** REDACTED** 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' total local exchange customers in Idaho that subscribe to each plan that your identify. Please produce all documents that reflect, refer or relate to the information you provide in response to this request. REDACTED RESPONSE: See the attached pricing sheets. The following table shows the percentage of Electric Lightwave customers by price sheet: Dialtone Lines Dialtone Trunks ISDN Other **REDACTED** REDACTED** REDACTED** REDACTED** 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. REDACTED RESPONSE: The following table provides average monthly retail minutes of use per line for January through October 2003, at the level of detail available from Electric Lightwave s accounting system. An extremely time consuming analysis of billing records would be required to provide accurate data at any other level. ELECTRIC LIGHTWAVE'S RESPONSE TO STAFF'S FIRST PRODUCTION REQUEST IN CASE NO. CJNR-O3- Retail Usage Statistics October 2003 YfD Interstate Intrastate Total Minutes REDACTED** REDACTED** REDACTED** Monthly Average per Line REDACTED** REDACTED** REDACTED** 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? REDACTED RESPONSE: Electric Lightwave has REDACTED** today. It is not possible to determine how many cross-connects have been completed since June 2001. The number would be **REDACTED** 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. Response: Electric Lightwave does not utilize a hot cut process. 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 rate. Indicate the source of the data, i.e. time/motion studies, SME analysis, etc. Response: Not applicable. See 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. Response: Electric Lightwave has not formed an opinion about a batch hot cut process that might satisfy the FCC's requirements. See 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, ELECTRIC LIGHTWAVE'S RESPONSE TO STAFF'S FIRST PRODUCTION REQUEST IN CASE NO. GNR-O3- the labor rate for the task, and the common overhead loading associated with the labor rate. Response: Not applicable. See response to Request No. 23. Request No. 25: If UNE- 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: Electric Lightwave utilizes its own switch so there will be no hot cuts required to migrate existing UNE-P customers to any other form of service or to connect new customers in the ordinary course of business.