20031210Qwest Objections to MCI Requests.pdf

Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoel.com
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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 (CC DOCKET NO. 01-338)
Case No. GNR-03-
QWEST CORPORATION'S OBJECTIONS
TO MCl's DISCOVERY REQUESTS TO
QWEST
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 hereby submits the following objections to MCr's Discovery
Requests.
INTRODUCTION
Qwest lodges numerous objections to the discovery propounded by MCr. It is important
to understand the context for these objections. First, it is critical to be clear about the issues that
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are part of the case and the issues that are not because discovery must bear a reasonable
relationship to the issues in the proceeding. The Federal Communications Commissions
FCC") Triennial Review Order ("TRO") 1 is a lengthy and complicated order that addresses a
wide array of unbundling and other issues under the Federal Act. However, this docket does not
purport to address all of those issues. Indeed, while the issues in this case are not simple, this
case is narrowly focused on one general issue: whether Qwest is entitled to relief from its
obligation to provide unbundled switching for mass market customers in certain portions of
Idaho. The focus of the mass market switching docket is on what individual competitors
(including CLECs) are actually doing or what an efficient CLEC would be able to do.
MCI ignores this focus completely and seeks information from Qwest related to mass
market or high-capacity loop unbundling, enterprise switching unbundling, dedicated transport
unbundling, next-generation loops, line sharing, line splitting, and other high-capacity or next
generation services, none of which is related to this case.
Despite the fact that the inquiry in this case is primarily focused on the actual and
potential activities of CLECs and other competitors in Idaho, MCI propounded 264 separate data
requests. One of them has 13 subparts-many others have as many as ten subparts. Further
even though Qwest has repeatedly stated that it did not intend to pursue either a high-capacity
loop case or a dedicated transport case in Idaho, many ofMCI's questions appear to be focused
on loop issues and it has devoted 69 questions to transport issues. Given the fact that Qwest is
not pursuing a loop case or a dedicated transport case, Qwest does not intend to respond to those
questions. Even after removing the 69 MCI transport questions, Qwest is left with 38 pages of
Report and Order and Order on Remand and Further Notice of Proposed Ru1emaking, In the Matter of
Review of the Section 25 I Unbundling Obligations of Incumbent Local Exchange Carriers, Implementation of the
Local Competition Provisions of the Telecommunications Act of 1996 Deployment of Wireline Service Offering
Advance Telecommunications Capability, CC Docket Nos. 01-338, 96-98 and 98-147 (August 21 2003) ("TRO"
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questions, comprising 195 data requests. With subparts, those questions consist of hundreds of
individual questions to which Qwest has been asked to respond.
GENERAL OBJECTIONS
Qwest objects to providing answers to data requests that require production of
CLEC/Carrier-specific data. The information requested pursuant to these data requests seeks
CLEC/Carrier-specific information that may be protected under paragraph (a) Section 222
Privacy of Customer Information ) of the Communications Act of 1934, 47 U. S. c. Ii 151 et.
seq, and/or other state and federal privacy laws. Qwest will provide the requested CLEC
information upon receiving either: (1) a Commission order requiring production of the
information; or (2) permission by the CLEC to release the requested information.
Qwest objects to MCI's data requests to the extent they seek to impose an
obligation on Qwest to respond on behalf of subsidiaries, affiliates, or other persons that are not
parties to this case on the grounds that such discovery is overly broad, unduly burdensome
oppressive and not permitted by the applicable discovery rules. Qwest will not be responding to
discovery that seeks information from parent, subsidiary and/or affiliate companies.
Qwest objects to each and every MCI data request that seeks information on a
region-wide basis insofar as these requests are overly broad, unduly burdensome and seek
information that is irrelevant to Qwest's mass-market switching case in Idaho.
Qwest objects to each and every data request to the extent that such request may
call for information that is exempt from discovery by virtue of the attorney-client privilege, or
other applicable privilege.
Qwest objects to each and every data request that seeks third party vendor
proprietary information that Qwest is under contractual obligation to maintain as confidential.
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Subject to this objection and all other objections, Qwest is in the process of obtaining vendor
authorization in order to provide responsive information, if applicable.
Qwest objects to these data requests insofar as they are vague, ambiguous, overly
broad, unduly burdensome, or utilize terms that are subject to multiple interpretations but are not
properly defined or explained for purposes of these data requests. Any and all answers of Qwest
in response to these data requests will be provided subject to, and without waiving, this
objection.
Qwest objects to each and every data request insofar as it is not reasonably
calculated to lead to the discovery of admissible evidence and is not relevant to the subject
matter of this action. While CLEC and Carrier data is relevant to the analysis the Commission
must perform in Qwest's mass market switching case concerning the ability of a CLEC/Carrier
to deploy switches to serve mass market customers, Qwest's data is not relevant to this analysis.
Qwest objects to providing information to the extent such information is already a
matter of public record before this or any other state commission or federal agency, or is
otherwise available as a matter of public record. Particularly in light of the voluminous nature of
MCI's requests , MCI is not entitled to require other parties to gather information that is equally
available and accessible to them.
Qwest objects to these data requests, instructions and definitions insofar as they
are vague, ambiguous, overly broad, unduly burdensome and/or seek to impose obligations on
Qwest that exceed the requirements ofthe Commission s Procedural Rules or the Idaho Rules of
Civil Procedure.
10.Qwest objects to these data requests insofar as they are overly broad, unduly
burdensome, expensive, or oppressive. For example, MCI's requests seek information for
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extended time periods (e., from July 2001) on a "daily, weekly and monthly" basis. Moreover
many of the data requests seek the information on a "daily, weekly and monthly basis" for
requests with subparts. Request No. MCI-5 is just one example of such a request. Qwest will
respond to relevant data requests with information it maintains in the ordinary course of its
business and within reasonable time limitations. Qwest does not intend to provide information
on a CLLI code basis for "each month since July 2001" for every wire center in the state of
Idaho as has been requested in many of the data requests. Qwest objects to such requests on the
grounds that retrieving, compiling and responding to such requests are unduly burdensome
overly broad, and oppressive. Qwest also objects to such requests as being irrelevant to these
proceedings and not reasonably calculated to lead to the discovery of admissible evidence.
Qwest is unable at this point to specifically define the markets in which it will seek relief from
unbundling obligations for switching for mass market customers. Qwest intends to specifically
define those market areas in its testimony to be filed on January 19, 2004. Once those market
areas are defined, all requested information for CLLI codes and/or wire centers outside ofthose
markets will be irrelevant in this docket. Within a reasonable time after Qwest makes its
proposed market definitions, Qwest will respond to relevant requests with relevant and
reasonable information to the extent it exists.
11.Qwest objects to the manner in which certain data is requested. Qwest may not
maintain information in the ordinary course of its business in the particular format requested by
MCI. Qwest objects to providing responsive information in the format requested by MCI on the
grounds that doing so would be overly broad, unduly burdensome, and oppressive.
12.Qwest objects to MCI's data requests to the extent that they seek to have Qwest
create documents not in existence at the time ofthe request and would require a special study.
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13.Further, in light of the short time frames in this proceeding and due to the
voluminous data requests served by MCI, Qwest has attempted to provide specific objections to
data requests. However, due to the compressed schedule in this and other proceedings, Qwest
reserves the right to lodge additional objections in its responses.
14.Finally, Qwest has a general objection with respect to all data requests concerning
the batch hot-cut process. Pursuant to the agreement reached between Qwest, MCI and AT&T
and outlined in a joint filing made with this Commission on October 31 , 2003, Qwest submitted
its batch hot cut proposal on November 2003. The proposal includes a detailed description of
the process, including but not limited to capacity, Pre-ordering, Ordering and Provisioning, and
the intervals. Qwest believes that many of the batch hot cut process data requests MCI has
proffered will be addressed in the Qwest proposal. To the extent a data request is not addressed
in the Qwest proposal and is not otherwise objectionable, Qwest will respond to that data
request.
MCI-
QWEST HOT CUT/CUSTOMER MIGRATION ISSUES
Please provide, a) on a Idaho-statewide basis, and b) on a CLLI-code-specific basis
monthly data for each month since July 2001 for your retail customer "chum
(i.customer change from one carrier to another) on each ofthe following bases:(a) number of customers changing carriers, and percentage ofthen-current
customers changing carriers, by customer type (e.residential, business with one
to three DS-O/voice grade lines to a single customer premises; business with more
than three DS-O/voice grade lines to a single customer premises);
(b) number of customers changing carriers, and percentage of then-current
customers changing carriers, by service type (i.local exchange voice
service only; long distance voice service only; bundled local exchange and
long distance voice services; bundled local exchange and DSL; and bundled
local exchange, long distance, and DSL services);
(c) number of customers changing carriers, and percentage of then-current
customers changing carriers, by customer type (e.residential, business with
one to three DS-O/voice grade lines to a single customer premises; business
with more than three DS-O/voice grade lines to a single customer premises) by
the following customer ages: 1) churn within the first three months after the
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customer s service is provisioned 2) churn within the first six months after the
customer s service is provisioned.
OBJECTION: Qwest objects to this request on the grounds that it is vague, ambiguous,
overly broad, unduly burdensome, and may require a special study. Qwest also objects to
this request on the grounds that it seeks information concerning DSL and long distance
data that is neither relevant nor reasonably calculated to lead to the discovery of admissible
evidence. Qwest also believes that the time period identified in this request is overly broad
and, therefore, producing responsive information, if it exists, would be unduly
burdensome. Finally, to the extent this request seeks CLEC/Carrier specific information
Qwest objects on the grounds that this request requires the production of data that may be
protected by Section 222 of the Communications Act of 1934 47 U.C. ~ 222, or other
privacy laws. Qwest will produce such information upon the entry of a Commission order
compelling Qwest to do so. Without waiving these objections, Qwest will supplement this
response if it determines that it has accessible, responsive and non-protected information
regarding customer churn data.
MCI-Please provide, a) on a Idaho-statewide basis, and b) on a CLLI-code-specific basis
monthly data for each month since July 2001 for your retail customer "churn
(i.the number of customers changing from one carrier to another) for
residential local exchange customers between each of the following service
configurations: I) Qwest voice only 2) Qwest voice plus DSL; 3) Qwest DSL
only; 4) CLEC UNE-P voice only; 5) CLEC switch-based voice only; 6) CLEC
line sharing; 7) CLEC line splitting; 8) CLEC DSL only (e., Qwest voice only
to CLEC UNE-P voice only; CLEC A switch-based voice only to CLEC B
switch-based voice only J.
OBJECTION: Qwest objects to this request on the grounds that it is vague, ambiguous
overly broad, unduly burdensome, and may require a special study. Qwest also objects to
this request on the grounds that it seeks information concerning DSL, line sharing and line
splitting data that is neither relevant nor reasonably calculated to lead to the discovery of
admissible evidence. Qwest also believes that the time period identified in this request is
overly broad, and, therefore, producing responsive information would be unduly
burdensome. Finally, to the extent this request seeks CLEC/Carrier specific information,
Qwest objects on the grounds that this request requires the production of data which may
be protected by Section 222 of the Communications Act of 1934,47 U.c. ~ 222, or other
privacy laws. Qwest will produce such information upon the entry of a Commission order
compelling Qwest to do so. Without waiving these objections, Qwest will supplement this
response if it determines that it has accessible, responsive and non-protected information
regarding customer churn data.
MCI-Please provide, a) on a Idaho-statewide basis, and b) on a CLLI-code-specific basis
monthly data for each month since July 2001 for your retail customer "churn
(i.the number of customers changing from one carrier to another) for business
local exchange voice customers with one to three lines between each of the
following service configurations: 1) Qwest voice only 2) Qwest voice plus DSL;
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3) Qwest DSL only; 4) CLEC UNE-P voice only; 5) CLEC switch-based voice
only; 6) CLEC line sharing; 7) CLEC line splitting; 8) CLEC DSL only (e.
Qwest voice only to CLEC UNE-P voice only; CLEC A switch-based voice only
to CLEC B switch-based voice only).
OBJECTION: Qwest objects to this request on the grounds that it is vague, ambiguous,
overly broad, unduly burdensome, and may require a special study. Qwest also objects to
this request on the grounds that it seeks information concerning DSL, line sharing and line
splitting data that is neither relevant nor reasonably calculated to lead to the discovery of
admissible evidence. Qwest also believes that the time period identified in this request is
overly broad, and, therefore, producing responsive information would be unduly
burdensome. Finally, to the extent this request seeks CLEC/Carrier specific information
Qwest objects on the grounds that this request requires the production of data which may
be protected by Section 222 of the Communications Act of 1934,47 U.C. ~ 222, or other
privacy laws. Qwest will produce such information upon the entry of a Commission order
compelling Qwest to do so. Without waiving these objections, Qwest will supplement this
response if it determines that it has accessible, responsive and non-protected information
regarding customer churn data.
MCI-Please provide, a) on a Idaho-statewide basis, and b) on a CLLI-code-specific basis
monthly data for each month since July 2001 for your retail customer "chum
(i.the number of customers changing from one carrier to another) for business
local exchange voice customers with more than three lines between each of the
following service configurations: 1) Qwest voice only 2) Qwest voice plus DSL;
3) Qwest DSL only; 4) CLEC UNE-P voice only; 5) CLEC switch-based voice
only; 6) CLEC line sharing; 7) CLEC line splitting; 8) CLEC DSL only (e.
Qwest voice only to CLEC UNE-P voice only; CLEC A switch-based voice only
to CLEC B switch-based voice only
OBJECTION: Qwest objects to this data request on the grounds that it is vague
ambiguous, overly broad, unduly burdensome, and may require a special study. Qwest
also objects to this request on the grounds that it seeks information concerning DSL, line
sharing and line splitting data that is neither relevant nor reasonably calculated to lead to
the discovery of admissible evidence. Qwest also believes that the time period identified in
this request is overly broad, and, therefore, producing responsive information would be
unduly burdensome. Finally, to the extent this request seeks CLEC/Carrier specific
information, Qwest objects on the grounds that this request requires the production of data
protected by Section 222 of the Communications Act of 1934 47 U.c. ~ 222, or other
privacy laws. Qwest will produce such information upon the entry of a Commission order
compelling Qwest to do so. Without waiving these objections, Qwest will supplement this
response if it determines that it has accessible, responsive and non-protected information
regarding customer churn data.
MCI-Please provide, on a CLLI-code-specific basis, the number of loops that Qwest has
migrated through hot cuts (i., individual coordinated simultaneous transfer of
DS-O/voice grade loops with live customers' service transferred) since July
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2001 that involved manual frame (MDF and/or IDF) jumper work, reported on a
daily, weekly and monthly basis, from each of the following: 1) Qwest retail
analog services; 2) CLEC UNE loops. Please provide all supporting documents
or information regarding such provisioning volumes.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Further, Qwest objects to this request because it seeks
information that is not relevant or reasonably calculated to the lead to the discovery of
admissible evidence. Qwest also believes that the time period identified in this request is
overly broad, and, therefore, producing responsive information would be unduly
burdensome. Qwest also objects to the extent this request seeks CLEC/Carrier specific
information which may be protected by Section 222 of the Communications Act of 1934, 47
c. ~ 222, or other privacy laws. Qwest will produce such information upon the entry of
a Commission order compelling Qwest to do so. Qwest is unable at this point to specifically
define the markets in which it will seek relief from unbundling obligations for switching for
mass market customers. Qwest intends to specifically define those market areas in its
testimony to be filed on January19, 2004. Once those market areas are defined, all
requested information for CLLI codes and/or wire centers outside of those areas will be
irrelevant in this docket. Within a reasonable time after Qwest makes its proposed market
definitions, Qwest will respond to this request with relevant information to the extent any
such information exists. Without waiving these objections, Qwest will respond to this
request with relevant information about the number of loops Qwest has migrated through
hot cuts to the extent such information exists.
MCI-6 .For each CLLI code in Idaho, please provide the number of individual cross
connects/jumper jobs performed on (1) the MDF, and (2) any IDF(s), during each
month since July 1 , 2001.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also believes that the time period identified in this request
is overly broad, and, therefore, producing responsive information would be unduly
burdensome. Qwest also objects to the extent this request seeks CLEC/Carrier specific
information which may be protected by Section 222 of the Communications Act of 1934, 47
c. ~ 222, or other privacy laws. Qwest will produce such information upon the entry of
a Commission order compelling Qwest to do so. Without waiving these objections Qwest
will respond to this request with relevant information to the extent it exists. Qwest also
refers MCI to the batch hot cut proposal filed by Qwest on November 11, 2003, and Qwest
notes that the general subject matter of this request will be addressed by the parties in the
batch hot cut forum that will take place during these proceedings. To the extent the
information sought by this data request is not addressed in the forum, and subject to
objections, Qwest will supplement its response to this data request.
MCI- 7 Please provide the actual (i., unadjusted and not subjected to performance measure
metrics) minimum, maximum, and mean provisioning intervals for Qwest
provisioning ofUNE loops for each month since July 1 2001 , reported on a CLLI
code basis.
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OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome and may require a special study. Qwest also believes that the time
period identified in this request is overly broad, and, therefore, producing responsive
information would be unduly burdensome. To the extent that Qwest has information
responsive to this request, and subject to objections, Qwest will supplement its response to
this data request.
MCI-For each CLLI code, and on a statewide basis in Idaho, please provide the number of
UNE-P orders that were fulfilled each month since July 1 , 2001 in Idaho.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also believes that the time period identified in this request
is overly broad, and, therefore, producing responsive information would be unduly
burdensome. Further, Qwest objects to the extent this request seeks CLEC/Carrier
specific information which may protected by Section 222 of the Communications Act of
1934 47 U.c. ~ 222, or other privacy laws. Qwest will produce such information upon
the entry of a Commission order compelling Qwest to do so. Also, Qwest objects to this
request on the grounds that it is neither relevant nor reasonably calculated to lead to the
discovery of admissible evidence. Qwest is unable at this point to specifically define the
markets in which it will seek relief from unbundling obligations for switching for mass
market customers. Qwest intends to specifically define those market areas in its testimony
to be filed on January19, 2004. Once those market areas are defined, all requested
information for CLLI codes and/or wire centers outside of those areas will be irrelevant in
this docket. Within a reasonable time after Qwest makes its proposed market definitions
Qwest will respond to this request with relevant non-protected information to the extent
any such information exists.
MCI-With regard to your response to MCI-, please provide on a CLLI code-specific basis
the number of trouble reports within the first five days after the hot cut.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest does not track the data in the manner in which it is
requested and objects on the basis that the request calls for a special study. Also, Qwestobjects to this request on the grounds that it is neither relevant nor reasonably calculated
to lead to the discovery of admissible evidence. Qwest noted in its Notice of Scope of
Docket that it is unable at this point to specifically define the markets in which it will seek
relief from unbundling obligations for switching for mass market customers. Qwest
intends to specifically define those market areas in its testimony to be filed on January 19,
2004. Once those market areas are defined, all requested information for CLLI codes
and/or wire centers outside of those areas will be irrelevant in this docket. Within a
reasonable time after Qwest makes its proposed market definitions, Qwest will respond to
this request with relevant information to the extent any such information exists.
MCI-With regard to your response to MCI-, please specify the percentage of hot cuts that
were performed within the agreed-upon time frame (e.as of the deadline set
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pursuant to an interconnection agreement or otherwise agreed to with the other
carrier or pursuant to other state requirements). Please report this information on
the same daily, weekly and monthly basis as in MCI-
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome, and may require a special study. Also, Qwest objects to this
request on the grounds that it is neither relevant nor reasonably calculated to lead to the
discovery of admissible evidence. Qwest noted in its Notice of Scope of Docket that it is
unable at this point to specifically define the markets in which it will seek relief from
unbundling obligations for switching for mass market customers. Qwest intends to
specifically define those market areas in its testimony to be filed on January 19, 2004. Once
those market areas are defined, all requested information for CLLI codes and/or wire
centers outside of those areas will be irrelevant in this docket. Within a reasonable time
after Qwest makes its proposed market definitions, Qwest will respond to this request with
relevant information to the extent any such information exists.
MCI-With regard to your response to MCI-, please state whether the existing customer
loop was re-used for each of the migrations identified. If the loop was not re-
used, please provide a detailed explanation of the reasons why it was not re-used
and any consequence of not being able to reuse the loop (i., delayed installation
interval, loss of customer telephone number, need for rewiring at remote
terminal/FDVcustomer NID, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad,
unduly burdensome, vague, ambiguous, irrelevant, and not reasonably calculated to lead to
the discovery of admissible evidence. Without waiving these objections, Qwest will
supplement this response if it determines that it has accessible responsive information
regarding the re-use of existing customer loops.
MCI-With respect to the hot cuts identified in response to MCI-, please provide a detailed
description of each work effort your personnel had to perform, the costs you
incurred, and the maximum number of hot cuts that you have accomplished per
day per CLLI code since July 1 , 2001.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also believes that the time period identified in this request
is overly broad, and, therefore, producing responsive information would be unduly
burdensome. Further, Qwest objects to this request on the grounds that it is neither
relevant nor reasonably calculated to lead to the discovery of admissible evidence. Qwest
noted in its Notice of Scope of Docket that it is unable at this point to specifically define the
markets in which it will seek relief from unbundling obligations for switching for mass
market customers. Qwest intends to specifically define those market areas in its testimony
to be filed on January 19, 2004. Once those market areas are defined, all requested
information for CLLI codes and/or wire centers outside of those areas will be irrelevant in
this docket. Within a reasonable time after Qwest makes its proposed market definitions,
Qwest will respond to this request with relevant information to the extent any such
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information exists. Without waiving these objections, Qwest refers MCI to the batch hot
cut proposal filed by Qwest on November 11, 2003, and Qwest notes that the general
subject matter concerning the work effort and the costs relating to hot cuts will be
addressed by the parties in the batch hot cut forum that will take place during these
proceedings.
MCI-For each CLLI in Idaho, provide the maximum number of hot cuts that can be
performed per day, week and month with current workforce levels for (a) loops
carrying voice only; and (b) loops carrying voice plus DSL. State the basis for the
maximum number (e., methods and procedures, union work rules, informal
guidelines, Qwest policy, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Also, Qwest objects to this request on the grounds that it is
neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.
Qwest noted in its Notice of Scope of Docket that it is unable at this point to specifically
define the markets in which it will seek relief from unbundling obligations for switching for
mass market customers. Qwest intends to specifically define those market areas in its
testimony to be filed on January 19,2004. Once those market areas are defined, all
requested information for CLLI codes and/or wire centers outside of those areas will be
irrelevant in this docket. Within a reasonable time after Qwest makes its proposed market
definitions, Qwest will respond to this request with relevant information to the extent any
such information exists. Without waiving these objections, Qwest refers MCI to the batch
hot cut proposal filed by Qwest on November 11, 2003, and Qwest notes that the general
subject matter concerning the number of hot cuts that can be performed during any given
time period will be addressed by the parties in the batch hot cut forum that will take place
during these proceedings.
MCI-State and describe in detail any plans to increase workforce levels in the next 12
months for job classifications that perform hot cuts, state whether such plans have
received budgetary approval and funding, and provide a copy of the approved and
funded budget and related documentation.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects to this request on the grounds of relevance to
the extent it does not seek existing factual information. Without waiving these objections,
Qwest refers MCI to the batch hot cut proposal filed by Qwest on November 11, 2003, and
Qwest notes that the general subject matter concerning workforce issues will be addressed
by the parties in the batch hot cut forum that will take place during these proceedings. To
the extent the information sought by this data request is not addressed in the forum, and
subject to objections, Qwest will supplement its response to this data request.
MCI-Please state whether you agree that a proper hot cut process requires Qwest to re-use
the existing loop for the following migration types: a) UNE-P to UNE DS-O/voice
grade loops; b) line sharing over UNE-P when the DSL service is removed; c) line
sharing overUNE-P migrated to line split UNE loop. If you agree, do you always
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perform hot cuts for the listed migration types in this manner? If not, why not? If
you disagree, please state concisely your reasons for disagreement.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects to this request on the grounds of relevance to
the extent it seeks an opinion rather than existing factual information, and to the extent it
seeks information relating to DSL services, line sharing, and line splitting information.
Without waiving these objections, Qwest refers MCI to the batch hot ,cut proposal filed by
Qwest on November 11, 2003, and Qwest notes that the general subject matter concerning
the re-use of existing loops will be addressed by the parties in the batch hot cut forum that
will take place during these proceedings. To the extent the information sought by this data
request is not addressed in the forum, and subject to objections, Qwest will supplement its
response to this data request.
MCI-On a Idaho-statewide basis and for each CLLI code, please identify all service
disruptions of the type referenced in paragraphs 421 , 422 and 459 of the Triennial
Review Order that have occurred each month since July 1 , 2001 during your hot
cut process, and provide a detailed explanation of the cause of the service
disruption. As part of your response, please quantify the subset of service
disruptions where customers were unable to place or receive calls and/or data for
a period of greater than five minutes.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects on the grounds that the request is vague and
ambiguous in that the service disruptions discussed in the Triennial Review Order are not
referenced in sufficient detail. Qwest also believes that the time period identified in this
request is overly broad, and, therefore, producing responsive information would be unduly
burdensome. Further, Qwest objects to this request on the grounds that it is neither
relevant nor reasonably calculated to lead to the discovery of admissible evidence. Qwest
noted in its Notice of Scope of Docket that it is unable at this point to specifically define the
markets in which it will seek relief from unbundling obligations for switching for mass
market customers. Qwest intends to specifically define those market areas in its testimony
to be filed on January 19,2004. Once those market areas are defined, all requested
information for CLLI codes and/or wire centers outside of those areas will be irrelevant in
this docket. Within a reasonable time after Qwest makes its proposed market definitions,
Qwest will respond to this request with relevant information to the extent any such
information exists.
MCI-On a Idaho-statewide basis and for each CLLI code, reported monthly for each month
since July 1 2001 , please provide a detailed description ofUNE loop orders
cancelled prior to customer migration. Your response should include the number
and percentage of such order cancellations compared to the total number of UNE
loop orders; a detailed description ofthe number and percentage of trouble reports
during the hot cut process; and a detailed description of the reason the customer
cancelled the order prior to migration.
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OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also believes that the time period identified in this request
is overly broad, and, therefore, producing responsive information would be unduly
burdensome. Further, Qwest objects to this request on the grounds that it is neither
relevant nor reasonably calculated to lead to the discovery of admissible evidence. Qwest is
unable at this point to specifically define the markets in which it will seek relief from
unbundling obligations for switching for mass market customers. Qwest intends to
specifically define those market areas in its testimony to be filed on January 19,2004. Once
those market areas are defined, all requested information for CLLI codes and/or wire
centers outside of those areas will be irrelevant in this docket. Within a reasonable time
after Qwest makes its proposed market definitions, Qwest will respond to this request with
relevant non-protected information to the extent any such information exists. Finally,
Qwest also objects on the grounds that it does not possess the information requested and it
would require a special study to produce the information.
MCI-On a Idaho-statewide basis and for each CLLI code, reported monthly for each month
since July 1 , 2001 , please provide the percentage of hot cuts that were
successfully completed and tested consistent with the time intervals specified in
Qwest's Methods and Procedures or other guidelines or work rules.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also believes that the time period identified in this request
is overly broad, and, therefore, producing responsive information would be unduly
burdensome. Qwest also objects to the extent this request seeks CLEC/Carrier specific
information which may be protected by Section 222 of the Communications Act of 1934
c. ~ 222, or other privacy laws. Qwest will produce such information upon the entry of
a Commission order compelling Qwest to do so. Qwest objects to this request on the
grounds that it is neither relevant nor reasonably calculated to lead to the discovery of
admissible evidence. Qwest is unable at this point to specifically define the markets in
which it will seek relief from unbundling obligations for switching for mass market
customers. Qwest intends to specifically define those market areas in its testimony to be
filed on January 19,2004. Once those market areas are defined, all requested information
for CLLI codes and/or wire centers outside of those areas will be irrelevant in this docket.
Within a reasonable time after Qwest makes its proposed market definitions, Qwest will
respond to this request with relevant information to the extent any such information exists.
MCI-Please provide the name(s) of the work group(s) whose members routinely perform
cross connects/jumper jobs in Qwest central offices, and provide the following
information for each:
(a) a list and description of every job classification (e.g. frame technician) within
such work group(s);
(b) whether each job classification is staffed by members of a union, and whether
non-union employees may perform the same job function;
(c) for each job classification, the minimum job requirements, including training,
job experience, education, etc;
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(d) a description of all on-the-job training required or provided for each job
classification once in the position;
(e) a copy of the methods and procedures or similar documents that contain any
kind of instructions specifying the steps, processes, techniques, tasks
materials, etc. for performing cross connects/jumper jobs.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Also, Qwest objects to this request on the grounds that it is
neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.
Without waiving these objections, Qwest refers MCI to the batch hot cut proposal filed by
Qwest on November 11, 2003, and Qwest notes that the general subject of hot cuts and
personnel who perform hot cuts will be addressed in the batch hot cut forum that will take
place during these proceedings. To the extent the information sought by this data request
is not addressed in the forum, and subject to objections, Qwest will supplement its response
to this data request.
MCI-Please 1) state whether Qwest's methods , procedures, scheduling, and/or completion
intervals are different in any way, 2) provide a detailed explanation of all such
differences, and 3) provide all Methods and Procedures and other documents that
describe the work effort required for the following types of cross connects/jumper
jobs:
(a) new retail service installation to a premises with no previous telephone
servIce;
(b) adding a second line to a premises with existing service;
(c) performing a line and station transfer ("LST") that involves cross
connects/jumper jobs at the MDF on a loop with live traffic;
(d) changing loops with live traffic from one type of retail service to another (e.
POTS to ISDN);
(e) changing loops with live traffic from one type of provider to another (e.
UNE-P to UNE loop; one CLEC UNE loop to another CLEC UNE loop)
(f) changing loops with live traffic from one service on a loop to two services on
a loop (e., line shared DSL and voice; line split DSL and voice);
(g) any other type of cross connect/jumper job in the Qwest central office not
covered by (a) through (f) above.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Also, Qwest objects to this request on the grounds that it is
neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.
Further, Qwest objects to this request on the grounds that providing a response would
require a special study. Without waiving these objections, Qwest refers MCI to the batch
hot cut proposal filed by Qwest on November 11, 2003, and Qwest notes that the general
subject of hot cuts and the procedures for performing hot cuts will be addressed in the
batch hot cut forum that will take place during these proceedings. To the extent the
information sought by this data request is not addressed in the forum, and subject to
objections, Qwest will supplement its response to this data request.
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MCI-For each type of cross connect/jumper job identified in response to MCI-, please
identify each step or task in the process (e., obtain work order for frame wiring,
review work order, travel to central office (if required), travel to remote
terminal/FDVcustomer premises serving terminal (if required), locate binder posts
for service to be installed, locate binder posts for service to be removed (if any),
remove oldjumper(s), install new jumper(s), test for dial tone/connectivity,
troubleshoot lack of dial tone/connectivity, enter job completion in work force
administration system and/or other record(s), etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Without waiving this objection, Qwest refers MCI to the batch
hot cut proposal filed by Qwest on November 11, 2003, and Qwest notes that the general
subject of hot cuts and the procedures for performing hot cuts will be addressed in the
batch hot cut forum that will take place during these proceedings. To the extent the
information sought by this data request is not addressed in the forum, and subject to
objections, Qwest will supplement its response to this data request.
MCI-On a Idaho-statewide basis and for each CLLI code, for each type of cross
connect/jumper job identified in response to MCI-, please identify the
minimum, maximum and average actual work time( s) for 1) the total work effort
and 2) each step or task in the work effort identified in response to MCI-
reported monthly for each month since July 1 , 2001.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also believes that the time period identified in this request
is overly broad, and, therefore, producing responsive information would be unduly
burdensome. Qwest objects to this request on the grounds that providing a response would
require a special study. Without waiving these objections Qwest refers MCI to the batch
hot cut proposal filed by Qwest on Novemberll, 2003, and Qwest notes that the general
subject of hot cuts and the time periods associated with performing hot cuts will be
addressed in the batch hot cut forum that will take place during these proceedings. To the
extent the information sought by this data request is not addressed in the forum, and
subject to objections, Qwest will supplement its response to this data request.
MCI-On a Idaho-statewide basis and for each CLLI code, for each type of cross
connect/jumper job identified in response to MCI-, please identify the
minimum, maximum and average work time(s) for 1) the total work effort and 2)
each step or task in the work effort identified in response to MCI-, specified in:
a) Qwest union contracts covering workers who routinely perform cross
connect/jumper jobs in the Qwest central offices; b) Qwest methods and
procedures, guidelines, rules, regulations, specifications or any other written
directive; c) employee performance evaluation criteria.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest objects to this request on the grounds that providing a
response would require a special study. Without waiving this objection Qwest refers MCI
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to the batch hot cut proposal filed by Qwest on November 11, 2003, and Qwest notes that
the general subject of hot cuts and the time periods associated with performing hot cuts
will be addressed in the batch hot cut forum that will take place during these proceedings.
To the extent the information sought by this data request is not addressed in the forum
and subject to objections, Qwest will supplement its response to this data request.
MCI-On a Idaho-statewide basis and for each CLLI code, for each type of cross
connect/jumper job identified in response to MCI-, and for cross
connect/jumper jobs in general, please identify the minimum, maximum and
average number of such jobs that must be performed by each individual employee
or worker during the time interval specified in Qwest employee performance
requirements and/or union contracts (i., the number of cross connect/jumper
jobs that must be performed per hour, day, shift, or other time interval).
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest objects to this request on the grounds that providing a
response would require a special study. Without waiving this objection Qwest refers MCI
to the batch hot cut proposal filed by Qwest on November 11, 2003, and Qwest notes that
the general subject of hot cuts and the time periods associated with performing hot cuts
will be addressed in the batch hot cut forum that will take place during these proceedings.
To the extent the information sought by this data request is not addressed in the forum,
and subject to objections, Qwest will supplement its response to this data request.
MCI-Please state whether cross connect/jumper job performance has ever been the subject
of litigation, arbitration, mediation, labor negotiations, formal labor disputes
informal labor disputes, or evaluation by any third party (e.g. federal or state
agencies, etc.). If the answer is anything other than an unqualified no, please
provide supporting details and documentation.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Without waiving this objection, Qwest refers MCI to the batch
hot cut proposal filed by Qwest on November 11 , 2003, and Qwest notes that the general
subject of hot cuts will be addressed in the batch hot cut forum that will take place during
these proceedings. Also, notwithstanding the objection, Qwest responds that it is not aware
of any such proceedings.
MCI-Please describe how you prioritize cross connects/jumper jobs during normal working
conditions (e., first come first served, by service type, etc.) and state whether
those priorities change during strikes and other labor related work disruptions.
the priorities change, please provide a detailed description of the manner in which
they change.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Without waiving this objection, Qwest refers MCI to the batch
hot cut proposal filed by Qwest on November 11, 2003, and Qwest notes that the general
subject of hot cuts will be addressed in the batch hot cut forum that will take place during
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 17
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these proceedings. To the extent the information sought by this data request is not
addressed in the forum, and subject to objections, Qwest will supplement its response to
this data request.
MCI-Please provide all time and motion studies, special studies, or other evaluations of
cross connect/jumper job work times and processes.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Without waiving this objection, Qwest refers MCI to the batch
hot cut proposal filed by Qwest on November 11, 2003, and Qwest notes that the general
subject of hot cuts and the time periods associated with performing hot cuts will be
addressed in the batch hot cut forum that will take place during these proceedings. To the
extent the information sought by this data request is not addressed in the forum, and
subject to objections, Qwest will supplement its response to this data request.
MCI-Please provide the studies, analyses, and/or calculations of cross connect/jumper job
work times and loaded labor costs from the most recent non-recurring cost study
submitted by Qwest to Idaho Public Utilities Commission.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Without waiving this objection, Qwest refers MCI to the batch
hot cut proposal filed by Qwest on November 11, 2003, and Qwest notes that the general
subject of hot cuts will be addressed in the batch hot cut forum that will take place during
these proceedings. To the extent the information sought by this data request is not
addressed in the forum, and subject to objections, Qwest will supplement its response to
this data request.
MCI-For each central office in Idaho, for each month since July 2001 please state:
(a) whether the central office was staffed with one or more resident frame
technician(s) (or other job c1assification(s) that routinely perform cross
connect/jumper jobs);
(b) for each central office that was so staffed, the hours during which it was
staffed;
(c) for each central office that was so staffed, the number of person hours per day
or per week devoted to cross connect/jumper jobs;
(d) for each central office that was not staffed, the number of person hours per
day or per week devoted to cross connect/jumper jobs.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also believes that the time period identified in this request
is overly broad, and, therefore, producing responsive information would be unduly
burdensome. Without waiving these objections, Qwest refers MCI to the batch hot cut
proposal filed by Qwest on November 11, 2003, and Qwest notes that the general subject of
hot cuts will be addressed in the batch hot cut forum that will take place during these
proceedings. To the extent the information sought by this data request is not addressed in
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 18
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the forum, and subject to objections, Qwest will supplement its response to this data
request.
MCI-Please provide a list, detailed description, method of sampling, method of calculation
and monetary penalty for all UNE performance measures or metrics applicable in
Idaho. State which of these measurements or metrics you assert is relevant to the
issues in this proceeding.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Without waiving this objection, Qwest refers MCI to the
Performance Assurance Plan for the state of Idaho, which is available as Exhibit K to the
Idaho SGAT. This document can be found at
www .Q w est.co m/w h 01 esale/ clecs/ s2atswirelin e.h tml.
MCI-Please provide all UNE performance measure or metric reports applicable in Idaho
including a report of any penalties paid, for each month since July 1 , 2001.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also believes that the time period identified in this request
is overly broad, and, therefore, producing responsive information would be unduly
burdensome. Without waiving these objections Qwest refers MCI to the Performance
Assurance Plan for the state of Idaho, which is available as Exhibit K to the Idaho SGAT.
This document can be found at www.Qwest.com/wholesale/clecs/s2atswireline.html.
MCI-Please provide all third party evaluations and/or reports addressing and/or assessing
Qwest performance under the UNE performance measures or metrics applicable
in Idaho.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects to this request on the grounds that it is vague
and ambiguous. Qwest also objects to this request on the grounds that it seeks irrelevant
information and is not reasonably calculated to lead to the discovery of admissible
evidence.
MCI-Please list, define and describe each type of migration of service from o!Je carrier to
another in Idaho for which you have current methods and procedures (e., hot
cut, coordinated hot cut, bulk hot cut, frame due time, project managed cutover
loop conversion, line and station transfer, etc.), and provide a copy of the business
rules and methods and procedures for each such migration type.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Without waiving these objections Qwest refers
MCI to the batch hot cut proposal filed by Qwest on November 11, 2003, and Qwest notes
that the general subject of the types of hot cut migrations available in Idaho will
addressed in the batch hot cut forum that will take place during these proceedings. To the
extent the information sought by this data request is not addressed in the forum, and
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subject to objections, Qwest will supplement its response to this data request.
MCI-For each type of service migration in Idaho listed in your response to MCI-, please:
(a) provide the current total non-recurring charge(s);
(b) separately state the service ordering charge(s), the provisioning (cross
connect/jumper job) charge(s), and any other charge(s);
(c) list and describe any current volume discounts applicable to non-recurring
charges;
(d) list any changes in non-recurring charges and/or volume discounts planned or
expected in the next 12 months.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Without waiving this objection, Qwest refers MCI to the batch
hot cut proposal filed by Qwest on November 11, 2003, and Qwest notes that the general
subject of types of hot cut migrations available in Idaho will be addressed in the batch hot
cut forum that will take place during these proceedings. To the extent the information
sought by this data request is not addressed in the forum, and subject to objections, Qwest
will supplement its response to this data request.
MCI-Please state the number of loops that you believe is appropriate to include in a single
batch " as the FCC uses that terminology and concept in ~ 489 of the Triennial
Review Order and provide the basis for your belief and all documentation that
supports your belief.
OBJECTION: Qwest objects to this request on the grounds of relevance to the extent it
seeks an opinion rather than existing factual information. Qwest will be providing its
advocacy on this issue when it files its testimony in this docket on January 19, 2004.
Without waiving this objection, Qwest refers MCI to the batch hot cut proposal filed by
Qwest on November 11 2003, and Qwest notes that the general subject matter concerning
the number of loops to include in the batch process will be addressed by the parties in the
batch hot cut forum that will take place during these proceedings.
MCI-Please provide a detailed description of the current QWEST OSS capabilities to
support automated, flow-through processes for Pre-ordering for DS-voice-grade
UNE loops on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC
and c) hybrid fiber-copper facilities using UDLC or NGDLc. Please provide a
copy of all documents describing these processes, including but not limited to
Telcordia documents, Qwest Methods and Procedures, Workgroup User Manuals
Guidelines, Bulletins, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad,
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving this objection, Qwest refers MCI to the
batch hot cut proposal filed by Qwest on November 11, 2003, and Qwest notes that the
general subject matter concerning hot cuts and OSS capabilities related to hot cuts will be
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addressed by the parties in the batch hot cut forum that will take place during these
proceedings.
MCI-Please provide a detailed description of the current QWEST OSS capabilities to
support automated, flow-through processes for Ordering for DS-voice-grade
UNE loops on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC
and c) hybrid fiber-copper facilities using UDLC or NGDLC. Please provide a
copy of all documents describing these processes, including but not limited to
Telcordia documents, Qwest Methods and Procedures, Workgroup User Manuals
Guidelines, Bulletins, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad,
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving this objection, Qwest refers MCI to the
batch hot cut proposal filed by Qwest on November 11, 2003, and Qwest notes that the
general subject matter concerning hot cuts and OSS capabilities related to hot cuts will be
addressed by the parties in the batch hot cut forum that will take place during these
proceedings.
MCI-Please provide a detailed description of the current QWEST OSS capabilities to
support automated, flow-through processes for Provisioning for DS-voice-grade
UNE loops on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC
and c) hybrid fiber-copper facilities using UDLC or NGDLC. Please provide a
copy of all documents describing these processes, including but not limited to
Telcordia documents, Qwest Methods and Procedures, Workgroup User Manuals
Guidelines, Bulletins, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving this objection, Qwest refers MCI to the
batch hot cut proposal filed by Qwest on November 11 , 2003, and Qwest notes that the
general subject matter concerning hot cuts and OSS capabilities related to hot cuts will be
addressed by the parties in the batch hot cut forum that will take place during theseproceedings.
MCI-Please provide a detailed description of the current QWEST OSS capabilities to
support automated, flow-through processes for Maintenance/Repair for DS-
voice-grade UNE loops on a) all-copper facilities; b) hybrid fiber-copper
facilities using IDLC and c) hybrid fiber-copper facilities using UDLC or
NGDLc. Please provide a copy of all documents describing these processes
including but not limited to Te1cordia documents, Qwest Methods and
Procedures, Workgroup User Manuals, Guidelines, Bulletins, etc.
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OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving this objection, Qwest refers MCI to the
batch hot cut proposal filed by Qwest on November 11, 2003, and Qwest notes that the
general subject matter concerning hot cuts and OSS capabilities related to hot cuts will be
addressed by the parties in the batch hot cut forum that will take place during these
proceedings.
MCI-Please provide a detailed description of the current QWEST OSS capabilities to
support automated, flow-through processes for Billing for DS-voice-grade UNE
loops on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC and
c) hybrid fiber-copper facilities using UDLC or NGDLC. Please provide a copy
of all documents describing these processes, including but not limited to Telcordia
documents, Qwest Methods and Procedures, Workgroup User Manuals
Guidelines, Bulletins, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving this objection, Qwest refers MCI to the
batch bot cutproposal filed by Qwest on November 11, 2003, and Qwest notes that the
general subject matter concerning hot cuts and OSS capabilities related to hot cuts will be
addressed by the parties in the batch hot cut forum that will take place during these
proceedings.
MCI-Please provide a detailed description of the current QWEST OSS capabilities to
support automated, flow-through processes for Pre-ordering for DSL-capable
UNE loops on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC
and c) hybrid fiber-copper facilities using UDLC or NGDLC. Please provide a
copy of all documents describing these processes, including but not limited to
Te1cordia documents, Qwest Methods and Procedures, Workgroup User Manuals
Guidelines, Bulletins, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad,
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to DSL services which is not relevant to these proceedings or
reasonably calculated to lead to the discovery of admissible evidence. Without waiving this
objection, Qwest refers MCI to the batch hot cut proposal filed by Qwest on November 11,
2003, and Qwest notes that the general subject matter concerning hot cuts and OSS
capabilities related to hot cuts will be addressed by the parties in the batch hot cut forum
that will take place during these proceedings.
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MCI-Please provide a detailed description of the current QWEST OSS capabilities to
support automated, flow-through processes for Ordering for DSL-capable UNE
loops on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC and
c) hybrid fiber-copper facilities using UDLC or NGDLc. Please provide a copy
of all documents describing these processes, including but not limited to Te1cordia
documents, Qwest Methods and Procedures, Workgroup User Manuals
Guidelines, Bulletins, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to DSL which is not relevant to these proceedings. Without waiving
these objections, Qwest refers MCI to the batch hot cut proposal filed by Qwest
November 11, 2003, and Qwest notes that the general subject matter concerning hot cuts
and OSS capabilities related to hot cuts will be addressed by the parties in the batch hot cut
forum that will take place during these proceedings.
MCI-Please provide a detailed description of the current QWEST OSS capabilities to
support automated, flow-through processes for Provisioning for DSL-capable
UNE loops on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC
and c) hybrid fiber-copper facilities using UDLC or NGDLc. Please provide a
copy of all documents describing these processes, including but not limited to
Te1cordia documents, Qwest Methods and Procedures, Workgroup User Manuals
Guidelines, Bulletins, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad,
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to DSL which is not relevant to these proceedings. Without waiving
these objections, Qwest refers MCI to the batch hot cut proposal filed by Qwest
November 11 , 2003, and Qwest notes that the general subject matter concerning hot cuts
and OSS capabilities related to hot cuts will be addressed by the parties in the batch hot cut
forum that will take place during these proceedings.
MCI-Please provide a detailed description ofthe current QWEST OSS capabilities to
support automated, flow-through processes for Maintenance/Repair for DSL-
capable UNE loops on a) all-copper facilities; b) hybrid fiber-copper facilities
using IDLC and c) hybrid fiber-copper facilities using UDLC or NGDLC. Please
provide a copy of all documents describing these processes, including but not
limited to Telcordia documents, Qwest Methods and Procedures, Workgroup User
Manuals, Guidelines, Bulletins, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad,
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 23
Boise-165130.10029164-00097
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to DSL which is not relevant to these proceedings. Without waiving
these objections, Qwest refers MCI to the batch hot cut proposal filed by Qwest
November 11, 2003, and Qwest notes that the general subject matter concerning hot cuts
and OSS capabilities related to hot cuts will be addressed by the parties in the batch hot cut
forum that will take place during these proceedings.
MCI-Please provide a detailed description of the current QWEST OSS capabilities to
support automated, flow-through processes for Billing for DSL-capable UNE
loops on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC and
c) hybrid fiber-copper facilities using UDLC or NGDLC. Please provide a copy
of all documents describing these processes, including but not limited to Te1cordia
documents, Qwest Methods and Procedures, Workgroup User Manuals
Guidelines, Bulletins, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to DSL which is not relevant to these proceedings. Without waiving
these objections, Qwest refers MCI to the batch hot cut proposal filed by Qwest
November 11 , 2003, and Qwest notes that the general subject matter concerning hot cuts
and OSS capabilities related to hot cuts will be addressed by the parties in the batch hot cut
forum that will take place during these proceedings.
MCI-Please provide a detailed description of the current QWEST OSS capabilities to
support automated, flow-through processes for Pre-ordering for UNE loops
capable of supporting line splitting (i.e. voice service and DSL service carried on
a single wire pair entering the customer s premises) on a) all-copper facilities; b)
hybrid fiber-copper facilities using IDLC and c) hybrid fiber-copper facilities
using UDLC or NGDLc. Please provide a copy of all documents describing
these processes, including but not limited to Te1cordia documents, Qwest
Methods and Procedures, Workgroup User Manuals, Guidelines, Bulletins, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to line splitting which is not relevant to these proceedings. Without
waiving these objections, Qwest refers MCI to the batch hot cut proposal filed by Qwest on
November 11 2003, and Qwest notes that the general subject matter concerning hot cuts
and OSS capabilities related to hot cuts will be addressed by the parties in the batch hot cut
forum that will take place during these proceedings.
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 24
Boise-165130.10029164-00097
MCI-Please provide a detailed description of the current QWEST OSS capabilities to
support automated, flow-through processes for Ordering for UNE loops capable
of supporting line splitting (i. e. voice service and DSL service carried on a single
wire pair entering the customer s premises) on a) all-copper facilities; b) hybrid
fiber-copper facilities using IDLC and c) hybrid fiber-copper facilities using
UDLC or NGDLC. Please provide a copy of all documents describing these
processes, including but not limited to Te1cordia documents, Qwest Methods and
Procedures, Workgroup User Manuals, Guidelines, Bulletins, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad,
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to line splitting which is not relevant to these proceedings. Without
waiving these objections, Qwest refers MCI to the batch hot cut proposal filed by Qwest on
November 11, 2003, and Qwest notes that the general subject matter concerning hot cuts
and OSS capabilities related to hot cuts will be addressed by the parties in the batch hot cut
forum that will take place during these proceedings.
MCI-Please provide a detailed description of the current QWEST OSS capabilities to
support automated, flow-through processes for Provisioning for UNE loops
capable of supporting line splitting (i. e. voice service and DSL service carried on
a single wire pair entering the customer s premises) on a) all-copper facilities; b)
hybrid fiber-copper facilities using IDLC and c) hybrid fiber-copper facilities
using UDLC or NGDLc. Please provide a copy of all documents describing
these processes, including but not limited to Telcordia documents, Qwest
Methods and Procedures, Workgroup User Manuals, Guidelines, Bulletins, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad,
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to line splitting which is not relevant to these proceedings. Without
waiving these objections, Qwest refers MCI to the batch hot cut proposal filed by Qwest on
November 11, 2003, and Qwest notes that the general subject matter concerning hot cuts
and OSS capabilities related to hot cuts will be addressed by the parties in the batch hot cut
forum that will take place during these proceedings.
MCI-Please provide a detailed description ofthe current QWEST OSS capabilities to
support automated, flow-through processes for Maintenance/Repair for UNE
loops capable of supporting line splitting (i.e. voice service and DSL service
carried on a single wire pair entering the customer s premises) on a) all-copper
facilities; b) hybrid fiber-copper facilities using IDLC and c) hybrid fiber-copper
facilities using UDLC or NGDLc. Please provide a copy of all documents
describing these processes, including but not limited to Telcordia documents
QWEST CORPORA nON'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 25
Boise-165130.10029164-00097
Qwest Methods and Procedures, Workgroup User Manuals, Guidelines, Bulletins
etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to line splitting which is not relevant to these proceedings. Without
waiving these objections, Qwest refers MCI to the batch hot cut proposal filed by Qwest on
November 11, 2003, and Qwest notes that the general subject matter concerning hot cuts
and OSS capabilities related to hot cuts will be addressed by the parties in the batch hot cut
forum that will take place during these proceedings.
MCI-Please provide a detailed description of the current QWEST OSS capabilities to
support automated, flow-through processes for Billing for UNE loops capable of
supporting line splitting (i.e. voice service and DSL service carried on a single
wire pair entering the customer s premises) on a) all-copper facilities; b) hybrid
fiber-copper facilities using IDLC and c) hybrid fiber-copper facilities using
UDLC or NGDLc. Please provide a copy of all documents describing these
processes, including but not limited to Telcordia documents, Qwest Methods and
Procedures, Workgroup User Manuals, Guidelines, Bulletins, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad,
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to line splitting which is not relevant to these proceedings. Without
waiving these objections, Qwest refers MCI to the batch hot cut proposal filed by Qwest on
November 11, 2003, and Qwest notes that the general subject matter concerning hot cuts
and OSS capabilities related to hot cuts will be addressed by the parties in the batch hot cut
forum that will take place during these proceedings.
MCI-To the extent that Qwest's responses to MCI-36 to MCI-50 assert that Qwest has in
place OSS capabilities to support automated, flow-through processes, please
provide for each response to Data Request MCI-36 to MCI-, the statewide
volumes that have been supported on an automated flow-through basis for each
month since July 1 , 2001.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad,
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to DSL and/or line splitting which is not relevant to these proceedings.
Without waiving these objections, Qwest refers MCI to the batch hot cut proposal filed by
Qwest on November 11, 2003, and Qwest notes that the general subject matter concerning
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 26
Boise-165130.1 0029164-00097
hot cuts and OSS capabilities related to hot cuts will be addressed by the parties in the
batch hot cut forum that will take place during these proceedings.
MCI-To the extent that Qwest's responses to MCI-36 to MCI-50 assert that Qwest has in
place OSS capabilities to support automated, flow-through processes, please
provide for each Data Request MCI-36 to MCI-50 the monthly fall-out rates (i.
percentage of transactions that were designed to flow through but did not) since
July 1 , 2001.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to DSL and/or line splitting which is not relevant to these proceedings.
Without waiving these objections, Qwest refers MCI to the batch hot cut proposal filed by
Qwest on November 11, 2003, and Qwest notes that the general subject matter concerning
hot cuts and OSS capabilities related to hot cuts will be addressed by the parties in the
batch hot cut forum that will take place during these proceedings.
MCI-To the extent that Qwest's responses to MCI-36 to MCI-50 assert that Qwest has in
place OSS capabilities to support automated, flow-through processes, please
provide for each response to Data Request MCI-36 to MCI-50 the maximum
daily, weekly and monthly volumes that can currently be supported.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to DSL and/or line splitting which is not relevant to these proceedings.
Without waiving these objections, Qwest refers MCI to the batch hot cut proposal filed by
Qwest on November 11 2003, and Qwest notes that the general subject matter concerning
hot cuts and OSS capabilities related to hot cuts will be addressed by the parties in the
batch hot cut forum that will take place during these proceedings.
MCI-To the extent that Qwest's responses to MCI-36 to MCI-50 state that Qwest does not
have in place OSS capabilities to support automated, flow-through processes
please provide for each response to Data Request MCI-36 to MCI-50 a detailed
estimate of the costs, work effort and timeframes associated with any OSS
modification or upgrade necessary to convert Qwest's manual and/or semi-
mechanized process to an automated, flow-through process for each of the OSS
functions and each of the service types in MCI-36 to MCI-50. Please provide a
copy of all documents describing these modifications or upgrades, including but
not limited to documents sent to or received from Telcordia, Qwest Methods and
Procedures, Workgroup User Manuals, Guidelines, Bulletins, etc.
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 27
Boise-165130.1 0029164-00097
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to DSL and/or line splitting which is not relevant to these proceedings.
Without waiving these objections, Qwest refers MCI to the batch hot cut proposal filed by
Qwest on November 11, 2003, and Qwest notes that the general subject matter concerning
hot cuts and OSS capabilities related to hot cuts will be addressed by the parties in the
batch hot cut forum that will take place during these proceedings.
MCI-To the extent that Qwest's responses to MCI-36 to MCI-50 state that Qwest does not
have in place OSS capabilities to support automated, flow-through processes
please provide a detailed description of the current manual and/or semi-
mechanized QWEST OSS processes for each of the OSS functions and each of
the service types in MCI-36 to MCI-50. Please provide a copy of all documents
describing these processes, including but not limited to documents sent to or
received from Telcordia, Qwest Methods and Procedures, Workgroup User
Manuals, Guidelines, Bulletins, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad,
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to DSL and/or line splitting which is not relevant to these proceedings.
Without waiving these objections, Qwest refers MCI to the batch hot cut proposal filed by
Qwest on November 11, 2003, and Qwest notes that the general subject matter concerning
hot cuts and OSS capabilities related to hot cuts will be addressed by the parties in the
batch hot cut forum that will take place during these proceedings.
MCI-Please provide a detailed description ofthe planned QWEST OSS capabilities to
support automated, flow-through processes for Pre-ordering for DS-O/voice-grade
UNE loops on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC
and c) hybrid fiber-copper facilities using UDLC or NGDLC. Please provide a
copy of all documents describing these processes, including but not limited to
documents sent to or received from Te1cordia, Qwest Methods and Procedures
Workgroup User Manuals, Guidelines, Bulletins, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving this objection, Qwest refers MCI to the
batch hot cut proposal filed by Qwest on November 11, 2003, and Qwest notes that the
general subject matter concerning hot cuts and OSS capabilities related to hot cuts will be
addressed by the parties in the batch hot cut forum that will take place during these
proceedings.
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 28
Boise-165130.10029164-00097
MCI-Please provide a detailed description of the planned QWEST OSS capabilities to
support automated, flow-through processes for Ordering for DS-O/voice-grade
UNE loops on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC
and c) hybrid fiber-copper facilities using UDLC or NGDLc. Please provide a
copy of all documents describing these processes, including but not limited to
documents sent to or received from Telcordia, Qwest Methods and Procedures
Workgroup User Manuals, Guidelines, Bulletins, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad,
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving this objection, Qwest refers MCI to the
batch hot cut proposal filed by Qwest on November 11, 2003, and Qwest notes that the
general subject matter concerning hot cuts and OSS capabilities related to hot cuts will be
addressed by the parties in the batch hot cut forum that will take place during these
proceedings.
MCI-Please provide a detailed description of the planned QWEST ass capabilities to
support automated, flow-through processes for Provisioning for DS-O/voice-grade
UNE loops on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC
and c) hybrid fiber-copper facilities using UDLC or NGDLc. Please provide a
copy of all documents describing these processes, including but not limited to
documents sent to or received from Telcordia, Qwest Methods and Procedures
Workgroup User Manuals, Guidelines, Bulletins, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving this objection, Qwest refers MCI to the
batch hot cut proposal filed by Qwest on November 11, 2003, and Qwest notes that the
general subject matter concerning hot cuts and OSS capabilities related to hot cuts will be
addressed by the parties in the batch hot cut forum that will take place during these
proceedings.
MCI-Please provide a detailed description of the planned QWEST OSS capabilities to
support automated, flow-through processes for Maintenance/Repair for DS-
O/voice-grade UNE loops on a) all-copper facilities; b) hybrid fiber-copper
facilities using IDLC and c) hybrid fiber-copper facilities using UDLC or
NGDLC. Please provide a copy of all documents describing these processes
including but not limited to documents sent to or received from Telcordia, Qwest
Methods and Procedures, Workgroup User Manuals, Guidelines, Bulletins, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad,
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving this objection, Qwest refers MCI to the
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 29
Boise-165130.10029164-00097
batch hot cut proposal filed by Qwest on November 11, 2003, and Qwest notes that the
general subject matter concerning hot cuts and OSS capabilities related to hot cuts will be
addressed by the parties in the batch hot cut forum that will take place during these
proceedings.
MCI-Please provide a detailed description of the planned QWEST OSS capabilities to
support automated, flow-through processes for Billing for DS-O/voice-grade UNE
loops on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC and
c) hybrid fiber-copper facilities using UDLC or NGDLc. Please provide a copy
of all documents describing these processes, including but not limited to
documents sent to or received from Telcordia, Qwest Methods and Procedures
Workgroup User Manuals, Guidelines, Bulletins, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving this objection, Qwest refers MCI to the
batch hot cut proposal filed by Qwest on November 11, 2003, and Qwest notes that the
general subject matter concerning hot cuts and OSS capabilities related to hot cuts will be
addressed by the parties in the batch hot cut forum that will take place during these
proceedings.
MCI-Please provide a detailed description of the planned QWEST OSS capabilities to
support automated, flow-through processes for Pre-ordering for DSL-capable
UNE loops on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC
and c) hybrid fiber-copper facilities using UDLC or NGDLC. Please provide a
copy of all documents describing these processes, including but not limited to
documents sent to or received from Telcordia, Qwest Methods and Procedures
Workgroup User Manuals, Guidelines, Bulletins, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad,
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to DSL which is not relevant to these proceedings. Without waiving
these objections, Qwest refers MCI to the batch hot cut proposal filed by Qwest on
November 11 , 2003, and Qwest notes that the general subject matter concerning hot cuts
and OSS capabilities related to hot cuts will be addressed by the parties in the batch hot cut
forum that will take place during these proceedings.
MCI-Please provide a detailed description of the planned QWEST OSS capabilities to
support automated, flow-through processes for Ordering for DSL-capable UNE
loops on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC and
c) hybrid fiber-copper facilities using UDLC or NGDLC. Please provide a copy
of all documents describing these processes, including but not limited to
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 30
Boise-165130.10029164-00097
documents sent to or received from Telcordia, Qwest Methods and Procedures
Workgroup User Manuals, Guidelines, Bulletins, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to DSL which is not relevant to these proceedings. Without waiving
these objections, Qwest refers MCI to the batch hot cut proposal filed by Qwest
November 11 , 2003, and Qwest notes that the general subject matter concerning hot cuts
and OSS capabilities related to hot cuts will be addressed by the parties in the batch hot cut
forum that will take place during these proceedings
MCI-Please provide a detailed description of the planned QWEST OSS capabilities to
support automated, flow-through processes for Provisioning for DSL-capable
UNE loops on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC
and c) hybrid fiber-copper facilities using UDLC or NGDLc. Please provide a
copy of all documents describing these processes, including but not limited to
documents sent to or received from Telcordia, Qwest Methods and Procedures
Workgroup User Manuals, Guidelines, Bulletins, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to DSL which is not relevant to these proceedings. Without waiving
these objections, Qwest refers MCI to the batch hot cut proposal filed by Qwest
November 11 2003, and Qwest notes that the general subject matter concerning hot cuts
and OSS capabilities related to hot cuts will be addressed by the parties in the batch hot cut
forum that will take place during these proceedings.
MCI-Please provide a detailed description of the planned QWEST OSS capabilities to
support automated, flow-through processes for Maintenance/Repair for DSL-
capable UNE loops on a) all-copper facilities; b) hybrid fiber-copper facilities
using IDLC and c) hybrid fiber-copper facilities using UDLC or NGDLc. Please
provide a copy of all documents describing these processes, including but not
limited to documents sent to or received from Te1cordia, Qwest Methods and
Procedures, Workgroup User Manuals, Guidelines, Bulletins, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to DSL which is not relevant to these proceedings. Without waiving
these objections, Qwest refers MCI to the batch hot cut proposal filed by Qwest
November 11, 2003, and Qwest notes that the general subject matter concerning hot cuts
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 31
Boise-165130.l 0029164-00097
and OSS capabilities related to hot cuts will be addressed by the parties in the batch hot cut
forum that will take place during these proceedings.
MCI-Please provide a detailed description of the planned QWEST OSS capabilities to
support automated, flow-through processes for Billing for DSL-capable UNE
loops on a) all-copper facilities; b) hybrid fiber-copper facilities using IDLC and
c) hybrid fiber-copper facilities using UDLC or NGDLc. Please provide a copy
of all documents describing these processes, including but not limited to
documents sent to or received from Telcordia, Qwest Methods and Procedures
Workgroup User Manuals, Guidelines, Bulletins, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad,
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to DSL which is not relevant to these proceedings. Without waiving
these objections, Qwest refers MCI to the batch hot cut proposal filed by Qwest
November 11, 2003, and Qwest notes that the general subject matter concerning hot cuts
and OSS capabilities related to hot cuts will be addressed by the parties in the batch hot cut
forum that will take place during these proceedings.
MCI-Please provide a detailed description of the planned QWEST OSS capabilities to
support automated, flow-through processes for Pre-ordering for UNE loops
capable of supporting line splitting (i.e. voice service and DSL service carried on
a single wire pair entering the customer s premises) on a) all-copper facilities; b)
hybrid fiber-copper facilities using IDLC and c) hybrid fiber-copper facilities
using UDLC or NGDLc. Please provide a copy of all documents describing
these processes, including but not limited to documents sent to or received from
Telcordia, Qwest Methods and Procedures, Workgroup User Manuals
Guidelines, Bulletins, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to line splitting which is not relevant to these proceedings. Without
waiving these objections, Qwest refers MCI to the batch hot cut proposal filed by Qwest on
November 11, 2003, and Qwest notes that the general subject matter concerning hot cuts
and OSS capabilities related to hot cuts will be addressed by the parties in the batch hot cut
forum that will take place during these proceedings.
MCI-Please provide a detailed description of the planned QWEST OSS capabilities to
support automated, flow-through processes for Ordering for UNE loops capable
of supporting line splitting (i.e. voice service and DSL service carried on a single
wire pair entering the customer s premises) on a) all-copper facilities; b) hybrid
fiber-copper facilities using IDLC and c) hybrid fiber-copper facilities using
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 32
Boise-165130.10029164-00097
UDLC or NGDLc. Please provide a copy of all documents describing these
processes, including but not limited to documents sent to or received from
Telcordia, Qwest Methods and Procedures, Workgroup User Manuals
Guidelines, Bulletins, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to line splitting which is not relevant to these proceedings. Without
waiving these objections, Qwest refers MCI to the batch hot cut proposal filed by Qwest
November 11 2003, and Qwest notes that the general subject matter concerning hot cuts
and OSS capabilities related to hot cuts will be addressed by the parties in the batch hot cut
forum that will take place during these proceedings.
MCI-Please provide a detailed description ofthe planned QWEST OSS capabilities to
support automated, flow-through processes for Provisioning for UNE loops
capable of supporting line splitting (i.e. voice service and DSL service carried on
a single wire pair entering the customer s premises) on a) all-copper facilities; b)
hybrid fiber-copper facilities using IDLC and c) hybrid fiber-copper facilities
using UDLC or NGDLc. Please provide a copy of all documents describing
these processes, including but not limited to documents sent to or received from
Te1cordia, Qwest Methods and Procedures, Workgroup User Manuals
Guidelines, Bulletins, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to line splitting which is not relevant to these proceedings. Without
waiving these objections, Qwest refers MCI to the batch hot cut proposal filed by Qwest on
November 11,2003, and Qwest notes that the general subject matter concerning hot cuts
and OSS capabilities related to hot cuts will be addressed by the parties in the batch hot cut
forum that will take place during these proceedings.
MCI-Please provide a detailed description of the planned QWEST OSS capabilities to
support automated, flow-through processes for Maintenance/Repair for UNE
loops capable of supporting line splitting (i.e. voice service and DSL service
carried on a single wire pair entering the customer s premises) on a) all-copper
facilities; b) hybrid fiber-copper facilities using IDLC and c) hybrid fiber-copper
facilities using UDLC or NGDLc. Please provide a copy of all documents
describing these, processes, including but not limited to documents sent to or
received from Telcordia, Qwest Methods and Procedures, Workgroup User
Manuals, Guidelines, Bulletins, etc.
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 33
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OBJECTION: Qwest objects to this data request on the grounds that it is overly broad,
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to line splitting which is not relevant to these proceedings. Without
waiving these objections, Qwest refers MCI to the batch hot cut proposal filed by Qwest on
November 11 , 2003, and Qwest notes that the general subject matter concerning hot cuts
and OSS capabilities related to hot cuts will be addressed by the parties in the batch hot cut
forum that will take place during these proceedings.
MCI- 70 Please provide a detailed description of the planned QWEST OSS capabilities to
support automated, flow-through processes for Billing for UNE loops capable of
supporting line s?litting (i. e. voice service and DSL service carried on a single
wire pair entering the customer s premises) on a) all-copper facilities; b) hybrid
fiber-copper facilities using IDLC and c) hybrid fiber-copper facilities using
UDLC or NGDLC. Please provide a copy of all documents describing these
processes, including but not limited to documents sent to or received from
Telcordia, Qwest Methods and Procedures, Workgroup User Manuals
Guidelines, Bulletins, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to line splitting which is not relevant to these proceedings. Without
waiving these objections, Qwest refers MCI to the batch hot cut proposal filed by Qwest
November 11, 2003, and Qwest notes that the general subject matter concerning hot cuts
and OSS capabilities related to hot cuts will be addressed by the parties in the batch hot cut
forum that will take place during these proceedings.
MCI-To the extent that Qwest's responses to MCI-56 to MCI-70 assert that Qwest plans to
deploy OSS capabilities to support automated, flow-through processes, please
provide for each Data Request MCI-56 to MCI- 70 the maximum daily, weekly
and monthly volumes that could be supported.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad,
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to DSL and/or line splitting which is not relevant to these proceedings.
Without waiving these objections, Qwest refers MCI to the batch hot cut proposal filed by
Qwest on November 11, 2003, and Qwest notes that the general subject matter concerning
hot cuts and OSS capabilities related to hot cuts will be addressed by the parties in the
batch hot cut forum that will take place during these proceedings.
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 34
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MCI-Please provide a detailed description of current and planned Qwest ass capabilities
to support automated, flow-through single-order migration between each of the
following service configurations: 1) Qwest voice only 2) Qwest voice plus data;
3) Qwest data only; 4) CLEC UNE-P voice only; 5) CLEC switch-based voice
only; 6) CLEC line sharing; 7) CLEC line splitting; 8) CLEC data only (e.
Qwest voice only to CLEC UNE-P voice only; CLEC A switch-based voice only
to CLEC B switch-based voice only J.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to line splitting and/or line sharing which is not relevant to these
proceedings. Without waiving these objections, Qwest refers MCI to the batch hot cut
proposal filed by Qwest on November 11, 2003, and Qwest notes that the general subject
matter concerning hot cuts and OSS capabilities related to hot cuts will be addressed by the
parties in the batch hot cut forum that will take place during these proceedings.
MCI- 73 Please provide a detailed description of current and planned Qwest OSS capabilities
to support automated, flow-through single-order migration from 1) Qwest to
CLEC; 2) CLEC to CLEC and 3) CLEC to Qwest, for each of the following: a)
adding or dropping local exchange voice service from line shared or line split
DSL; b) adding 0f dropping DSL service from line shared or line split local
exchange voice service.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to DSL, line splitting and/or line sharing which is not relevant to these
proceedings. Without waiving these objections, Qwest refers MCI to the batch hot cut
proposal filed by Qwest on November 11, 2003, and Qwest notes that the general subject
matter concerning hot cuts and OSS capabilities related to hot cuts will be addressed by the
parties in the batch hot cut forum that will take place during these proceedings.
MCI- 7 4 Please state whether Qwest provides CLECs with real-time, read-only access to all
data in all Qwest OSS (including what some QWEST'S have called back-office
systems) related to loop and transport facilities.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad,
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving this objection, Qwest refers MCI to the
batch hot cut proposal filed by Qwest on November 11 2003, and Qwest notes that the
general subject matter concerning hot cuts and OSS capabilities related to hot cuts will be
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 35
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addressed by the parties in the batch hot cut forum that will take place during these
proceedings.
MCI- 75 To the extent that the response to MCI- 74 indicates that CLECs have real time, read-
only access to the described data, please provide a detailed description of the
manner in which CLECs may access and use all data in Qwest OSS related to
loop and transport facilities on a real-time, read-only basis.
OBJECTION: Qwest objects to this data request on the gro~nds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving this objection, Qwest refers MCI to the
batch hot cut proposal filed by Qwest on November 11, 2003, and Qwest notes that the
general subject matter concerning hot cuts and OSS capabilities related to hot cuts will be
addressed by the parties in the batch hot cut forum that will take place during these
proceedings.
MCI- 76 Please provide a list of all OSS used by Qwest for pre-ordering, ordering,
provisioning, maintenance and repair and billing for Qwest retail services
including all of the following: 1) full name of system; 2) acronym for system (if
any); 3) detailed description of capabilities and function of system; 4) whether
system was developed and is maintained by Qwest or by third party (and name of
third party).
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad,
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving this objection, Qwest refers MCI to the
batch hot cut proposal filed by Qwest on November 11, 2003, and Qwest notes that the
general subject matter concerning hot cuts and OSS capabilities related to hot cuts will be
addressed by the parties in the batch hot cut forum that will take place during these
proceedings.
MCI- 77 Please provide a list of all OSS used by Qwest for pre-ordering, ordering,
provisioning, maintenance and repair and billing for services offered by a Qwest
subsidiary or affiliate, including all of the following: 1) full name of system; 2)
acronym for system (if any); 3) detailed description of capabilities and function of
system; 4) whether system was developed and is maintained by Qwest or by third
party (and name of third party).
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad,
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving this objection, Qwest refers MCI to the
batch hot cut proposal filed by Qwest on November 11, 2003, and Qwest notes that the
general subject matter concerning hot cuts and OSS capabilities related to hot cuts will be
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 36
Boise-165130.10029164-00097
addressed by the parties in the batch hot cut forum that will take place during these
proceedings.
MCI- 78 Please provide a list of all OSS used by Qwest for pre-ordering, ordering,
provisioning, maintenance and repair and billing for CLEC UNE-including all
of the following: 1) full name of system; 2) acronym for system (if any); 3)
detailed description of capabilities and function of system; 4) whether system was
developed and is maintained by Qwest or by third party (and name of third party).
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving this objection, Qwest refers MCI to the
batch hot cut proposal filed by Qwest on November 11, 2003, and Qwest notes that the
general subject matter concerning hot cuts and OSS capabilities related to hot cuts will be
addressed by the parties in the batch hot cut forum that will take place during these
proceedings.
MCI- 79 Please provide a list of all OSS used by Qwest for pre-ordering, ordering,
provisioning, maintenance and repair and billing for UNE loop and transport
facilities, including all of the following: 1) full name of system; 2) acronym for
system (if any); 3) detailed description of capabilities and function of system; 4)
whether system was developed and is maintained by Qwest or by third party (and
name of third party).
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad,
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving this objection, Qwest refers MCI to the
batch hot cut proposal filed by Qwest on November 11, 2003, and Qwest notes that the
general subject matter concerning hot cuts and OSS capabilities related to hot cuts will be
addressed by the parties in the batch hot cut forum that will take place during these
proceedings.
MCI-Please provide a schematic drawing showing the interrelationships between all OSS
used by Qwest for pre-ordering, ordering, provisioning, maintenance and repair
and billing for Qwest retail services, including but not limited to the following: 1)
full name of system; 2) acronym for system (if any).
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving this objection, Qwest refers MCI to the
batch hot cut proposal filed by Qwest on November 11, 2003, and Qwest notes that the
general subject matter concerning hot cuts and OSS capabilities will be addressed by the
parties in the batch hot cut forum that will take place during these proceedings.
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 37
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MCI-Please provide a schematic drawing showing the interrelationships between all OSS
used by Qwest for pre-ordering, ordering, provisioning, maintenance and repair
and billing for services offered by a Qwest subsidiary or affiliate, including but
not limited to the following: 1) full name of system; 2) acronym for system (if
any).
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad,
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving this objection, Qwest refers MCI to the
batch hot cut proposal filed by Qwest on November 11, 2003, and Qwest notes that the
general subject matter concerning hot cuts and OSS capabilities related to hot cuts will be
addressed by the parties in the batch hot cut forum that will take place during these
proceedings.
MCI-Please provide a schematic drawing showing the interrelationships between all OSS
used by Qwest for pre-ordering, ordering, provisioning, maintenance and repair
and billing for CLEC UNE-including but not limited to the following: 1) full
name of system; 2) acronym for system (if any).
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad,
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving this objection, Qwest refers MCI to the
batch hot cut proposal filed by Qwest on November 11, 2003, and Qwest notes that the
general subject matter concerning hot cuts and OSS capabilities related to hot cuts will be
addressed by the parties in the batch hot cut forum that will take place during these
proceedings.
MCI-Please provide a schematic drawing showing the interrelationships between all OSS
used by Qwest for pre-ordering, ordering, provisioning, maintenance and repair
and billing for UNE loop and transport facilities, including but not limited to the
following: 1) full name of system; 2) acronym for system (if any).
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad,
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving this objection, Qwest refers MCI to the
batch hot cut proposal filed by Qwest on November 11, 2003, and Qwest notes that the
general subject matter concerning hot cuts and OSS capabilities related to hot cuts will be
addressed by the parties in the batch hot cut forum that will take place during these
proceedings.
MCI-Please provide a detailed process flow chart for all OSS used by Qwest for pre-
ordering, ordering, provisioning, maintenance and repair and billing for Qwest
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 38
Boise-165130.10029164-00097
retail services including but not limited to the following: 1) full name of system;
2) acronym for system (if any).
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving this objection, Qwest refers MCI to the
batch hot cut proposal filed by Qwest on November 11, 2003, and Qwest notes that the
general subject matter concerning hot cuts and OSS capabilities related to hot cuts will be
addressed by the parties in the batch hot cut forum that will take place during these
proceedings.
MCI-Please provide a detailed process flow chart for all OSS used by Qwest for pre-
ordering, ordering, provisioning, maintenance and repair and billing for services
offered by a Ow est subsidiary or affiliate, including but not limited to the
following: 1) full name of system; 2) acronym for system (if any).
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving this objection, Qwest refers MCI to the
batch hot cut proposal filed by Qwest on November 11 , 2003", and Qwest notes that the
general subject matter concerning hot cuts and OSS capabilities related to hot cuts will be
addressed by the parties in the batch hot cut forum that will take place during these
proceedings.
MCI-Please provide a detailed process flow chart for all OSS used by Qwest for pre-
ordering, ordering, provisioning, maintenance and repair and billing for CLEC
UNE-including but not limited to the following: 1) full name of system; 2)
acronym for system (if any).
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving this objection, Qwest refers MCI to the
batch hot cut proposal filed by Qwest on November 11 2003, and Qwest notes that the
general subject matter concerning hot cuts and OSS capabilities related to hot cuts will be
addressed by the parties in the batch hot cut forum that will take place during theseproceedings.
MCI-Please provide a detailed process flow chart for all OSS used by Qwest for pre-
ordering, ordering, provisioning, maintenance and repair and billing for UNE loop
and transport facilities, including but not limited to the following: 1) full name of
system; 2) acronym for system (if any).
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 39
Boise-165130.1 0029164-00097
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving this objection, Qwest refers MCI to the
batch hot cut proposal filed by Qwest on November 11 , 2003, and Qwest notes that the
general subject matter concerning hot cuts and OSS capabilities related to hot cuts will be
addressed by the parties in the batch hot cut forum that will take place during these
proceedings.
MCI-Please provide a complete set of the current business rules for all OSS used by Qwest
for pre-ordering, ordering, provisioning, maintenance and repair and billing for
Qwest retail services, including but not limited to the following: 1) full name of
system; 2) acronym for system (if any).
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving this objection, Qwest refers MCI to the
batch hot cut proposal filed by Qwest on November 11 , 2003, and Qwest notes that the
general subject matter concerning hot cuts and OSS capabilities related to hot cuts will be
addressed by the parties in the batch hot cut forum that will take place during these
proceedings.
MCI-Please provide a complete set of the current business rules for all ass used by Qwest
for pre-ordering, ordering, provisioning, maintenance and repair and billing for
services offered by a Qwest subsidiary or affiliate, including but not limited to the
following: 1) full name of system; 2) acronym for system (if any).
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad,
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving this objection, Qwest refers MCI to the
batch hot cut proposal filed by Qwest on November 11, 2003, and Qwest notes that the
general subject matter concerning hot cuts and OSS capabilities related to hot cuts will be
addressed by the parties in the batch hot cut forum that will take place during these
proceedings.
MCI-Please provide a complete set of the current business rules for all OSS used by Qwest
for pre-ordering, ordering, provisioning, maintenance and repair and billing for
CLEC UNE-including but not limited to the following: 1) full name of system;
2) acronym for system (if any).
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad,
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving this objection, Qwest refers MCI to the
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 40
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batch hot cut proposal filed by Qwest on November 11, 2003, and Qwest notes that the
general subject matter concerning hot cuts and OSS capabilities related to hot cuts will be
addressed by the parties in the batch hot cut forum that will take place during these
proceedings.
MCI-Please provide a complete set of the current business rules for all OSS used by Qwest
for pre-ordering, ordering, provisioning, maintenance and repair and billing for
UNE loop and transport facilities, including but not limited to the following: 1)
full name of system; 2) acronym for system (if any).
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving this objection, Qwest refers MCI to the
batch hot cut proposal filed by Qwest on November 11 2003, and Qwest notes that the
general subject matter concerning hot cuts and OSS capabilities related to hot cuts will be
addressed by the parties in the batch hot cut forum that will take place during these
proceedings.
MCI-Please provide a detailed description of any current Qwest processes that you claim
will support batch cuts (as defined in Rule 51.319(d)(2)(ii)) between each of the
following service configurations: 1) Qwest voice only 2) Qwest voice plus DSL;
3) Qwest DSL only; 4) CLEC UNE-P voice only; 5) CLEC switch-based voice
only; 6) CLEC line sharing; 7) CLEC line splitting; 8) CLEC DSL only (e.
Qwest voice only to CLEC UNE-P voice only; CLEC A switch-based voice only
to CLEC B switch-based voice only J.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad,
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to DSL, line splitting and line sharing which is not relevant to these
proceedings. Without waiving these objections, Qwest refers MCI to the batch hot cut
proposal filed by Qwest on November 11, 2003, and Qwest notes that the general subject
matter concerning hot cuts and OSS capabilities related to hot cuts will be addressed by the
parties in the batch hot cut forum that will take place during these proceedings.
MCI-With regard to your response to MCI-, please indicate whether your electronic back
end systems can accomplish each migration type on each ofthe following bases:
(a) automated flow-through batch cuts (please indicate the maximum number of
simultaneous loop migrations that you can support
(b) automated flow-through individual loop hot cuts;
(c) manual batch cuts (please indicate the maximum number of simultaneous loop
migrations that you can support
(d) manual individual loop hot cuts.
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 41
Boise-165130.10029164-00097
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to DSL which is not relevant to these proceedings. Without waiving
these objections, Qwest refers MCI to the batch hot cut proposal filed by Qwest
November 11,2003, and Qwest notes that the general subject matter concerning hot cuts
and OSS capabilities related to hot cuts will be addressed by the parties in the batch hot cut
forum that will take place during these proceedings.
MCI-Please provide a detailed description of any current Qwest processes to support
individual loop hot cuts between each of the following service configurations: 1)
Qwest voice only 2) Qwest voice plus DSL; 3) Qwest DSL only; 4) CLEC UNE-
P voice only; 5) CLEC switch-based voice only; 6) CLEC line sharing; 7) CLEC
line splitting; 8) CLEC DSL only (e., Qwest voice only to CLEC UNE-P voice
only; CLEC A switch-based voice only to CLEC B switch-based voice only
Please provide a copy of all documents or information describing or discussing
such processes.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to DSL, line splitting and line sharing which is not relevant to these
proceedings. Without waiving these objections, Qwest refers MCI to the batch hot cut
proposal filed by Qwest on November 11, 2003, and Qwest notes that the general subject
matter concerning hot cuts and OSS capabilities related to hot cuts will be addressed by the
parties in the batch hot cut forum that will take place during these proceedings.
MCI-Please provide a detailed description of any planned Qwest processes to support batch
cuts between each of the following service configurations: 1) Qwest voice only 2)
Qwest voice plus DSL; 3) Qwest DSL only; 4) CLEC UNE-P voice only; 5)
CLEC switch-based voice only; 6) CLEC line sharing; 7) CLEC line splitting;
8) CLEC DSL only (e., Qwest voice only to CLEC UNE-P voice only; CLEC A
switch-based voice only to CLEC B switch-based voice onlyJ. Please provide a
copy of all documents or information describing or discussing such processes.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to DSL, line splitting and line sharing which is not relevant to these
proceedings. Without waiving these objections, Qwest refers MCI to the batch hot cut
proposal filed by Qwest on November 11, 2003, and Qwest notes that the general subject
matter concerning hot cuts and OSS capabilities related to hot cuts will be addressed by the
parties in the batch hot cut forum that will take place during these proceedings.
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Boise-165130.10029164-00097
MCI-Please provide a detailed description of any planned Qwest processes to support
individual customer hot cuts between each ofthe following service
configurations: 1) Qwest voice only 2) Qwest voice plus DSL; 3) Qwest DSL
only; 4) CLEC UNE-P voice only; 5) CLEC switch-based voice only; 6) CLEC
line sharing; 7) CLEC line splitting; 8) CLEC DSL only (e., Qwest voice only
to CLEC UNE-P voice only; CLEC A switch-based voice only to CLEC B
switch-based voice only J. Please provide a copy of all documents or information
describing or discussing such processes.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, vague and ambiguous. Qwest also objects to this request on the
grounds that it seeks irrelevant information and is not reasonably calculated to lead to the
discovery of admissible evidence. Qwest also objects on the grounds that this request seeks
information relating to DSL, line splitting and line sharing which is not relevant to these
proceedings. Without waiving these objections, Qwest refers MCI to the batch hot cut
proposal filed by Qwest on November 11, 2003, and Qwest notes that the general subject
matter concerning hot cuts and OSS capabilities related to hot cuts will be addressed by the
parties in the batch hot cut forum that will take place during these proceedings.
MCI-
QWEST MASS MARKET UNE SWITCHING TRIGGER ISSUES
For each switch you use to provide local exchange service to Idaho customers, please
provide the following information for the switch and/or the switch location:
(a) the 8-digit common language location identifier ("CLLI") code as it appears
in the Local Exchange Routing Guide ("LERG"
(b) V &H coordinates;
( c) street address, city and zip code;
(d) switch manufacturer and model;
(e) currently loaded version of switch software;
(f) currently equipped line side capacity in (1) DS-O/voice grade circuits and (2)
DS-l circuits;
(g) currently utilized line side capacity in (1) DS-O/voice grade circuits and (2)
DS-l circuits;
(h) current switch processor capacity in CCS;
(i) busy hour and busy season utilized switch processor capacity in CCS;
(j) function of the switch (e., stand-alone, host, or remote, other (e.g. DLC node
with no intelligence and/or no or limited switching capability));
(k) the initial cost ofthe switch, including equipment, software, and EF&I
engineered, furnished and installed") costs;
(1) number of (1) DS-O/voice grade circuits and (2) DS-l circuits equipped at the
time of installation;
(m)any central offices or wire centers currently served by your switch for which
you are considering discontinuing service for any reason within the next
months.
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 43
Boise-165130.1 0029164-00097
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Also, Qwest objects to this request because it seeks information
that is publicly available. Further, Qwest objects to this request on the grounds that it is
neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.
Qwest noted in its Notice of Scope of Docket that it is unable at this point to specifically
define the markets in which it will seek relief from unbundling obligations for switching for
mass market customers. Qwest intends to specifically define those market areas in its
testimony to be filed on January 19,2004. Once those market areas are defined, all
requested information for CLLI codes and/or wire centers outside of those areas will be
irrelevant in this docket. Within a reasonable time after Qwest makes its proposed market
definitions, Qwest will respond to this request with relevant information to the extent any
such information exists.
MCI-For each switch identified in response to MCI-97 above, please provide the
information requested in TABLE 1:
TABLE 1
Qwest Number Number of Type of Number of Number of N umber of
Switch Of Loops Local End-User Voice Only DSL Only Line
CLLI Per End-Service Customer End User End User SharedN oice
User End-User Customers Plus DSLCustomers
Customer Customers End User
Premises Customers
ABC g. 10 155 Residential g. 10 000 g. 5 g. 100
g. 5 300 Business g. 5 000 g. 100 g. 100
Residential
Business
Residential
Business
. . . (continue pattern as above)
Residential
Business
19-Residential
19-Business
one DS-Residential
one DS-Business
more than Business
one DS-
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
This category includes loops used for fax and/or modem-only traffic.
This category includes voice and DSL on the same wire pair (i., line sharing and QWEST voice plus
DSL).
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 44
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and unduly burdensome. Qwest objects to this request on the grounds that it is neither
relevant nor reasonably calculated to lead to the discovery of admissible evidence. Qwest
noted in its Notice of Scope of Docket that it is unable at this point to specifically define the
markets in which it will seek relief from unbundling obligations for switching for mass
market customers. Qwest intends to specifically define those market areas in its testimony
to be filed on January 19, 2004. Once those market areas are defined, all requested
information for CLLI codes and/or wire centers outside of those areas will be irrelevant in
this docket. Within a reasonable time after Qwest makes its proposed market definitions
Qwest will respond to this request with relevant information to the extent any such
information exists.
MCI-For each switch you own or control and from which you offer or provide wholesale
local switching capacity via UNE-P to carriers that are not affiliated with you
please provide the following information for the switch and/or the switch
location:
(a) the 8-digit common language location identifier ("CLLI") code as it appears
in the Local Exchange Routing Guide ("LERG"
(b) V&H coordinates;
(c) street address, city and zip code;
(d) switch manufacturer and model;
( e) current loaded version of switch software;
(f) currently equipped line side capacity in (1) DS-O/voice grade circuits and (2)
DS-l circuits;
(g) currently utilized line side capacity in (1) DS-O/voice grade circuits and (2)
DS-l circuits;
(h) current switch processor capacity in CCS;
(i) busy hour and busy season utilized processor capacity in CCS;
(j) percentage of line side or processor capacity reserved for your own current or
future use;
(k) percentage of line side and processor capacity that you currently make
available, or that you plan to make available, on a wholesale basis to other
CLECs;
(I) the expected useful service life of each switch;
(m)whether your company intends to utilize the switch for the full expected useful
service life;
(n) the rates, terms and conditions under which you provide wholesale switching
for local exchange service, and/or loops and transport provided in conjunction
with wholesale switching (if rates, terms and conditions are not currently
available, please state when they will be available);
(0) any wire center subtending areas currently served by your switch for which
you are considering discontinuing wholesale local switching for any reason
within the next 12 months.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad,
unduly burdensome, and seeks information that is publicly available. Also, Qwest objects
to this request on the grounds that it is neither relevant nor reasonably calculated to lead to
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the discovery of admissible evidence. Qwest is unable at this point to specifically define the
markets in which it will seek relief from unbundling obligations for switching for mass
market customers. Qwest intends to specifically define those market areas in its testimony
to be filed on January 19,2004. Once those market areas are defined, all requested
information for CLLI codes and/or wire centers outside of those areas will be irrelevant in
this docket. Within a reasonable time after Qwest makes its proposed market definitions,
Qwest will respond to this request with relevant information to the extent any such
information exists.
MCI-I00 For each switch identified in response to MCI-99 above, please provide the
information requested in TABLE 2:
TABLE 2
Qwest Number N umber Type of Number of Number of
Switch Of Loops Local End-User Voice Only Line Split
CLLI Per End-Service Customer End User End User
User End-User Customers Customers
Customer Customers
Premises
ABC g. 10 155 Residential g. 10 000 g. 100
g. 5 300 Business g. 5 000 g. 100
Residential
Business
Residential
Business
. . . (continue pattern as above)
Residential
Business
19-Residential
19-Business
one DS-Residential
one DS-Business
More than Business
one DS-
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Also, Qwest objects to this request on the grounds that it is
neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.
Qwest is unable at this point to specifically define the markets in which it will seek relief
from unbundling obligations for switching for mass market customers. Qwest intends to
specifically define those market areas in its testimony to be filed on January 19, 2004. Once
those market areas are defined, all requested information for CLLI codes and/or wire
This category includes loops used for fax and/or modem-only traffic.
This category includes UNE-P voice and CLEC DSL on the same wire pair.
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centers outside of those areas will be irrelevant in this docket. Within a reasonable time
after Qwest makes its proposed market definitions, Qwest will respond to this request with
relevant information to the extent any such information exists. Finally, Qwest also objects
to this request on the grounds that those parts of this data request that seek information
concerning DSL or DS-l1evel facilities are not relevant or reasonably calculated to lead to
the discovery of admissible evidence.
MCI-1O1
MCI-I02
Please provide the following information regarding (1) the Class 5 (end office) circuit
switch most recently installed in Idaho by Qwest, and (2) any planned new
installations of a Class 5 (end office) circuit switch in Idaho by Qwest: a)
manufacturer, b) model, c) date to be placed in service, d) location (street address
city, and zip code), e )CLLI code and 1) V &H coordinates.
For each switch identified in your response to MCI-97 above other than circuit
switches, please provide the following:
(a) any differences in quality of service compared to local exchange service
provided on circuit switches (i., reliability, throughput, ubiquity, outages
mean time to repair, etc.
a. the date( s) on which you installed the switch and began providing local
exchange service on the switch;
(c) the geographic area served by the switch compared to the geographic area
served by any circuit switches you use to provide local exchange service;
(d) any differences in the technical or operational requirements for the customer
to obtain local exchange service from the switch, including customer premises
equipment or software (i., specialized phone set; availability of computer
cable modem, set top box), access method (i., DSL, cable television, satellite
service), provisioning interval;
(e) any central offices or wire centers currently served by your switch for which
you are considering discontinuing service for any reason within the next 12
months.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Also, Qwest objects to this request on the grounds that it is
neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.
Further, Qwest objects to this request on the grounds that it seeks information concerning
DSL service that is not relevant or reasonably calculated to lead to the discovery of
admissible evidence. To the extent that Qwest has information responsive to this request
and subject to objections, Qwest will supplement its response to this data request.
MCI-I03 Please identify all switches, other than circuit switches, currently in use by cable
operators to provide local exchange voice service in Idaho or regionwide (Qwest
14 states (AZ , MN, MT, NE, ND, NM, OR, SD, UT, W A, WY)J )J if
Qwest is unable to provide Idaho-specific data, or at any geographic level, if
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Qwest cannot provide either Idaho-specific or regionwide data, stated separately
for residential and business customers, and provide the following information:
(a) the identity of the cable operator;
(b) the number of units passed (reported separately by residential and business units)
by the portion of the cable operator s network capable of supporting local
exchange voice service;
(c) the number of residential units passed by the cable operator s network that are
subscribing to cable (video) services;
(d) the number of residential units passed by the cable operator s network that are
subscribing to broadband data services;
(e) the number of residential units subscribing to cable (video) services that also
obtain local exchange voice service from the cable operator;
(f) the date on which the cable operator first began providing local exchange voice
servIce;
(g) the price oflocal exchange voice service provided by the cable operator;
(h) service quality oflocal exchange service provided by CMRS operators compared
to local exchange service provided by Qwest (e., service outages, dropped calls;
E911 , etc.
(i) maps of the cable operator s serving territories with locations ofQWEST central
offices or wire centers identified;
(j) any business cases, analysis, or projections for entry of cable companies into the
broadband data and/or local exchange voice markets (whether the information or
documents were prepared by you, on your behalf, or by a third party).
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Also, Qwest objects to this request on the grounds that it seeks
data concerning 14 states that is overly broad, unduly burdensome and irrelevant to these
proceedings. Qwest objects to this request because the information it seeks is publicly
available and may be obtained in the LERG. Finally, Qwest objects to this request on the
grounds that it seeks information concerning broadband that is not relevant or reasonably
calculated to lead to the discovery of admissible evidence. To the extent that Qwest has
information responsive to this request, and subject to objections, Qwest will supplement its
response to this data request.
MCI-I04 Please identify all switches, other than circuit switches, currently in use by CMRS
operators to provide local exchange voice service in Idaho or regionwide (Qwest
14 states (AZ, CO, ID, lA, MN, MT, NE, ND, NM, OR, SD, UT, WA, WY)J)J if
Qwest is unable to provide Idaho-specific data, or at any geographic level, if
Qwest cannot provide either Idaho-specific or regionwide data, stated separately
for residential and business customers, and provide the following information:
(a) the identity of the CMRS operator;
(b) the number of customers of the CMRS operator who are subscribing to local
exchange voice services;
(c) the number of customers of the CMRS operator who are subscribing to
broadband data services;
(d) the minimum, maximum and average throughput rate for the CMRS
operator s broadband data services each month for the last 12 months;
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 48
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(e) the date on which the CMRS operator first began providing local exchange
VOIce servIce;
(f) the price of local exchange voice service provided by the CMRS operator;
(g) the service quality of local exchange service provided by the CMRS operator
compared to local exchange service provided by Qwest (e., service outages
dropped calls. etc.
(h) a description of the entire service territory the CMRS operator can reach;
(i) the percentage of Qwest' s serving territory (by central office or wire center)
that the CMRS operator can reach;
(j) the percentage of Qwest' s serving territory (by central office or wire center) to
which the CMRS operator is providing local exchange voice service;
(k) the percentage of Qwest's serving territory (by central office or wire center) to
which the CMRS operator is providing broadband data service;
(1) any business cases, analysis, or projections for entry of CMRS operators into
the broadband data and/or local exchange voice markets (whether the
information or documents were prepared by you, on your behalf, or by a third
party).
OBJECTION: Qwest objects to this request on the grounds that it is overly broad, unduly
burdensome, and seeks information regarding a Qwest subsidiary. Also, Qwest objects to
this request on the grounds that it seeks data concerning 14 states that is overly broad,
unduly burdensome and irrelevant to these proceedings. Finally, Qwest objects to this
request on the grounds that it seeks information concerning broadband that is not relevant
or reasonably calculated to lead to the discovery of admissible evidence. To the extent that
Qwest has information responsive to this request, and subject to objections, Qwest will
supplement its response to this data request.
MCI-I05 For each CLEC or other carrier collocation arrangement in each Qwest wire center in
Idaho, please provide the following information, reported by CLLI code, street
address and zip code:
(a) name ofCLEC 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-, OC-, etc.), and number of circuits at each level of
capacity.
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OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Also, Qwest objects to this request on the grounds that it is
neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.
Qwest noted in its Notice of Scope of Docket that it is unable at this point to specifically
define the markets in which it will seek relief from unbundling obligations for switching for
mass market customers. Qwest intends to specifically define those market areas in its
testimony to be filed on January 19, 2004. Once those market areas are defined, all
requested information for CLLI codes and/or wire centers outside of those areas will be
irrelevant in this docket. Within a reasonable time after Qwest makes its proposed market
definitions, Qwest will respond to this request with relevant information to the extent any
such information exists. Qwest also objects to this request on the grounds that this request
seeks CLEC/Carrier specific information which may be protected by Section 222 of the
Communications Act of 1934, 47 U.c. ~ 222, or other privacy laws. Qwest will produce
such information upon the entry of a Commission order compelling Qwest to do so.
MCI-I06 For each Qwest wire center in Idaho, please identify the amount of available unused
collocation space, in terms of total square feet of space and type(s) of collocation
for which available space can be used. Please identify all wire centers that you
previously listed as out of space for collocation that now have space available.
Please provide a detailed explanation of what was done to free up space, and
identify for disclosure of all documents on which you relied for your response, or
that are relevant to this request.
OBJECTION: Qwest objects to this request on the grounds that Qwest does not possess
the information requested and it would require a special study to produce the information.
MCI-I07 With regard to all CLEC to CLEC cross connections you have provisioned, please
identify the following, reported by wire center:
(a) number of such cross connections that you have provisioned;
(b) the identity of both CLECs for whom you provisioned the cross connect
(c) the type of collocation arrangement of both CLECs;
(d) the minimum, maximum and average provisioning time for CLEC to CLEC
cross connections;
(e) the identity ofthe entity or personnel who performs the cross connect (e.
QWEST central office technician, certified CLEC technician, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Also, Qwest objects to this request on the grounds that it is
neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.
Qwest noted in its Notice of Scope of Docket that it is unable at this point to specifically
define the markets in which it will seek relief from unbundling obligations for switching for
mass market customers. Qwest intends to specifically define those market areas in its
testimony to be filed on January 19, 2004. Once those market areas are defined, all
requested information for CLLI codes and/or wire centers outside of those areas will be
irrelevant in this docket. Within a reasonable time after Qwest makes its proposed market
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definitions, Qwest will respond to this request with relevant information to the extent any
such information exists. Finally, Qwest objects to this request on the grounds that this
request seeks CLEC/Carrier specific information which may be protected by Section 222 of
the Communications Act of 1934,47 U.C. ~ 222, or other privacy laws. Qwest will
produce such information upon the entry of a Commission order compelling Qwest to do
so.
MCI-I08 For each Qwest central office or wire center at which loops and transport are
connected at collocation arrangements to form EELs in Idaho or regionwide
(Qwest 14 states (AZ, CO, ID, IA, MN, MT, NE, ND, NM, OR, SD, UT, WA
WY)J if Qwest is unable to provide Idaho-specific data, please provide the
following information:
(a) the CLLI code, street address, zip code, and V &H coordinates of the Qwest
central office or wire center where such EELs are created;
(b) the CLLI code, street address, zip code, 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-l transport connected to multiplexed
DS-O/voice grade loops;
(e) number of such EELs that comprise DS-l transport connected to multiplexed
and concentrated DS-O/voice grade loops, and the loop-to-transport
concentration 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-transport
concentration ratio;
(h) number of such EELs that comprise DS-l transport connected to DS-l loops;
(i) number of such EELs that comprise DS-3 transport connected to multiplexed
DS-l loops;
G) number of such EELs that comprise DS-3 transport connected to multiplexed
and concentrated DS-l loops, and the loop-to-transport concentration ratio;
(k) what equipment is required to deploy EELs;
(I) whether collocation is required for CLECs to utilize EELs;
(m)the concentration ratio allowed for EELs.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Also, Qwest objects to this request on the grounds that it seeks
data concerning 14 states that is overly broad, unduly burdensome and irrelevant to these
proceedings. Further, Qwest objects to this request on the grounds that it is neither
relevant nor reasonably calculated to lead to the discovery of admissible evidence. Qwest
noted in its Notice of Scope of Docket that it is unable at this point to specifically define the
markets in which it will seek relief from unbundling obligations for switching for mass
market customers. Qwest intends to specifically define those market areas in its testimony
to be filed on January 19, 2004. Once those market areas are defined, all requested
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information for CLLI codes and/or wire centers outside of those areas will be irrelevant in
this docket. Within a reasonable time after Qwest makes its proposed market definitions
Qwest will respond to this request with relevant information to the extent any such
information exists. Qwest also objects to this request as irrelevant and not reasonably
calculated to lead to the discovery of admissible evidence to the extent it requests
information concerning DSI and above facilities connected to DSI and above loops.
MCI-I09 For each Qwest central office or wire center at which loops and transport are
connected to form EELs without using collocation in Idaho or regionwide (Qwest
14 states (AZ, CO, ID , IA, MN, MT, NE, ND, NM, OR, SD, UT, W A, WY)J if
Qwest is unable to provide Idaho-specific data, please provide the following
information:
(a) the CLLI code, street address, zip code, and V &H coordinates of the Qwest
central office or wire center where such EELs are created;
(b) the CLLI code, street address, zip code, 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-l transport connected to multiplexed
DS-O/voice grade loops;
(e) number of such EELs that comprise DS-l transport connected to multiplexed
and concentrated DS-O/voice grade loops, and the loop-to-transport
concentration 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-transport
concentration ratio;
(h) number of such EELs that comprise DS-l transport connected to DS-l loops;
(i) number of such EELs that comprise DS-3 transport connected to multiplexed
DS-l loops;
(j) number of such EELs that comprise DS-3 transport connected to multiplexed
and concentrated DS-l loops, and the loop-to-transport concentration ratio.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest objects to this request on the grounds that it is neither
relevant nor reasonably calculated to lead to the discovery of admissible evidence. Also,
Qwest objects to this request on the grounds that it seeks data concerning 14 states that is
overly broad, unduly burdensome and irrelevant to these proceedings. Qwest noted in its
Notice of Scope of Docket that it is unable at this point to specifically define the markets in
which it will seek relief from unbundling obligations for switching for mass market
customers. Qwest intends to specifically define those market areas in its testimony to be
filed on January 19 2004. Once those market areas are defined, all requested information
for CLLI codes and/or wire centers outside of those areas will be irrelevant in this docket.
Within a reasonable time after Qwest makes its proposed market definitions, Qwest will
respond to this request with relevant information to the extent any such information exists.
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Qwest also objects to this request as irrelevant and not reasonably calculated to lead to the
discovery of admissible evidence to the extent it requests information concerning DSI and
above facilities connected to DSI and above loops.
MCI-IlO
MCI-lll
MCI-1l2
MCI-I13
Please provide the definition you use internally for business purposes for the
following terms: (1) "mass market customer" and (2) "enterprise customer " in
terms of type of customer (e., residential vs. business), number of lines per
customer, use of analog loop facilities vs. DS-l s, or any other basis you use to
distinguish these terms.
Please state whether you view a crossover point between mass market customers and
enterprise customers set at 4 DS-O/voice grade lines per single customer premises
to have any economic, engineering, operational, or business basis from the
perspective of your non-regulatory business purposes. If your response is not an
unqualified "" please explain such basis in detail and provide supporting
documentation.
Please provide your calculation, estimate, or view of the economic crossover point, in
terms of number of DS-O/voice grade lines to a single customer premises, at
which you offer service at a DS-l level rather than using a number of analog
lines, and provide the basis for that crossover point (e., equivalency point of
analog service rates and DS-l service rates, consideration of whether the customer
premises equipment can accept a DS-l interface, etc.
With respect to each of the two customer categories identified in response to MCI-
110, please provide the following information:
(a) the number of customers in each category, reported by central office/wire center
for each month since July 1 , 2001;
(b) the percentage of your total customer base in Idaho in each of the two categories;
(c) whether you target your business plans or marketing to particular sub-sets of
customers within each of the two categories identified in response to MCI-llO.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Also, Qwest objects to this request on the grounds that it is
neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.
Qwest noted in its Notice of Scope of Docket that it is unable at this point to specifically
define the markets in which it will seek relief from unbundling obligations for switching for
mass market customers. Qwest intends to specifically define those market areas in its
testimony to be filed on January 19,2004. Once those market areas are defined, all
requested information for CLLI codes and/or wire centers outside of those areas will be
irrelevant in this docket. Within a reasonable time after Qwest makes its proposed market
definitions, Qwest will respond to this request with relevant information to the extent any
such information exists.
MCI-114 Please identify, by CLLI code, city, street address and zip code, all switches you have
deployed in Idaho in density zone 1 of the top 50 largest Metropolitan Statistical
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Areas (MSAs), and whether each of those switches is subject to the FCC's
unbundled switching "carve out."
MCI-115 Please state the technical characteristics and capabilities of all loops that you consider
to be a DS-O and/or voice grade loop, and provide any relevant public and/or
confidential technical publications and any other documents that describe these
characteristics and capabilities.
MCI -116 Please state the technical characteristics and capabilities of a DSL-capable loop, and
provide any relevant public and/or confidential technical publications and any
other documents that describe these characteristics and capabilities.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence.
MCI-1l7 Please state the technical characteristics and capabilities of loops capable of
supporting 1) line sharing and 2) line splitting (i.e. voice service and DSL service
carried on a single wire pair entering the customer s premises), and provide any
relevant public and/or confidential technical publications and any other
documents that describe these characteristics and capabilities.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence.
MCI-118 Please provide, a) on a Colorado-statewide basis, and b) on a CLLI-code-specific
basis, monthly data for each month since July 2001 on the number ofloops
carrying DS-O/voice grade service on all of the following bases: 1) total loops in
service 2) residential loops in service; 3) business loops for business with 1-
loops in service to a single customer premises; 4) business loops for businesses
with more than 3 loops in service to a single customer premises; 5) UNE loops.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome and would require a special study. Also, Qwest objects to this
request on the grounds that it is neither relevant nor reasonably calculated to lead to the
discovery of admissible evidence. Qwest noted in its Notice of Scope of Docket that it is
unable at this point to specifically define the markets in which it will seek relief from
unbundling obligations for switching for mass market customers. Qwest intends to
specifically define those market areas in its testimony to be filed on January 26, 2004. Once
those market areas are defined, all requested information for CLLI codes and/or wire
centers outside of those areas will be irrelevant in this docket. Within a reasonable time
after Qwest makes its proposed market definitions, Qwest will respond to this request with
relevant information to the extent any such information exists. Finally, Qwest objects to
the production of this information in that it requires production of CLEC/Carrier specific
information which may be protected by Section 222 of the Communications Act of 1934
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C. ~ 222, or other privacy laws. Qwest will produce such information upon the entry of
a Commission order compelling Qwest to do so.
MCI-119 Please provide, a) on a Idaho-statewide basis, and b) on a CLLI-code-specific basis
monthly data for each month since July 1, 2001 on the number ofloops carrying
standalone DSL service on all of the following bases: 1) total loops in service 2)
residential loops in service; 3) business loops for business with 1-3 loops in
service to a single customer premises; 4) business loops for businesses with more
than 3 loops in service to a single customer premises; 5) UNE loops.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence. Qwest also objects to this data request on the grounds that the
request is unduly broad and it would be unduly burdensome to produce such information.
Finally, Qwest objects to the production ofthis information in that it requires production
of CLEC/Carrier specific information which may be protected by Section 222 of the
Communications Act of 1934 47 U.C. ~ 222, or other privacy laws. Qwest will produce
such information upon the entry of a Commission order compelling Qwest to do so.
MCI-120 Please provide, a) on a Idaho-statewide basis, and b) on a CLLI-code-specific basis
monthly data for each month since July 1 , 2001 on the number ofloops carrying
line shared Qwest voice plus CLEC DSL service on all of the following bases: 1)
total loops in service 2) residential loops in service; 3) business loops for business
with 1-3 loops in service to a single customer premises; 4) business loops for
businesses with more than 3 loops in service to a single customer premises; 5)
UNE loops.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request concerns DSL service that is not relevant or reasonably calculated to lead
to the discovery of relevant evidence. Qwest objects to this data request on the grounds
that the request is unduly broad and it would be unduly burdensome to produce such
information. Finally, Qwest objects to the production of this information in that it requires
production of CLEC/Carrier specific information which may be protected by Section 222
of the Communications Act of 1934 47 U.c. ~ 222, or other privacy laws. Qwest will
produce such information upon the entry of a Commission order compelling Qwest to do
so.
MCI-I21 Please provide, a) on a Idaho-statewide basis, and b) on a CLLI-code-specific basis
monthly data for each month since July 1 , 2001 on the number ofloops carrying
line split voice plus DSL service on all ofthe following bases: 1) total loops in
service 2) residential loops in service; 3) business loops for business with 1-
loops in service to a single customer premises; 4) business loops for businesses
with more than 3 loops in service to a single customer premises; 5) UNE loops.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request concerns DSL service that is not relevant or reasonably calculated to lead
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to the discovery of relevant evidence. Qwest objects to this data request on the grounds
that the request is unduly broad and it would be unduly burdensome to produce such
information. Finally, Qwest objects to the production of this information in that it requires
production of CLEC/Carrier specific information which may be protected by Section 222
of the Communications Act of 1934 47 U.c. ~ 222, or other privacy laws. Qwest will
produce such information upon the entry of a Commission order compelling Qwest to do
so.
MCI-122 Please provide, a) on a Idaho-statewide basis, and b) on a CLLI-code-specific basis
monthly data for each month since July 1 , 2001 on the number of loops carrying
Qwest voice plus Qwest/Qwest affiliate DSL service on all of the following bases:
1) total loops in service 2) residential loops in service; 3) business loops for
business with 1-3 loops in service to a single customer premises; 4) business
loops for businesses with more than 3 loops in service to a single customer
premIses.
OBJECTION: Qwest objects to this request on the grounds that it seeks information
concerning DSL service which is not relevant or reasonably calculated to lead to the
discovery of relevant evidence. Qwest also objects to this data request on the grounds that
the request is unduly broad and it would be unduly burdensome to produce such
information. Finally, Qwest objects to the production of this information in that it requires
production of CLEC/Carrier specific information which may be protected by Section 222
of the Communications Act of 1934 47 U.C. ~ 222, or other privacy laws. Qwest will
produce such information upon the entry of a Commission order compelling Qwest to do
so.
MCI-123 Please provide, a) on a Idaho-statewide basis, and b) on a CLLI-code-specific basis
monthly data for each month since July 1 , 2001 on the number ofloops that are
provisioned using: 1) all-copper facilities; 2) hybrid fiber/copper facilities; 3) all-
fiber facilities; 4) IDLC; 5) UDLC; 6) NGDLC; 7) DAML.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Also, Qwest objects to this request on the grounds that it is
neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.
Qwest noted in its Notice of Scope of Docket that it is unable at this point to specifically
define the markets in which it will seek relief from unbundling obligations for switching for
mass market customers. Qwest intends to specifically define those market areas in its
testimony to be filed on January 19,2004. Once those market areas are defined, all
requested information for CLLI codes and/or wire centers outside of those areas will be
irrelevant in this docket. Within a reasonable time after Qwest makes its proposed market
definitions, Qwest will respond to this request with relevant information to the extent any
such information exists.
MCI-124 Please state whether you currently provision in Idaho UNE loops over loops
provisioned using 1) IDLC and 2) NGDLC. Please provide a copy of any
methods and procedures, technical service descriptions, and other technical
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documents that describe the service arrangement and/or identify the supported
features, functions and supported throughput rates.
MCI-125 Please provide, on a CLLI-code-specific basis for Idaho, detailed information
concerning copper feeder plant that 1) has been retired since January 2000 or 2)
Qwest plans to or is considering retiring in the next three years.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence. Qwest also objects to this data request on the grounds that the
request is unduly broad and it would be unduly burdensome to produce such information.
MCI-126 Please provide, on a CLLI-code-specific basis, detailed information concerning
Qwest's plans for Idaho over the next three years to use copper feeder plant that
has been replaced with fiber-feeder plant, for reinforcement to meet growth needs
on shorter all-copper feeder routes.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence. Qwest also objects to this data request on the grounds that the
request is unduly broad and it would be unduly burdensome to produce such information.
MCI-127 Please provide a detailed description of Qwest's current policy for Idaho regarding
maintenance of copper outside plant facilities once those facilities have been
retired. Please provide a copy of all documents, including Methods and
Procedures, guidelines, bulletins, business rules and/or business analysis on which
you relied, or that are relevant to this Request. Also please state whether Qwest is
considering revising this policy, and if so, when such revision is anticipated.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is overly broad, unduly burdensome and that it is not relevant or
reasonably calculated to lead to the discovery of admissible evidence.
MCI-128 Please provide detailed information, including supporting and related documents
regarding Qwest's plans , incentives, justification, benefits and/or analysis of
upgrading its loop plant in Idaho by installing additional 1) hybrid copper/fiber
loops; 2) all-fiber loops.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request overly broad, unduly burdensome and that it is not relevant or reasonably
calculated to lead to the discovery of admissible evidence.
MCI-129 Please provide, on a wire center basis, detailed information concerning dark fiber
the loop plant that is currently available in Idaho for use by CLECs.
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OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request overly broad, unduly burdensome and that it is not relevant or reasonably
calculated to lead to the discovery of admissible evidence.
MCI-130 On a statewide and CLLI-code-specific basis in Idaho, please state the percentage of
working loops used or available to support Qwest retail services that are
configured as "connect through"/"warm line" (i., loops that have electrical
continuity between the customer premises and the Qwest switch, and over which
a person at the customer premises can call 911 and Qwest repair service).
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest objects to this request on the grounds that it is neither
relevant nor reasonably calculated to lead to the discovery of admissible evidence. Qwest
noted in its Notice of Scope of Docket that it is unable at this point to specifically define the
markets in which it will seek relief from unbundling obligations for switching for mass
market customers. Qwest intends to specifically define those market areas in its testimony
to be filed on January 19,2004. Once those market areas are defined, all requested
information for CLLI codes and/or wire centers outside of those areas will be irrelevant in
this docket. Within a reasonable time after Qwest makes its proposed market definitions,
Qwest will respond to this request with relevant information to the extent any such
information exists.
MCI-131 Please state whether collocation rates, terms and conditions in Qwest's service
territory in Idaho are controlled by tariff, interconnection agreements, documents
controlled by Qwest (e., CLEC handbook) or a combination of these documents.
Please provide a complete copy (including attachments or amendments) of each
such document.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and that it would be unduly burdensome to require Qwest to provide all interconnection
agreements or other documents concerning collocation rates, terms and conditions for its
service territory in Idaho. Without waiving this objection, Qwest states that all of its
interconnection agreements with CLECs/Carriers in Idaho are publicly available through
the Idaho Public Utilities Commission.
MCI-132 With respect to MCI-131 , if the collocation rates, terms and/or conditions vary among
interconnection agreements, please provide a copy of each different collocation
section.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and that it would be unduly burdensome to require Qwest to provide all interconnection
agreements or other documents concerning collocation rates, terms and conditions for its
service territory in Idaho. Without waiving this objection, Qwest states that all of its
interconnection agreements with CLECs/Carriers in Idaho are publicly available through
the Idaho Public Utilities Commission.
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MCI-133 With respect to MCI-131 , please state whether Qwest is considering changing the
type of document that controls collocation rates, terms and conditions (e.g. using
tariffs instead of interconnection agreements). If Qwest is considering such
change, please provide all documents that address such change.
MCI-134 Please list and describe all types of physical collocation offered by Qwest in Idaho.
MCI-135 Please provide the non-recurring (including EF&I ("engineered, furnished and
installed"J charges) and monthly recurring charges that Qwest charges for all
elements of all types of collocation in Idaho.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. To the extent that Qwest has information responsive to this
request, and subject to objections, Qwest will supplement its response to this data request.
MCI-136 Please list and describe all restrictions on the types and/or quantities of equipment or
facilities that may be placed in Qwest collocation space in Idaho. For each such
restriction, please provide the rationale for the restriction and the basis for the
restriction (e.g. QWEST business decision, FCC order, Idaho PUC order, etc.
MCI-137 With respect to MCI-136, please provide all documents that support or address the
restriction or the basis for the restriction.
MCI-138 On an individual wire center basis, please provide the following for Qwest in Idaho:
(a) total collocation space (used and unused space stated in square feet) for each
type of collocation you offer;
(b) total collocation space currently occupied by carriers (in square feet; for caged
collocation, state the number of cages);
(c) names of carriers currently occupying collocation space;
(d) collocation space (stated in square feet) held by carriers who are currently in
bankruptcy proceedings;
(e) collocation space (stated in square feet) occupied by CLECs no longer
operating;
(f) total unoccupied collocation space (stated in square feet) available for carriers;
and
(g) total non-collocation space available or suitable for conversion to collocation
space.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, and may require a special study. Qwest also objects on the grounds
that this request seeks information that is neither relevant to these proceedings nor
reasonably calculated to lead to the discovery of admissible evidence. Qwest also objects to
the production of this information in that it requires production of CLEC/Carrier specific
information which may be protected by Section 222 of the Communications Act of 1934
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C. ~ 222, or other privacy laws. Qwest will produce such information upon the entry of
a Commission order compelling Qwest to do so.
MCI-139
MCI-140
MCI-141
Please list, by CLLI code and street address, the central offices in Idaho where
collocation space of any type has been exhausted, or for which collocation space
exhaustion is anticipated in the next 3 years, including the date of exhaust or
expected exhaust.
For cross-connects between CLEC collocation arrangements in your central offices in
Idaho, please provide:
(a) your Methods and Procedures, guidelines, and practices relevant to, or
describing cross-connects between CLEC collocation arrangements;
(b) non-recurring charges;
(c) monthly recurring charges;
(d) applicable performance measures and penalties;
( e) complaints from CLECs regarding any aspect of such cross-connects (e.
cost, timeliness, etc.
(f) your response to and resolution of any such complaints.
Please state the rates you charge for flat and measured local exchange service for all
1) residential and 2) business customers in Idaho, and if the rate varies by
location, please identify the geographic coverage of the area to which the rate
applies (e., wire center, rate zone, etc.) and the statewide average rate you
charge for each category. If the rates you charge vary by central office, please
identify the rate that applies to each central office by CLLI code, and the rate zone
applicable to each central office.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
unduly burdensome, and may require a special study. Qwest also objects on the grounds
that this request seeks information that is neither relevant to these proceedings nor
reasonably calculated to lead to the discovery of admissible evidence. Qwest is unable at
this point to specifically define the markets in which it will seek relief from unbundling
obligations for switching for mass market customers. Qwest intends to specifically define
those market areas in its testimony to be filed on January 19, 2004. Once those market
areas are defined, all requested information for CLLI codes and/or wire centers outside of
those areas will be irrelevant in this docket. Within a reasonable time after Qwest makes
its proposed market definitions, Qwest will respond to this request with relevant
information to the extent any such information exists.
MCI-142 Please identify the average monthly revenue per line that you consider to constitute
low revenue, average revenue and high revenue for 1) residential customers and
2) business customers. Please provide a detailed explanation of whether
customers typically purchase a single service, or a bundle of services, and if they
purchase a bundle, which services, features or functions are included in the bundle
and the average monthly revenue for each type of bundle.
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MCI-143 Please identify, by CLLI code, all wire centers for which you receive universal
service fund subsidies and provide the following information for each:
(a) whether the subsidy is from federal or state sources
(b) the amount of the subsidy on a per loop or per customer basis
(c) whether the subsidy applies to all customers served by the central office/wire
center, or only a portion thereof;
(d) if the subsidy applies only to a portion of the customers, please provide the
number of customers and the percentage of those customers to the total
number of customers served in the central office/wire center.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects on the grounds that this request seeks
information that is neither relevant to these proceedings nor reasonably calculated to lead
to the discovery of admissible evidence. Qwest is unable at this point to specifically define
the markets in which it will seek relief from unbundling obligations for switching for mass
market customers. Qwest intends to specifically define those market areas in its testimony
to be filed on January 19, 2004. Once those market areas are defined, all requested
information for CLLI codes and/or wire centers outside of those areas will be irrelevant in
this docket. Within a reasonable time after Qwest makes its proposed market definitions,
Qwest will respond to this request with relevant information to the extent any such
information exists.
MCI-144 With respect to any subsidies that you contend are implicit and/or explicit in your
Idaho retail rates for any service, please:
(a) identify and describe the service;
(b) state separately the amount of the subsidy you contend is implicit and/or
explicit in the non-recurring and monthly recurring rates for the service;
(c) provide all cost studies, calculations, and other materials that directly support
your contention that the service is implicitly and/or explicitly being
subsidized.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects on the grounds that the information requested
does not exist in the form requested and it would require a special study to produce such
information.
MCI-145 With respect to each of the rows of Table 1 identified in response to MCI-98 above
please state the average total monthly revenues earned each month per line in
Idaho since July 1 2001 by wire center, MSA and LATA. Also please identify
the source of those revenues by service and/or feature type (i., local voice only,
local voice plus vertical features, local long distance only, DSL only, bundles of
any of the above, and/or other services or features).
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects on the grounds that this request seeks
information that is neither relevant to these proceedings nor reasonably calculated to lead
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to the discovery of admissible evidence. Qwest noted in its Notice of Scope of Docket that it
is unable at this point to specifically define the markets in which it will seek relief from
unbundling obligations for switching for mass market customers. Qwest intends to
specifically define those market areas in its testimony to be filed on January 19, 2004. Once
those market areas are defined, all requested information for CLLI codes and/or wire
centers outside of those areas will be irrelevant in this docket. Within a reasonable time
after Qwest makes its proposed market definitions, Qwest will respond to this request with
relevant information to the extent any such information exists. Finally, Qwest objects to
this request on the grounds that it seeks information concerning DSL service that is not
relevant or reasonably calculated to lead to the discovery of relevant evidence.
MCI-146 For each switch identified in your response to MCI-97 above other than circuit
switches, please provide the following for each switch:
(a) all costs arising from the provision oflocal exchange service using the switch
(including the recurring and non-recurring charges for the switch, software
installation, maintenance, loops, collocation, transmission/concentration
equipment, etc.
(b) the average total monthly revenues earned per line in Idaho since July 2001
reported by wire center, MSA and LATA. Also please identify the source of
those revenues by service and/or feature type (i., local voice only, local
voice plus vertical features, local long distance only, DSL only, bundles of
any of the above, and/or other services or features);
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence. Qwest also objects to this data request on the grounds that the
request is overly broad and it would be unduly burdensome to produce such information.
Without waiving this objection, Qwest is in the process of investigating whether it has
information responsive to this request and will provide such information if it exists.
MCI-147 With respect to each of the two customer categories identified in response to MCI-
110 please provide the following:
(a) all categories and amounts of costs arising from providing local exchange
service to each customer category (including the recurring and non-recurring
charges for the switch, software, installation, maintenance, loops, collocation
transmission/concentration equipment, transport, hot cuts, OSS, signaling,
etc.
(b). the average total monthly revenues earned per line since July 2001 for each
customer category, reported by wire center, MSA and LATA.
(c) the source of all revenues derived from each category loop identified in
subpart (b) by service and/or feature type (i., local voice only, local voice
plus vertical features, local long distance only, DSL only, bundles of any of
the above, and/or other services or features).
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad and
unduly burdensome. Qwest also objects to this request on the grounds that the information
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sought in the data request relating to its "enterprise costs" is not relevant or reasonably
calculated to lead to the discovery of admissible evidence. Qwest also believes that the time
period identified in this request is overly broad, and, therefore, producing responsive
information would be unduly burdensome. Finally, Qwest objects to this request on the
grounds that it seeks information concerning DSL service that is not relevant or reasonably
calculated to lead to the discovery of relevant evidence.
MCI-148 For each type of digital loop carrier ("DLC") equipment deployed by Qwest, please
state the minimum and maximum configuration deployed in Idaho, in terms of
number of lines supported.
OBJECTION: Qwest objects to this request on the grounds that it seeks 3rd party vendor
proprietary information that Qwest is under contractual obligation to maintain as
confidential. Subject to this objection, Qwest is in the process of soliciting vendor
authorization to make responsive information available and, to the extent such permission
is granted, will do so upon receipt of authorization.
MCI-149 For each type of digital loop carrier ("DLC") equipment deployed by Qwest in Idaho
please provide Qwest's equipment capital costs for minimum, average and
maximum configurations, in terms of number of lines supported.
OBJECTION: Qwest objects to this request on the grounds that it seeks 3rd party vendor
proprietary information that Qwest is under contractual obligation to maintain as
confidential. Subject to this objection, Qwest is in the process of soliciting vendor
authorization to make responsive information available and, to the extent such permission
is granted, will do so upon receipt of authorization.
MCI-150 For each type of digital loop carrier ("DLC") equipment deployed by Qwest in Idaho
please provide Qwest's Engineered, Furnished and Installed ("EF&I") costs for
minimum, average and maximum configurations, in terms of number of lines
supported.
OBJECTION: Qwest objects to this request on the grounds that it seeks 3rd party vendor
proprietary information that Qwest is under contractual obligation to maintain as
confidential. Subject to this objection, Qwest is in the process of soliciting vendor
authorization to make responsive information available and, to the extent such permission
is granted, will do so upon receipt of authorization.
MCI-151 Please provide all non-recurring and recurring rates and charges applicable in Idaho
for UNE loops of all types as found in:
(a) intrastate tariffs
(b) interstate tariffs
(c) currently effective Interconnection Agreement(s) with CLEC(s)
(d) your Statement of Generally Available Terms ("SGAT"
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OBJECTION: Qwest objects to this request on the grounds that it seeks information that
is publicly available.
MCI-152 Please provide all non-recurring and recurring rates and charges applicable in Idaho
for UNE transport of all types as found in:
( a) intrastate tariffs
(b) interstate tariffs
(c) currently effective Interconnection Agreement(s) with CLEC(s)
(d) your Statement of Generally Available Terms ("SGAT"
OBJECTION: Qwest objects to this request on the grounds that it seeks information that
is publicly available.
MCI-153 Please provide a copy of all business cases, business analysis, cost studies, or other
analyses or evaluations concerning whether entry into the mass market in Idaho
or regionwide (Qwest 14 states (AZ, CO, ID, IA, MN, MT, NE, ND, NM, OR
, UT, WA, WY)J)J if Qwest is unable to provide Idaho-specific data, is
economically feasible without access to Qwest's switches , including those
analyses and studies that were submitted to the FCC, performed but not submitted
to the FCC, and performed since February 22 2003. Provide all supporting
documentation and work papers, in electronic format if available.
OBJECTION: Qwest objects to this request to the extent it seeks information protected by
the attorney client and/or attorney work product privileges. Also, Qwest objects to this
request on the grounds that it seeks data concerning 14 states that is overly broad, unduly
burdensome and irrelevant to these proceedings. Without waiving these objections, Qwest
will provide the information supporting its case relating to CLEC or Carrier entry into the
mass market" in its written testimony on January 19, 2004.
MCI-154 Please state whether you have deployed facilities of any type (e.g. switches, loops
transport, DLC , DSLAMs, splitters, etc.) to provide local services as a CLEC in
any state or other geographic area outside your QWEST serving territory. If so
please provide all of the following:
(a) all states, cities or other geographic area in which you have deployed
facilities;
(b) a detailed description of the facilities for each geographic region;
(c) a detailed description of the criteria you used to choose the geographic areas
in which you would deploy facilities;
(d) a copy of all business cases, business analysis, cost studies, or other analyses
or evaluations (whether created by you or on your behalf) regarding
competitive entry into the geographic area outside your QWEST serving
territory;
( e) the date on which you first began providing competitive local services using
your own facilities in each state, city or other geographic region outside your
QWEST serving territory;
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(f) the number of 1) residential and 2) business customers at the most granular
level for which data has been retained (e., QWEST wire center, city, state
etc.) for your operations outside your QWEST serving territory for each
month since such operations began;
(g) all categories and amounts of costs arising from providing competitive local
services in each state, city or other geographic region outside your QWEST
serving territory (including the recurring and non-recurring charges for the
switch, software, installation, maintenance, loops, collocation
transmission/concentration equipment, transport, hot cuts, OSS , signaling,
etc.
(h) the average total monthly revenues earned per customer for each customer
type (e., residential, small business, enterprise) served in each state, city or
other geographic region outside your QWEST serving territory, reported by
CLLI, LATA, MSA;
(i) the source of all revenues derived from each customer type identified in your
response to subpart (h) by service and/or feature type (i., local voice only,
local voice plus vertical features, local long distance only, DSL only, bundles
of any of the above, and/or other services or features).
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence. Qwest also objects to this data request on the grounds that the
request is overly broad and it would be unduly burdensome to produce such information.
Finally, Qwest objects to this request on the grounds that it seeks information concerning
DSL service that is not relevant or reasonably calculated to lead to the discovery of
admissible evidence. Notwithstanding this objection, Qwest Corporation affirmatively
states that it does not operate as a CLEC outside of its ILEC service territory.
MCI-155 Please state whether you have ever offered, or are currently offering, local services
via UNE-P as a CLEC in any state or other geographic area outside your QWEST
serving territory. If so, please provide all of the following:
(a) all states, cities or other geographic area in which you have, or are, offering
local services;
(b) a detailed description of the criteria you used to choose the geographic areas
in which you would offer local services;
(c) a copy of all business cases, business analysis, cost studies, or other analyses
or evaluations (whether created by you or on your behalf) regarding
competitive entry into the geographic area outside your QWEST serving
territory;
(d) the date on which you first began providing competitive local services using
UNE-P in each state, city or other geographic region outside your QWEST
serving territory;
(e) the number of 1) residential and 2) business customers at the most granular
level for which data has been retained (e., QWEST wire center, city, state
etc.) for your operations outside your QWEST serving territory for each
month since such operations began;
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(f) all categories and amounts of costs arising from providing competitive local
services in each state, city or other geographic region outside your QWEST
serving territory;
(g) the average total monthly revenues earned per customer for each customer
type (e., residential, small business, enterprise) served in each state, city or
other geographic region outside your QWEST serving territory, reported by
CLLI, LATA and MSA;
(h) the source of all revenues derived from each customer type identified in
subpart (g) by service and/or feature type (i., local voice only, local voice
plus vertical features, local long distance only, DSL only, bundles of any of
the above, and/or other services or features).
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence. Qwest also objects to this data request on the grounds that the
request is overly broad and it would be unduly burdensome to produce such information.
Finally, Qwest objects to this request on the grounds that it seeks information concerning
DSL service that is not relevant or reasonably calculated to lead to the discovery of
admissible evidence. Notwithstanding this objection, Qwest Corporation affirmatively
states that it does not operate as a CLEC outside of its ILEC service territory.
MCI-156 Please state whether you have ever offered, or are currently offering, local services
via resale as a CLEC in any state or other geographic area outside your QWEST
serving territory. If so, please provide all of the following:
(a) all states, cities or other geographic area in which you have, or are, offering
local services;
(b) a detailed description of the criteria you used to choose the geographic areas
in which you would offer local services;
(c) a copy of all business cases, business analysis, cost studies, or other analyses
or evaluations (whether created by you or on your behalf) regarding
competitive entry into the geographic area outside your QWEST serving
territory;
(d) the date on which you first began providing competitive local services using
resale in each state, city or other geographic region outside your QWEST
serving territory;
(e) the number of 1) residential and 2) business customers at the most granular
level for which data has been retained (e., QWEST wire center, city, state
etc.) for your operations outside your QWEST serving territory for each
month since such operations began;
(f) all categories and amounts of costs arising from providing competitive local
services in each state, city or other geographic region outside your QWEST
serving territory;
(g) the average total monthly revenues earned per customer for each customer
type (e., residential, small business, enterprise) served in each state, city or
other geographic region outside your QWEST serving territory, reported by
CLLI, LATA, and MSA;
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 66
Boise-165130.10029164-00097
(h) the source of all revenues derived from each customer type identified in
subpart (g) by service and/or feature type (i., local voice only, local voice
plus vertical features, local long distance only, DSL only, bundles of any of
the above, and/or other services or features).
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence. Qwest also objects to this data request on the grounds that the
request is overly broad and it would be unduly burdensome to produce such information.
Finally, Qwest objects to this request on the grounds that it seeks information concerning
DSL service that is not relevant or reasonably calculated to lead to the discovery of
admissible evidence. Notwithstanding this objection, Qwest Corporation affirmatively
states that it does not operate as a CLEC outside of its ILEC service territory.
MCI-157 Please provide all documents addressing Qwest currently offered bundles of the
following: a) business local exchange and long distance services, b) residential
local exchange and long distance services, c) business local exchange, long
distance and broadband/DSL services, d) residential local exchange, long distance
and broadband/DSL services; e) residential local exchange and DSL; and f)
business local exchange and DSL.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence. Qwest also objects to this request on the grounds that this data
request seeks information concerning DSL service and broadband that is not relevant or
reasonably calculated to lead to the discovery of admissible evidence. To the extent that
Qwest has information responsive to this request, and subject to objections, Qwest will
supplement its response to this data request.
MCI-158 Please provide all documents addressing Qwest planned bundling of the following: a)
business local exchange and long distance services, b) residential local exchange
and long distance services, c) business local exchange, long distance and
broadband/DSL services, d) residential local exchange, long distance and
broadband/DSL services; e) residential local exchange and DSL; and f) business
local exchange and DSL.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence. Qwest also objects to this request on the grounds that this data
request seeks information concerning DSL service and broadband that is not relevant or
reasonably calculated to lead to the discovery of admissible evidence. To the extent that
Qwest has information responsive to this request, and subject to objections, Qwest will
supplement its response to this data request.
MCI-159 On a CLLI-code-specific basis in Idaho, please provide all forecasts of Qwest's
expected, estimated or forecasted demand growth or decline for each of the next
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 67
Boise-165130.1 0029164-00097
five years for circuit switched voice grade services, stated on all available bases
(e., number oflines, minutes of use, processor utilization CCS, etc.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is vague, ambiguous, overly broad, unduly burdensome and not relevant
or reasonably calculated to lead to the discovery of admissible evidence.
MCI-160 On a CLLI-code-specific basis in Idaho, please provide Qwest's current capacity
utilization for each Class 5 circuit switch for the major switch components (e.
processor, line cards, trunk cards, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects on the grounds that this request seeks
information that is neither relevant to these proceedings nor reasonably calculated to lead
to the discovery of admissible evidence. Qwest noted in its Notice of Scope of Docket that it
is unable at this point to specifically define the markets in which it will seek relief from
unbundling obligations for switching for mass market customers. Qwest intends to
specifically define those market areas in its testimony to be filed on January 19, 2004. Once
those market areas are defined, all requested information for CLLI codes and/or wire
centers outside of those areas will be irrelevant in this docket. Within a reasonable time
after Qwest makes its proposed market definitions, Qwest will respond to this request with
relevant information to the extent any such information exists.
MCI-161 On a CLLI-code-specific basis in Idaho, please provide the Qwest's demand growth
or decline for circuit switched voice grade services for each of the last three years
stated on all available bases (e., number oflines, minutes of use, processor
utilization CCS, etc.
OBJECTION: Qwest objects to this data request on the grounds that it is vague
ambiguous, overly broad and unduly burdensome. Qwest also objects on the grounds that
this request seeks information that is neither relevant to these proceedings nor reasonably
calculated to lead to the discovery of admissible evidence. To the extent that Qwest has
information responsive to this request, and subject to objections, Qwest will supplement its
response to this data request.
MCI-162 On a CLLI-code-specific basis in Idaho, please provide the Qwest's demand growth
or decline for each of the last three years for each of the following Qwest retail
services: primary business voice lines, primary residential voice lines, additional
business voice lines, additional residential voice lines, standalone DSL lines
Qwest DSL service provisioned in the high frequency portion of a loop that also
supports Qwest narrowband analog voice service, CLEC DSL service provisioned
in the high frequency portion of a loop that also supports Qwest narrowband
analog voice service, and CLEC DSL service provisioned in the high frequency
portion of a loop that also supports (CLEC) narrowband analog voice service.
OBJECTION: Qwest objects to this data request on the grounds that it is vague
ambiguous, overly broad and unduly burdensome. Qwest also objects to this request on
the grounds that this data request seeks information concerning DSL service that is not
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 68
Boise-165130.10029164-00097
relevant or reasonably calculated to lead to the discovery of admissible evidence. Qwest
also objects on the grounds that this request seeks information that is neither relevant to
these proceedings nor reasonably calculated to lead to the discovery of admissible evidence.
To the extent that Qwest has information responsive to this request, and subject to
objections, Qwest will supplement its response to this data request.
MCI-163 On a CLLI-code-specific basis in Idaho, please provide Qwest'current in-service
quantities for each of the following Qwest retail services: primary business voice
lines, primary residential voice lines, additional business voice lines, additional
residential voice lines, standalone DSL lines, Qwest DSL service provisioned in
the high frequency portion of a loop that also supports Qwest narrowband analog
voice service, CLEC DSL service provisioned in the high frequency portion of a
loop that also supports Qwest narrowband analog voice service, and CLEC DSL
service provisioned in the high frequency portion of a loop that also supports
(CLECJ narrowband analog voice service.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects to this request on the grounds that this data
request seeks information concerning DSL or broadband service that is not relevant or
reasonably calculated to lead to the discovery of admissible evidence. Qwest also objects on
the grounds that this request seeks information that is neither relevant to these proceedings
nor reasonably calculated to lead to the discovery of admissible evidence. Qwest noted in
its Notice of Scope of Docket that it is unable at this point to specifically define the markets
in which it will seek relief from unbundling obligations for switching for mass market
customers. Qwest intends to specifically define those market areas in its testimony to be
filed on January 19, 2004. Once those market areas are defined, all requested information
for CLLI codes and/or wire centers outside of those areas will be irrelevant in this docket.
Within a reasonable time after Qwest makes its proposed market definitions, Qwest will
respond to this request with relevant information to the extent any such information exists.
MCI-164 On a CLLI-code-specific basis in Idaho, please provide Qwest's expected , estimated
or forecasted demand growth or decline for each of the next three years for each
ofthe following Qwest retail services: primary business voice lines, primary
residential voice lines, additional business voice lines, additional residential voice
lines, standalone DSL lines, Qwest DSL service provisioned in the high frequency
portion of a loop that also supports Qwest narrowband analog voice service
CLEC DSL service provisioned in the high frequency portion of a loop that also
supports Qwest narrowband analog voice service, and CLEC DSL service
provisioned in the high frequency portion of a loop that also supports (CLEC)
narrowband analog voice service.
OBJECTION: Qwest objects to this data request on the grounds that it is vague,
ambiguous, overly broad and unduly burdensome. Qwest also objects to this request on
the grounds that this data request seeks information concerning DSL or broadband service
that is not relevant or reasonably calculated to lead to the discovery of admissible evidence.
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Boise-165130.10029164-00097
MCI-165 On a CLLI-code-specific basis in Idaho , please provide the Qwest's demand growth
or decline for each of the last three years for each of the following: a) UNE loops
used for circuit switched voice service, b) UNE loops used for DSL service
(including line split configurations), c) UNE-P residential local exchange service
d) UNE-P business local exchange service, e) resold QWEST business local
exchange service and t) resold QWEST residential local exchange service.
OBJECTION: Qwest objects to this data request on the grounds that it is vague,
ambiguous, overly broad and unduly burdensome. Qwest also objects to this request on
the grounds that this data request seeks information concerning DSL or broadband service
that is not relevant or reasonably calculated to lead to the discovery of admissible evidence.
Qwest also objects on the grounds that this request seeks information that is neither
relevant to these proceedings nor reasonably calculated to lead to the discovery of
admissible evidence. To the extent that Qwest has information responsive to this request
and subject to objections, Qwest will supplement its response to this data request.
MCI-166 On a CLLI-code-specific basis in Idaho, please provide the Qwest's current in-service
quantities for each of the followIng: a) UNE loops used for circuit switched voice
service, b) UNE loops used for DSL service (including line split configurations),
c) UNE-P residential local exchange service, d) UNE-P business local exchange
service, e) resold QWEST business local exchange service and t) resold QWEST
residential local exchange service.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects to this request on the grounds that this data
request seeks information concerning DSL or broadband service that is not relevant or
reasonably calculated to lead to the discovery of admissible evidence. Qwest also objects on
the grounds that this request seeks information that is neither relevant to these proceedings
nor reasonably calculated to lead to the discovery of admissible evidence. Qwest noted in
its Notice of Scope of Docket that it is unable at this point to specifically define the markets
in which it will seek relief from unbundling obligations for switching for mass market
customers. Qwest intends to specifically define those market areas in its testimony to be
filed on January 19, 2004. Once those market areas are defined, all requested information
for CLLI codes and/or wire centers outside of those areas will be irrelevant in this docket.
Within a reasonable time after Qwest makes its proposed market definitions, Qwest will
respond to this request with relevant information to the extent any such information exists.
MCI-167 On a CLLI-code-specific basis in Idaho, please provide the Qwest's expected
estimated or forecasted demand growth or decline for each of the next three years
for each of the following: a) UNE loops used for circuit switched voice service
b) UNE loops used for DSL service (including line split configurations), c) UNE-
P residential local exchange service, d) UNE-P business local exchange service
e) resold QWEST business local exchange service and t) resold QWEST
residential local exchange service.
OBJECTION: Qwest objects to this data request on the grounds that it is vague
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 70
Boise-165130.10029164-00097
ambiguous, overly broad and unduly burdensome. Qwest also objects to this request on
the grounds that this data request seeks information concerning DSL or broadband service
that is not relevant or reasonably calculated to lead to the discovery of admissible evidence.
Qwest also objects on the grounds that this request seeks information that is neither
relevant to these proceedings nor reasonably calculated to lead to the discovery of
admissible evidence.
MCI-168 Please provide all documents that address or assess the risk of stranded capacity on all
or any portion of Qwest' s existing network in Idaho.
OBJECTION: Qwest objects to this data request on the grounds that this request is overly
broad and unduly burdensome. Qwest also objects to this request to the extent it requests
information protected by the attorney client and/or attorney work product privileges.
Finally, Qwest objects to this request on the grounds that it seeks information that is not
relevant or reasonably calculated to lead to the discovery of admissible evidence.
MCI-169 Please provide all calculations and/or estimates in Qwest's custody or control of the
market demand elasticity for local exchange service in Idaho or regionwide
(Qwest 14 states (AZ, CO, ID, IA, MN, MT, NE, ND, NM, OR, SD, UT, WA
WY)J )J if Qwest is unable to provide Idaho-specific data, or at any geographic
level, if Qwest cannot provide either Idaho-specific or regionwide data, stated
separately for residential and business customers, if such separate calculations
and/or estimates exist. Please provide all supporting documentation for such
calculations and/or estimates.
OBJECTION: Qwest objects to this request on the grounds that this request is overly
broad, unduly burdensome and may require a special study. Also, Qwest objects to this
data request because the information it seeks is not relevant or reasonably calculated to
lead to the discovery of admissible evidence. Further, Qwest objects to this request on the
grounds that it seeks data concerning 14 states that is overly broad, unduly burdensome
and irrelevant to these proceedings.
MCI-170 Please provide all calculations and/or estimates in Qwest's custody or control of the
market demand elasticity for long distance service in Idaho or regionwide (Qwest
14 states (AZ, CO, ID, IA, MN, MT, NE, ND, NM, OR, SD, UT, WA, WY)J)J if
Qwest is unable to provide Idaho-specific data, or at any geographic level, if
Qwest cannot provide either Idaho-specific or regionwide data, stated separately
for residential and business customers, if such separate calculations and/or
estimates exist. Please provide all supporting documentation for such calculations
and/or estimates.
OBJECTION: Qwest objects to this request on the grounds that this request is overly
broad, unduly burdensome and may require a special study. Also, Qwest objects to this
data request because the information it seeks is not relevant or reasonably calculated to
lead to the discovery of admissible evidence. Further, Qwest objects to this request on the
grounds that it seeks data concerning 14 states that is overly broad, unduly burdensome
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 71
Boise-165130.10029164-00097
and irrelevant to these proceedings.
MCI-171 Please provide all calculations and/or estimates in Qwest's custody or control of the
market demand elasticity for broadband service (i., DSL) in Idaho or regionwide
(Qwest 14 states (AZ, CO, ID, IA, MN, MT, NE, ND, NM, OR, SD, UT, WA
WY)J )J if Qwest is unable to provide Idaho-specific data, or at any geographic
level, if Qwest cannot provide either Idaho-specific or regionwide data, stated
separately for residential and business customers, if such separate calculations
and/or estimates exist. Please provide all supporting documentation for such
calculations and/or estimates.
OBJECTION: Qwest objects to this request on the grounds that this request is overly
broad and unduly burdensome and that the information sought in the data request is not
relevant or reasonably calculated to lead to the discovery of admissible evidence. Qwest
also objects to this request on the grounds that this data request seeks information
concerning broadband service and is not relevant or reasonably calculated to lead to the
discovery of admissible evidence. Qwest objects to this request on the grounds that it seeks
data concerning 14 states that is overly broad, unduly burdensome and irrelevant to these
proceedings. Notwithstanding these objections, Qwest does not track this data.
MCI-172 Please provide all calculations and/or estimates in Qwest's custody or control of the
market demand elasticity for bundled local and long distance service in Idaho or
regionwide (Qwest 14 states (AZ, CO, ID, IA, MN, MT, NE, ND, NM, OR, SD
, W A, WY) J ) J if Qwest is unable to provide Idaho-specific data, or at any
geographic level, if Qwest cannot provide either Idaho-specific or regionwide
data, stated separately for residential and business customers, if such separate
calculations and/or estimates exist. Please provide all supporting documentation
for such calculations and/or estimates.
OBJECTION: Qwest objects to this request on the grounds that this request is overly
broad, unduly burdensome and may require a special study. Also, Qwest objects to this
data request because the information it seeks is not relevant or reasonably calculated to
lead to the discovery of admissible evidence. Further, Qwest objects to this request on the
grounds that it seeks data concerning 14 states that is overly broad, unduly burdensome
and irrelevant to these proceedings.
MCI-173 Please provide all calculations and/or estimates in Qwest's custody or control of the
market demand elasticity for bundled local. long distance, and broadband service
(i., DSL) in Idaho or regionwide (Qwest 14 states (AZ, CO, ID, IA, MN, MT
, ND, NM, OR, SD, UT, WA, WY)J)J if Qwest is unable to provide Idaho-
specific data, or at any geographic level, if Qwest cannot provide either Idaho-
specific or regionwide data, stated separately for residential and business
customers, if such separate calculations and/or estimates exist. Please provide all
supporting documentation for such calculations and/or estimates.
OBJECTION: Qwest objects to this request on the grounds that this request is overly
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 72
Boise-165130.10029164-00097
broad, unduly burdensome and may require a special study. Qwest also objects to this
request on the grounds that this data request seeks information concerning broadband
service and is not relevant or reasonably calculated to lead to the discovery of admissible
evidence. Also, Qwest objects to this data request because the information it seeks is not
relevant or reasonably calculated to lead to the discovery of admissible evidence. Further
Qwest objects to this request on the grounds that it seeks data concerning 14 states that is
overly broad, unduly burdensome and irrelevant to these proceedings.
MCI-174 Please define the following terms, as Qwest understands and uses them in Idaho, and
whether Qwest's definition these terms is the same as those found in the Idaho
PUC's Costing and Pricing Rules found at 4 CCR 723-30 and the Idaho PUC'
decisions in Docket Nos. 96A-331 T and 97 A-577T defining total element long
run incremental costs ("TELRIC") and distinguish each defined term from all of
the others on this list:
(a) variable cost
(b) sunk cost
(c) marginal cost
(d) incremental service incremental cost
(e) Total Service Long Run Incremental Costs ("TSLRIC"
(f) TELRIC.
OBJECTION: Qwest objects to this request on the grounds that it seeks legal analysis
and/or conclusions. Qwest also objects because the request makes assumptions that are
contrary to fact, i.e. that the Idaho Commission has adopted "Costing and Pricing Rules
and that it has entered decisions in "Docket Nos. 96A-331T and 97-577T.
MCI-175 Please provide Qwest's calculation and/or estimate of its variable costs for providing
local exchange service in Idaho or regionwide (Qwest 14 states (AZ, CO, ID, IA
, MT, NE, ND, NM, OR, SD, UT, WA, WY)J if Qwest is unable to provide
Idaho-specific data, stated separately for residential and business customers, if
such separate calculations and/or estimates exist. Please provide all supporting
documentation for such calculations and/or estimates.
OBJECTION: Qwest objects to this request on the grounds that this request is overly
broad and unduly burdensome and that the information sought in the data request is not
relevant or reasonably calculated to lead to the discovery of admissible evidence. Qwest
also objects to this request on the grounds that it does not track this data and that it would
require a special study to produce such information. Qwest objects to this request on the
grounds that it seeks data concerning 14 states that is overly broad, unduly burdensome
and irrelevant to these proceedings.
MCI-176 Please provide Qwest's calculation and/or estimate of its marginal costs for providing
local exchange service in Idahp or regionwide (Qwest 14 states (AZ, CO, ID, IA
, MT, NE, ND, NM, OR, SD, UT, WA, WY)J if Qwest is unable to provide
Idaho-specific data, stated separately for residential and business customers, if
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 73
Boise-165130.10029164-00097
such separate calculations and/or estimates exist. Please provide all supporting
documentation for such calculations and/or estimates.
OBJECTION: Qwest objects to this request on the grounds that this request is overly
broad and unduly burdensome and that the information sought in the data request is not
relevant or reasonably calculated to lead to the discovery of admissible evidence. Qwest
also objects to this request on the grounds that it does not track this data and that it would
require a special study to produce such information. Qwest objects to this request on the
grounds that it seeks data concerning 14 states that is overly broad, unduly burdensome
and irrelevant to these proceedings.
MCI-177 Please provide Qwest's calculation and/or estimate of its variable costs for providing
long distance service in Idaho or regionwide (Qwest 14 states (AZ, CO, ID, IA
, MT, NE, ND, NM, OR, SD, UT, W A, WY)J if Qwest is unable to provide
Idaho-specific data, stated separately for residential and business customers, if
such separate calculations and/or estimates exist. Please provide all supporting
documentation for such calculations and/or estimates.
OBJECTION: Qwest objects to this request on the grounds that this request is overly
broad and unduly burdensome and that the information sought in the data request is not
relevant or reasonably calculated to lead to the discovery of admissible evidence. Qwest
also objects to this request on the grounds that it does not track this data and that it would
require a special study to produce such information. Qwest objects to this request on the
grounds that it seeks data concerning 14 states that is overly broad, unduly burdensome
and irrelevant to these proceedings.
MCI-178 Please provide Qwest's calculation and/or estimate of its marginal costs for providing
long distance service in Idaho or regionwide (Qwest 14 states (AZ, CO, ill, IA
, MT, NE, ND, NM, OR, SD, UT, WA, WY)J if Qwest is unable to provide
Idaho-specific data, stated separately for residential and business customers, if
such separate calculations and/or estimates exist. Please provide all supporting
documentation for such calculations and/or estimates.
OBJECTION: Qwest objects to this request on the grounds that this request is overly
broad and unduly burdensome and that the information sought in the data request is not
relevant or reasonably calculated to lead to the discovery of admissible evidence. Qwest
also objects to this request on the grounds that it does not track this data and that it would
require a special study to produce such information. Qwest objects to this request on the
grounds that it seeks data concerning 14 states that is overly broad, unduly burdensome
and irrelevant to these proceedings.
MCI-179 Please provide Qwest's calculation and/or estimate of its variable costs for providing
broadband service (i.e. DSL) in Idaho or regionwide (Qwest 14 states (AZ, CO
, IA, MN, MT, NE, ND, NM, OR, SD, UT, W A, WY)J if Qwest is unable to
provide Idaho-specific data, stated separately for residential and business
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 74
Boise-165130.10029164-00097
customers, if such separate calculations and/or estimates exist. Please provide all
supporting documentation for such calculations and/or estimates.
OBJECTION: Qwest objects to this request on the grounds that this request is overly
broad and unduly burdensome and that the information sought in the data request is not
relevant or reasonably calculated to lead to the discovery of admissible evidence. Qwest
also objects to this request on the grounds that it does not track this data and that it would
require a special study to produce such information. Qwest also objects to this request on
the grounds that this data request seeks information concerning broadband service and is
not relevant or reasonably calculated to lead to the discovery of admissible evidence.
Qwest objects to this request on the grounds that it seeks data concerning 14 states that is
overly broad, unduly burdensome and irrelevant to these proceedings.
Mcr-180 Please provide Qwest's calculation and/or estimate of its marginal costs for providing
broadband service (i.e. DSL) in Idaho or regionwide (Qwest 14 states (AZ, CO
, IA, MN, MT, NE, ND, NM, OR, SD, UT, WA, WY)J if Qwest is unable to
provide Idaho-specific data, stated separately for residential and business
customers, if such separate calculations and/or estimates exist. Please provide all
supporting documentation for such calculations and/or estimates.
OBJECTION: Qwest objects to this request on the grounds that this request is overly
broad and unduly burdensome and that the information sought in the data request is not
relevant or reasonably calculated to lead to the discovery of admissible evidence. Qwest
also objects to this request on the grounds that it does not track this data and that it would
require a special study to produce such information. Qwest also objects to this request on
the grounds that this data request seeks information concerning broadband service and is
not relevant or reasonably calculated to lead to the discovery of admissible evidence.
Qwest objects to this request on the grounds that it seeks data concerning 14 states that is
overly broad, unduly burdensome and irrelevant to these proceedings.
MCI-181 Please provide Qwest's calculation and/or estimate of its variable costs for providing
bundled local exchange and long distance service in Idaho or regionwide (Qwest
14 states (AZ, CO, ID, lA, MN, MT, NE, ND, NM, OR, SD, UT, W A, WY)J if
Qwest is unable to provide Idaho-specific data, stated separately for residential
and business customers, if such separate calculations and/or estimates exist.
Please provide all supporting documentation for such calculations and/or
estimates.
OBJECTION: Qwest objects to this request on the grounds that this request is overly
broad and unduly burdensome and that the information sought in the data request is not
relevant or reasonably calculated to lead to the discovery of admissible evidence. Qwest
also objects to this request on the grounds that it does not track this data and that it would
require a special study to produce such information. Qwest objects to this request on the
grounds that it seeks data concerning 14 states that is overly broad, unduly burdensome
and irrelevant to these proceedings.
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 75
Boise-165130.10029164-00097
MCI-182 Please provide Qwest's calculation and/or estimate of its marginal costs for providing
bundled local exchange and long distance service in Idaho or regionwide (Qwest
14 states (AZ, CO, ID, IA, MN, MT, NE, ND, NM, OR, SD, UT, W A, WY)J if
Qwest is unable to provide Idaho-specific data, stated separately for residential
and business customers, if such separate calculations and/or estimates exist.
Please provide all supporting documentation for such calculations and/or
estimates.
OBJECTION: Qwest objects to this request on the grounds that this request is overly
broad and unduly burdensome and that the information sought in the data request is not
relevant or reasonably calculated to lead to the discovery of admissible evidence. Qwest
also objects to this request on the grounds that it does not track this data and that it would
require a special study to produce such information. Qwest objects to this request on the
grounds that it seeks data concerning 14 states that is overly broad, unduly burdensome
and irrelevant to these proceedings.
MCI-183 Please provide Qwest's calculation and/or estimate of its variable costs for providing
bundled local exchange, long distance and broadband service in Idaho or
regionwide (Qwest 14 states (AZ, CO, ID, IA, MN, MT, NE, ND, NM, OR, SD
, W A, WY) J if Qwest is unable to provide Idaho-specific data, stated
separately for residential and business customers, if such separate calculations
and/or estimates exist. Please provide all supporting documentation for such
calculations and/or estimates.
OBJECTION: Qwest objects to this request on the grounds that this request is overly
broad and unduly burdensome and that the information sought in the data request is not
relevant or reasonably calculated to lead to the discovery of admissible evidence. Qwest
also objects to this request on the grounds that it does not track this data and that it would
require a special study to produce such information. Qwest also objects to this request on
the grounds that this data request seeks information concerning broadband service and is
not relevant or reasonably calculated to lead to the discovery of admissible evidence.
Qwest objects to this request on the grounds that it seeks data concerning 14 states that is
overly broad, unduly burdensome and irrelevant to these proceedings.
MCI-184 Please provide Qwest's calculation and/or estimate of its marginal costs for providing
bundled local exchange, long distance and broadband service in Idaho or
regionwide (Qwest 14 states (AZ, CO, ID, IA, MN, MT, NE, ND, NM, OR, SD
, W A, WY) J if Qwest is unable to provide Idaho-specific data, stated
separately for residential and business customers, if such separate calculations
and/or estimates exist. Please provide all supporting documentation for such
calculations and/or estimates.
OBJECTION: Qwest objects to this request on the grounds that this request is overly
broad and unduly burdensome and that the information sought in the data request is not
relevant or reasonably calculated to lead to the discovery of admissible evidence. Qwest
also objects to this request on the grounds that it does not track this data and that it would
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require a special study to produce such information. Qwest also objects to this request on
the grounds that this data request seeks information concerning broadband service and
not relevant or reasonably calculated to lead to the discovery of admissible evidence.
Qwest objects to this request on the grounds that it seeks data concerning 14 states that is
overly broad, unduly burdensome and irrelevant to these proceedings.
MCI-185 Please state whether Qwest has any affiliates or subsidiaries that provide local
exchange voice services, long distance voice services and/or DSL services in
Idaho. If the response for any of these services is affirmative, please provide the
full name of the affiliate or subsidiary and a list of the service(s) provided by the
affiliate or subsidiary.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence. Qwest also objects to this request on the grounds that this data
request seeks information concerning affiliates and subsidiaries, and DSL service, which is
not relevant or reasonably calculated to lead to the discovery of admissible evidence.
MCI-186 Please provide a copy of each executed contract (including attachments and/or
amendments) between Qwest and a long distance carrier that Qwest uses to
provide inter-LATA toll services and/or facilities.
OBJECTION: Qwest objects to this request on the grounds that this request is overly
broad and unduly burdensome. Qwest also objects to this request on the grounds that the
information sought in the data request is not relevant or reasonably calculated to lead to
the discovery of admissible evidence.
MCI-187 With respect to each contract requested in MCI-186, please provide the total minutes
of use, and/or total transport capacity purchased, as well as the total dollar amount
paid for such minutes of use and/or transport capacity, stated on a quarterly basis
for the past three years.
OBJECTION: Qwest objects to this request on the grounds that this request is overly
broad and unduly burdensome. Qwest also objects to this request on the grounds that the
information sought in the data request is not relevant or reasonably calculated to lead to
the discovery of admissible evidence.
MCI-188 Please provide all calculations or estimates in Qwest's custody or control of Qwest'
current total and component (e., debt, preferred stock, equity, etc.) cost of
capital, in Idaho or regionwide (Qwest 14 states (AZ, CO, ID, IA, MN, MT, NE
, NM, OR, SD, UT, WA, WY)J if Qwest is unable to provide Idaho-specific
data, based on each of the following: a) market capital structure, b) book capital
structure, and c) target capital structure. Please provide supporting
documentation, including the documents relied upon to answer this question.
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OBJECTION: Qwest objects to this request on the grounds that this request is overly
broad, unduly burdensome, vague and ambiguous. Qwest also objects to this request on
the grounds that the information sought in the data request is not relevant or reasonably
calculated to lead to the discovery of admissible evidence. Qwest objects to this request on
the grounds that it seeks data concerning 14 states that is overly broad, unduly
burdensome and irrelevant to these proceedings.
MCI-189 With respect to the cost of capital calculations or estimates requested in MCI-188
please provide such calculations or estimates for Qwest's major types of service
at the most granular level available, including the following: a) residential local
exchange service, b) business local exchange service, c) long distance service, d)
DSL service and e) unbundled network elements (UNEs). Please provide
supporting documentation, including the documents relied upon to answer this
question.
OBJECTION: Qwest objects to this request on the grounds that this request is overly
broad, unduly burdensome, vague and ambiguous. Qwest also objects to this request on
the grounds that the information sought in the data request is not relevant or reasonably
calculated to lead to the discovery of admissible evidence. Qwest also objects to that
portion of this request that seeks information concerning DSL service which is not relevant
or reasonably calculated to lead to the discovery of admissible evidence.
MCI-190
MCI-191
Please describe in detail the approach and manner in which Qwest segments its sales
and marketing efforts and personnel on the basis of customer size, type (e.
residential, small business, medium business, large business), monthly level of
revenues, and/or service(s) taken by customer (individually or as part of a
bundle), and provide the basis on which such segmentation is made.
Please describe in detail any legal, regulatory or other constraints on Qwest's ability
to target price reductions 1) to specific geographic areas, and 2) to types of
customers (including individual customers), for each of the following: a) business
local exchange service, b) residential local exchange service, c) long distance
service and d) DSL service.
OBJECTION: Qwest objects to this request on the grounds that this request is overly
broad, unduly burdensome, vague and ambiguous. Qwest also objects to this request on
the grounds that the information sought in the data request is not relevant or reasonably
calculated to lead to the discovery of admissible evidence. Without waiving these
objections, Qwest is investigating whether it has information responsive to this request and
will supplement this response to the extent such information exists.
MCI-192 Please describe in detail any price floors imposed by any law, regulation, Idaho PUC
orders or rulings that constrain Qwest's ability to reduce prices for each of the
following: a) business local exchange service, b) residential local exchange
service, c) long distance service and d) DSL service. For each such price floor
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provide the basis for the calculation for the price floor (e., price freeze, cost-
based calculation, etc.
OBJECTION: Qwest objects to this request on the grounds that it improperly seeks legal
analysis or conclusions. Qwest also objects to that portion of this request that seeks
information concerning DSL service which is not relevant or reasonably calculated to lead
to the discovery of admissible evidence.
MCI-193 Please provide average total revenue for each Qwest wire center in Idaho.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects on the grounds that this request seeks
information that is neither relevant to these proceedings nor reasonably calculated to lead
to the discovery of admissible evidence. Qwest is unable at this point to specifically define
the markets in which it will seek relief from unbundling obligations for switching for mass
market customers. Qwest intends to specifically define those market areas in its testimony
to be filed on January 19, 2004. Once those market areas are defined, all requested
information for CLLI codes and/or wire centers outside of those areas will be irrelevant in
this docket. Within a reasonable time after Qwest makes its proposed market definitions,
Qwest will respond to this request with relevant information to the extent any such
information exists.
MCI-194 For each CLLI code in Idaho, please provide for the most recent period available (1)
the underlying data Qwest used to provide the Idaho-statewide data found in
Table II and Table III of the most recently filed FCC ARMIS Report 43-08; (2)
the number of switched DS-l lines/loops in service when Qwest filed its most
recently filed FCC ARMIS Report 43-08; (2) the number of non-switched DS-
lines/loops in service when Qwest filed its most recently filed FCC ARMIS
Report 43-08; and (4) the number ofDS-3 lines/loops in service when Qwest filed
its most recently filed FCC ARMIS Report 43-08.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects to that portion of the request that seeks
information concerning DS-l and above loops which is not relevant or reasonably
calculated to lead to the discovery of admissible evidence. Qwest also objects on the
grounds that this request seeks information that is neither relevant to these proceedings
nor reasonably calculated to lead to the discovery of admissible evidence. Qwest noted in
its Notice of Scope of Docket that it is unable at this point to specifically define the markets
in which it will seek relief from unbundling obligations for switching for mass market
customers. Qwest intends to specifically define those market areas in its testimony to be
filed on January 19, 2004. Once those market areas are defined, all requested information
for CLLI codes and/or wire centers outside of those areas will be irrelevant in this docket.
Within a reasonable time after Qwest makes its proposed market definitions, Qwest will
respond to this request with relevant information to the extent any such information exists.
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MCI-195 For each CLLI code in Idaho, please provide the most current monthly average
revenues per line for (1) residential voice-only customers; (2) residential voice
plus DSL customers; (3) business DS-O/voice grade customers; (4) business DS-
customers; for local service, vertical features, and voice mail. For customers in
each of these four categories who also subscribe to Qwest long distance service
provide the current monthly average long distance revenues per line.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects to that portion of the request that seeks
information concerning DSL and DS-l and above loops which is not relevant or reasonably
calculated to lead to the discovery of admissible evidence. Qwest also objects on the
grounds that this request seeks information that is neither relevant to these proceedings
nor reasonably calculated to lead to the discovery of admissible evidence. Qwest noted in
its Notice of Scope of Docket that it is unable at this point to specifically define the markets
in which it will seek relief from unbundling obligations for switching for mass market
customers. Qwest intends to specifically define those market areas in its testimony to be
filed on January 19,2004. Once those market areas are defined, all requested information
for CLLI codes and/or wire centers outside of those areas will be irrelevant in this docket.
Within a reasonable time after Qwest makes its proposed market definitions, Qwest will
respond to this request with relevant information to the extent any such information exists.
QWEST UNE TRANSPORT IMPAIRMENT ISSUES
MCI 195A Does Qwest intend to present a case to remove any transport routes that it
contends should be removed from the list of available DS-l UNEs pursuant
to FCC Rules 951.319( e )(1 )(ii) (existence of competitive wholesale facilities
If the answer to Question 195A is ", do not respond to Questions MCI-196
through MCI-231 , and skip to Question MCI-231A.
OBJECTION: Qwest objects to data requests MCI 195A through 231 because these
requests seek data that is not relevant or reasonably calculated to lead to the discovery of
admissible evidence. Qwest is not challenging the national findings of impairment with
respect to route specific dedicated transport in these proceedings.
MCI-196 Please list each and every transport route which you contend should be removed from
the list of available DS-l UNEs pursuant to FCC Rules 951.319(e)(I)(ii)
(existence of competitive wholesale facilities. J For each listed route, please list:
a) the CLLI code identifications of the endpoints; b) the identities of each claimed
alternative competitive provider.
MCI-197 For each alternative competitive provider listed in your response to MCI-196, indicate
whether it is an "affiliate" (as defined in 47 USC 9153(1)) of Qwest or of any
other listed alternative competitive provider.
MCI-198 For each route listed in your response to MCI-196, please provide the following
information:
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MCI-199
(a) The type of terminating facility (e., collocation) used at each end of the
route and a copy of the authority by which that facility is governed (i., tariff
pages, collocation contract, or interconnection agreement.)
(b) The exact route of each claimed alternative facility, including the owner of
each facility segment, its date of installation and date of initial operation, the
nature of the alternative competitive provider s ownership/occupancy rights
(i.
, "
fee simple ownership
, "
IRU", etc.), and the identity of any underlying
owners or interest holders in the facility.
(c) Any and all documents you have that state that each claimed alternative
competitive provider is willing immediately to provide, on a widely available
basis, dedicated DS 1 transport along the particular route.
(d) The terms, including copies of any governing documents, by which requesting
telecommunications carriers are able to obtain reasonable and
nondiscriminatory access through cross connection to the facilities of the
alternative competitive provider.
Please list each and every transport route which you contend should be removed from
the list of available DS-3 UNEs pursuant to FCC Rules ~51.319( e )(2)(i)(A)
(existence of alternative self-provisioned facilities. J For each listed route, please
list: a) the CLLI code identifications of the endpoints; b) the identities of each
claimed alternative competitive provider.
MCI-200 For each alternative competitive provider listed in your response to MCI-199, indicate
whether it is an "affiliate" (as defined in 47 USC ~153(1)) of Qwest or of any
other listed alternative competitive provider.
MCI-20l
MCI-202
For each route listed in your response to MCI-199, please provide the following
information:
(a) The type of terminating facility (i., collocation) used at each end and a copy
of the authority by which that facility is governed (i., tariff pages
collocation contract, or interconnection agreement.)
(b) The exact route of each claimed alternative facility, including the owner of
each facility segment, its date of installation and date of initial operation, the
nature of the alternative competitive provider s ownership/occupancy rights
(i.
, "
fee simple ownership
, "
IRU", etc.), and the identity of any underlying
owners or interest holders in the facility.
(c) Any and all documents you have that state that each claimed alternative
competitive provider is operationally ready to use the listed transport facilities
to provide dedicated DS-3 transport along the particular route.
Please list each and every transport route which you contend should be removed from
the list of available DS-3 UNEs pursuant to FCC Rules ~51.319( e )(2)(i)(B)
(existence of competitive wholesale facilities. J For each listed route, please list:
a) the CLLI code identifications of the endpoints; b) the identities of each claimed
alternative competitive provider.
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MCI-203 For each alternative competitive provider listed in your response to MCI-202, indicate
whether it is an "affiliate" (as defined in 47 USC g 153(1)) of Qwest or of any
other listed alternative competitive provider.
MCI-204
MCI.205
MCI-206
MCI-207
For each route listed in your response to MCI-202, please provide the following
information:
(a) The type of terminating facility (i., collocation) used at each end and a copy
of the authority by which that facility is governed (i., tariff pages
collocation contract, or interconnection agreement.)
(b) The exact route of each claimed alternative facility, including the owner of
each facility segment, its date of installation and date of initial operation, the
nature of the alternative competitive provider s ownership/occupancy rights
(i.
, "
fee simple ownership
, "
IRU", etc.), and the identity of any underlying
owners or interest holders in the facility.
(c) Any and all documents you have that state that each claimed alternative
competitive provider is willing immediately to provide, on a widely available
basis, dedicated DS-3 transport along the particular route.
(d) The terms, including copies of any governing documents, by which requesting
telecommunications carriers are able to obtain reasonable and
nondiscriminatory access through cross connection to the facilities of the
alternative competitive provider.
Please list each and every transport route which you contend should be removed from
the list of available DS-3 UNEs pursuant to FCC Rules g51.319(e)(2)(ii)
(potential deployment of alternative facilities.J For each listed route, please list:
a) the CLLI code identifications of the endpoints; b) the identities of any
identified alternative competitive provider.
For each route listed in your response to MCI-205, please provide copies of all
information in your possession relating to:
(a) local engineering costs of building and utilizing transmission facilities
(b) the cost of underground or aerial laying of fiber or copper;
(c) the cost of equipment needed for transmission; installation and other
necessary costs involved in setting up service;
(d) relevant local topography such as hills and rivers;
(e) availability of reasonable access to rights-of-way;
(f) availability/feasibility of similar quality/reliability alternative transmission
technologies along the particular route;
(g) customer density and addressable market; and
(h) existing facilities-based competition.
For each alternative competitive provider listed in your response to MCI-205 and for
each provider of any existing facilities-based competition listed in your response
to MCI-206(h), indicate whether it is an "affiliate" (as defined in 47 USC
g 153(1)) of Qwest or of any other listed alternative competitive provider.
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MCI-208 Please list each and every transport route which you contend should be removed from
the list of available Dark Fiber UNEs pursuant to FCC Rules 951.319( e )(3)(i)(A)
( existence of alternative self-provisioned facilities. J For each listed route, please
list: a) the CLLI code identifications of the endpoints; b) the identities of each
claimed alternative competitive provider.
MCI-209 For each alternative competitive provider listed in your response to MCI-208, indicate
whether it is an "affiliate" (as defined in 47 USC 9153(1)) of Qwest or of any
other listed alternative competitive provider.
MCI-210
MCI-211
For each route listed in your response to MCI-208, please provide the following
information:
(a) The type of terminating facility (i., collocation) used at each end and a copy
of the authority by which that facility is governed (i., tariff pages
collocation contract, or interconnection agreement.
(b) The exact route of each claimed alternative facility, including the owner of
each facility segment, its date of installation and date of initial operation, the
nature of the alternative competitive provider s ownership/occupancy rights
(i.
, "
fee simple ownership
, "
IRU", etc.), and the identity of any underlying
owners or interest holders in the facility.
(c) Any and all documents you have that state that each claimed alternative
competitive provider is operationally ready to use the listed transport facilities
to provide dedicated Dark Fiber transport along the particular route.
Please list each and every transport route which you contend should be removed from
the list of available Dark Fiber UNEs pursuant to FCC Rules 951.319(e)(3)(i)(B)
(existence of competitive wholesale facilities. J For each listed route, please list:
a) the CLLI code identifications of the endpoints; b) the identities of each claimed
alternative competitive provider.
MCI-212 For each alternative competitive provider listed in your response to MCI-211 , indicate
whether it is an "affiliate" (as defined in 47 USC 9153(1)) of Qwest or of any
other listed alternative competitive provider.
MCI-213 For each route listed in your response to MCI-211 , please provide the following
information:
(a) The type of terminating facility (i., collocation) used at each end and a copy of
the authority by which that facility is governed (i., tariff pages, collocation
contract, or interconnection agreement.)
(b) The exact route of each claimed alternative facility, including the owner of each
facility segment, its date of installation and date of initial operation, the nature of
the alternative competitive provider s ownership/occupancy rights (i.
, "
fee
simple ownership
, "
IRU", etc.), and the identity of any underlying owners or
interest holders in the facility.
(c) Any and all documents you have that state that each claimed alternative
competitive provider is willing immediately to provide, on a widely available
basis, dedicated Dark Fiber transport along the particular route.
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MCI-214
MCI-215
MCI-216
MCI-217
MCI-218
(d) The terms, including copies of any governing documents, by which requesting
telecommunications carriers are able to obtain reasonable and
nondiscriminatory access through cross connection to the facilities of the
alternative competitive provider.
Please list each and every transport route which you contend should be removed from
the list of available Dark Fiber UNEs pursuant to FCC Rules 95l.319( e )(3)(ii)
(potential deployment of alternative facilities.J For each listed route, please list:
a) the CLLI code identifications of the endpoints; b) the identities of any
identified alternative competitive provider.
For each route listed in your response to MCI-214, please provide copies of all
information in your possession relating to:
(a) local engineering costs of building and utilizing transmission facilities;
(b) the cost of underground or aerial laying of fiber or copper;
(c) the cost of equipment needed for transmission; installation and other
necessary costs involved in setting up service;
(d) relevant local topography such as hills and rivers;
(e) availability of reasonable access to rights-of-way;
(f) availability/feasibility of similar quality/reliability alternative transmission
technologies along the particular route;
(g) customer density and addressable market; and
(h) existing facilities-based competition.
For each alternative competitive provider listed in your response to MCI-214 and for
each provider of any existing facilities-based competition listed in your response
to MCI-215(h), indicate whether it is an "affiliate" (as defined in 47 USC
9153(1)) of Qwest or of any other listed alternative competitive provider.
Please describe and provide supporting documents for any state or locally enacted or
enforced barriers to entry by competing providers ofDS-, DS-, OC-n, or Dark
Fiber transport, including, but not limited to, any moratoria or restrictions on
construction or access to rights of way. Include all relevant legal provisions and a
description of any Qwest deployment or construction projects which have been
undertaken since the enactment of the restriction or moratoria. Describe the steps
taken or qualifications met in order for the identified Qwest projects to either
comply with or avoid the effects of the restriction or moratoria.
For each route identified in your responses to MCI-196 through MCI-2l4, please
provide the following information:
(a) All forecasts of Qwest expected, estimated, anticipated, or forecasted demand
growth or decline for all classes of transport service. To the extent you have
information disaggregated by type of customer or demand (e.
, "
business
data
, "
UNE"
, "
special access , or other categories) please provide such
disaggregated figures. To the extent different documents may provide differing
figures, estimates, or forecasts based upon the impact or implementation of any
regulatory or judicial action (including, but not limited to, the Triennial Review
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MCI-219
MCI-220
MCI-221
Order and related proceedings) provide all such figures, estimates, and forecasts
identifying which relate to which different regulatory or judicial outcomes;
(b) Qwest's current transport capacity utilization , including total number and type of
fibers or copper cabling
(c) number of "unlit" or "dark" fibers;
(d) number of "lit" fibers with the current operational level implemented for each
(i., which OC level);
(e) current utilization of copper wire, if any, including identification and capacity of
implemented digital and analog transmission capability
(f) identification of unused copper facilities, if any.
Please provide the following information for each fiber or conduit deployment project
by Qwest in Idaho since January 2000:
(a) type, size, and capacity of conduit installed along all or any separate portion
of the route;
(b) type and number of fibers initially installed along all or any separate portion
of the route
(c) type and number of fibers for each and every subsequent installation along all
or any portion of the route;
(d) all available budgetary and actual cost data for both initial and any subsequent
installations, including all costs for permits, authority, ROW, lobbying, public
policy, excavation, trenching, boring, backfill, surface repair, remediation
vault construction, termination, payments-in-kind, related usage rights
materials (including conduit and cabling), and any other expenses necessary
to the proj ect.
Please provide the following information for each planned fiber or conduit
deployment project by Qwest in Idaho for the next 3 years: (Include in this
response any current projects not included in MCI-219, as well as future projects.
(a) type, size, and capacity of conduit to be installed along all or any separate portion
of the route;
(b) type and number of fibers to be initially installed along all or any separate portion
of the route
(c) type and number of fibers for each and every planned subsequent installation
along all or any portion of the route;
(d) all available budgetary cost data and estimates for both initial and any subsequent
installations, including all costs and estimates for permits, authority, ROW
lobbying, public policy, excavation, trenching, boring, backfill, surface repair
remediation, vault construction, termination, payments-in-kind, related usage
rights, materials (including conduit and cabling), and any other expenses
necessary to the project.
Please provide copies of contracts, agreements, tariffs, or other governing documents
by which Qwest:
(a) sells, rents, leases, or otherwise provides telecommunications transport services
between its switches and/or wire centers to others in Idaho;
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 85
Boise-165130.1 0029164-00097
(b) buys, rents, leases, or otherwise acquires telecommunications transport services
between its switches and/or wire centers from others in Idaho.
MCI-222 With respect to all documents identified in your response to (d), please provide
quarterly totals for the last 3 years of the amount of transport capacity provided or
acquired, identifying the quantity, route, and opposite party for each segment.
MCI-223 Please describe in detail any price floors or other limitation imposed by any law
regulation, Idaho PUC orders or rulings that constrain Qwest's ability to reduce
prices for each ofthe following: a) dark fiber service, b) OC-n level service, c)
DS-3 service and d) DS-l service. For each such price floor or other limitation
provide the basis for the calculation for the price floor or other limitation (e.
price freeze, cost-based calculation, etc.
MCI-224 Please provide a description and supporting documentation for all Qwest currently
offered bundles and volume discounts involving the following: a) dark fiber
service, b) OC-n level service, c) DS-3 service and d) DS-l service.
MCI-225 Please provide a description and supporting documentation for all Qwest planned or
contemplated bundles and volume discounts involving the following: a) dark
fiber service, b) OC-n level service, c) DS-3 service and d) DS-l service.
MCI-226 Please provide all documents that address or assess the risk of stranded transport
capacity on all or any portion of Qwest' s existing network in Idaho.
MCI-227
MCI-228
For this and the immediately following four questions, the phrase "lit enterprise
circuit(s)" means one or more circuits at the DS-, DS-, or OC-x capacity levels.
Please describe all your current procedures for moving portions of lit enterprise
circuits from your own network to a CLEC or IXC network. Include all
procedures for circuits which serve multiple end-users by virtue of connection to
multiple Qwest "tail circuits" or "loops" via Qwest provided MUX or DACS
equipment.
When a lit enterprise circuit provided by Qwest under UNE procedures or Special
Access tariffs serves multiple end-user customers through Qwest provided MUX
or DACS equipment, will Qwest perform a "hot cut" of all or part of the lit
enterprise circuit portion to non-Qwest provided transport?
(a) Ifno, why not?
(b) If yes, will Qwest perform this function based on a single Access Service Request
ASR") submission by the carrier customer or does Qwest require multiple
ASRs? If the answer is that a single ASR is acceptable, please identify any prior
periods when multiple ASRs were required.
MCI-229 As part of any required transition from UNE enterprise circuit transport to non-Qwest
transport, will Qwest perform a "hot cut" of all or part of any lit enterprise circuit
portion to non-Qwest provided transport?
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MCI-230
MCI-231
MCI-231A
(a) Ifno, why not?
(b) If yes, will Qwest perform this function based on a single service request, or
will Qwest require separate requests for each end-user circuit?
Has Qwest ever imposed restrictions on the number of lit enterprise circuits it would
transition from the Qwest network to the networks of others? If yes, state all such
restrictions imposed and all terms of such restrictions (i., any specifics as to
numbers of such transitions within a specific time and/or region; conditions as to
time "out of service ; any required impositions of unfavorable customer
conditions; any mandatory classification of any such transition as "project work"
( or other non-standard undertakingJ thereby changing or avoiding any otherwise
applicable service guarantees, performance standards, or terms ensuring quality of
service, etc.
Please produce all internal methods & procedures, business rules, memoranda
communications, e-mail, reports, etc. which describe in any way issues related to
the migration of lit enterprise circuits or circuit portions from the Qwest network
to any non-Qwest network. In addition, if not already encompassed in the prior
sentence, include all such documents which discuss any potential means of
discouraging such moves, or any complaints or comments received relating to
procedures used to undertake such moves, or any refusals of such moves.
QWEST ENTERPRISE UNE LOOP IMPAIRMENT ISSUES
Does Qwest intend to present a case to remove any customer location which it
contends should be removed from the list of available DS-l UNE loop
destinations pursuant to FCC Rules ~51.319( a)( 4)(ii) (existence of competitive
wholesale facilitiesJ? If the answer to Question 231A is ", do not respond to
Questions MCI-232 through MCI-263.
OBJECTION: Qwest objects to data requests MCI-231A through 263 because these
requests seek data that is not relevant or reasonably calculated to lead to the discovery of
admissible evidence. Qwest is not challenging the national findings of impairment with
respect to high capacity loops in these proceedings.
MCI-232 Please state the proportion of "unlit" or "dark" fiber in loop feeder and distribution
plant a) for each of the last 3 years; b) currently; and c) all projections for the next
3 years.
MCI-233 Please state the "OCn" level(s) at which fiber in the loop feeder and distribution plant
has been, is being, or will be operated:
(a) for each ofthe last 3 years;
(b) currently; and
(c) all projections for the next 3 years.
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 87
Boise-165130.1 0029164-00097
MCI-234
MCI-235
MCI-236
Please describe and supply supporting documentation for any change in the last three
years, and any change currently in progress, in deployment plans or schedules
which would tend to either a) lower or reduce the future transmission ("OCn
level of any fiber in the loop feeder and/or distribution plant; b) reduce any
expected, anticipated, or planned increases in the future transmission ("OCn
level of any fiber in the loop feeder and/or distribution plant; c) increase the
number of fibers used at any point in the loop feeder and/or distribution plant; or
d) reduce the number of "unlit" fibers available for provision of "dark fiber" to
others.
Please define "customer location" and "customer premises" in the context of
enterprise UNE loop impairment analyses. Are these terms synonymous in your
view? If not, please describe in detail your view of the differences in these terms
with respect to DS-, DS-, and Dark Fiber UNE loops.
Please list each and every customer location which you contend should be removed
from the list of available DS-l UNE loop destinations pursuant to FCC Rules
951.319(a)( 4)(ii) (existence of competitive wholesale facilities.J For each listed
location, please list:
(a) the CLL! code identification of the network endpoint;
(b) the identities of each claimed alternative competitive provider;
(c) the exact location of the customer endpoint;
(d) all persons owning an interest in or controlling access to the customer
location;
(e) whether the location is a single-tenant or multi-tenant facility;
(f) all documents or information in your possession, custody or control regarding
any and all rights of access either you or any other telecommunications carrier
may have within the location;
(g) whether you claim ownership or control over any intra-building wire, fiber
cabling, or right of access;
(h) whether you are willing to make available any intra-building wire, fiber
cabling or right of access you may have to other telecommunications carriers
at no cost;
(i) whether you are willing to make available any intra-building wire, fiber
cabling, or right of access you may have to other telecommunications carriers
for consideration, including the amounts and all terms of that consideration;
G) what other means, if any, you are aware of that could be used by other
telecommunications carriers to access tenants within the location.
MCI-237 For each alternative competitive provider listed in your response to MCI-236, indicate
whether it is an "affiliate" (as defined in 47 USC 9153(1)) of Qwest or of any
other listed alternative competitive provider.
MCI-238 For each location listed in your response to MCI-236, please provide the following
information:
(a) The type of alternative loop provisioned and made available.
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 88
Boise-165130.10029164-00097
MCI-239
(b) The exact location of each claimed alternative facility, including the owner of
each facility segment, its date of installation and date of initial operation, the
nature of the alternative competitive provider s ownership/occupancy rights
(i.
, "
fee simple ownership
, "
IRU", etc.), and the identity of any underlying
owners or interest holders in the facility.
(c) Any and all documents in your possession, custody or control that state that
each claimed alternative competitive provider is willing immediately to
provide, on a widely available basis, dedicated DS 1 loop facilities at the
specified location.
(d) The terms, including copies of any governing documents, by which requesting
telecommunications carriers are able to obtain reasonable and
nondiscriminatory access to the facilities of the alternative competitive
provider.
Please list each and every customer location which you contend should be removed
from the list of available DS-3 UNE loop destinations pursuant to FCC Rules
g51.319(a)(5)(i)(A) (existence of alternative self-provisioned facilities.J For each
listed location, please list:
(a) the CLLI code identification of the network endpoint;
(b) the identities of each claimed alternative competitive provider;
(c) the exact location of the customer endpoint;
(d) all persons owning an interest in or controlling access to the customer
location;
(e) whether the location is a single-tenant or multi-tenant facility;
(f) all documents or information in your possession, custody or control regarding
any and all rights of access either you or any other telecommunications carrier
may have within the location;
(g) whether you claim ownership or control over any intra-building wire, fiber
cabling, or right of access;
(h) whether you are willing to make available any intra-building wire, fiber
cabling or right of access you may have to other telecommunications carriers
at no cost;
(i) whether you are willing to make available any intra-building wire, fiber
cabling, or right of access you may have to other telecommunications carriers
for consideration, including the amounts and all terms of that consideration;
(j) what other means, if any, you are aware of that could be used by other
telecommunications carriers to access tenants within the location.
MCI-240 For each alternative competitive provider listed in your response to MCI-239, indicate
whether it is an "affiliate" (as defined in 47 USC g 153(1)) of Qwest or of any
other listed alternative competitive provider.
MCI-241 For each location listed in your response to MCI-239, please provide the following
information:
(a) The type of alternative loop provisioned and made available.
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 89
Boise-165130.1 0029164-00097
MCI-242
(b) The exact route of each claimed alternative facility, including the owner of
each facility segment, its date of installation and date of initial operation, the
nature of the alternative competitive provider s ownership/occupancy rights
(i.
, "
fee simple ownership
, "
IRU", etc.), and the identity of any underlying
owners or interest holders in the facility.
(c) Any and all documents in your possession, custody or control that state that
each claimed alternative competitive provider is operationally ready to use the
listed loop facilities to provide dedicated DS-3 loop facilities at the specified
location.
Please list each and every customer location which you contend should be removed
from the list of available DS-3 UNE loop destinations pursuant to FCC Rules
~51.319(a)(5)(i)(B) (existence of competitive wholesale facilities.J For each
listed location, please list:
(a) the CLLI code identification of the network endpoint;
(b) the identities of each claimed alternative competitive provider;
(c) the exact location of the customer endpoint;
(d) all persons owning an interest in or controlling access to the customer
location;
(e) whether the location is a single-tenant or multi-tenant facility;
(f) all documents or information in your possession, custody or control regarding
any and all rights of access either you or any other telecommunications carrier
may have within the location;
(g) whether you claim ownership or control over any intra-building wire, fiber
cabling, or right of access;
(h) whether you are willing to make available any intra-building wire, fiber
cabling or right of access you may have to other telecommunications carriers
at no cost;
(i) whether you are willing to make available any intra-building wire, fiber
cabling, or right of access you may have to other telecommunications carriers
for consideration, including the amounts and all terms of that consideration;
(j) what other means, if any, you are aware ofthat could be used by other
telecommunications carriers to access tenants within the location.
MCI-243 For each alternative competitive provider listed in your response to MCI-242, indicate
whether it is an "affiliate" (as defined in 47 USC ~ 153(1)) of Qwest or of any
other listed alternative competitive provider.
MCI-244 For each location listed in your response to MCI-242 , please provide the following
information:
(a) The type alternative loop provisioned and made available.
(b) The exact route of each claimed alternative facility, including the owner of
each facility segment, its date of installation and date of initial operation, the
nature of the alternative competitive provider s ownership/occupancy rights
(i.
, "
fee simple ownership
, "
IRU", etc.), and the identity of any underlying
owners or interest holders in the facility.
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 90
Boise-165130.10029164-00097
MCI-245
MCI-246
(c) Any and all documents in your possession, custody or control that state that
each claimed alternative competitive provider is willing immediately to
provide, on a widely available basis, dedicated DS-3 loop facilities at the
specified location.
(d) The terms, including copies of any governing documents, by which requesting
telecommunications carriers are able to obtain reasonable and
nondiscriminatory access through cross connection to the facilities of the
alternative competitive provider.
Please list each and every customer location which you contend should be removed
from the list of available DS-3 UNE loop destinations pursuant to FCC Rules
~51.319(a)(5)(ii) (potential deployment of alternative facilities.J For each listed
location, please list:
(a) the CLLI code identification ofthe network endpoint;
(b) the identities of any identified alternative competitive provider;
(c) the exact location of the customer endpoint;
(d) all persons owning an interest in or controlling access to the customer
location;
(e) whether the location is a single-tenant or multi-tenant facility;
(f) all documents or information in your possession, custody or control regarding
any and all rights of access either you or any other telecommunications carrier
may have within the location;
(g) whether you claim ownership or control over any intra-building wire, fiber
cabling, or right of access;
(h) whether you are willing to make available any intra-building wire, fiber
cabling or right of access you may have to other telecommunications carriers
at no cost;
(i) whether you are willing to make available any intra-building wire, fiber
cabling, or right of access you may have to other telecommunications carriers
for consideration, including the amounts and all terms of that consideration;
(j) what other means, if any, you are aware of that could be used by other
telecommunications carriers to access tenants within the location.
For each location listed in your response to MCI-245, please provide copies of all
documents and information in your possession, custody or control relating to:
(a) local engineering costs of building and utilizing loop facilities;
(b) the cost of underground or aerial laying of fiber or copper;
(c) the cost of equipment needed for loop facilities; installation and other
necessary costs involved in setting up service;
(d) relevant local topography such as hills and rivers;
( e) availability of reasonable access to rights-of-way;
(f) availability/feasibility of similar quality/reliability alternative loop
technologies along the particular route;
(g) customer density and addressable market; and
(h) existing facilities-based competition.
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 91
Boise-165130.1 0029164-00097
MCI-247
MCI-248
For each alternative competitive provider listed in your response to MCI-245 and for
each provider of any existing facilities-based competition listed in your response
to MCI-246(h), indicate whether it is an "affiliate" (as defined in 47 USC
~ 153(1)) of Qwest or of any other listed alternative competitive provider.
Please list each and every customer location which you contend should be removed
from the list of available Dark Fiber UNEs pursuant to FCC Rules
51.319( a)( 6)(i) (existence of alternative self-provisioned facilities. J For each
listed location, please list:
(a) the CLLI code identification of the network endpoint;
(b) the identities of each claimed alternative competitive provider;
(c) the exact location of the customer endpoint;
(d) all persons owning an interest in or controlling access to the customer
location;
(e) whether the location is a single-tenant or multi-tenant facility;
(f) all documents or information in your possession, custody or control regarding
any and all rights of access either you or any other telecommunications carrier
may have within the location;
(g) whether you claim ownership or control over any intra-building wire, fiber
cabling, or right of access;
(h) whether you are willing to make available any intra-building wire, fiber
cabling or right of access you may have to other telecommunications carriers
at no cost;
(i) whether you are willing to make available any intra-building wire, fiber
cabling, or right of access you may have to other telecommunications carriers
for consideration, including the amounts and all terms of that consideration;
(j) what other means, if any, you are aware of that could be used by other
telecommunications carriers to access tenants within the location.
MCI-249 For each alternative competitive provider listed in your response to MCI-248, indicate
whether it is an "affiliate" (as defined in 47 USC ~153(1)) of Qwest or of any
other listed alternative competitive provider.
MCI-250 For each location listed in your response to MCI-248, please provide the following
information:
(a) The type of alternative loop provisioned and made available.
(b) The exact route of each claimed alternative facility, including the owner of
each facility segment, its date of installation and date of initial operation, the
nature of the alternative competitive provider s ownership/occupancy rights
(i.
, "
fee simple ownership
, "
IRU", etc.), and the identity of any underlying
owners or interest holders in the facility.
(c) Any and all documents in your possessiqn, custody or control that state that
each claimed alternative competitive provider is operationally ready to use the
listed loop facilities to provide dedicated Dark Fiber loop facilities at the
specified location.
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 92
Boise-165130.10029164-00097
MCI-251
MCI-252
MCI-253
MCI-254
Please list each and every customer location which you contend should be removed
from the list of available Dark Fiber UNEs pursuant to FCC Rules
951.319(a)(6)(ii) (potential deployment of alternative facilities.J F0f each listed
location, please list:
(a) the CLLI code identification of the network endpoint;
(b) the identities of each claimed alternative competitive provider;
(c) the exact location of the customer endpoint;
(d) all persons owning an interest in or controlling access to the customer
location;
(e) whether the location is a single-tenant or multi-tenant facility;
(f) all documents or information in your possession, custody or control regarding
any and all rights of access either you or any other telecommunications carrier
may have within the location;
(g) whether you claim ownership or control over any intra-building wire, fiber
cabling, or right of access;
(h) whether you are willing to make available any intra-building wire, fiber
cabling or right of access you may have to other telecommunications carriers
at no cost;
(i) whether you are willing to make available any intra-building wire, fiber
cabling, or right of access you may have to other telecommunications carriers
for consideration, including the amounts and all terms of that consideration;
(j) what other means, if any, you are aware of that could be used by other
telecommunications carriers to access tenants within the location.
For each location listed in your response to MCI-251 , please provide copies of all
documents and information in your possession, custody or control relating to:
(a) local engineering costs of building and utilizing loop facilities;
(b) the cost of underground or aerial laying of fiber or copper;
(c) the cost of equipment needed for loop facilities; installation and other necessary
costs involved in setting up service;
(d) relevant local topography such as hills and rivers;
(e) availability of reasonable access to rights-of-way;
(f) availability/feasibility of similar quality/reliability alternative
(g) loop technologies along the particular route;
(h) customer density and addressable market; and
(i) existing facilities-based competition.
For each alternative competitive provider listed in your response to MCI-251 and for
each provider of any existing facilities-based competition listed in your response
to MCI-252(h), indicate whether it is an "affiliate" (as defined in 47 USC
9153(1)) of Qwest or of any other listed alternative competitive provider.
Please describe and provide supporting documents for any state or locally enacted or
enforced limitations on or barriers to entry by competing providers of DS-, DS-
, OC-n, or Dark Fiber loop, including, but not limited to, any moratoria or
restrictions on construction or access to rights of way. Include all relevant legal
provisions and a description of any Qwest deployment or construction projects
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 93
Boise-165130.10029164-00097
MCI-255
MCI-256
MCI-257
which have been undertaken since the enactment of the restriction or moratoria.
Describe the steps taken or qualifications met in order for the identified Qwest
projects to either comply with or avoid the effects of the restriction or moratoria.
For each location identified in your responses to MCI-236 through MCI-251 , please
provide the following information:
(a) All forecasts of Qwest expected, estimated, anticipated, or forecasted demand
growth or decline for all classes of loop facilities. To the extent you have
information disaggregated by type of customer or demand (e.
, "
business
data
, "
UNE"
, "
special access , or other categories) please provide such
disaggregated figures. To the extent different documents may provide
differing figures, estimates, or forecasts based upon the impact or
implementation of any regulatory or judicial action (including, but not limited
, the Triennial Review Order and related proceedings) provide all such
figures, estimates, and forecasts, identifying which relate to which different
regulatory or judicial outcomes;
(b) Qwest's current loop capacity utilization , including total number and type of
fibers or copper cabling;
(c) number of "unlit" or "dark" fibers;
(d) number of "lit" fibers with the current transmission level implemented for
each (i., which OCn level);
( e) current utilization of copper wire, if any, including identification and capacity
of implemented digital and analog loop capability;
(f) identification of unused copper facilities, if any.
Please provide the following information for each fiber or conduit deployment project
by Qwest in Idaho since January 1 , 2000:
(a) type, size, and capacity of conduit installed along all or any separate portion
of the route;
(b) type and number of fibers initially installed along all or any separate portion
of the route
(c) type and number of fibers for each and every subsequent installation along all
or any portion of the route;
(d) all available budgetary and actual cost data for both initial and any subsequent
installations, including all costs for permits, authority, ROW, lobbying, public
policy, excavation, trenching, boring, backfill, surface repair, remediation
vault construction, termination, payments-in-kind, related usage rights
materials (including conduit and cabling), and any other expenses necessary to
the project.
Please provide the following information for each planned fiber or conduit
deployment project by Qwest in Idaho for the next 3 years: (Include in this
response any current projects not included in MCI-256, as well as future projects.
(a) type, size, and capacity of conduit to be installed along all or any separate
portion of the route;
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 94
Boise-165130.10029164-00097
MCI-258
(b) type and number of fibers to be initially installed along all or any separate
portion of the route
(c) type and number of fibers for each and every planned subsequent installation
along all or any portion of the route;
(d) all available budgetary cost data and estimates for both initial and any
subsequent installations, including all costs and estimates for permits
authority, ROW, lobbying, public policy, excavation, trenching, boring,
backfill, surface repair, remediation, vault construction, termination
payments-in-kind, related usage rights, materials (including conduit and
cabling), and any other expenses necessary to the project.
Please provide copies of all contracts, agreements, tariffs, or other governing
documents by which Qwest:
(a) sells, rents, leases, or otherwise provides telecommunications loop facilities to
others in Idaho;
(b) buys, rents, leases, or otherwise acquires loop facilities from others in Idaho.
MCI-259 With respect to all documents identified in your response to MCI-258, please provide
quarterly totals since January 1 , 2000 ofthe amount ofloop capacity provided or
acquired, identifying the quantity, route, and opposite party for each segment.
MCI-260 Please describe in detail any price floor(s) or other limitation(s) imposed by any law
regulation, Idaho PUC orders or rulings that constrain Qwest's ability to reduce
prices for each of the following:
(a) dark fiber loop service
(b) OC-n level loop service
(c) DS-3 loop service and
(d) DS-l loop service. For each such price floor or other limitation, provide the
basis for the calculation for the price floor or other limitation (e., price
freeze, cost-based calculation, etc.
MCI-261 Please provide a description and supporting documentation for all Qwest currently
offered bundles and volume discounts involving the following: a) dark fiber loop
service, b) OC-n level loop service, c) DS-3 loop service and d) DS-l100p
servIce.
MCI-262 Please provide a description and supporting documentation for all Qwest planned or
contemplated bundles and volume discounts involving the following: a) dark
fiber loop service, b) OC-n level loop service, c) DS-3 loop service and d) DS-
loop service.
MCI-263 Please provide all documents in your possession, custody or control that address or
assess the risk of stranded loop capacity on all or any portion of Qwest's existing
network in Idaho.
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 95
Boise-165130.10029164-00097
MCI-264 Please provide a copy of your responses to all audit and data requests that you have
received in this proceeding to date and to any audit and data requests you receive
in the future from other parties in this proceeding.
MCI-265 Please provide a copy of your responses to all audit and data requests that you have
received in this proceeding to date and to any audit and data requests you receive
in the future from other parties in this proceeding.
OBJECTION: Qwest objects to this request to the extent that responding to said request
may require Qwest to provide CLEC specific information and/or 3rd party vendor
proprietary information that Qwest is under contractual obligation to maintain as
confidential. With respect to the request to provide copies of responses that require
production of CLEC/Carrier specific data, the information requested may contain
CLEC/Carrier-specific information that may be protected under paragraph (a) Section 222
of the Communications Act of 1934 47 U.C. ~ 222 and/or other state and federal privacy
laws. Qwest will provide the requested CLEC/Carrier information upon receiving either:
(1) a Commission order compelling production of the information; or (2) permission by the
CLEC/Carrier to release the requested information. To the extent responding to this data
request would result in providing 3rd party vendor proprietary information, Qwest is in the
process of soliciting vendor authorization so that Qwest may make such information
available and, to the extent such permission is granted, will do so upon receipt of
authorization.
Respectfully submitted this 8th day of December, 2003.
Qwest Corporation
~tlt- n t Ih I:JJ
Mary S. :I-Ydbson
Stoel Rives LLP
Adam L. Sherr
Qwest
Attorneys for Qwest Corporation
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 96
Boise-165130.10029164-00097
CERTIFICATE OF SERVICE
I hereby certify that on this 8th day of December, 2003, I served QWEST
CORPORATION'S OBJECTIONS TO MCI'S DISCOVERY REQUESTS TO QWEST as
follows:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ID 83720-0074
Phone: [phone]
Fax: [phone]
11 ewell(Q")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, ID 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, ID 83720-0074
Phone: [phone]
Fax: [phone]
wstutzm~puc.state.id. us
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 OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 97
Boise-165130.10029164-00097
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, ID 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]
bpomero y~ho llandhart. com
Attorney for AT&T
Hand Delivery
~ U.Mail
Overnight Delivery
Facsimile
Email
Adam L. Sherr
Qwest
1600 7th Avenue - Room 3206
Seattle, W A 98191
Telephone: [phone]
Facsimile: [phone]
adam.sherr~qwest.com
Hand Delivery~ U.Mail
Overnight Delivery
Facsimile
Email
Clay R. Sturgis
Moss Adams LLP
601 West Riverside - Suite 1800
Spokane, WA 99201-0663
Telephone: [phone]
Facsimile: [phone]
clays~mossadams.com
Attorney for ITA
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 98
Boise-165130.!0029164-00097
Brian Thomas
Time Warner Telecom
223 Taylor Avenue North
Seattle, W A 98109
Brian. Thomas((l),twtelecom.com
Hand Deli very
U. S. Mail
Overnight Delivery
Facsimile
Email
Mary B. Tribby
Letty S. D. Friesen
AT&T Communications of the Mountain States, Inc.
1875 Lawrence Street- Suite 1575
Denver, CO 80202
Telephone: [phone]
Facsimile: [phone]
Isfriesen~att.com
Hand Delivery-L u. S. Mail
Overnight Delivery
Facsimile
Email
Conley E. Ward
Givens Pursley LLP
277 North 6th Street - Suite 200
O. Box 2720
Boise, ID 83701
Telephone: [phone]
Facsimile: [phone]
cew01gi venspurs lev. com
Attorney for ITA
Hand Delivery-L U. S. Mail
Overnight Delivery
Facsimile
Email
Brandi L. Gearhart, PLS
Legal Assistant to Mary S. Hobson
Stoel Rives LLP
QWEST CORPORATION'S OBJECTIONS TO MCI's DISCOVERY REQUESTS TO QWEST - Page 99
Boise-165130.10029164-00097