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Home My WebLink About200404151st Request of Staff to Qwest.pdfWELDON B. STUTZMAN DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0318 IDAHO BAR NO. 3283 ' ;:- ' ' c-\ ! r- . '- l, '- \ r. ~! ED '(."01 ".;- . .1 .;' 44 I'i;i'iULiC; uf', 11"-" I'r"jl("' --- 0l."tJlli il.JJI it Street Address for Express Mail: 472 W WASHINGTON BOISE ID 83702-5983 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION FOR AMENDMENT OF THE CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY OF QWEST COMMUNICATIONS)CORPORATION. CASE NO. QCC-04- FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO QWEST COMMUNICATIONS CORPORATION (QCC) The Staff of the Idaho Public Utilities Commission, by and through its attorney of record Weldon Stutzman, Deputy Attorney General, requests that Qwest Communications Corporation (QCC) provide the following documents and information on or before THURSDAY, APRIL 29, 2004. The Company is reminded that responses pursuant to Commission Rules of Procedure must include the name and phone number of the person preparing the document, and the name location and phone number of the record holder. Reference IDAPA 31.01.01.228. This Production Request is to be considered as continuing, and QCC is requested to provide, by way of supplementary responses, additional documents that it or any person acting on its behalf may later obtain that will augment the documents produced. FIRST PRODUCTION REQUEST TO QCC APRIL 15 , 2004 Please provide answers to each question; supporting workpapers that provide detail or are the source of information used in calculations; the name and telephone number of the person preparing the documents; and the name, location and telephone number ofthe record holder. For each item, please indicate the name of the person(s) preparing the answers, along with the job title of such person(s) and the witness who can sponsor the answer at hearing. For all responses to the following requests, please provide all workpapers, diskettes (3.5 in.) and all underlying formulas in Excel (version 5) language. Request No.1: What is the intended market of Qwest Communications Corporation (QCC). What products does QCC intend to sell to which types of customers? a. Does QCC intend to enter the residential basic local exchange service (POTS) market? b. Does QCC intend to enter the small business POTS market? Request No.2: QCC is already certificated to provide local exchange service in V erizon' s service area in Idaho. Please describe the types of services currently being provided in Idaho by QCC. How many local exchange customers does QCC have in Verizon s service area? Request No.3: Does QCC intend to construct or own any facilities? Request No.4: QCC and Qwest Corporation (QC) are currently subject to the federal separate affiliate requirements of Section 272. Qwest may seek to eliminate some separation requirements 3 years after Qwest obtained 271 authority. What is the intent of Qwest in regards to maintaining such separation at the end of the mandatory period? Will both QCC and QC continue to operate? Request No.5: What is the extent of joint marketing expected between QC and QCC? Will QCC use QC customer service representatives (CSRs)? If so, how will branding be provided for QCC? How will branding be provided for QC? What provisions will be made to ensure that the CSRs are discussing the correct company policies, terms and conditions? FIRST PRODUCTION REQUEST TO QCC APRIL 15 2004 Request No.6: How will customers be made aware of the different "Qwests ? Will they have different 800 numbers? If a potential new customer calls "Qwest" to sign up for basic local exchange service, will they initially be offered such service from Qwest the ILEC or Qwest the CLEC? If the rates or terms are different, how will this be made clear to the customer? Will the bonuses or commissions paid to sales personnel be greater or different for QCC than QC? Request No.7: Can an individual be a customer ofQC for some products and a customer of QCC for other products? (Same location) If so, please describe. Request No.8: In its Application, QCC indicated it had obtained certificates to provide local exchange services in a number of other states in which QC is the ILEe. What is the scope of QCC operations in those states? How many customers for what types of services? Please provide the terms under which any joint marketing may be conducted between QCC and QC in those states? Request No.9: Has QCC signed any interconnection agreements with QC in any other states? If so, please identify? With Verizon or other ILECs? Request No. 10: Will the line splitting policies ofQCC be the same as those ofQC? If not, please describe. Request No. 11: Please explain how the presence of a Qwest Corporation affiliate as a competitor to Qwest's own services is in the public interest. Request No. 12: What Title 62 services, other than long distance services, is QCC currently providing in QC's certificated territory? FIRST PRODUCTION REQUEST TO QCC APRIL 15 2004 DATED at Boise, Idaho, this 6ft-- day of April 2004. Technical Staff: Wayne Hart i:umisc:prodreq/qcctO4.1 wswh FIRST PRODUCTION REQUEST TO QCC Weldon B. Stutzman Deputy Attorney General APRIL 15 , 2004 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 15TH DAY OF APRIL 2004 SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO QWEST COMMUNICATIONS CORPORATION IN CASE NO. QCC-04-, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING: MARY S HOBSON STOEL RIVES LLP SUITE 1900 101 S CAPITOL BLVD BOISE ID 83702-5958 ADAM L SHERR QWEST 1600 7TH AVE ROOM 3206 SEATTLE WA 98191 CERTIFICATE OF SERVICE