20020906Second Request to Qwest.doc

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 3283

Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983

Attorney for the Commission Staff

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF DETERMINING PRICES FOR UNBUNDLED NETWORK ELEMENTS (UNE) IN QWEST CORPORATION’S STATEMENT OF GENERALLY AVAILABLE TERMS (SGAT). )
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CASE NO. QWE-T-01-11

SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO QWEST CORPORATION

The Staff of the Idaho Public Utilities Commission by and through its attorney of record, Weldon B. Stutzman, Deputy Attorney General, requests Qwest Corporation (Qwest) provide the following documents and information, pursuant to Commission Rule of Procedure 225, IDAPA 31.01.01.225, on or before WEDNESDAY, OCTOBER 2, 2002.
This Production Requests is to be considered as continuing, and Qwest 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. 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.

Request No. 5: Please identify the top twenty Unbundled Network Elements purchased from the Exhibit A of the most recent SGAT either submitted to the FCC or pending 271 filing. In determining the “top twenty” please use revenue as a percent of total wholesale revenue sales for each of Qwest’s 14 states. Please list the state and then itemize by element and the percent of total wholesale sales.
Example:
2 Wire Analogue Loop Transport Switching __
Arizona Total # purchased/% of total sales Total # purchased/% of total sales Total # purchased/% of total sales
Colorado Total # purchased/% of total sales Total # purchased/% of total sales Total # purchased/% of total sales

Request No. 6: Please identify for each of Qwest’s 14 states, those states that have adopted Qwest’s ICM model for setting all UNE rates. “Adopted” means Commission Ordered or ALJ recommended and pending Commission final decision.
Request No. 7: Please identify for each of Qwest’s 14 states, those states that have adopted the HAI model for setting all UNE rates. “Adopted” means Commission Ordered or ALJ recommended and pending Commission final decision.
Request No. 8: Please identify for each of Qwest’s 14 states, those states that have adopted something other than Qwest’s ICM or HAI model for setting all UNE rates. “Adopted” means Commission Ordered or ALJ recommended and pending Commission final decision. Please explain the method or model(s) used in setting UNE rates.
Request No. 9: In the Company’s Idaho Third Revision Exhibit A (Second Amended), please explain what the difference is between 9.2.8 Private Line to Unbundled Loop Conversions and 9.23.7 EEL C and Loop MUX Conversions. If there is no difference, please explain why the same service requires two sections for pricing.
Request No. 10: Please list by each state what the following input values are:
* Depreciation Rates
* Drop Distances
* Cable placement – trenching, boring, etc.
* DLC Investments
* Fill Factors – Distribution, Feeder and Switch
* Sharing
* Overhead Loading Factors
* Network Operating Factors
Switching – S1FF, PAL, SAI
If these are Commission Ordered, please indicate which cost model was adopted in that particular proceeding. If the values are ALJ recommended, please indicate which model was recommended. If there is no recommendation or final Order, please indicate whether they are Qwest’s ICM default inputs or Qwest’s advocacy for that particular state.
Request No. 11: Please provide Idaho specific model run results and backup using the HAI 5.2a. This report shall explicitly list all the inputs used by Qwest along with all documented results for each runs. There should be two runs associated with this analysis. One run using the HAI 5.2a with its default inputs and another using the HAI 5.2a model with Qwest inputs.
Request No. 12: Please provide the same information in Request Number 10 using Qwest’s ICM model.
Request No. 13: Please provide the same information in Request Number 10 using the FCC’s Synthesis Model.

DATED at Boise, Idaho, this day of September 2002.

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Weldon B. Stutzman
Deputy Attorney General

Technical Staff: Carolee Hall

WS:CH::umisc/prdreg/qwet01.11wsch2

SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF TO QWEST 1 SEPTEMBER 6, 2002