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Home My WebLink About200302052nd Request of Staff to Qwest.pdf~,Cf WELDON B. STUTZMAN DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0318 ISB NO. 3283 EECEIVED FILED r--"1 20aJ FEG -5 AN 8: 48 ! ., ;' i" ! . uTlLiT it~ CUr SION 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 THE APPLICATION OF QWEST CORPORATION FOR DEREGULATION OF BASIC LOCAL EXCHANGE RATES IN ITS BOISE, NAMPA CALDWELL, MERIDIAN, TWIN FALLS, IDAHO FALLS, AND POCATELLO EXCHANGES. CASE NO. QWE- T -02- 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 , IDAP A 31.01.01.225 , on or before February 21, 2003. This Production Request is to be considered as continuing, and Qwest is requested to provide, by way of supplementary responses, additional documents and information that it or any person acting on its behalf may later obtain that will augment the documents and information produced. For each request, please state 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. responses include workpapers or spreadsheets, please provide the responses on computer media (3.5" diskette or CD) using Lotus 123 (4.0) or Exce15.0 language. SECOND PRODUCTION REQUEST TO QWEST FEBRUARY 4, 2003 DEFINITIONS and INSTRUCTIONS The words "the Company" and "Qwest" refer to Qwest Corporation Document" includes any written or recorded or graphic matter, however produced or reproduced, including but not limited to correspondence, telegrams, contracts agreements, notes in any form, memoranda, diaries, voice recording tapes, microfilms microfiche, pictures, data processing cards or discs, computer tapes and other computer- generated and stored information or data base, work papers, calendars, minutes of meetings or any other writings or graphic matter, including copies containing marginal notes or variations of any of the foregoing, now or previously in your possession. (1) (2) In the event that any document called for is to be withheld on the basis of a claim of privilege, identify the item being withheld as follows: addressor; addressee; indicated or blind copies; and all persons to whom distributed, shown, or explained. Also identify the nature and legal basis of the privilege asserted. In the event that any document called for by this request has been destroyed or transferred beyond the control of the Company, (a) state the identity of the person by whom it was destroyed and person authorizing destruction and the time, place and method of, and reasons for its destruction, and if destroyed or disposed of by operation of a retention policy, state the retention policy; and, iftransferred, the person authorizing transfer and the time, place, and method of, and reason for, its transfer, and (b) identify it as follows: addressor; addressee; indicated or blind copies; dates; subject matter; number of pages, attachments or appendices; and all persons to whom distributed, shown, or explained. Identify, " " Identity," or "Identification " when used in reference to an individual person means to state that person s full name and residence address, including zip code and phone number, if known, and present or last known business position and duties and business address, if known. Identify, " " Identity," or "Identification " when used in reference to a document, means to state the type of document (e., computer-stored information, microfilm, letter memorandum, policy circular, minute book, telegram, chart, etc.), or some other means of identifying it, and its present location and custodian. If any such document was, but is no longer, in your possession or subject to your control, state what disposition was made of it, and if destroyed or disposed of by operation of a retention policy, state the retention policy. Identify, " " Identity," or "Identification " when used in reference to a number or other specific information, means to identify the document containing this information or some other means of identifying it, and to specify the approximate location of the requested information within that document. SECOND PRODUCTION REQUEST TO QWEST FEBRUARY 4 2003 Identify, " " Identity," or "Identification " when used in reference to a business organization, means to state the corporate name or other names under which said organization does business, and location of its principal place of business. Note: to the extent the specific information requested herein is not available, but analogous or reasonably comparable information is available, please provide that information instead, and explain any differences between what was requested and what has been provided. To the extent the information requested herein is not available in the exact format requested, but the information can be more easily provided in a different format, please provide your response in the more readily available format, but explain any differences in format. Please provide an electronic copy of the requested information in Excel spreadsheet or compatible format. Request for Production No. 12: Please provide electronic copies of all numerical exhibits filed by Qwest in this proceeding. Provide numerical exhibits in standard spreadsheet format (e. Excel) with functioning macros and formulas used to generate any computed numbers. Request for Production No. 13: To the extent not already provided, please provide all source documents and workpapers supporting all exhibits filed by Qwest in this proceeding. To the extent already provided, please identify all source documents and workpapers supporting each Exhibit filed by Qwest in this proceeding. This request includes source documents supporting workpapers and source documents supporting other source documents. The intent of this request is to ensure that we have received all available documentation which supports the information provided in the Exhibits. If available, provide this information in standard spreadsheet format (e., Excel) with functioning macros and formulas used to generate any computed numbers. Request for Production No. 14: Please refer to Qwest's response to Staff Request for Production 1-6. Please provide copies of the "national statistics" referenced in this response. Request for Production No. 15: Please refer to Qwest's response to Staff Request for Production 1-6. Please provide the requested information for all wireless service providers own by or affiliated with the Company or Qwest Communications International Inc. Request for Production No. 16: For each of the 7 exchanges at issue in this proceeding, please provide the following: number of residential customers; number of business customers; number of residential access lines; and, number of business access lines. Request for Production No. 17: For each of the 7 exchanges at issue in this proceeding, please provide the number of residential customers who also receive wireless service from a wireless service provider own by or affiliated with the Company or Qwest Communications International Inc. Request for Production No. 18: Please refer to Qwest's response to Staff Request for Production 1-7. Please provide the requested information for consumers who are customers of both the Company and any wireless service provider own by or affiliated with the Company or Qwest Communications International Inc. SECOND PRODUCTION REQUEST TO QWEST FEBRUARY 4, 2003 Request for Production No. 19: Please provide copies of all data or other information reviewed by Qwest (other than the information previously filed by Qwest in this proceeding) which tends to prove that wireless services are "functionally equivalent" to Qwest's basic local exchange servIce. Request for Production No. 20: Please provide copies of all data or other information reviewed by Qwest (other than the information previously filed by Qwest in this proceeding) which tends to prove that wireless services are not functionally equivalent" to Qwest's basic local exchange servIce. Request for Production No. 21: Please provide copies of all data or other information reviewed by Qwest (other than the information previously filed by Qwest in this proceeding) which tends to prove that wireless services are "competitively priced" with Qwest's basic local exchange servIce. Request for Production No. 22: Please provide copies of all data or other information reviewed by Qwest (other than the information previously filed by Qwest in this proceeding) which tends to prove that wireless services are not competitively priced" with Qwest's basic local exchange servIce. Request for Production No. 23: Please provide copies of all data or other information reviewed by Qwest (other than the information previously filed by Qwest in this proceeding) which tends to prove that wireless services are "reasonably available to both residential and small business customers" in the 7 exchanges at issue in this proceeding. Request for Production No. 24: Please provide copies of all data or other information reviewed by Qwest (other than the information previously filed by Qwest in this proceeding) which tends to prove that wireless services are not reasonably available to both residential and small business customers" in the 7 exchanges at issue in this proceeding. Request for Production No. 25: Please refer to page 19 of the testimony of Douglas Lincoln. Please provide copies of the 36 responses referenced on line 9. Request for Production No. 26: Please refer to page 20 of the testimony of Douglas Lincoln. Please provide copies of the questionnaire referenced on line 17. Request for Production No. 27: Please refer to page 27 of the testimony of Douglas Lincoln. Please provide a complete narrative explanation of the "data editing" referenced on line 3. Request for Production No. 28: Please refer to Exhibit 8 attached to the testimony of Douglas Lincoln. Please provide the information included in this exhibit for each of the 7 exchanges at issue in this proceeding. Request for Production No. 29: Please refer to Exhibit 10 attached to the testimony of Douglas Lincoln. Please provide the information included in this exhibit for each of the 7 exchanges at issue in this proceeding. SECOND PRODUCTION REQUEST TO QWEST FEBRUARY 2003 Request for Production No. 30: Please refer to page 9 ofthe testimony of Harry Shooshan. Please provide a copy of the presentation referenced in footnote 15. Request for Production No. 31: Please refer to page 11 of the testimony of Douglas Lincoln. Please provide a copy of the article referenced in footnote 21. DATED at Boise, Idaho, this day of February 2003. Weldon B. Stutzman Deputy Attorney General Technical Staff: Joe Cusick Wayne Hart SECOND PRODUCTION REQUEST TO QWEST FEBRUARY 2003 CERTIFICATE OF SERVICE HEREBY CERTIFY THAT I HAVE THIS 5TH DAY OF FEBRUARY 2003 SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO QWEST CORPORATION, IN CASE NO. QWE-02- 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 ADAM L SHERR QWEST 1600 7TH AVE, ROOM 3206 SEATTLE WA 98191 CONLEY WARD GIVENS PURSLEY LLP 277 N 6TH ST, SUITE 200 PO BOX 2720 BOISE ID 83701-2720 CLAY R STURGIS MOSS ADAMS LLP 601 W RIVERSIDE, SUITE 1800 SPOKANE WA 99201-0663 DEAN J MILLER McDEVITT & MILLER LLP 420 W BANNOCK ST PO BOX 2565 (83701) BOISE ID 83702 BRIAN THOMAS TIME WARNER TELECOM 223 TAYLOR AVE NORTH SEATTLE WA 98109 DEAN J MILLER McDEVITT & MILLER LLP 420 W BANNOCK ST PO BOX 2565 (83701) BOISE ID 83702 SUSAN TRAVIS WORLDCOM INC 707 17TH STREET, SUITE 4200 DENVER CO 80202 DEAN J MILLER McDEVITT & MILLER LLP 420 W BANNOCK ST PO BOX 2565 (83701) BOISE ID 83702 MARY JANE RASHER AT&T COMMUNICATIONS OF THE MOUNTAIN STATES INC 10005 S GWENDEL YN LANE HIGHLANDS RANCH, CO 80129-6217 CERTIFICATE OF SERVICE MARLIN D ARD WILLARD L FORSYTH HERSHNER, HUNTER, ANDREWS , NEILL & SMITH, LLP 180 E 11 TH AVE PO BOX 1475 EUGENE OR 97440-1475 JOHN GANNON ATTORNEY AT LAW 1101 W RIVER, SUITE 110 BOISE ID 83702 DEAN RANDALL VERIZON NORTHWEST INC 17933 NW EVERGREEN PKWY BEA VERT ON OR 97006-7438 BEN JOHNSON ASSOCIATES INC 2252 KILLEARN CENTER BLVD TALLAHASSSEE FL 32308 ~Q0~ SECRETARY CERTIFICATE OF SERVICE