200302184th Request of Staff to Qwest.pdf

2.JJt
WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 3283
f\ECEiVED IT)fiLED
ZOD3 FES r 8 PN 2: 32
,,"'.' ,.,
i Ii
UTILITiES COI'II,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-02-
FOURTH 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 Friday, March 7, 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 Excel 5.0 language.
FOURTH PRODUCTION REQUEST
TO QWEST FEBRUARY 18 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, if transferred, 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.
FOURTH PRODUCTION REQUEST
TO QWEST FEBRUARY 18 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.
Interrogatory No. 16: Please provide Subscriber Line Usage data for Qwest's Idaho local
service categories. Provide this information for the month of December 2002 , or most recent
month for which the data is available. Disaggregate this data by time of day into as much detail
as possible. Disaggregate the data by customer usage levels into as much detail as possible. (E.
separately for those access lines in the lowest usage decile, second lowest usage decile, etc.
Provide the number of access lines included in each usage group. Provide this information
separately for residential and business access lines.
Interrogatory No. 17. To the extent not already provided, please provide the following
information on usage per line of the typical business subscriber for the most recent month for
which the data is available, disaggregated in as much detail as is available (e.g. by type of
exchange, by number oflines serving the customer, by tariff category, by time of day, etc.) To
the extent this information, or similar information, has been developed, analyzed, or summarized
in a study or report, please also provide a copy of the study or report in question.
(a) The monthly volume of incoming calls.
(b) The monthly volume of outgoing calls.
(c) The monthly volume of incoming minutes.
(d) The monthly volume of outgoing minutes.
Interrogatory No. 18. Provide the average number of business access lines for the month
covered by the data provided in response the preceding question.
Interrogatory No. 19. To the extent not already provided, please provide the following
information on usage per line of the typical residential subscriber for the most recent month for
which the data is available, disaggregated in as much detail as is available (e., by type of
exchange, by number of lines serving the customer, by tariff category, by time of day, etc.) To
the extent this information, or similar information, has been developed, analyzed, or summarized
in a study or report, please also provide a copy of the study or report in question.
(a) The monthly volume of incoming calls.
FOURTH PRODUCTION REQUEST
TO QWEST FEBRUARY 18 2003
(b) The monthly volume of outgoing calls.
(c) The monthly volume of incoming minutes.
(d) The monthly volume of outgoing minutes.
Interrogatory No. 20. Provide the average number of residential access lines for the month
covered by the data provided in response the preceding question.
Interrogatory No. 21. To the extent not already provided, please provide copies of any studies
completed in the past 2 years which show minutes of use, messages, or other usage data for
specific categories of local service (e., Residential, Business I-party; PBX).
DATED at Boise, Idaho, this day of February 2003.
Weldon B. Stutzman
Deputy Attorney General
Technical Staff: Joe Cusick
Wayne Hart
FOURTH PRODUCTION REQUEST
TO QWEST FEBRUARY 18 2003
CERTIFICA TE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 18TH DAY OF FEBRUARY 2003
SERVED THE FOREGOING FOURTH 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
SUSAN TRAVIS
WORLDCOM INC
707 17TH STREET, SUITE 4200
DENVER CO 80202
MARY JANE RASHER
AT&T COMMUNICATIONS OF THE
MOUNTAIN STATES INC
10005 S GWENDELYNLANE
HIGHLANDS RANCH, CO 80129-6217
CERTIFICATE OF SERVICE
MARLIN D ARD
WILLARD L FORSYTH
HERSHNER, HUNTER, ANDREWS, NEILL
& SMITH, LLP
180 E 11TH 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 VER TON OR 97006-7438
BEN JOHNSON ASSOCIATES INC
2252 KILLEARN CENTER BLVD
ALLAHASSSEE FL 32308
~0J~
SECRETARY
CERTIFICATE OF SERVICE