200302283rd Response of Qwest.pdf

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Boise. Idaho 83702
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ATTORNEYS AT LAW
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MARY S. HOBSON
Direct [phone]
mshobsonl1!)stoel.com
February 28, 2003
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, ill 83702-5983
RE:Docket No. QWE-O2-
Dear Ms. Jewell:
Enclosed for filing with this Commission is an original and three (3) copies ofQWEST
CORPORATION'S RESPONSES TO TIDRD REQUEST FOR THE PRODUCTION OF
DOCUMENTS OF THE COMMISSION STAFF. Copies ofthe confidential attachments are
provided under separate cover and have been provided to those parties who have executed the
Protective Agreement.
If you have any questions, please contact me. Thank you for your cooperation in this matter.
Very truly yoursJtL~1~~
Mary S. Hollson
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Enclosures
Oregon
Washington
California
Boise-153788.10029164-00087
Utah
Idaho
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101 5, Capitol Boulevard. Suite 1900
Boise. Idaho 83702
main 208.389.9000
fax [phone]
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ATTORNEYS AT LAW
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-'J~.~MARY S. HOBSON
Direct [phone]
mshobsonl1!)stoeLcomFebruary 28 , 2003
VIA HAND DELIVERY
PROPRIETARY AND CONFIDENTIAL
Jean Jewell
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington
Boise, ill 83702-5983
RE:Docket No. QWE-O2-
Dear Ms. Jewell:
Enclosed for filing with this Commission is an original and three (3) copies of the confidential
Attachments A and B to Response to Request No. 0151 to QWEST CORPORATION'
RESPONSES TO TIDRD REQUEST FOR THE PRODUCTION OF DOCUMENTS OF THE
COMMISSION STAFF in the above-referenced matter. Also enclosed is a cd containing the
confidential information.
Also enclosed is an Attorney Certificate in support ofthis confidential filing.
Thank you for your cooperation in this matter.
Very truly yours
Atlv~
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Mary S.lab;on
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Enclosures
Oregon
Washington
California
Utah
Boise-153787.1 0029164-00087 Idaho
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 7th Avenue - Room 3206
Seattle, W A 98191
Telephone: [phone]
Facsimile: [phone]
asherr~qwest. com
Attorneys for Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF QWEST CORPORATION FOR PRICE
DEREGULATION OF BASIC LOCAL
EXCHANGE SERVICES
Case. No. QWE-O2-
QWEST CORPORATION'S RESPONSES TO
TIDRD PRODUCTION REQUEST OF THE
COMMISSION STAFF
Qwest Corporation, through its undersigned attorneys, hereby files the attached responses
to the Third Production Request of the Commission Staff.
Respectfully submitted this 28th day of February, 2003.
Qwest Corporation
~4L-~
Mary S. bson
Stoel Rives LLP
Adam L. Sherr
Qwest Corporation
Attorneys for Qwest Corporation
QWEST CORPORATION'S RESPONSES TO THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - Page -
Boise-153785.10029164-00087
CERTIFICATE OF SERVICE
I hereby certify that on this 28th day of February, 2003 , I served QWEST
CORPORATION'RESPONSES TO TIDRD PRODUCTION REQUEST OF THE
COMMISSION STAFF as follows:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83720-0074
iiewell~puc.state.id.
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Marlin D. Ard
Willard L. Forsyth
Hershner, Hunter, Andrews, Neill & Smith LLP
180 East 11 th Avenue
O. Box 1475
Eugene, OR 97440-1475
Attorneys for Verizon
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
John Gannon, Esq.
1101 West River - Suite 110
Boise, ill 83702
Telephone: [phone]
Attorney for Meierotto, Padget, Herrick Neal
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Dean J. Miller
McDevitt & Miller LLP
420 West Bannock Street
O. Box 2565
Boise, ID 83701
Telephone: [phone]
Facsimile: [phone]
i oe~mcdevitt -miller .com
Attorneys for WorldCom, Inc.
Attorneys for AT&T
Attorneys for Time Warner Telecom
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Dean Randall
Verizon Northwest Inc.
17933 NW Evergreen Parkway
Beaverton, OR 97006-7438
dean.randall~verizon. com
Hand Delivery
-.2L u. S. Mail
Overnight Delivery
Facsimile
Email
QWEST CORPORATION'S RESPONSES TO THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF-Page - 2
Boise-153785.1 0029164-00087
Mary Jane Rasher
10005 South Gwendelyn Lane
Highlands Ranch, CO 80129-6217
Telephone: [phone]
mirasher~msn.com
Clay R. Sturgis
Moss Adams LLP
601 West Riverside - Suite 1800
Spokane, W A 99201-0663
Brian Thomas
TimeWarner Telecom
223 Taylor Avenue North
Seattle, W A 98109
Brian. Thomas~twtelecom.com
Susan Travis
WorldCom, Inc.
707 I ih Street - Suite 4200
Denver, CO 80202
Telephone: [phone]
Susan. a. Travis~worldcom.com
Conley E. Ward, Jr.
Givens Pursley LLP
277 North 6th Street - Suite 200
O. Box 2720
Boise, ill 83701-2720
Telephone: [phone]
Facsimile: [phone]
cew~~6venspursley .com
Attorneys for Idaho Telephone Association
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Hand Delivery
U. S. Mail
Overnight Delivery
FacsimileEmail
Hand Delivery-2L U. S. Mail
Overnight Delivery
Facsimile
Email
:J if
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l?i t?/l /T, c7i/ a~ /t d1;T
Brandi L. Gearhart, PLS
Legal Secretary to Mary S. Hobson
Stoel Rives LLP
QWEST CORPORATION'S RESPONSES TO THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - Page - 3
Boise-153785.10029164-00087
Idaho
Case No. QWE-02-
STF 03-0131
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:0131
Please identify any promotions or special offers that the Company has
conducted for either primary lines , additional lines , or packages
involving primary or additional lines , between January 1 , 1999 and
December 31 , 2002. Please identify the timeframe of the promotion, as
well as the applicable rates , terms and conditions of the promotion.
RESPONSE:
Qwest objects on the grounds that this request is overly broad, unduly
burdensome and seeks information to which Staff already has access.
Without waiving those objections , and specifically subject thereto, Qwest
responds as follows:
Attachment A contains all of the available promotions or special offers that
Qwest Corporation has conducted on either primary lines, additional lines, or
packages involving primary or additional lines , between January 1 , 1999 and
December 21 , 2002 including the timeframe of the promotion, as well as the
applicable rates , terms , and conditions of the promotion,
Respondent:Susan Mohr
Terry Lucas
IDAHO
Case No. QWE-02-
STF 03-0131
Attachment A
Idaho Promotions
Primary Line, Additional Line, or Packages Involving Primary Or Additional Lines
Additional Line Promotion - 11/23/98 through 01/30/99
Residence customers purchasing up to two additional lines were offered a $15 credit against the
one-time charges for each additional line as well as $15 offthe installation charge of the first
telephone jack associated with the additional line.
Premiere customers(l) will receive a Best Selections(2) mailing in the November timeframe. A
$5.00 coupon will be included in this mailing to be used in conjunction with the Additional Line
campaign. After the customer orders an Additional Line (during the promotion) they can mail the
coupon to US West for an additional $5.00 credit towards their jack installation. When the
customer mails in the coupon, and it has been confinned that they did in fact order the Additional
Line during the promo, with a phone jack, a $5.00 credit will be issued on their phone bill.
(I) A "Premier" customer is defined as one who spends $50.00 or more per month across all lines
of business, on the average over a 3-month time. This does not include nonrecurring charges.(2) A "Best Selections" mailing goes out to all Premier customers, as a loyalty or retention type
mailer. It thanks them for being a customer, advises them of promotions, and special offers, and
also has coupons like free TCBY, or 10% off a retail store.
Page 1 of 12
IDAHO
Case No. QWE-02-
STF 03-0131
Attachment A
Idaho Promotions
Primary Line, Additional Line, or Packages Involving Primary Or Additional Lines
Lines-Lines-Lines and Feature Sale" - 01/04/99 through 02/26/99
Following is a description of the services included in the promotion, and their offers.
PRODUCTS CAMP AIGN OFFERS
Additional Flat Business Line (lFB)$24 offNRC (1)
Additional $75 per account if service
stays in for 90 days. Mail in coupon.
Additional Centrex 21 Rated Stabilized $25 offNRC (1)
Analog Line Additional $75 per account if service
stays in for 90 days. Mail in coupon,
Regrade from 1FR to 1FB Waiver ofNRC
Features, purchase any:Waiver ofNRC (3)
Custom Calling Features(2)
Customized Call Management Services
(2)
U S West Custom Ringing Service
Caller ID Name and Number -Stand Waiver ofNRC and Free CWID Box
alone or included in a feature pkg. (i.(incl. shipping and handling)
SmartSet, SmartSet Plus Call Manager
Connection, or Start Up, Upgrade)(4)
Business Daytime Connection Plus $10 Credit
Volume Calling Connection $10 Credit
(1) Promotion not available with Start-Up or Upgrade Business Packages.
(2) Excludes usage based features. Excludes CCS Wann Line and Hot Line Features, and CCMS
800 Features.
(3) Only 1 Rebate per business line.
(4) The Promotion for these services begins December 28, 1999 to coincide with the Consumer
Caller ID offer.
Page 2 of 12
IDAHO
Case No. QWE- T -02-
STF 03-0131
Attachment A
Idaho Promotions
Primary Line, Additional Line, or Packages Involving Primary Or Additional Lines
Phone Improvement Promotion - 02/15/99 through 03/26/99
The following services and their corresponding NonRecurring Waiver are included in the
promotion:
Additional Residence Line
. The Additional Line Offer will be $25.00 Credit on the installation of
the Telephone Jack. One Jack per order.
Custom Calling Services
. Call Waiting
. Call Forwarding (Variable)
. Three-Way Calling
. Speed Call 8 Code Capacity
. Speed Call 30 Code Capacity
. Call Following (Remote Access Forwarding)
. Wireless Extension
Custom Local Area Signalling Services (CLASS)
. Caller ID - Name and Number
. Priority Call
. Last Call Return
. Continuous Redial
. Call Rejection
. Selective Call Forwarding
Custom Ringing
Voice Messaging Service
Business Additional Line Sales Promotion - 03/22/99 through 03/14/99
Customers in southern Idaho purchasing an additional flat-rated business line(s) along with
selected features or an additional rate stabilized Centrex 21 analog line will be offered a :tree color
printer.
Residence Additional Line Promotion - 03/29/99 through OS/22/99
Residential customers will receive a waiver of 50% off of the installation charge for each
additional exchange access line purchased, per customer location, up to two additional lines.
Also, included will be the additionalline(s) for customers ordering new service.
$25.00 credit on the additional line, jack installation.
Page 3 of 12
IDAHO
Case No. QWE-02-
STF 03-0131
Attachment A
Idaho Promotions
Primary Line, Additional Line, or Packages Involving Primary Or Additional Lines
Do Business From Anywhere Promotion - 05/17/99 through 06/25/99
Following is a description of all services included in the promotion, and their offers:
Products Campaign Offers
Additional Flat Business Line (lFB)Free Plantronics Wireless Headset (IJ
Additional Centrex 21 Analog Line
Business Packages (Start-Up/Upgrade)
MegaBit Service (minimum I-year
contract)
Call Forwarding Variable Waiver of the NRC
(includingw/o call completion)
Call Forwarding Busy Line (all)
Call Forwarding don t Answer (all)
Call Forwrading Busy Line/Don
Answer (all)
Call Waiting
Caller ID Name and Number
Remote Access Forwarding
Scheduled Forwarding
1 JOne free wireless headset upper customer account and location
Residential Additional Line Promotion - 06/28/99 through 08/07/99
Residential customers will receive a $15.00 credit for each additional exchange access line
purchased, for up to two additional lines per customer location. Also, included will be the
additionalline(s) for customers ordering new service.
Page 4 of 12
IDAHO
Case No. QWE-02-
STF 03-0131
Attachment A
Idaho Promotions
Primary Line, Additional Line, or Packages Involving Primary Or Additional Lines
Custom Choice for Small Business - 06/28/99 through 08/20/99
Following is a description of all services included in the promotion, and relative offers.
Products Campaign Offers
Additional Flat Business Line (IFB)$20 mail in coupon
(1)
Additional Centrex 21 Line (rate $20 mail in coupon
stabilized) (1)
Business Customer Choice $20 mail in coupon
Conversion from IFB to Centrex 21 Waiver of the NRC
Line
ISDN Single-Line Service (minimum $150 mail in coupon
year contract)
Simple Value Calling Plan and $10 one time credit
Business CustomChoice
Business Voice Messaging $20 mail in coupon
$20 answering machine trade-, mail in
coupon (4)
US Westnet OfficeWorks, BVMS Additional discounted savings as part of CCFB
CPE, Remote Access and Scheduled packages
Forwarding
(1) Customers must retain service for 60 days. Customers can combine with the CustomChoice
offer. Therefore, all customers purchasing an additional line and CustomChoice will be eligible
for $40.00 mail in coupons.
(2) Customers must retain service for 60 days. Business CustomChoice will be available about
June 7, 1999.
(3) Includes new service, additions, or upgrades.
(4) Customers must sign up for BVMS to be eligible for the answering machine trade in rebate.
Page 5 of 12
IDAHO
Case No. QWE-02-
STF 03-0131
Attachment A
Idaho Promotions
Primary Line, Additional Line, or Packages Involving Primary Or Additional Lines
Sell Better Goods and Services - 08/23/99 through 09/30/99
Following is a description of all services included in the promotion:
Customers Purchasin2(1)Will Receive
Additional Flat Business Line (lFB)ProspectSmart Software
Additional Centrex 21 Analog Line (minimum I-year
contract)
Business CustomChoice
ISDN Single-Line Service (minimum I-year contract)
Conversion from IFB to Business CustomChoice
Conversion from IFR to IFB
PC Caller ID
MegaBit (FCC)
ISDN Terminal Adapter
US Westnet Office Works
Call Reports w/Call Graphics
, ,
Residential Additional Line Promotion -12/27/99 through 02/11/00
Customers in the Company s northern and southern Idaho territories will be offered a $15 credit
per line when they purchase up to two additional flat rated access lines.
Page 6 of 12
IDAHO
Case No. QWE-02-
STF 03-0131
Attachment A
Idaho Promotions
Primary Line, Additional Line, or Packages Involving Primary Or Additional Lines
Small Business Solutions for the New Millenium - 12/27/99 through 03/17/00
Following is a description of the services included in the promotion, and the offers.
Products Campai~n Offers
AdditionallFB line $25 credit on bill
Additional Centrex 21 (rate stabilized)
line
Additional Centrex 21 rate stabilized $75.00 rebate (2)
w/2 qualifying features(1)
Re-grade IFR to IFB Waiver ofre-grade NRC
CustomChoice wlcaller ID N&N(3)Free Call Waiting ill Box
CustomChoice wlSimple Value calling $5 credit on Simple value Plan
Plan(3)
CustomChoice wi additional line (3)$75.00 rebate(2)
800 ServiceLine Service $18.00 credit on bill
ISDN Single Line Service (min I-year Waiver ofNRC
contract)
(1) Qualifying features;
Remote access Forwarding
Scheduled Call Forwarding
Call Park
Caller ID Name and Number
Simple Value Calling Plan
(2) Must be in service a minimum of 90 days
(3) Offer begins December 2ih, 1999 through 3/17/00
Page 7 of 12
IDAHO
Case No. QWE- T -02-
STF 03-0131
Attachment A
Idaho Promotions
Primary Line, Additional Line, or Packages Involving Primary Or Additional Lines
Business "Power Lines" Promotion - 05/01/00 through 06/30/00
Following is a description of the services included in the promotion, and their offers.
Products Campaign Offers
Additional Flat Business Line Gift Certificate to Giftpointcom or catalog
(lFB)$30 value (1)
Additional Centrex 21 Rate Gift Certificate to Giftpointcom or catalog
Stabilized Line $30 value.(2)
2 qualifying features on an existing Gift Certificate to Giftpointcom or catalog-
Centrex 21 line (features listed $50 value.(2)
below)
Business CustomChoice Gift Certificate to Giftpointcom or catalog
$50 value.
Call Forwarding Don t Answer Waiver ofNRC
(4/10-6/30)
Call Forwarding Busy Line/Don I-month recurring
Answer
BVMS (4/10/00 through 6/30/00)Waiver ofNRC
I-month recurring
800 Service Line (4/17/00 through $18 bill credit
6/30/00)
(1) Service must be in for 90 days. One per customer account
(2) One per customer account
Qualifying Centrex 21 Features:
Remote Access Forwarding
Scheduled Forwarding
Call Park
Caller ill Name and Number
Toll Calling Plans
Volume Calling Connection
Business Daytime Connection
Business Daytime Connection Plus
Super Saver Plan
BVMS
LocallNational/ Alphanumeric Paging
Venture Phone
Business Receptionist Phone
Call Reports
FAX Services-Fax Power, Never Busy Fax, Faxmail+, Fax Request, and Broadcast-fax
Page 8 ofl2
IDAHO
Case No. QWE-02-
STF 03-0131
Attachment A
Idaho Promotions
Primary Line, Additional Line, or Packages Involving Primary Or Additional Lines
Business "Power Strategy 2000" Promotion - 07/05/00 through 09/30/00
Following is a description of the services and the offers included in the promotion:
Products Campai2n Offers
Additional Flat Business Line (lFB)$75 Best Buy Gift Certificate (1), (2)
Additional Centrex 21 Line $75 Best Buy Gift Certificate (1), (2)
Add a new Business CustomerChoice or $75 Best Buy Gift Certificate (lJ, (2)
convert a 1FB to CustomChoice
ISDN Service (minimum 1-yr contract)$100 Rebate
BVMS $25 Best Buy Gift Certificate
All offers are one per customer account
(1) American Express certificate in the same amount will be offered when a Best Buy store is not
in a 45 mile radius,
(2) Must remain in service for a minimum of 90 days,
Residential Additional Line Promotion - 03/27/00 through 05/05/00
Customers purchasing up to two additional flat-rated residential access lines will be offered a
50% waiver of the non-recurring charges.
Residence CustomChoice Promotion - 7/2/01 through 8/11/01
Residence customers who purchased CustomChoice or Two-Line CustomChoice during the
promotional period were mailed a coupon to verify their name and address. Once the customer
returned the coupon, a $20.00 rebate check was mailed to the customer. The customer must have
kept CustomChoice in service for 60 days before the check was mailed.
Business CustomChoice Promotion - 7/2/01 through 8/24/01
Business customers who purchased CustomChoice for Business during the promotional period
were mailed a coupon to verify their name and address. Once the customer returned the coupon
a $50.00 Visa Gift Card was mailed to the customer. The customer must have kept
CustomChoice in service for 60 days before the card was mailed.
Business CustomChoice/Qwest Business Line Plus Promotion - 1/7/02 through 3/29/02
New or existing business customers who purchased CustomChoice For Business or a Qwest
Business Line Plus during the promotional period were given a $50.00 rebate coupon after they
have had the service(s) for 60 days. The customer then returned the coupon with their next bill
payment. Only one rebate was provided per account.
Page 9 of 12
IDAHO
Case No. QWE-02-
STF 03-0131
Attachment A
Idaho Promotions
Primary Line, Additional Line, or Packages Involving Primary Or Additional Lines
Residence CustomChoice Promotion - 2/11/02 through 3/30/02
Residence customers who purchased CustomChoice or Two-Line CustomChoice during the
promotional period were mailed a coupon to verify their name and address. Once the customer
returned the coupon, a $20,00 rebate check was mailed to the customer. The customer must have
kept CustomChoice in service for 60 days before the check was mailed.
Business CustomChoice and Qwest Business Line Plus Promotion - 7/1/02 through 8/31/02
Existing business customers who purchased CustomChoice For Business or an additional Qwest
Business Line Plus line during the promotional period received a credit on their bill for $50.00.
The waiver only applied to one line per account.
Business CustomChoice and Qwest Business Line Plus Promotion - 7/1/02 through 8/31/02
Existing business customers who purchased CustomChoice For Business or an additional Qwest
Business Line Plus line during the promotional period received a credit on their bill for $50.00.
The waiver only applied to one line per accou1;lt.
Business CustomChoice Promotion - 8/5/02 through 9/27/02
New or existing business customers who purchased CustomChoice for Business that includes
Caller ID Name & Number during the promotional period received a free Caller ID unit and only
had to pay a $4.95 shipping and handling charge. In addition a business customer who ordered
Caller ID Name and Number on a stand-alone basis received a waiver ofthe nonrecurring charge
to install the feature and received a free Caller ID unit and only had to pay a $4.95 shipping and
handling charge.
Business Additional Flat Rated Line or CustomChoice Promotion - 12/26/00 through 2/9/01
A customer who purchased an additional flat-rated business line or CustomChoiceTM for Business
received a premium valued at $200.00. The premium was a Two-Line Call Waiting ID
Speakerphone/Telephone. After 30 days, the customer was sent a letter asking them to provide
an address to which the telephone can be sent. Once the letter was returned, the telephone was
shipped to the customer at the address provided. Customers who disconnected the additional line
and/or CustomChoice prior to the 30th day were not eligible for the premium.
A customer who purchased an additional flat-rated business line received a premium valued at
$50.00. The premium was a $50.00 Gift Card. After 90 days, the customer was sent a letter
asking them to provide an address to which the Gift Card can be sent. Once the letter was
returned, the Gift Card was sent to the customer at the address provided. Customers who
disconnected the additional line prior to the 90th day were not eligible for the premium.
Page 10 of 12
IDAHO
Case No. QWE-02-
STF 03-0131
Attachment A
Idaho Promotions
Primary Line, Additional Line, or Packages Involving Primary Or Additional Lines
Business Additional Flat Rated Line or Additional Centrex 21 Analog Line Promotion -
4/23/01 through 6/30/01
Business customers, who purchased an additional flat-rated business line or an additional Centrex
21 analog line received a credit of $30.00 on their bill for each line purchased.
Residence CustomChoice Promotion - 7/2/01 through 8/11/01
Residence customers who purchased CustomChoice or Two-Line CustomChoice during the
promotional period were mailed a coupon to verify their name and address. Once the customer
returned the coupon, a $20.00 rebate check was mailed to the customer. The customer must have
kept CustomChoice in service for 60 days before the check was mailed.
Business CustomChoice Promotion - 7/2/01 through 8/24/01
Business customers who purchased CustomChoice for Business during the promotional period
were mailed a coupon to verify their name and address. Once the customer returned the coupon
a $50.00 Visa Gift Card was mailed to the customer. The customer must have kept
CustomChoice in service for 60 days before the card was mailed.
Business Additional Flat Rated Line or Additional Centrex 21 Analog Line Promotion -
7/9/01 through 9/28/01
Business customers who purchased an additional flat-rated business line or an additional Centrex
21 analog line during the promotional period were mailed a coupon to verify their name and
address. Once the customer returned the coupon, a $50.00 Visa Gift Card was mailed to the
customer. The customer must have kept the additional business line or Centrex 21 analog
additional line in service for 60 days before the card was mailed.
Centrex 21 Conversion Charge Waiver Promotion - 8/6/01 through 9/28/01
Business customers who converted from flat-rated business lines to Centrex 21 analog lines
during the promotional period were given a waiver of the nonrecurring conversion charge for the
first three lines converted per customer location.
Business Stand-By Line Promotion - 9/4/01 through 11/2/01
Business customers who purchased a Stand-By Line during the promotional period were mailed a
coupon to verify their name and address. Once the customer returned the coupon, a $50.
Office Max Gift Card was mailed to the customer. The customer must have kept the Stand-
Line in service for 60 days before the gift card was mailed.
Page 11 of 12
IDAHO
Case No. QWE-02-
STF 03-0131
Attachment A
Idaho Promotions
Primary Line, Additional Line, or Packages Involving Primary Or Additional Lines
Business Additional Flat Rated Line or Additional Centrex 21 Analog Line Promotion -
10/1/01 through 12/28/01
Existing business customers who purchased an additional flat-rated business line or an additional
Centrex 21 analog line during the promotional period were mailed three $50.00 credit coupons.
The customer was allowed to submit only one credit coupon per month with their bill payment
and all coupons must have redeemed by October 1 , 2002.
Business CustomChoice/Qwest Business Line Plus Promotion - 1/7/02 through 3/29/02
New or existing business customers who purchased CustomChoice For Business or a Qwest
Business Line Plus during the promotional period were given a $50.00 rebate coupon after they
have had the service(s) for 60 days. The customer then returned the coupon with their next bill
payment. Only one rebate was provided per account.
Business Additional Flat Rated Line, Custom Choice, Additional Centrex 21 Analog Line
Promotion -1/7/02 through 3/29/02
Existing business customers who purchased an additional flat-rate business line, CustomChoice
For Business, an additional analog Centrex 21 line, an additional Qwest Business Line Plus line
or a Qwest Utility Line during the promotional period were given a waiver of the nonrecurring
charge associated with the installation of the line. The waiver only applied to one line per
account.
Residence CustomChoice Promotion - 2/11/02 through 3/30/02
Residence customers who purchased CustomChoice or Two-Line CustomChoice during the
promotional period were mailed a coupon to verify their name and address, Once the customer
returned the coupon, a $20.00 rebate check was mailed to the customer. The customer must have
kept CustomChoice in service for 60 days before the check was mailed.
Business Market Expansion Line Promotion - 5/13/02 through 6/29/02
New or existing business customers who purchased Market Expansion Line during the
promotional period received a waiver of the nonrecurring charge to install the service. The
waiver applied to a maximum of three Market Expansion Lines per customer.
Business Additional Flat Rated Line, CustomChoice for Business, Additional Centrex 21
Analog Line, Qwest Business Line Plus and Utility Line Promotion - 7/1/02 through 8/31/02
Existing business customers who purchased an additional flat-rate business line, CustomChoice
For Business, an additional analog Centrex 21 line, an additional Qwest Business Line Plus line
or a Qwest Utility Line during the promotional period received a credit on their bill for $50.00.
The waiver only applied to one line per account.
Page 12 of 12
Idaho
Case No. QWE-02-
STF 03-0141
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:0141
Please identify any promotions or special offers that the Company has
conducted for custom calling features or caller identification services,
either individually or in packages or combinations , between January 1
1999 and December 31 , 2002. Please identify the timeframe of the
promotion, as well as the applicable rates, terms and conditions of the
promot ion.
RESPONSE:
Qwest objects on the grounds that this request is overly broad , unduly
burdensome and not reasonably calculated to lead to the discovery of
admissible evidence,
Without waiving those objections , and specifically subject thereto , Qwest
responds as follows:
Attachment A contains all of the available promotions or special offers that
Qwest Corporation has conducted on custom calling features or caller
identification services, either individually or in packages or combinations
between January 1 , 1999 and December 31 , 2002 including the timeframe of the
promotion, as well as the applicable rates, terms , and conditions of the
promot ion.
Respondent:Susan Mohr
Terry Lucas
IDAHO
Case No. QWE-02-
STF 03-0141
Attachment A
Idaho Custom Calling or Caller ID Promotions
Lines-Lines-Lines and Feature Sale" - 01104/99 through 02/26/99
Following is a description of the services included in the promotion, and their offers.
PRODUCTS CAMPAIGN OFFERS
Additional Flat Business Line (lFB)$24 offNRC (1)
Additional $75 per account if service
stays in for 90 days. Mail in coupon.
Additional Centrex 21 Rated Stabilized $25 offNRC (1)
Analog Line Additional $75 per account if service
stays in for 90 days. Mail in coupon.
Regrade from lFR to lFB Waiver ofNRC
Features, purchase any:Waiver ofNRC (3)
Custom Calling Features(2)
Customized Call Management Services
(2)
U S West Custom Ringing Service
Caller ID Name and Number -Stand Waiver ofNRC and Free CWID Box
alone or included in a feature pkg. (i,(incl. shipping and handling)
SmartSet, SmartSet Plus Call Manager
. .
Connection, or Start Up, Upgrade)(4)
Business Daytime Connection Plus $10 Credit
Volume Calling Connection $10 Credit
(1) Promotion not available with Start-Up or Upgrade Business Packages.
(2) Excludes usage based features. Excludes CCS Warm Line and Hot Line Features, and CCMS
800 Features.
(3) Only 1 Rebate per business line.
(4) The Promotion for these services begins December 28, 1999 to coincide with the Consumer
Caller ID offer.
Page 1 of 9
IDAHO
Case No. QWE-02-
STF 03-0141
Attachment A
Idaho Custom Calling or Caller ID Promotions
Phone Improvement Promotion - 02/15/99 through 03/26/99
The following services and their corresponding NonRecurring Waiver are included in the
promotion:
Additional Residence Line
. The Additional Line Offer will be $25.00 Credit on the installation of
the Telephone Jack. One Jack per order.
Custom Calling Services
. Call Waiting
. Call Forwarding (Variable)
. Three-Way Calling
. Speed Call 8 Code Capacity
. Speed Call 30 Code Capacity
. Call Following (Remote Access Forwarding)
. Wireless Extension
Custom Local Area Signalling Services (CLASS)
. Caller ID - Name and Number
. Priority Call
. Last Call Return
. Continuous Redial
. Call Rejection
. Selective Call Forwarding
Custom Ringing
Voice Messaging Service
Do Business From Anywhere Promotion - 05/17/99 through 06/25/99
Following is a description of all services included in the promotion, and their offers:
Products Campai~n Offers
Additional Flat Business Line (lFB)Free Plantronics Wireless Headset (1
Additional Centrex 21 Analog Line
Business Packages (Start-Up/Upgrade)
MegaBit Service (minimum I-year contract)
Call Forwarding Variable (includingw/o call Waiver ofthe NRC
completion)
Call Forwarding Busy Line (all)
Call Forwarding don t Answer (all)
Call Forwrading Busy Line/Don t Answer (all)
Call Waiting
Caller ID Name and Number
Remote Access Forwarding
Scheduled Forwarding
(lJOne free wireless headset upper customer account and location.
Page 2 of 9
IDAHO
Case No. QWE-02-
STF 03-0141
Attachment A
Idaho Custom Calling or Caller ID Promotions
Custom Choice for Small Business - 06/28/99 through 08/20/99
Following is a description of all services included in the promotion, and relative offers.
Products Campai~n Offers
Additional Flat Business Line (lFB) (1)$20 mail in coupon
Additional Centrex 21 Line (rate $20 mail in coupon
stabilized) (I)
Business Customer Choice $20 mail in coupon
Conversion from 1FB to Centrex 21 Waiver of the NRC
Line
ISDN Single-Line Service (minimum 1-$150 mail in coupon
year contract)
Simple Value Calling Plan and Business $10 one time credit
CustomChoice
Business Voice Messaging $20 mail in coupon
$20 answering machine trade-, mail in
coupon (4)
US Westnet Office Works, BVMS, CPE Additional discounted savings as part of
Remote Access and Scheduled Forwarding CCFB packages
(1) Customers must retain service for 60 days. Customers can combine with the CustomChoice
offer. Therefore, all customers purchasing an additional line and CustomChoice will be eligible
for $40.00 mail in coupons.
(2) Customers must retain service for 60 days. Business CustomChoice will be available about
June 7 , 1999.
(3) fucludes new service, additions, or upgrades.
(4) Customers must sign up for BVMS to be eligible for the answering machine trade in rebate.
Page 3 of 9
IDAHO
Case No. QWE-02-
STF 03-0141
Attachment A
Idaho Custom Calliug or Caller ID Promotions
Sell Better Goods and Services - 08/23/99 through 09/30/99
Following is a description of all services included in the promotion:
Customers Purchasin2(1)Will Receive
Additional Flat Business Line (lFB)ProspectSmart Software
Additional Centrex 21 Analog Line (minimum I-year
contract)
Business CustomChoice
ISDN Single-Line Service (minimum I-year contract)
Conversion from IFB to Business CustomChoice
Conversion from IFR to IFB
PC Caller ID
MegaBit (FCC)
ISDN Tenninal Adapter
US Westnet Office Works
Call Reports wlCall Graphics
Small Business Solutions for the New Millenium - 12/27/99 through 03/17/00
Following is a description of the services included 'in the promotion, and the offers.
Products Campai2n Offers
Additional IFB line $25 credit on bill
Additional Centrex 21 (rate stabilized)
line
Additional Centrex 21 rate stabilized $75.00 rebate (2)
w/2 qualifying features(l)
Re-grade IFR to IFB Waiver of re-grade NRC
CustomChoice wlcaller ID N&N(3)Free Call Waiting ID Box
CustomChoice wlSimple Value calling $5 credit on Simple value Plan
Plan(3)
CustomChoice wi additional line (3)$75.00 rebate(2)
800 ServiceLine Service $18.00 credit on bill
ISDN Single Line Service (min I-year Waiver ofNRC
contract)
(1) Qualifying features;
Remote access Forwarding
Scheduled Call Forwarding
Call Park
Caller ID Name and Number
Simple Value Calling Plan
(2) Must be in service a minimum of 90 days
(3) Offer begins December 27tl1, 1999 through 3/17/00
Page 4 of 9
IDAHO
Case No. QWE-02-
STF 03-0141
Attachment A
Idaho Custom Calling or Caller ID Promotions
Business "Power Lines" Promotion - 05/01/00 through 06/30/00
Following is a description of the services included in the promotion, and their offers.
Products Campai2n Offers
Additional Flat Business Line Gift Certificate to Giftpointcom or catalog
(lFB)$30 value (1)
Additional Centrex 21 Rate Gift Certificate to Giftpointcom or catalog
Stabilized Line $30 value.(2)
2 qualifying features on an existing Gift Certificate to Giftpointcom or catalog-
Centrex 21 line (features listed $50 value.(2)
below)
Business CustomChoice Gift Certificate to Giftpointcom or catalog
$50 value.
Call Forwarding Don t Answer Waiver ofNRC
(4/1 0-6/30)
Call Forwarding Busy Line/Don I-month recurring
Answer
BVMS (4/1 0100 through 6/30100)Waiver ofNRC
I-month recurring
800 Service Line (4/17/00 through $18 bill credit
6/30100)
(1) Service must be in for 90 days. One per customer account
(2) One per customer account
Qualifying Centrex 21 Features:
Remote Access Forwarding
Scheduled Forwarding
Call Park
Caller ID Name and Number
Toll Calling Plans
Volume Calling Connection
Business Daytime Connection
Business Daytime Connection Plus
Super Saver Plan
BVMS
Local/N ationall Alphanumeric Paging
Venture Phone
Business Receptionist Phone
Call Reports
FAX Services-Fax Power, Never Busy Fax, Faxmail+, Fax Request, and Broadcast-fax
Page 5 of 9
IDAHO
Case No. QWE-02-
STF 03-0141
Attachment A
Idaho Custom Calling or Caller ID Promotions
Business "Power Strategy 2000" Promotion - 07/05/00 through 09/30/00
Following is a description of the services and the offers included in the promotion:
Products CamDahm Offers
Additional Flat Business Line (lFB)$75 Best Buy Gift Certificate (1), (2)
Additional Centrex 21 Line $75 Best Buy Gift Certificate (1), (2)
Add a new Business CustomerChoice or $75 Best Buy Gift Certificate (1), (2)
convert a 1FB to CustomChoice
ISDN Service (minimum 1-yr contract)$100 Rebate
BVMS $25 Best Buy Gift Certificate
All offers are one per customer account
(1) American Express certificate in the same amount will be offered when a Best Buy store is not
in a 45 mile radius.
(2) Must remain in service for a minimum of 90 days.
Residence Caller ID/Call Waiting Promotion -12/26/00 through 2/9/01
Residence customers who purchased Caller ID or any two of the following products: Call
Waiting, Call Waiting ID, Caller ID .- Name and Number and Talking Call Waiting (includes
customers who purchased CustomChoice ) during the promotional period received a free Caller
ID unit manufactured by CIDCO. The unit is used in conjunction with the Caller ID feature.
Business Caller ID/Call Waiting Promotion -12/26/00 through 2/9/01
Business customers, who purchased Caller ID - Name and Number, Talking Call Waiting, Call
Waiting, Call Waiting ID, SmartSetSM or SmartSet pIUSSM during the promotional period received
a waiver of the nonrecurring charge associated with installing the feature. Customers who
purchase Caller ID, SmartSet, SmartSet Plus or Caller ID and Call Waiting will receive a free
Call Waiting ID unit manufactured by Consumerware. The unit is used in conjunction with the
Call Waiting ID and Caller ID features.
Residence Talking Call Waiting Promotion - 4/23/01 through 6/30/01
Residence customers who purchased Talking Call Waiting during the promotional period
received a waiver of the first month's recurring rate.
Residence Caller ID Promotion - 5/14/01 through 6/30/01
Residence customers who purchased Caller ID - Name & Number during the promotional period
received a free Caller ID unit manufactured by CIDCO. The unit is used in conjunction with the
Caller ID feature.
Page 6 of 9
IDAHO
Case No, QWE-02-
STF 03-0141
Attachment A
Idaho Custom Calling or Caller ID Promotions
Business Caller ID Promotion - 5/14/01 through 6/30/01
Business customers, who purchased Caller ID - Name and Number, Talking Call Waiting, Call
Waiting, Call Waiting ID, SmartSet or SmartSet Plus during the promotional period received a
waiver of the nonrecurring charge associated with installing the feature. Customers who purchase
Caller ID, SmartSet, SmartSet Plus or Caller ID and Call Waiting will receive a free Call Waiting
ID unit manufactured by Consumerware. The unit is used in conjunction with the Call Waiting
ID and Caller ID features.
Residence CustomChoice Promotion - 7/2/01 through 8/11101
Residence customers who purchased CustomChoice or Two-Line CustomChoice during the
promotional period were mailed a coupon to verify their name and address. Once the customer
returned the coupon, a $20.00 rebate check was mailed to the customer. The customer must have
kept CustomChoice in service for 60 days before the check was mailed.
Business CustomChoice Promotion - 7/2/01 through 8/24/01
Business customers who purchased CustomChoice for Business during the promotional period
were mailed a coupon to verify their name and address. Once the customer returned the coupon
a $50.00 Visa Gift Card was mailed to the. customer. The customer must have kept
CustomChoice in service for 60 days before the card was mailed.
Residence Security Screen Promotion - 7/16/01 through 10/13/01
Residence CustomChoice customers who ordered Security Screen during the promotional period
received a waiver ofthe first month's recurring charge for Security Screen.
Residence Caller ID Promotion - 12/26/01 through 2/9/02
Residence customers who purchased Caller ID during the promotional period received a waiver
of the first month's recurring rate and a free Caller ID unit manufactured by CIDCO. The unit is
used in conjunction with the Caller ID feature. The customer was required to pay a $4.
shipping and handling charge,
Residence Security Screen Promotion - 12/26/01 through 3/22/02
Residence customers who purchased Security Screen during the promotional period received a
waiver of the first month's recurring rate.
Business CustomChoice/Qwest Business Line Plus Promotion -117/02 through 3/29/02
New or existing business customers who purchased CustomChoice For Business or a Qwest
Business Line Plus during the promotional period were given a $50.00 rebate coupon after they
have had the service(s) for 60 days. The customer then returned the coupon with their next bill
payment. Only one rebate was provided per account.
Page 7 of 9
IDAHO
Case No. QWE-02-
STF 03-0141
Attachment A
Idaho Custom Calling or Caller ID Promotions
Business Caller ID Promotion 1/21/02 through 3/8/02
New or existing business customers who purchased CustomChoice for Business that includes
Caller ID Name & Number during the promotional period received a ftee Caller ID unit and only
had to pay the $4.95 shipping and handling charge. In addition a business customer who ordered
Caller ID Name and Number on a stand-alone basis received a waiver of the nonrecurring charge
to install the feature and received a ftee Caller ID unit and only had to pay the $4.95 shipping and
handling charge.
Residence CustomChoice Promotion - 2/11/02 through 3/30/02
Residence customers who purchased CustomChoice or Two-Line CustomChoice during the
promotional period were mailed a coupon to verify their name and address. Once the customer
returned the coupon, a $20.00 rebate check was mailed to the customer. The customer must have
kept CustomChoice in service for 60 days before the check was mailed.
Residence Caller ID Promotion - 6/24/02 through 8/10/02
Residence customers who purchased Caller ID during the promotional period received a waiver
the first month's recurring rate. In addition, customers who purchased Caller ID received a free
Caller ID unit manufactured by CIDCO. The unit is used in conjunction with the Caller ID
feature. The customer was required to pay a $4.95 shipping and handling charge.
Residence Security Screen Promotion - 6/24/02 through 9/21/02
Residence customers who purchased Security Screen during the promotional period received a
waiver ofthe first month's recurring rate.
Business CustomChoice and Qwest Business Line Plus Promotion - 7/1/02 through 8/31/02
Existing business customers who purchased CustomChoice For Business or an additional Qwest
Business Line Plus line during the promotional period received a credit on their bill for $50.00.
The waiver only applied to one line per account.
Business CustomChoice and Qwest Business Line Plus Promotion - 7/1/02 through 8/31/02
Existing business customers who purchased CustomChoice For Business or an additional Qwest
Business Line Plus line during the promotional period received a credit on their bill for $50.00.
The waiver only applied to one line per account.
Business Custom Choice Promotion - 8/5/02 through 9/27/02
New or existing business customers who purchased CustomChoice for Business that includes
Caller ID Name & Number during the promotional period received a free Caller ID unit and only
had to pay a $4.95 shipping and handling charge. In addition a business customer who ordered
Caller ID Name and Number on a stand-alone basis received a waiver of the nonrecurring charge
Page 8 of 9
IDAHO
Case No. QWE-02-
STF 03-0141
Attachment A
to install the feature and received a free Caller ID unit and only had to pay a $4.95 shipping and
handling charge.
Idaho Custom Calling or Caller ID Promotions
Residence Caller ID Promotion - 11/1/02 through 12/31/02
Residence customers who purchased Caller ID during the promotional period received a free
Caller ID unit manufactured by CIDCO. The unit is used in conjunction with the Caller ID
feature. The customer was required to pay a $4.95 shipping and handling charge.
Page 9 of 9
Idaho
Case No. QWE-02-
STF 03-0151
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:0151
Please provide the latest available data for subscriber line usage that
would identify the average number of local minutes (both originating and
terminating) used by Qwest subscribers. Please provide such data for
weekdays and weekend days, and for peak and of f peak periods.
RESPONSE:
Qwest objects to this request on the grounds that it is overly-broad and
unduly burdensome. Qwest also obj ects on the grounds that this request is
vague in its use of the phrases "weekdays and weekend days" and "peak and off
peak. "
Without waiver of its objections , and specifically subject thereto , Qwest
responds as follows:
Qwest does not possess "data for subscriber line usage that would identify
the average number of local minutes (both originating and terminating) used
by Qwest subscribers.Qwest has and provides Subscriber Line Usage Study
(" SLUS") data. The purpose of SLUS is to provide originating local telephone
usage patterns by service, It does not track local terminating usage or any
toll usage. The SLUS tracks both voice and data local usage , and thus is not
an accurate measure of "two-way interactive switched voice communication"
within the local exchange calling area.
SLUS data is not actual usage data for all lines in Idaho. In order to
manage the amount of data that could be available , SLUS works with a random
sample of available accounts. SLUS studies are based on statistically
derived samples. The size of the sample is dependent on the mean and
standard deviation of the call rate and the stratification of the sample
universe. The sample size is calculated for each sample by state, stratum
and class of service. The algorithm used to calculate the sample size sets
the confidence level at 95% +/ - 10%. Once the appropriate sample size is
derived, that number of lines are randomly sampled beginning January 1 of
each year. The local usage on those lines is tracked without interruption
unless the line disconnects during the year, If a sampled line disconnects,
the usage on that line is not included in the monthly usage total for all
sampled lines. The data is tracked on an aggregate, monthly basis. The
number of lines in the sample is not increased unless Qwest determines that
additional lines are needed to maintain a statistically adequate sample size.
Attached as Confidential Attachment A is the 2002 SLUS report for Idaho.
That report is disaggregated into four separate tables, one each for the 1FB
1FR, 1MR and 1MB products. It is also disaggregated by day of the week and
by hour. For each product , each day of the week and each hour , the totaltracked minutes (rounded to the nearest minute) for the year are provided
from the
provided
request,
length.
sampled lines. The average number of lines being sampled is alsofor each product. Qwest has not included, but could provide upon
the total minutes broken down into total calls and average call
As additional information , attached as Confidential Attachment B is the 2002
SLUS call distribution report for Idaho. That report is disaggregated into
four separate tables, one each for the 1FB , 1FR , 1MR and 1MB products. Those
tables provide the number of calls made per month on the sampled lines. For
instance , the 1FB chart (page 1) reflects "4501-6000 1 0.01%." That means
that one sampled line in one month registered between 4501 and 6000
originating local calls.
Respondent:Becky Triplett