200303074th Response of Qwest.pdf

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101 S. Capilol Boulevard, Suite 1900
Boise, Idaho 83702
main 208.389.9000
fax [phone]
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March 7, 2003
MARY S. HOBSON
Direct [phone]
mshobson(iYstoel,com
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 of QWEST
CORPORATION'S RESPONSES TO FOURTH REQUEST FOR THE PRODUCTION OF
DOCUMENTS OF THE COMMISSION STAFF. Copies of the 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 yours
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Enclosurescc: Service List
Oregon
Washington
Caiifornia
Boise-154073.1 0029164-00087
Utah
Idaho
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Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
msho bson(i:V,stoel. com
RECEIVED
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UTILi"; icJ Cun;-\! ~SION
Adam L. Sherr (WSBA #25291)
Qwest
1600 7th Avenue - Room 3206
Seattle, WA 98191
Telephone: [phone]
Facsimile: [phone]
asherr(i:V,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
FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF
Qwest Corporation, through its undersigned attorneys, hereby files the attached responses
to the Fourth Production Request of the Commission Staff.
Respectfully submitted this ih day of March, 2003.
Qwest Corporation
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tLft'~j/(-h
Mary S. H son
Stoel Rives LLP
Adam L. Sherr
Qwest Corporation
Attorneys for Qwest Corporation
QWEST CORPORATION'S RESPONSES TO FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - Page -
Boise-154072.1 0029164-00087
CERTIFICATE OF SERVICE
I hereby certify that on this ih day of March, 2003, I served QWEST CORPORATION'
RESPONSES TO FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
follows:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83720-0074
i i ewell(i:V,puc.state.id. us
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
Protective Agreement
John Gannon, Esq.
1101 West River - Suite 110
Boise, ill 83702
Telephone: [phone]
Attorney for Meierotto, Padget, Herrick Neal
Dean J. Miller
McDevitt & Miller LLP
420 West Bannock Street
O. Box 2565
Boise, ill 83701
Telephone: [phone]
Facsimile: [phone]
i oe(i:V,mcdevitt -miller. com
Attorneys for WorldCom, Inc.
Attorneys for AT&T
Attorneys for Time Warner Telecom
Protective Agreement
Dean Randall
Verizon Northwest Inc.
17933 NW Evergreen Parkway
Beaverton, OR 97006-7438
dean.randall ~v erizon. com
Protective Agreement
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Hand Delivery-L 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
QWEST CORPORATION'S RESPONSES TO FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - Page - 2
Boise-154072.1 0029164-00087
Mary Jane Rasher
10005 South Gwendelyn Lane
Highlands Ranch, CO 80129-6217
Telephone: [phone]
mirasher(i:V,msn.com
Clay R. Sturgis
Moss Adams LLP
601 West Riverside - Suite 1800
Spokane, W A 99201-0663
Brian Thomas
TimeWamer Telecom
223 Taylor Avenue North
Seattle, W A 98109
Brian. Thomas(i:V,twtelecom.com
Susan Travis
WorldCom, Inc.
707 17'h 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(i:V,gi venspursley. com
Attorneys for Idaho Telephone Association
Protective Agreement
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
Facsimile
Email
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
&d41tO
Brandi L. Gearhart, PLS
Legal Secretary to Mary S. Hobson
Stoel Rives LLP
QWEST CORPORATION'S RESPONSES TO FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - Page - 3
Boise-154072.1 0029164-00087
Idaho
Case No. QWE-02-
STF 04-0161
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:0161
Please provide Subscriber Line Usage data for Qwest I s Idaho local servicecategories. 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. g., separately
for those access lines in the lowest usage decile, second lowest usagedecile, etc.Provide the number of access lines included in each usagegroup. Provide this information separately for residential and businessaccess lines.
RESPONSE:
Qwest objects to this request on the grounds that it is overly-broad and
unduly burdensome. Qwest also objects on the grounds that this request is
vague in its use of the phrases "usage levels," "lowest usage decile" and
second lowest usage deci le
. "
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"
wi thin the local exchange call ing 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 is randomly sampled beginning January 1 of eachyear. 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.
In response to request Staff 03-0151, Qwest produced the 2002 SLUS report for
Idaho and the 2002 SLUS call distribution report for Idaho. Those reports
were described in the body of Qwest's response to Staff 03-0151. Attached as
Confidential Attachment A is the December 2002 SLUS report for Idaho.
Attached as Confidential Attachment B is the December 2002 SLUS call
distribution report for Idaho.
Respondent:Becky Triplett
Idaho
Case No. QWE-02-
STF 04-0171
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:0171
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 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 ~ncoming calls.
(b)The monthly volume of outgoing calls.
(c)The monthly volume of ~ncoming minutes.
(d)The monthly volume of outgoing minutes.
RESPONSE:
See Qwest's objections and responses to Staff 03-0151 and 04-0161. In
addition , to the extent that Staff is seeking usage data for other than
local usage , Qwest has attached as Confidential Attachment A a report
showing intraLATA toll usage on Qwest residence and business lines in
southern Idaho for the month of December 2002. This data only showsoriginatinqtoll usage for lines which have Qwest Corporation as their
designated intraLATA toll carrier. It does not show any usage for Qwest
lines that have presubscribed to other intraLATA toll carriers. Attached
as Confidential Attachment B is a document disclosing the approximate
number of Qwest lines in southern Idaho today that have Qwest Corporation
as their designated intraLATA toll carrier. Qwest does not know for
certain whether that is the same number of lines on which usage was
. ~
tracked in Confidential Attachment A. The number set forth in
Confidential Attachment B also does not include the number of lines in
southern Idaho that have QLDC as their designated intraLATA toll carrier;
that number is not currently available.
Respondent:Legal
Sharon Alvarado
Idaho
Case No. QWE-02-
STF 04-0181
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:0181
Provide the average number of business access lines for the month covered
by the data provided in response the preceding question.
RESPONSE:
See Qwest I s objections and responses to Staff 03-0151, 04-0161 and
04-0171.
Respondent:Legal
Idaho
Case No. QWE-02-
STF 04-0191
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:0191
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.g. 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 lncoming calls.
(b)The monthly volume outgoing calls.
(c)The monthly volume lncoming minutes.
(d)The monthly volume outgoing minutes.
RESPONSE:
See Qwest's objections and responses to Staff 03-0151 , 04-0161 and
04-0171.
Respondent:Legal
Idaho
Case No. QWE-02-
STF 04-0201
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:0201
Provide the average number of residential access lines for the month
covered by the data provided in response the preceding question.
RESPONSE:
See Qwest's objections and responses to Staff 03-0151, 04-0161 and
04-0171.
Respondent:Legal
Idaho
Case No. QWE-02-
STF 04-0211
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:0211
To the extent not already provided, please provide
completed in the past 2 years which show minutes of
usage data for specific categories of local serviceBusiness I-party: PBX).
copies of any studies
use, messages , or other
(e.g., Residential
RESPONSE:
See Qwest I s objections and responses to Staff 03-0151 and 04-0161.
Respondent:Legal
CONFIDENTIAL DOCUMENTS
WERE INCLUDED IN THIS FILING