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Home My WebLink About200303125th Response of Qwest.pdf1./5f! 5 TO E L ~~,':' ' 1'-~\ LV t:.\ \; L r:u Fr ; "-",,--, IX) f'~'101 5, Capitol Boulevard, Suite 1900 Boise, Idaho 83702 main 208.389,9000 rax 208.389,9040'0 P !? ' '1 5: 06\iU I:r \' www,sloeLcom ATTORNEYS AT lAW F:' , iSS!ONJTlun~s c March 12, 2003 MARY S. HOBSON Direct (208) 387-4277 mshobson0sloel.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 FIFTH REQUEST FOR THE PRODUCTION OF DOCUMENTS OF THE COMMISSION STAFF. Copies of the confidential attachment is 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 plat-tiC Mary S. It;bson :blg Enclosurescc: Service List Oregon Washington California Boise-154251.l 0029164-00087 Utah Idaho Mary S. Hobson (ISB #2142) Stoel Rives LLP 101 South Capitol Boulevard - Suite 1900 Boise, ill 83702 Telephone: (208) 389-9000 Facsimile: (208) 389-9040 mshobson~stoe1.com "-" '\'C!\t. ' - ! ' f L -_oILED ill t"" '11\11'.)1;\1') lUiJ. ',"'" , In t t:C UTlL i\ lis CCH"H'1fSSION Adam L. Sherr (WSBA #25291) Qwest 1600 7th Avenue - Room 3206 Seattle, WA 98191 Telephone: (206) 398-2507 Facsimile: (206) 343-4040 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 FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF Qwest Corporation, through its undersigned attorneys, hereby files the attached responses to the Fifth Production Request of the Commission Staff. Respectfully submitted this 12th day of March, 2003. Qwest Corporation ~/~ Mary S. obson Stoel Rives LLP Adam L. Sherr Qwest Corporation Attorneys for Qwest Corporation QWEST CORPORATION'S RESPONSES TO FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF - Page - 1 Boise-154249.10029164-00087 CERTIFICATE OF SERVICE I hereby certify that on this 12th day of March, 2003, I served QWEST CORPORATION'RESPONSES TO FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF as follows: Jean Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Street Boise, Idaho 83720-0074 i i ewell~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: (208) 433-0629 Attorney for Meierotto, Padget, Herrick Neal Dean J. Miller McDevitt & Miller LLP 420 West Bannock Street O. Box 2565 Boise, ill 83701 Telephone: (208) 343-7500 Facsimile: (208) 336-6912 i oe~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 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 FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF - Page - 2 Boise-154249.l 0029164-00087 Mary Jane Rasher 10005 South Gwendelyn Lane Highlands Ranch, CO 80129-6217 Telephone: (303) 470-3412 mirasher~msn.com Clay R. Sturgis Moss Adams LLP 601 West Riverside - Suite 1800 Spokane, WA 99201-0663 Brian Thomas TimeWarner Telecom 223 Taylor Avenue North Seattle, W A 98109 Brian. Thomas~twtelecom.com Susan Travis WorldCom, Inc. 707 17th Street - Suite 4200 Denver, CO 80202 Telephone: (303) 390-6333 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: (208) 388-1200 Facsimile: (208) 388-1300 cew~givenspursley.com Attorneys for Idaho Telephone Association Protective Agreement Hand Delivery ~ U.Mail Overnight Delivery Facsimile Email Hand Delivery ~ U.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.Mail Overnight Delivery Facsimile Email ~d ~~ Brandi L. Gearhart, PLS Legal Secretary to Mary S. Hobson Stoel Rives LLP QWEST CORPORATION'S RESPONSES TO FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF - Page - 3 Boise-154249.10029164-00087 Idaho Case No. QWE-02- STF 05-032P INTERVENOR:Staff of the Idaho Public Utilities Commission REQUEST NO:032P Please list every individual USOC (rate element) that is included within the scope of Qwest I s Application (thereby clearly identifying the rates that would potentially be subject to change if Qwest I s Application weregranted). Please also include the tariff page and section where the rate is listed in Qwest' s Idaho intrastate tariffs. RESPONSE: Please see Attachment A for a list of individual USOCs that are included within the scope of Qwest I s Application. Respondent: Dawn Salaver , Regulatory USOC RESIDENTIAL SERVICES Measured Line - Section 2 1RWV Primary LineAWV Additional Line Flat Rated Line - Section 1 FR/HFR Primary LineAFH Additional Line Service Description BUSINESS SERVICES Measured Line - Section LMB First LineALM Additional Line Flat Rated Line - Section 1 FB/HFB First LineAFK Additional Line91 L 911 Individual Access Line Computer Port Line - Flat - Section 1 FA Flat - First LineAFV Flat - Additional LineB4Q Measured - First LineA4Q Measured - Additional Line Secretarial Answering Service - Section S3L Flat Rated Line Stand-By Line - Section A2Y/1 TM Measured Line Qwest Utility Line - Section AWL Flat Rated Line wlPackage PBX Trunks - Measured - Section TV1 2 WayTVW 1 Way OutTV4 1 Way InTTT Hotel, LD TerminalTDV 1 Way In wi hunting for DID PBX Trunks - Message - Section TMB Hotel , First LineTM2 Hotel , AdditionalTMN In OnlyTMU Out OnlyTZZ 1 Way In wi hunting for DID PBX Trunks - Flat - Section TFB 2 WayTHHCX 2 Way, 4 WireTFU 1 Way OutTFN 1 Way InD4D Centrex COTDD 1 Way In wi hunting for DID Qwest Business Line Plus - Section NLUDE Month-to-Month IDAHO Case No. QWE-02- STF 05-032P Attachment A Exchange & Network Svcs. Tariff Page Catalog Page 40.12. 79.4 138.4 NLUDD/NLUDY 1 Year RSPNLUDG/NLUDZ 2 Year RSPNLUDL 3 Year RSP Centrex 21 Service - Section 9.RXB Month-to-MonthRSX Rate Stabilized Plan 79.4 79.4 79.4 IDAHO Case No. QWE-O2- STF 05-032P138.4 Attachment A 138.4 138.4 Idaho Case No. QWE-02- STF 05-033P INTERVENOR:Staff of the Idaho Public Utilities Commission REQUEST NO:033P For each USOC (rate element) listed in response to the preceding question provide the following information: The USOC A brief description of the rate element Billing units as of December 2002; The current rate (s) Revenues (e.g. billing units times the rate) F. An indication of whether the rate is a recurring or nonrecurring charge. To the extent this information is not available as of December 2002 please provide the requested information as of the most recent representative time period for which billing quantities are available andindicate the time period used. Please provide this information electronically, using an Excel format , or other industry standard spreadsheet format. RESPONSE: Please see Confidential Attachment A which provides the quantities in service as of December 2002 and the rates for those services. More detailed descriptions of the services can be found in the Southern Idaho Exchange and Network Services Tariff. Respondent: Dawn Salaver , Regulatory Patrick Reynolds Idaho Case No. QWE-O2- STF 05-034P INTERVENOR:Staff of the Idaho Public Utilities Commission REQUEST NO:034P To the extent not provided in response to the preceding question , please also provide the information requested with respect to all of the USOCS included in the following service categories: Bas ic local exchange service, Custom calling services (e.g. call waiting) CLASS services (e. g. CallerID) All usage sensi ti ve (e. g. per minute) charges applicable to localcalls (e.g. the per-minute or per-message rates associated with measured local service) and All packages which include some form of local exchange service in conjunction with at least one other service (e.g. Custom Choice) RESPONSE: A. Basic Local Exchange Service USOCs are provided in the response to STF 05-033P. B. Qwest obj ects to this request on the grounds and for the reason that it seeks information that is not reasonably calculated to lead to thediscovery of admissible evidence. Without waiving the foregoing obj ection and specifically relying thereon, Qwest provides the following response. Custom Calling Services are Title 62 services and are found in the Southern Idaho Exchange and Network Exchange Services Catalog, Section C. Qwest obj ects to this request on the grounds and for the reason that it seeks information that is not reasonably calculated to lead to the discovery of admissible evidence. Without waiving the foregoing objection and specifically relying thereon, Qwest provides the following response. CLASS Services are Title 62 services and are found in the Southern Idaho Exchange and Network Exchange Services Catalog, Section 5. D. Usage sensitive charges are provided in the response to STF 05-033P. Additional information regarding usage was provided in response to STF 04-0161. E. Qwest objects to this request on the grounds and for the reason that it seeks information that is not reasonably calculated to lead to the discovery of admissible evidence. Without waiving the foregoing objection and specifically relying thereon , Qwest provides the following response. All Basic Local Exchange Line USOCs associated with packages are included in the response to STF 05-033P. The feature portion of Local Exchange Service packages are Title 62 services and are found in the Southern Idaho Exchange and Network Services Catalog, Section 5.1. This feature package , combined with a Basic Local Exchange Service line (which may either a Title 61 or Title 62 product), is marketed and billed as the total service package. One exception to the rate structure described above for packages is Qwest Business Line Plus, which was tariffed at a single rate and therefore is also found in the Southern Idaho Exchange and Network Services Tariff for customers purchasing 1-5 lines. Respondent:Dawn Salaver, Regulatory Legal CONFIDENTIAL DOCUMENTS WERE INCLUDED IN THIS FILING