200304022nd Pro Request of Qwest to Staff.pdf

Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoel.com
.. "
RECEIVEn IT)FilED
2003 APR -2 PM~:
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) j'
J8LJCUTILITIES COMMISSION
Adam L. Sherr (WSBA #25291)
Qwest
1600 7th Avenue - Room 3206
Seattle, WA 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 SECOND
INTERROGATORIES AND REQUESTS FOR
PRODUCTION OF DOCUMENTS TO STAFF
Qwest Corporation ("Qwest") pursuant to Rule 225 of the Rules of Procedure of the
Idaho Public Utilities Commission and Idaho Rules of Civil Procedure 33 and 34 hereby submits
the following Interrogatories and Requests for Production of Documents to the Staff of the Idaho
Public Utilities Commission ("Staff'). Staff is requested to answer the following Interrogatories
and Requests in writing and under oath by April 14, 2003.
These Interrogatories and Requests shall be deemed continuing, and if Staff, its
consultants or its attorneys discover additional information and facts related to the matters
inquired of between the time answers are made and the time of the hearing in this matter
QWEST CORPORATION'S SECOND INTERROGATORIES AND
REQUESTS FOR PRODUCTION OF DOCUMENTS TO STAFF - Page
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supplemental answers shall be made informing Qwest and Qwest's attorneys as to said newly
discovered information as far in advance of the hearing as possible.
DEFINITIONS
The term "Staff'
, "
you" or "your" refers to the Staff of the Idaho Public Utilities
Commission, and its agents, consultants and representatives including its attorneys or any
employee, agent, investigator or representative of its attorneys.
The term "Qwest" refers to and shall mean Qwest Corporation.
The terms "relating
, "
related", or "which relates to" means constitutes, refers to
contains, embodies, evidences, reflects, contradicts, refutes, identifies, states, deals with, bears
upon, or is in any way logically or factually connected with any matter described.
The word "person" means any individual, corporation, joint venture, limited
partnership, association, group or entity of any kind.
The terms "document" or "statement" refer to and shall mean and include any
written, typed, printed, recorded or computer-produced or graphic matter of every type and
description, however and by whomever prepared, produced, reproduced, disseminated or made
including, but not limited to, reports, letters, correspondence, memoranda, records, summaries
analyses, results or reports of investigations, recommendations, diaries, books, messages
electronic mail (whether in hard copy form or as stored on disc or computer hard drive), notes
tapes, drawings, graphs, photographs, microfilms, telegrams, periodical articles, computer
printouts and any other writing, drawing, or records.
Terms in the plural include the singular, and terms in the singular include the
plural.
QWEST CORPORATION'S SECOND INTERROGATORIES AND
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INSTRUCTIONS
Whenever you are requested to identify or describe a document or statement, state
with respect to such document or statement the following:
The nature, date and substance of the document or statement with
sufficient particularity to enable it to be identified, including its title, if any;
The name, business affiliation and address of each person or persons who
drafted, caused to be drafted and/or revised such document or statement; and
The name, business affiliation and address of each person who presently
has custody of the document or any copy of it and any other description necessary to enable its
custodian to locate the document or statement.
Whenever you are requested to identify or describe a person, state with respect to
each such person the following:
his, her or its full name;
his, her or its present or last known address;
his, her or its present or last known telephone number; and
his, her or its position, title and business affiliation.
If you object to any Interrogatory or Request for Production, set forth all reasons
for the objection. If you claim privilege as a basis for not complying with any Interrogatory or
Request for Production, in full or in part, describe the factual basis for the claim of privilege in
detail sufficient to permit the Commission to rule upon the validity of the claim. If you object to
any part of any Interrogatory or Request for Production, answer the remaining partes)
completely.
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If any information called for by an Interrogatory or Request for Production is
unknown to you, so state and then state all remaining information that is known to you.
INTERROGATORY NO.Please identify all of Mr. Hart's credentials to offer
expert opinion testimony on the wireless industry and on wireless technology. For purposes of
this Interrogatory, "expert opinion testimony" refers to any written or verbal testimony not
specifically supported by a third party document (i., not one produced by or on behalf Mr.
Hart) identified and produced in this case. By "credentials " Qwest seeks an identification of
specific educational, vocational and first hand research experiences, as well as any studies
reports or publications authored by Mr. Hart.
INTERROGATORY NO. 2-Please identify all of Dr. Johnson s credentials to offer
expert opinion testimony on the wireless industry and on wireless technology. For purposes of
this Interrogatory, "expert opinion testimony" refers to any written or verbal testimony not
specifically supported by a third party document (i., not one produced by or on behalf Dr.
Johnson) identified and produced in this case. By "credentials " Qwest seeks an identification of
specific educational, vocational and first hand research experiences, as well as any studies
reports or publications authored by Dr. Johnson.
REQUEST FOR PRODUCTION NO.Please produce all documents identified in
response to Interrogatory Nos. 2-1 and 2-
INTERROGATORY NO. 2-At pages 3-4 of his testimony, Mr. Hart states
, "
As a
result of the statutory requirements not being met, the Company has failed to demonstrate that
wireless competition is sufficient to effectively replace regulation in protecting the public from
Qwest's monopoly position in the provision of local services.(Emphasis added.) Describe
whether "local services" Mr. Hart meant to refer to "basic local exchange services " as that term
QWEST CORPORATION'S SECOND INTERROGATORIES AND
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is defined in Idaho Code 9 62-603(1), or to refer to something else. If something else, please
specifically describe what Mr. Hart means by that term and why that definition of "local
services" is relevant to this case.
INTERROGATORY NO. 2-Aside from the statutory references made by Mr. Hart
on pages 5-6 of his Direct Testimony, please identify all facts and documents that support Mr.
Hart's conclusion that "the legislature s selection of terms ('local services ' vs. 'basic local
exchange services ) was deliberate and directs a review of the full functions of the two services
to determine whether one is 'functionally equivalent' to the other.
REQUEST FOR PRODUCTION NO. 2-Please produce all documents identified in
response to Interrogatory No. 2-
INTERROGATORY NO. 2-Does Mr. Hart contend that Dr. Lincoln s value
proposition theory - as defined in Dr. Lincoln s testimony starting at page 7 , line 1 is incorrect?
Please fully explain your answer and identify all facts and documents supporting your answer.
REQUEST FOR PRODUCTION NO. 2-Please produce all documents identified in
response to Interrogatory No. 2-
INTERROGATORY NO. 2-On page 13 of his Direct Testimony, Mr. Hart states
that "the average customer does not spend enough on long distance to make up the difference
(between Qwest's rates and wireless rates)." Identify all facts and documents Mr. Hart reviewed
or relied upon to draw this conclusion.
REQUEST FOR PRODUCTION NO. 2-Please produce all documents identified in
response to Interrogatory No. 2-
INTERROGATORY NO. 2-With regard to Mr. Hart's statement at page 13 of his
Direct Testimony that "the average customer does not spend enough on long distance to make up
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the difference " would Mr. Hart admit that any decline in wireline long distance revenues is due
in substantial part to the use by consumers of wireless phones to place long distance calls?
Mr. Hart denies this, please fully explain and identify all facts and documents supporting such
denial.
REQUEST FOR PRODUCTION NO. 2-Please produce all documents identified in
response to Interrogatory No. 2-
INTERROGATORY NO. 2-Mr. Hart speaks generally about wireless carriers and
their plans between page 13, line 23, and page 14, line 5. Identify specifically which plans of
which companies Mr. Hart is citing in that section of his Direct Testimony.
REQUEST FOR PRODUCTION NO. 2-For all wireless plans identified in
response to Interrogatory No. 2-, produce all documents in Staffs possession concerning those
plans.
REQUEST FOR PRODUCTION NO. 2-Please provide any studies or other
empirical evidence available to Staff or its consultant, relative to Idaho or any other state
showing that a change in the relationship between wireless and wire line service prices (either by
wireline service prices increasing or wireless service prices decreasing) does not have a cross-
elastic demand impact between these services.
REQUEST FOR PRODUCTION NO. 2-Produce all surveys, studies, facts and
documents supporting Mr. Hart's testimony at page 13 of his Direct Testimony that wireless
carriers typically charge 20 cents or more per minute for all long distance calls in excess of
included minutes.
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REQUEST FOR PRODUCTION NO. 2-Produce all surveys, studies, facts and
documents supporting Mr. Hart's testimony at page 14 of his Direct Testimony that wireless
carriers typically charge 45 cents per minute for excess minute charges.
REQUEST FOR PRODUCTION NO. 2-10:At page 15 of his testimony, Mr. Hart
asserts "sometimes a wireless customer s call is carried by another company, even though they
are located in their home area or even in their home.Please provide all document, studies
reports or other empirical evidence available to you that this occurs in Idaho.
INTERROGATORY 2-Mr. Hart testifies that wireless service quality is inferior to
wireline service quality. Assuming arguendo that this is a true statement, does Staff believe the
average consumer of telephone services in the seven exchanges is aware of this fact?
INTERROGATORY NO. 2-10:Fully explain and identify all facts and documents that
support Mr. Hart's assertion at page 19 of his testimony that
, "
(wJhile this sampling is small
(referring to the fifty calls made on March 17, 2003 J, I believe it is sufficient to be generally
considered statistically significant." In responding, please identify the population of which Mr.
Hart believes the fifty calls was a statistically significant sample and state the total number of
calls made on an average day for the identified population.
REQUEST FOR PRODUCTION NO. 2-11:Please produce all documents identified
in response to Interrogatory No. 2-10 and all documents relied upon to provide said response.
INTERROGATORY NO. 2-11:Does Staff contend that a wireless customer
subscribing to an unlimited usage plan will, or is more likely to, experience poorer service
quality than 1) a wireless customer of the same wireless carrier subscribing to a limited usage
plan or 2) a wireless customer whose provider does not offer an unlimited usage plan? If your
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answer is other than simply "" identify all studies, surveys, data, facts or documents that
support this opinion.
REQUEST FOR PRODUCTION NO. 2-12:Produce all documents identified in
response to Interrogatory No. 2-11.
REQUEST FOR PRODUCTION NO. 2-13:Produce all studies, surveys, data, facts or
documents indicating or supporting a belief that individuals calling 911 from home are more
likely to experience network congestion, signal blockage or other connection difficulties than a
wireline customer calling 911 from home.
REQUEST FOR PRODUCTION NO. 2-14:Produce all studies, surveys, data, facts or
documents supporting Mr. Hart's testimony at page 23 that "(aJ voice grade line usually allows
users to connect at speeds between 28 000 and 53 000 baud, with typical connection speeds in
the low 40'
REQUEST FOR PRODUCTION NO. 2-15:Produce all studies, surveys, data, facts or
documents supporting Mr. Hart's testimony at page 23 that "(gJeneral wireless Internet
connections are much slower, typically between 9600 and 14 400.
REQUEST FOR PRODUCTION NO. 2-16:Produce all reports, studies, price lists
and other empirical evidence to support Mr. Hart's statement on page 24 of his testimony that
usage of wireless services for data applications could lead to a cancellation of wireless service.
INTERROGATORY NO. 2-12:Identify all known pockets within the seven exchanges
where wireless services is not available.
REQUEST FOR PRODUCTION NO. 2-17:Produce all studies, surveys, data, maps
facts or documents supporting Staffs opinion that wireless service is not available in the pockets
identified in Interrogatory No. 2-12.
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REQUEST FOR PRODUCTION NO. 2-18:Produce all studies, surveys, data, facts or
documents supporting Mr. Hart's testimony at page 27 that "(wJireless signals also do not travel
well through brick or concrete.
INTERROGATORY NO. 2-13:Identify all facts and documents supporting Mr. Hart'
testimony generally concerning the Legislature s intent in enacting Idaho Code 9 62-622(3).
REQUEST FOR PRODUCTION NO. 2-19:Produce all documents identified in
response to Interrogatory No.
REQUEST FOR PRODUCTION NO. 2-20:Produce a copy of the contract and
engagement correspondence between Dr. Johnson (or his employer) and Staff in connection with
this case. Please also produce copies of all travel vouchers, invoices and receipts submitted to or
paid by or for the Commission for Dr. Johnson.
REQUEST FOR PRODUCTION NO. 2-21:On page 9 of his testimony, Dr. Johnson
defines "functionally equivalent" as follows
, "
(aJccordingly, for two services to be 'functionally
equivalent' these services need to be virtually identical with respect to their functional attributes-
those characteristics of the service which relate directly to the purpose for which each service is
specially fitted or used." Please produce any state or federal decision or any scholarly article or
report that has adopted this definition of "functionally equivalent."
REQUEST FOR PRODUCTION NO. 2-22:Produce all studies or surveys Dr.
Johnson performed, administered, relied upon or reviewed in order to probe whether consumers
perceive wireless and wireline services to be functionally equivalent.
INTERROGATORY NO. 2-Is Dr. Johnson aware of any empirical studies or
surveys that contradict Dr. Lincoln s survey results and findings? If so, please identify all such
studies or surveys.
QWEST CORPORATION'S SECOND INTERROGATORIES AND
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REQUEST FOR PRODUCTION NO. 2-23:Produce all documents identified in
response to Interrogatory No. 2-14.
REQUEST FOR PRODUCTION NO. 2-24:Produce all research, reports, studies or
other empirical evidence relied upon to support Dr. Jo~son s statement at page 11 of his
testimony that "because of important functional differences, the vast majority of consumers do
not substitute wireless for wireline services or vice versa." By this request Qwest seeks all
documents that support Dr. Johnson s conclusions as to why the vast majority of consumers" do
not substitute.
INTERROGATORY NO. 2-15:Starting on page 12 at line 23 of his testimony, Dr.
Johnson testifies that "(iJf the two services were functionally equivalent, they would tend to be
redundant and thus most people would decide it was a waste of money to pay for both services at
the same time.Identify all studies, surveys, data, facts and documents supporting this
conclusion.
REQUEST FOR PRODUCTION NO. 2-25:Produce all documents identified in
response to Interrogatory No. 2-15.
INTERROGATORY NO. 2-16: Define and contrast the terms "substitute" and "close
substitute" used by Dr. Johnson on page 14 of his testimony.
INTERROGATORY NO. 2-17:At page 16 of his testimony, Dr. Johnson testifies that
( s Jome consumers stop purchasing Qwest's services when they obtain a mobile phone but even
these consumers don t necessarily consider these services to be 'close substitutes' nor do they
necessarily think they are functionally equivalent." (Emphasis added)Identify all studies
. surveys, data, facts and documents supporting the underlined conclusion reached by Dr. Johnson.
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REQUEST FOR PRODUCTION NO. 2-26:Produce all documents identified in
response to Interrogatory No. 2-17.
INTERROGATORY NO. 2-18:At page 17 of his testimony, Dr. Johnson testifies that
most consumers only use mobile phone (sic J when they need to place a call while traveling
around-because of the usage fees associated with wireless, calls poorer sound quality, physical
discomfort, or other reasons." Identify all studies, surveys, data, facts and documents supporting
this conclusion.
REQUEST FOR PRODUCTION NO. 2-27:Produce all documents identified in
response to Interrogatory No. 2-18.
REQUEST FOR PRODUCTION NO. 2-28:Please produce the Yankee Group study
referenced on page 16 of Dr. Johnson s testimony.
INTERROGATORY NO. 2-19:Please provide Staffs technical explanation as to why
some mobile phones warm up during usage" as Dr. Johnson alleges on page 25 of his testimony
and provide the technical specifications relied upon by Dr. Johnson in making that statement.
Please identify the make and model of phones that have been known to "warm up" and identify
all research addressing this situation or which identify this condition as being a detriment to
mobile phone usage.
REQUEST FOR PRODUCTION NO. 2-29:Please produce all documents identified
in your response to Interrogatory No. 2-19.
REQUEST FOR PRODUCTION NO. 2-30:Produce all studies, surveys, data, facts
and documents that support Dr. Johnson s statement on page 25 that "given a choice between
pulling a cell phone out of their pocket or walking across the room to use a conventional phone
consumers will often choose the latter option because of the quality differences.
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INTERROGATORY NO. 2-20:With respect to any surveys or research studies
produced in response to Request for Production No. 2-, please identify the number of
consumers evaluated, the location and date of such evaluation, and explain the quality
differences that were present at that specific location at that specific point in time for both
wireline and wireless services. Please also identify the firm that conducted the research.
REQUEST FOR PRODUCTION NO. 2-31:Produce all studies, surveys, data, facts
and documents supporting a conclusion that the safety concerns identified by Dr. Johnson on
page 27 of his testimony affect customer choice between use of a wireline and wireless phone.
REQUEST FOR PRODUCTION NO. 2-32:Produce all studies, surveys, data, facts
and documents supporting the conclusion that the ergonomic factors identified in Dr. Johnson
testimony affect consumer choice between use of a wireless and wireline phone.
INTERROGATORY NO. 2-21:On page 30 of his testimony, Dr. Johnson testifies that
(tJhese types of transmissions (fax and internetJ take place using sounds that occur within the
same frequency range as the human voice.Identify all studies, surveys, data, facts and
documents supporting this conclusion. In addition, does Staff contend that fax and internet
transmissions are, in fact
, "
voice" transmissions? If your answer is other than "" please fully
explain your answer and identify all studies, surveys, data, facts and documents supporting your
response.
REQUEST FOR PRODUCTION NO. 2-33:Produce all documents identified in
response to Interrogatory No. 2-21.
REQUEST FOR PRODUCTION NO. 2-34:On page 31 of his testimony, Dr. Johnson
testifies that "wireline customers J would continue to do so (pay for wireline service J even if the
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price of wire line service were to increase substantially.Produce all price elasticity studies
surveys, data, facts and documents supporting this conclusion.
INTERROGATORY NO. 2-22:Between page 33 , line 3, and page 34, line 16 of his
testimony, Dr. Johnson offers several observations about how wireless services are priced.
Identify all wireless plans reviewed by Dr. Johnson to draw these conclusions and all studies
surveys, data, facts and documents supporting these conclusions.
REQUEST FOR PRODUCTION NO. 2-35:Produce all documents identified in
response to Interrogatory No. 2-22.
INTERROGATORY NO. 2-23:On page 37 of his testimony, Dr. Johnson testifies that
some wireless prices have been declining. However, there are indications that this downward
trend has slowed.Identify all studies, surveys, data, facts and documents supporting the
conclusion that the downward trend in wireless pricing has slowed.
REQUEST FOR PRODUCTION NO. 2-36:Produce all documents identified in
response to Interrogatory No. 2-23.
INTERROGATORY NO. 2-24:Are there any circumstances under which Dr. Johnson
could foresee that wireless service could be found by the Commission to be "functionally
equivalent" to wireline basic local exchange service? If so, please specifically describe such
circumstances.
INTERROGATORY NO. 2-25:As a matter of public policy, does Staff contend that
any Commission decision in connection with a Idaho Code 9 62-622(3) application that will lead
to increased rates for basic local exchange service for some or all customers is de facto contrary
to the public interest? Please fully explain your answer and specify the circumstances under
which Staff would not consider such a rate increase to be contrary to public policy.
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INTERROGATORY NO. 2-26:As a matter of public policy, does Staff contend that
any Commission decision in connection with a Idaho Code 9 62-622(3) application that could
lead to increased rates for basic local exchange services for some or all customers is de facto
contrary to the public interest? Please fully explain your answer and specify the circumstances
under which Staff would not consider the possibility of such an increase to be contrary to public
policy.
INTERROGATORY NO. 2-27:As a matter of public policy, does Staff contend that
Qwest's residential and small business customers in the more populous, urban regions of the
state should subsidize or support the cost of basic local exchange service for Qwest's residential
and small business customer in the less populous, rural regions of the state? Please fully explain
your answer.
Respectfully submitted this 2nd day of April, 2003.
Qwest Corporation
(JJ ~~4 fJn Mary S. Hobson
Stoel Rives LLP
Adam L. Sherr
Qwest Corporation
Attorneys for Qwest Corporation
QWEST CORPORATION'S SECOND INTERROGATORIES AND
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CERTIFICATE OF SERVICE
I hereby certify that on this 2nd day of April, 2003 , I served the foregoing QWEST
CORPORATION'SECOND INTERROGATORIES AND REQUEST FOR
PRODUCTION OF DOCUMENTS TO STAFF upon all parties of record in this matter as
follows:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, ill 83720-0074
Phone: [phone]
Fax: [phone]
ii ewell0lpuc. state.id. us
Weldon Stutzman, Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
W stutzm~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
Executed protective agreement
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
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Email
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Email
Hand Delivery
~ U.Mail
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~ U.Mail
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Email
QWEST CORPORATION'S SECOND INTERROGATORIES AND
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Dean J. Miller
McDevitt & Miller LLP
420 West Bannock Street
O. Box 2565
Boise, ill 83701
Telephone: [phone]
Facsimile: [phone]
oe~mcdevitt -miller .com
Attorneys for Time Warner Telecom
Executed protective agreement
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Dean Randall
Verizon Northwest Inc.
17933 NW Evergreen Parkway
Beaverton, OR 97006-7438
dean.randall ~verizon. co
Executed protective agreement
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Mary Jane Rasher
10005 South Gwendelyn Lane
Highlands Ranch, CO 80129-6217
Telephone: [phone]
mirasher~msn.com
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Adam Sherr
Qwest
1600 ih Avenue - Room 3206
Seattle, W A 98191
Telephone: [phone]
Facsimile: [phone]
asherr~qwest.com
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Clay R. Sturgis
Moss Adams LLP
601 West Riverside - Suite 1800
Spokane, W A 99201-0663
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Email
Brian Thomas
TimeWarner Telecom
223 Taylor Avenue North
Seattle, W A 98109
Brian. Thomas~twtelecom. com
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U. S. Mail
Overnight Delivery
Facsimile
Email
QWEST CORPORATION'S SECOND INTERROGATORIES AND
REQUESTS FOR PRODUCTION OF DOCUMENTS TO STAFF - Page 16
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Susan Travis
WorldCom, Inc.
707 1 ih Street - Suite 4200
Denver, CO 80202
Telephone: [phone]
Susan.a. Travis((U,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~givenspursley.com
Attorneys for Idaho Telephone Association
Executed protective agreement
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' . // /
i./
OA (t71(l~,~(7i(! rZ1t/
Brandi L. Gearhart, PLS
Legal Secretary to Mary S. Hobson
Stoel Rives LLP
QWEST CORPORATION'S SECOND INTERROGATORIES AND
REQUESTS FOR PRODUCTION OF DOCUMENTS TO STAFF - Page 17
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