200304172nd Response of Commission to Qwest.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 3283
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
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RECEIVED
FILED
2003 APR f 6 PH It: 05
/C/\i-!J PUbLIC
UTILITIES COMMISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
QWEST CORPORATION FOR DEREGULATION OF BASIC LOCAL
EXCHANGE RATES IN ITS BOISE, NAMPA,
CALDWELL, MERIDIAN, TWIN FALLS,
IDAHO FALLS, AND POCATELLO EXCHANGES. '
CASE NO. QWE- T -02-
COMMISSION STAFF
RESPONSE TO QWEST'
SECOND INTERROGATORIES
AND REQUESTS FOR
PRODUCTION OF
DOCUMENTS
The Staff of the Idaho Public Utilities Commission by and through its attorney of record
Weldon B. Stutzman, Deputy Attorney General, hereby responds to Qwest Corporation s Second
IntelTogatories and Requests for Production of Documents to Staff filed April 1 , 2003.
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 IntelTogatory, "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 behalfMr.
Hart) identified and produced in this case. By "credentials " Qwest seeks an identification of
STAFF'S RESPONSE TO QWEST'S SECOND
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specific educational, vocational and first hand research experiences, as well as any studies
reports or publications authored by Mr. Hart.
Response to Interrogatory No.I: Staff objects to this IntelTogatory on the grounds
that is vague in its use of the term "expert opinion testimony" and appears to be inconsistent with
evidentiary rules regarding expert witness testimony. Without waiving that objection, Staff
responds as follows: Mr. Hart has over 16 years of experience in the utility industry, working
with water, sewer, electric, gas and telecommunications industries, the past six have been
devoted almost exclusively to telecommunications. His knowledge of wireless
telecommunication has been gained through experience working exclusively with
telecommunication issues during the last six years. He has not authored any previous work
directly related to wireless telecommunications.
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 IntelTogatory, "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.
Response to Interrogatory No. 2-2: : Staff objects to this IntelTogatory on the grounds
that is vague in its use of the term "expert opinion testimony" and appears to be inconsistent with
evidentiary rules regarding expert witness testimony. Without waiving that objection, Staff
responds as follows: Dr. Johnson received a B.A. in Economics from the University of South
Florida. Dr. Johnson received an M.S. in Economics and a Ph. D. in Economics from Florida
State University. For more than 25 years, Dr. Johnson has specialized as a consultant and expert
witness in telecommunications and other public utility industries. During the course of this
work, Dr. Johnson has testified as an expert witness in hundreds of proceedings involving
telecommunications providers and the telecommunications industry. Dr. Johnson also routinely
monitors news, FCC reports, and other publicly available information concerning various
segments of the telecommunications industry, including providers of wireless service and the
STAFF'S RESPONSE TO QWEST'S SECOND
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technologies they rely upon. In addition, Dr. Johnson and his staff maintain a website-
www.utilitvregulation.com-whichprovides news and information concerning the
telecommunications industry, including PCS and cellular carriers. Because of Dr. Johnson
education, experience and expertise, he is qualified to assist the Commission as an expert witness
in this proceeding, particularly with respect to the topics discussed in his pre filed testimony.
REQUEST FOR PRODUCTION NO.Please produce all documents identified in
response to Interrogatory Nos. 2-1 and 2-
Response to Production Request No.I: A copy of Dr. Johnson s resume is attached
as Attachment A (electronic).
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 oflocal services (Emphasis added.) Describe
whether "local services" Mr. Hart meant to refer to "basic local exchange services " as that term
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.
Response to Interrogatory No. 2-3: Staff objects to this Interrogatory to the extent it
attempts to elicit a legal analysis from Mr. Hart. Without waiving that objection, Staff responds
as follows: Mr. Hart explained in his testimony why it is necessary to compare the different
functions and features of the services provided by wireline and cellular services. That position is
consistent with much of the testimony provided by Qwest's witnesses where reference is made to
something other than "basic local exchange service " and functions and features between
wireline and cellular services are referenced or compared. For example, Mr. Souba states his
opinion that "the ubiquity of communication services offered by a multitude of wireless
providers throughout the seven exchanges satisfies the requirements of this statute for economic
deregulation." Souba direct, p. 3. Mr. Souba notes that Mr. Teitzel "provides testimony
STAFF'S RESPONSE TO QWEST'S SECOND
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regarding the functional equivalency between wireless services and traditional land-line service.
Souba direct, p. 5. Likewise, Mr. Souba opines that "customers have embraced wireless
technology as a competitive alternative to traditional land-line service." Souba direct, p. 25. Mr.
Teitzel in his testimony opines that "wireless providers now serving Idaho customers represent
effective competition to Qwest's traditionallandline services." Teitzel direct, p. 3. At page 8 of
his testimony, Mr. Teitzel selects five "service attributes" of local service he compares with
service attributes available from wireless service providers. Qwest Exhibit 13 includes a
comparison of "service attributes" between wireline and wireless services. These are just a few
examples in Qwest's testimony where its witnesses compare or reference different functions
between wireline and wireless services. Staff agrees that it is necessary to compare the functions
of the different services to determine whether they are functionally equivalent and competitively
priced and whether wireless services effectively compete with Qwest's local service so that
competition can effectively replace regulation in protecting the public interest.
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.
Response to Interrogatory No. 2-4: Mr. Hart was merely stating a self-evident
characteristic of Section 62-622 and was not attempting to provide a legal analysis of the statute.
REQUEST FOR PRODUCTION NO. 2-: Please produce all documents identified in
response to Interrogatory No. 2-
Response to Production Request No. 2-2: No documents identified.
INTERROGATORY NO. 2-5: 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.
STAFF'S RESPONSE TO QWEST'S SECOND
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Response to Interrogatory No. 2-5: Staff objects to this question as presented.
Although Mr. Hart does not dispute Dr. Lincoln s value proposition theory as an economic
concept, Mr. Hart is not a trained economist. Staff witness Dr. Johnson has obtained educational
degrees in economics and is better qualified to respond to questions regarding Dr. Lincoln
value proposition theory, which may have little relevance to this case. The theory apparently is
used by Dr. Lincoln in an attempt to compare services that have different functions and prices
and which are purchased by customers as complementary to each other, rather than as
substitutes.
REQUEST FOR PRODUCTION NO. 2-Please produce all documents identified in
response to Interrogatory No. 2-
Response to Production Request No. 2-3: No documents identified.
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 J." Identify all facts and documents Mr. Hart reviewed
or relied upon to draw this conclusion.
Response to Interrogatory No. 2-6: The facts and documents relied upon by Mr. Hart
were identified in Exhibit 102, and provided in response to Production Request 1-
REQUEST FOR PRODUCTION NO. 2-Please produce all documents identified in
response to Interrogatory No. 2-
Response to Production Request No. 2-4: No documents identified.
INTERROGATORY NO. 2-With regard to Mr. Hart's statement at page 13 ofhis
Direct Testimony that "the average customer does not spend enough on long distance to make up
the difference" would Mr. Hart admit that any decline in wireline long distance revenues is due
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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.
Response to Interrogatory No. 2-7: Staff objects to this Interrogatory as vague in its
use of terms susceptible to different interpretations. Without waiving its objection, Staff
responds as follows: Mr. Hart would admit that a decline in wireline long distance revenues may
result from several causes, including use of pre-paid calling cards, lower prices resulting from
competition among long distance providers, increased use of electronic mail, stagnant or
depressed economy, and use of cell phones.
REQUEST FOR PRODUCTION NO. 2-Please produce all documents identified in
response to Interrogatory No. 2-
Response to Production Request No. 2-5: No documents identified
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.
Response to Interrogatory No. 2-8: The plans used for each wireless company is
identified in the spreadsheet "Wireless Plan Samples" provided in response to Request for
Production No. 1-
REQUEST FOR PRODUCTION NO. 2-For all wireless plans identified in
response to Interrogatory No. 2-8 , produce all documents in Staffs possession concerning those
plans.
Response to Production Request No. 2-6: The spreadsheet "Wireless Plan Samples
was provided in response to Request for Production No. 1-
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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 wireline service prices (either by
wireline service prices increasing or wireless service prices decreasing) does not have a cross-
elastic demand impact between these services.
Response to Production Request No. 2-7: Other than requesting a copy of the similar
studies used by Qwest in its preparation of its application, to which the company replied it did
not have any such studies, Staffhas not sought such studies and therefore does not have any such
studies in its possession. The studies identified by Dr. Johnson in response to Interrogatory 2-
include some discussion of the economic relationship between wireline and wireless
telecommunication 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
included minutes.
Response to Production Request No. 2-8: The long distance rates for the various plans
for each wireless company are identified in the spreadsheet "Wireless Plans" provided in
response to Request for Production No. 1-3. The source ofthe information for this spreadsheet
was the web pages of each wireless company. Copies of a printout of the web page of a few
examples of such rates are attached as Attachment B.
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.
Response to Production Request No. 2-9: The excess minute rates for the various plans
for each wireless company are identified in the spreadsheet "Wireless Plans" provided in
response to Request for Production No. 1-3. The source of the information for this spreadsheet
STAFF'S RESPONSE TO QWEST'S SECOND
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was the web pages of each wireless company. Copies of a printout of the web page of a few
examples of such rates are attached as Attachment C.
REQUEST FOR PRODUCTION NO. 2-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.
Response to Production Request No. 2-10: Staff does not have any studies or other
documents showing that a wireless customer s call in Idaho may be carried by another company.
Mr. Hart identified this as a characteristic of wireless service in general and has no reason to
believe it does not occur in Idaho. A copy of an article identifying this problem is attached
Attachment D.
INTERROGATORY NO. 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?
Response to Interrogatory No. 2-9: Included as part ofMr. Hart's testimony are copies
of articles addressing the inferior quality of wireless services. These and other articles are
readily available to the average consumer of telephone services. Such articles have run in
publications, such as Consumer Reports, which are widely read, and these articles have
subsequently been quoted by other local publications, such as the Idaho Statesman. On lines 15-
20 of page 17 of his testimony, Mr. Hart referred to a comment by Mr. Travis Larson, a
spokesperson for the wireless industry trade association, who was quoted as saying "Consumers
know when they pick up a wireless phone they re making a trade off between mobility and
service quality." Staff has no reason to believe Idaho consumers are any less informed than the
users to which Mr. Larson was referring. In addition, Staff believes the average Idaho user of
wireless services is aware from experience of the service quality differences.
STAFF'S RESPONSE TO QWEST'S SECOND
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INTERROGATORY NO. 2-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, 2003J, 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.
Response to Interrogatory No. 2-10: Mr. Hart's assertion that 50 calls would generally
be considered statistically significant was based upon his understanding of the principles of
statistics gained from his graduate study at the University of Wisconsin, and recently updated by
participating in the statistics tutorial and other statistics discussions that were part of the ROC
multi-state test of Qwest's operational support systems. Mr. Hart has not made any calculations
or further analysis of the data. The population being tested was wireless phone call attempts
during a peak period of the day.
REQUEST FOR PRODUCTION NO.Please produce all documents identified
in response to Interrogatory No. 2- 10 and all documents relied upon to provide said response.
Response to Production Request No. 2-11: No documents identified.
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 I) 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
answer is other than simply "" identify all studies, surveys, data, facts or documents that
support this opinion.
Response to Interrogatory No.II: Staff is not aware of any studies or empirical
evidence comparing the service quality of wireless companies with per minute fees with those
that provide unlimited usage for a flat rate. Staff believes that wireless service quality is highly
dependent upon the facilities the wireless company has in place in a community and the load
STAFF'S RESPONSE TO QWEST'S SECOND
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placed upon those facilities by its customers. Any wireless company, regardless of how it prices
its services, may not have sufficient facilities for its customer base to meet its peak usage
periods. However, Staff believes that a company that provides unlimited usage for a fixed fee is
likely to experience greater peak usage than a company that charges for usage by the minute.
the costs for a wireless company are sensitive to the amount of usage, this higher peak usage
would require more investment, yet the flat rate structure would generate no additional funding
to pay for this investment. Such companies might be under more pressure to trade off quality for
reduced investment.
REQUEST FOR PRODUCTION NO. 2-Produce all documents identified in
response to Interrogatory No. II.
Response to Production Request No. 2-12: No documents identified.
REQUEST FOR PRODUCTION NO. 2-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.
Response to Production Request No. 2-13: Staff is not aware of any studies or
documents that directly compare the probability of a problem when calling 911 from home using
a wireless phone with calls ptaced from home using a wireline phone. Mr. Hart's testimony
identified problems in reaching 911 that had been confirmed by Consumer Reports in two
separate locations. Staff has no reason to believe similar problems are not occurring in Idaho.
Staff s primary concern regarding wireless 911 remains its inability to provide accurate location
information to the E-911 PSAPs located in these seven exchanges.
REQUEST FOR PRODUCTION NO. 2-Produce all studies, surveys, data, facts or
documents supporting Mr. Hart's testimony at page 23 that "(a) 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'
STAFF'S RESPONSE TO QWEST'S SECOND
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Response to Production Request No. 2-14: This comment was primarily based upon
Mr. Hart's personal experience and knowledge of data transmission capabilities, gained through
over 20 years of experience in personal computing and data transmission over wireline
connections.
REQUEST FOR PRODUCTION NO. 2-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.
Response to Production Request No. 2-15: This comment was based upon Mr. Hart'
personal knowledge, gained through reading of magazine articles and information on the
Internet. The following web site is an example of such information. A copy of a print-out from
this site is attached: http://cellphones.about.com/librarylbl qa wireless data.htm. See
Attachment E.
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.
Response to Production Request No. 2-16: Please see item No.Prohibited Uses
the following web site:
www.cricketcommunications.com/terms.asp#ternls%20and%2 Ocondi tions %200 f%20service
INTERROGATORY NO. 2-Identify all known pockets within the seven exchanges
where wireless services is not available.
Response to Interrogatory No. 2-12: Staff did not attempt to locate all pockets within
the seven exchanges where wireless service is not available. Qwest maintains the burden to
establish that wireless service is functionally equivalent and readily available in the seven
exchanges. Based upon conversations with consumers with held orders for wireline service
STAFF'S RESPONSE TO QWEST'S SECOND
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Staff understands that wireless service is not available to some customers in the Robie Creek
area of the Boise exchange. Conversations with customers at the Pocatello workshop held in this
proceeding indicated wireless service was not available to some customers in the Pocatello Creek
area of the Pocatello exchange.
Based upon Staff s understanding of the propagation of wireless signals, the basic theory
of the design of cell systems and the locating of towers, as well as reports from other states of
pockets within residential neighborhoods where signals are not available, Staff has reason to
believe additional such locations exist in these seven exchanges.
REQUEST FOR PRODUCTION NO. 2-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.
Response to Production Request No. 2-17: No documents or surveys available.
REQUEST FOR PRODUCTION NO. 2-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.
Response to Production Request No. 2-18: Mr. Hart based this claim upon his general
knowledge about the characteristics of electromagnetic energy in the frequencies used by
wireless technology, his personal experience in using wireless phones, and his observations of
others using wireless phones. The attached printouts from the following web pages provide
additional confirmation of this claim as Attachment F:
www.criterioncellular.com/htmllbasics.htmi
http://www.cellantenna.com/common question requires simple.htm
INTERROGATORY NO. 2-Identify all facts and documents supporting Mr. Hart'
testimony generally concerning the Legislature s intent in enacting Idaho Code 9 62-622(3).
STAFF'S RESPONSE TO QWEST'S SECOND
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Response to Interrogatory No. 2-13: The Legislature s intent was identified in the
statement of intent contained in Idaho Code 9 62-602. In addition, the testimony of two of
Qwest's witnesses referred to Staff testimony in Case No. USW-99-15 presented by Joe
Cusick, in which Mr. Cusick characterizes the Legislature s intent in enacting Idaho Code 9 62-
622 as follows:
Regulation is a substitute for competition. It is an imperfect substitute, but
without competition, a necessary one. Its purpose is to protect consumers
from companies that may take advantage of a monopoly position by charging
excessive rates or providing an inferior grade of service. In addition
regulation helps ensure that rural, high-cost areas have service available at
reasonable, affordable rates.
The legislature passed S 62-622(3) in recognition of the fact that once
competition is present throughout an exchange, it affords customers sufficient
protection. Therefore, regulation is no longer necessary. The assessment of
the Application must then focus on whether or not competition is present
throughout the exchange and whether competitive forces are sufficient to
protect customers.
Finally, the Commission reviewed the Legislature s stated intent in Order No. 28369
Case No. USW - T -99-, concluding "the legislature stated and reiterated that competition must
be actual, effective, substantive and meaningfuL.. ..before the Commission is required by law to
cease regulating basic service rates." Order No. 28369
, p.
REQUEST FOR PRODUCTION NO. 2-Produce all documents identified in
response to Interrogatory No.
Response to Production Request No. 2-19: No documents, other than the referenced
section of the Idaho Code and Qwest's testimony in this case and Order No. 28369 , were
identified.
REQUEST FOR PRODUCTION NO. 2-Produce a copy of the contract and
engagement correspondence between Dr. Johnson (or his employer) and Staff in connection with
STAFF'S RESPONSE TO QWEST'S SECOND
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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.
Response to Production Request No. 2-20: Staff objects to this request to the extent its
seeks to obtain confidential communications protected by the attorney-client privilege or is
attorney work product. Without waiving any objection, a copy ofthe contract and the three
invoices received to date are attached as Attachment G.
REQUEST FOR PRODUCTION NO. 2-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."
Response to Production Request No. 2-21: Dr. Johnson is not aware of any decisions
articles or reports which have adopted this or any other specific definition of the term
functionally equivalent."
REQUEST FOR PRODUCTION NO. 2-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.
Response to Production Request No. 2-22: Dr. Johnson reviewed the studies and
surveys provided by Qwest during the course of this proceeding, which will not be reproduced in
response to this request. In addition to those studies and surveys, Dr. Johnson also considered
responses to a poll conducted by the Wall Street Journal in which it asked readers whether they
would consider eliminating their land line and using only their wireless phone. Those responses
can be viewed at the following web page:
http://discussions.wsi .com/n/mb/message.asp ?webtag=wsivoices&nav=messages&msg=2499 .619
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Dr. Johnson also considered information gathered in a survey conducted by the National
Regulatory Research Institute. A discussion of the results of that survey are included in:
Consumer Utility Benchmark Survey: A Comparison of Consumer Perceptions of Customer
Service Francine Sevel, Ph.D. and Ling Bei Xu, February, 2003. A copy of the survey is
attached as Attachment H (electronic).
As part of the its survey, NRRI asked respondents whether they planned various actions
with respect to their wireless telephone, including the possibility of "disconnecting home
telephone." Although the results of this particular question were not included in the published
report mentioned above, based upon communications with personnel at NRRI, it is Dr. Johnson
understanding that approximately 5.7% of the respondents in the NRRI West region
affirmatively responded to this possibility. This data suggests that very few customers are
seriously considering the option of substituting a wireless telephone for their landline telephone.
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.
Response to Interrogatory No. 2-14: Based upon the results of two studies, Dr. Lincoln
concludes:
(RJesidential and small business customers perceive wireless services to
represent a functionally equivalent, competitively priced, and reasonably
available alternative to Qwest's basic local exchange service in these
seven exchange areas.
Dr. Johnson is not aware of any studies or surveys demonstrating the extent to which
consumers in these exchanges perceive wireless services to be a functionally equivalent
competitively priced and reasonably available alternative to wireline services. In fact, the above
quoted "findings" by Dr. Lincoln go well beyond his actual survey data. Dr. Johnson has not
conducted an exhaustive search of other studies and surveys relating to this issue, but he is aware
of studies which tend to contradict Dr. Lincoln s findings, particularly with regard to the
question of whether wireless and landline service are close substitutes. See, for example, the
following publications:
STAFF'S RESPONSE TO QWEST'S SECOND
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An Economic Analysis of the Demand for Access to Mobile Tele?hone Networks, Hyungtaik
Ahn and Myeong-Ho Lee, Information Economics and Policy 11 , p. 297 (1999)
Are Main Lines and Mobile Phones Substitutes or Complements? Evidence from Africa
Jacqueline Hamilton, Telecommunications Policy 27, p. 109 (2003)
Going Mobile: Substitutability Between Fixed and Mobile Access, Mark Rodini, Michael R.
Ward and Glenn A. Woroch, Telecommunication Policy
p.
(2003)
REQUEST FOR PRODUCTION NO. 2-Produce all documents identified in
response to Interrogatory No. 2- 14.
Response to Production Request No. 2-23: See attached as Attachment I (electronic).
REQUEST FOR PRODUCTION NO. 2-Produce all research, reports, studies or
other empirical evidence relied upon to support Dr. Johnson 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 "
not substitute.
Response to Production Request No. 2-24: Dr. Johnson relied in part upon the
responses to Qwest's surveys and other information provided by the Company in this
proceeding. This information will not be reproduced in response to this request. Dr. Johnson
also relied in part upon responses to the Wall Street Journal poll referenced in response to
Request for Production 2-22. Dr. Johnson also relied in part upon discussions with family
members, friends and coworkers.
INTERROGATORY NO. 2-Starting on page 12 at line 23 of his testimony, Dr.
Johnson testifies that "(iJfthe 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.
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PRODUCTION OF DOCUMENTS APRIL 16, 2003
Response to Interrogatory No. 2-15: Dr. Johnson s conclusion is based upon his
education, experience, and common sense. If two products or services have the same or
equivalent functional attributes and they serve all of the same purposes, many consumers would
find that they have no need to purchase both, and they could save money by purchasing only one
(e.g. whichever is cheaper). Dr. Johnson is not aware of any studies or surveys specifically
focusing on the question of functional equivalency. However, he is aware of various data that
suggests relatively few consumers are eliminating their landline because it is redundant to their
wireless phone. The fact that most wireless users continue to pay for a landline supports the
conclusion that wireless and wireline services have different functional attributes, and they are
not redundant.
REQUEST FOR PRODUCTION NO. 2-Produce all documents identified in
response to Interrogatory No. 2-15.
Response to Production Request No. 2-25: No documents identified. See also
response to 2-23.
INTERROGATORY NO. 2-Define and contrast the terms "substitute" and "close
substitute" used by Dr. Johnson on page 14 of his testimony.
Response to Interrogatory No. 2-16: At a basic level, all products can be classified as
substitutes or complements. Whether two products are substitutes or complements depends upon
their cross price elasticities. Products are categorized as substitutes if an increase in the price of
one increases the demand for the other, or a decrease in the price of one decreases the demand
for the other. A more detailed analysis indicates that products can have multiple attributes, and
can serve multiple functions. Hence, products can both be complementary to and serve as a
substitute for another product. In classifying products, economists focus on the net effect of
these factors. Products will likely have negative cross price elasticities, and thus be classified as
substitutes" if many of their attributes are similar and they serve similar functions (are used for
similar or identical purposes). The term "close substitutes" is not as precisely defined, but in
STAFF'S RESPONSE TO QWEST'S SECOND
INTERROGATORIES AND REQUESTS FOR
PRODUCTION OF DOCUMENTS APRIL 16, 2003
general it describes the relationship between two products in which many, if not all, of their
attributes are very similar, if not identical. For example, gasoline and diesel fuel might be
categorized as "substitutes , whereas Exxon and BP regular grade unleaded gasoline might be
categorized as "close substitutes.
INTERROGATORY NO. 2-At page 16 of his testimony, Dr. Johnson testifies that
(sJome 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.
Response to Interrogatory No. 2-17: Dr. Johnson has not had occasion to identify all
studies, surveys, data, facts and documents supporting this conclusion. However, the following
studies generally support the general conclusion that wireless and wireline services are not close
substitutes, and may not even be unambiguously classified as substitutes: The Technology and
Economics Of Cross-Platform Competition In Local Telecommunications Markets, Richard A.
Chandler, A. Daniel Kelley and David M. Nugent, April 4, 2002 (HAl Report); An Economic
Analysis of the Demand for Access to Mobile Telephone Networks, Hyungtaik Ahn and
Myeong-Ho Lee, Information Economics and Policy 11 , p. 297 (1999); Are Main Lines and
Mobile Phones Substitutes or Complements? Evidence from Africa, Jacqueline Hamilton
Telecommunications Policy 27, p. 109 (2003): Going Mobile: Substitutability Between Fixed
and Mobile Access, Mark Rodini, Michael R. Ward and Glenn A. Woroch, Telecommunication
Policy
p.
(2003)
REQUEST FOR PRODUCTION NO. 2-Produce all documents identified in
response to Interrogatory No. 2- 17.
Response to Production Request No. 2-26: See Attachment I and J (electronic).
INTERROGATORY NO. 2-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
STAFF'S RESPONSE TO QWEST'S SECOND
INTERROGATORIES AND REQUESTS FOR
PRODUCTION OF DOCUMENTS APRIL 16, 2003
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.
Response to Interrogatory No. 2-18: This conclusion is supported in part by responses
to the poll conducted by the Wall Street Journal, a link to which was provided in response to
Request for Production No. 2-24. See also the following documents, which contain discussions
of differences in the attributes of wireless and wireline services:
The Technology and Economics Of Cross-Platform Competition In Local Telecommunications
Markets, Richard A. Chandler, A. Daniel Kelley and David M. Nugent, April 4, 2002 (HAl
Report)
Reply Comments of AT&T Corp, FCC Docket No. 01-338, July 17, 2002
Reply Comments of World com. Inc., FCC Docket No. 01-338 , July 17, 2002
The Status of Telecommunications Competition in California, California Public Utilities
Commission, June 5, 2002
REQUEST FOR PRODUCTION NO. 2-Produce all documents identified in
response to Interrogatory No. 2- 18.
Response to Production Request No. 2-27: See Attachment J and K (electronic).
REQUEST FOR PRODUCTION NO. 2-Please produce the Yankee Group study
referenced on page 16 of Dr. Johnson s testimony.
Response to Production Request No. 2-28: Dr. Johnson does not have a copy of the
Yankee Group study. His comments about the study were based upon a discussion by the FCC
contained in the FCC's Seventh Report, FCC 02-179, June 13 2002. A copy of the Seventh
Report is attached as Attachment L (electronic).
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
STAFF'S RESPONSE TO QWEST'S SECOND
INTERROGATORIES AND REQUESTS FOR
PRODUCTION OF DOCUMENTS APRIL 16, 2003
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.
Response to Interrogatory No. 2-19: Staff has not had occasion to analyze the
technical aspects of this phenomena, nor has it conducted or identified research addressing the
tendency for some mobile phones to heat up. Dr. Johnson s comments were based, in part, upon
personal experience. Logically, there are multiple factors that might explain the heat. For
example, batteries may give off heat as they deplete. Also, microprocessors emit heat as they
operate.
REQUEST FOR PRODUCTION NO. 2-Please produce all documents identified
in your response to Interrogatory No. 2- 19.
Response to Production Request No. 2-29: No documents identified.
REQUEST FOR PRODUCTION NO. 2-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.
Response to Production Request No. 2-30: Dr. Johnson s comment is based primarily
upon personal observation and his general knowledge. He is not aware of any studies, surveys or
other data concerning the exact frequency with which individuals choose one or the other option
under the referenced circumstances.
INTERROGATORY NO. 2-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
STAFF'S RESPONSE TO QWEST'S SECOND
INTERROGATORIES AND REQUESTS FOR
PRODUCTION OF DOCUMENTS APRIL 16, 2003
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.
Response to Interrogatory No. 2-20: Not applicable.
REQUEST FOR PRODUCTION NO. 2-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.
Response to Production Request No. 2-31: Dr. Johnson concluded that consumers with
such concerns "may refuse to use a wireless phone, or they may try to avoid using one as much
as possible." He is not aware of any studies, surveys or other data concerning the extent ofthese
safety concerns, or individual responses to these concerns. A review of the responses to the Wall
Street Journal poll confirms that such concerns do exist, and they affect at least some consumers
decisions to use wireless phones.
REQUEST FOR PRODUCTION NO. 2-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 wire line phone.
Response to Production Request No. 2-32: Dr. Johnson has not had occasion to
identify all studies, surveys, data, facts and documents supporting this conclusion. Nor has he
had occasion to investigate any formal research that may have been conducted into these
ergonomic factors. Dr. Johnson s comments were based, in part, upon personal knowledge and
experience, taking into consideration his general knowledge concerning the impact of ergonomic
factors on consumer behavior. In the context of wire line services where mobility and weight are
not important considerations, desktop phones and handsets have remained essentially the same
size and shape for decades, despite technological advances which would allow manufacturers to
produce smaller and smaller units. The lack of downsizing in this context suggest that there are
tradeoffs involved in telephone design. The ergonomics of traditional (and still popular)
handsets is based in part upon the average size and shape of the human hand, and the average
STAFF'S RESPONSE TO QWEST'S SECOND
INTERROGATORIES AND REQUESTS FOR
PRODUCTION OF DOCUMENTS APRIL 16, 2003
distance between an individual's ear and mouth. Wireless phones, on the other hand, have been
reduced to sizes that do not provide optimal levels of comfort, but which offer greater mobility,
lower weight, and a less obtrusive appearance. Smaller phones are easier to carryon one
person throughout the day, but they generally aren t as comfortable to use, since they haven
been optimized to the average size and shape of the human hand, and the average distance
between an individual's ear and mouth. Stated simply, a compromise is struck: to achieve
greater mobility, some degree of comfort is lost.
INTERROGATORY NO. 2-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.
Response to Interrogatory No. 2-21: Dr. Johnson has not had occasion to identify all
studies, surveys, data, facts and documents supporting this conclusion. Dr. Johnson s comments
were based, in part, upon his personal knowledge, gained from more than 25 years in the
telecommunications field. Speech is the most common signal transmitted over the public
switched telephone network. The analog waveform of a typical speech signal is in frequencies
ranging from 30 hertz (Hz) to 10 000 Hz, with most of the energy in the 200 Hz and 3 500 Hz
band. Telephone circuits are generally limited to the band from approximately 200 Hz and 3 500
, consistent with their intended use as a means for transmitting the human voice. The signals
produced by computers and fax machines usually consist of a stream of pulses containing
information coded into binary digits (Bits). The signals produced by these pulses are converted
to sounds that can travel over ordinary analog channels within the 200 Hz to 3 500 Hz band
through a process of "modulation . The signals are "demodulated" at the other end of the circuit
so that they can be processed by the receiving modem or fax machine. For a discussion of
transmission signals and the process of modulation, see: Engineering and Operations in the Bell
STAFF'S RESPONSE TO QWEST'S SECOND
INTERROGATORIES AND REQUESTS FOR
PRODUCTION OF DOCUMENTS APRIL 16, 2003
System. AT&T Bell Laboratories, Murray Hill, N., 1984; Understanding Telecommunications
and Lightwave Systems, John G. Nellist, IEEE PRESS , 1996.
Staff does not believe that fax and internet transmissions are, in fact
, "
voice
transmissions. However, these transmissions often occur over circuits that are primarily
designed to accommodate voice transmissions, using services (e.g. basic local exchange service)
that are frequently marketed and purchased for that purpose. In fact, the same circuits are
sometimes used for both voice and fax transmissions. Similarly, the same circuits are sometimes
used for both voice and internet transmissions.
REQUEST FOR PRODUCTION NO. 2-Produce all documents identified in
response to Interrogatory No. 2-21.
Response to Production Request No. 2-33: Dr. Johnson does not possess multiple
copies of the two identified books. Qwest may already possess copies of these documents.
Alternatively, copies may be available from the publishers.
REQUEST FOR PRODUCTION NO. 2-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
price of wire line service were to increase substantially." Produce all price elasticity studies
surveys, data, facts and documents supporting this conclusion.
Response to Production Request No. 2-34: Dr. Johnson has not had occasion to
identify all price elasticity studies, surveys, data, facts and document supporting this conclusion.
This statement is based upon Dr. Johnson s general knowledge and information, gained during
more than 25 years in the telecommunications field. The statement implicitly relies on Dr.
Johnson s knowledge of the elasticity of demand for telephone service; it is broadly consistent
with a wide variety of different studies, reports, analyses, discovery responses, and other
documents that he has reviewed over the course of his work. Although Dr. Johnson has not had
occasion to identify all such documents, the following documents contain a useful overview of
the published literature: Telecommunications Demand: A Survey and Critique, Lester D. Taylor
Ballinger Publishing Co., 1980; Telecommunications Demand in Theory and Practice, Lester D.
STAFF'S RESPONSE TO QWEST'S SECOND
INTERROGATORIES AND REQUESTS FOR
PRODUCTION OF DOCUMENTS APRIL 16, 2003
Taylor, Kluwer, Norwell, MA, 1994. Dr. Johnson is familiar with both of these documents, but
has not retained copies of them.
INTERROGATORY NO. 2-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.
Response to Interrogatory No. 2-22: Dr. Johnson has not had occasion to identify all
studies, surveys, data, facts and documents supporting these conclusions. Dr. Johnson
observations were based in part upon his personal experience as a wireless consumer. With
regard to Idaho market conditions specifically, Dr. Johnson relied in part on the wireless pricing
information provided by Qwest in this proceeding, as well as the pricing information provided by
Staff Witness Wayne Hart. Finally, Dr. Johnson relied upon a review of information provided on
some of the major wireless providers' websites.
REQUEST FOR PRODUCTION NO. 2-Produce all documents identified in
response to Interrogatory No. 2-22.
Response to Production Request No. 2-35: Qwest already possesses the pricing
information provided by Qwest and Staff witness Wayne Hart. For additional information
concerning wireless pricing see:
http://www1.sprintpcs.com
http://www.attws.com
http://www.verizonwireless.com
http://cingular.com
http://nextelonline.nextel.com
http://voicestream.com
INTERROGATORY NO. 2-On page 37 of his testimony, Dr. Johnson testifies that
some wireless prices have been declining. However, there are indications that this downward
STAFF'S RESPONSE TO QWEST'S SECOND
INTERROGATORIES AND REQUESTS FOR
PRODUCTION OF DOCUMENTS APRIL 16, 2003
trend has slowed." Identify all studies, surveys, data, facts and documents supporting the
conclusion that the downward trend in wireless pricing has slowed.
Response to Interrogatory No. 2-23: Dr. Johnson has not had occasion to identify all
studies, surveys, data, facts and documents supporting such a conclusion. See the FCC's
Seventh Report, FCC 02-179, June 13 2002, which contains a discussion of recent trends in
wireless pricing through 2001. Also see the January 24 2003 Lehman Brothers Equity Research
article on AT&T Wireless and the February 9 2003 wireless.com article AT&T Wireless Sets
New Plans. Reduces Free Minutes for a discussion of recent price increases by AT&T Wireless
and other major wireless providers.
REQUEST FOR PRODUCTION NO. 2-Produce all documents identified in
response to Interrogatory No. 2-23.
Response to Production Request No. 2-36: See Attachment M (electronic).
INTERROGATORY NO. 2-Are there any circumstances under which Dr. Johnson
could foresee that wireless service could be found by the Commission to be "functionally
equivalent" to wire line basic local exchange service? If so, please specifically describe such
circumstances.
Response to Interrogatory No. 2-24: Staff objects to this interrogatory on the grounds
that it violates IPUC Rule of Procedure 225 in that it seeks to obtain statements of opinion or
policy not previously written or published. In addition, Dr. Johnson does not wish to speculate
about whether, or under what circumstances, these services could be found by the Commission to
be functionally equivalent. Dr. Johnson s testimony contains extensive discussions of the
reasons why he believes the two services are not "functionally equivalent". While it seems
unlikely, it is conceivable that circumstances could evolve to a point where these services are
perceived by consumers to be virtually identical with respect to the relevant functional attributes.
Under such hypothetical circumstances, Dr. Johnson might change his opinion with regard to
whether or not the services are "functionally equivalent"
STAFF'S RESPONSE TO QWEST'S SECOND
INTERROGATORIES AND REQUESTS FOR
PRODUCTION OF DOCUMENTS APRIL 16, 2003
INTERROGATORY NO. 2-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.
Response to Interrogatory No. 2-25: Staff objects to this interrogatory on the grounds
that it violates IPUC Rule of Procedure 225 in that it seeks to obtain statements of opinion or
policy not previously written or published. Staff merely contends that approving Qwest's
application in this case where there is no demonstration of effective competition is not in the
public interest and likely will result in an increase in Qwest's basic service rates.
INTERROGATORY NO. 2-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.
Response to Interrogatory No. 2-26: Staff objects to this interrogatory on the grounds
that it violates IPUC Rule of Procedure 225 in that it seeks to obtain statements of opinion or
policy not previously written or published. Staff merely contends that approving Qwest'
application in this case where there is no demonstration of effective competition is not in the
public interest and likely will result in an increase in Qwest's basic service rates.
INTERROGATORY NO. 2-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.
STAFF'S RESPONSE TO QWEST'S SECOND
INTERROGATORIES AND REQUESTS FOR
PRODUCTION OF DOCUMENTS APRIL 16, 2003
Response to Interrogatory No. 2-27: Staff objects to this interrogatory on the grounds
that it violates IPUC Rule of Procedure 225 in that it seeks to obtain statements of opinion or
policy not previously written or published. Without waiving Staffs objection, Staff responds as
follows:
The residential and small business customers of the more populous, urban regions of the
state currently subsidize and support the cost of basic local exchange service for Qwest'
residential and small business customers in the less populous, rural regions under current
averaged prices of Qwest' s basic local exchange service. In addition, all of Qwest' s customers
provide support for basic local exchange customers in extremely high cost areas of the state in
the form ofIdaho s Universal Service Fund. Such support is clearly intended and required under
the federal Telecommunications Act of 1996, and the Idaho statutes, Sections 62-602 (1), 62-602
(6)(a) and (b), and 62-610.
In Case No. GNR- T -00-, the Commission adopted a generic process for implementing
a high cost fund for non-rural local exchange companies, but deferred implementation of that
fund. When implemented, such support will be converted from indirect to direct support. Until
implemented, it is appropriate that such support remain in the rates.
DATED at Boise, Idaho, this l~ day of April 2003.
Weldon B. stUtzman
Deputy Attorney General
Technical Staff: Wayne Hart
Ben Johnson
WS:WH::umisc/prdreg/response/qwetO2.25response to QWE 2ws
STAFF'S RESPONSE TO QWEST'S SECOND
INTERROGATORIES AND REQUESTS FOR
PRODUCTION OF DOCUMENTS APRIL 16, 2003
TT A CHMENT A
COMMISSION STAFF'S RESPONSE TO
QWEST'SECOND INTERROGATORIES
AND REQUESTS FOR PRODUCTION
OF DOCUMENTS
ELECTRONICALLY FILED
APRIL 16, 2003
Verizon Wireless - Plans and Pricing: Local DigitaIChoice(R)
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Attachment B
Case No. QWE-02-
Staffs 2nd Response to Qwest
04/16/03 Page 1 of11
Page 1 of 2
Home I FAQs I Contact Us I Store Locator I About Us I News I
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Verizon Wireless - Plans and Pricing: Local DigitaIChoice(R)Page 2 of 2
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Attachment B
Case No. QWE-02-
Staffs 2nd Response to Qwest
04/16/03 Page 2 of
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Iof2
Chanqe vour shoppinq zip code
Current zip code:&nbsp83709mUte National Plan - Next Generation
multi-band
mUfe National Plans are the ideal solution , offering coverage to select cities, while paying no roaming or domestic long
distance when calling within your Home Coverage Area.
. AT&T Wireless National Network is your Home Service Area (Click for coveraqe map)
. Compatible Multi-Band device and minimum one-year contract required
. $175.00 Cancellation Fee
Included Features: Toll Free USA from Home Service Area AT&T Caller ID Call Waitinq Detailed Billinq Text
Messaqinq from AT&T Wireless
Free Features Upon Request: AT&T VoiceMaii Call Forwardinq Three-Wav Callinq
--- - .--- - -----..- -.-..-----.-.--..-...-----..-..-..---..-----.---..- -------..- - .......---.-.---..-----... .---.....--. - ------
3~lkb Addt'IData Charge
45~/min Addt'l Airtime
OO~/miri Long Histance
20~/mln Off Network
Domestic Long Distance
69~/minNational ROaming
Rate
$36.00 Activation Fee
30 INCLUDED
.--------....-.-........ "-"-..-............---...--..-........-...-........
200
INCLUDED
.. ""...-. -. - ------.-..------- - -... -. "".. ......- ...-.-. .........-
mUle National Plan.
Next Generation
Multiband
$29.
mUfeNational Plan-
Next Generation
Multiba
$39.
3~/kb Addt'l Data Charge
45~/min Addt'l Airtime
OO~/min Long Distance
20~/min Off Network
Domestic Long Distance
69~/min National Roaming
Rate
$36.00 Activation Fee
1 or 2 Years
1 or2Years With a 12monthora24
month signed contract you
receive:
100 Additional Anvtime
Minutes each month
Unlimited Niqht and
Weekend minutes per
month
.-----
350
INCLUDED
3~/kbAddt'l Data Charge
40~/min Addt'l Airtime
OO#minLOng Distance
20~/ininOffNetw()rk
Domestic Long Distance
69l!1minNational. RoamingRate
$36~00 ActivationFee
1 or2YearsWitha 12 moJith ora24
r11onthsigned contract you
receive:
200. Addilional Amtime
Minutes each month
Unlimited Niqht and
Weekend Minutes per
month
-......-..................... ...............-......-----..... ....-..""..........-.----.-----------..---..-......-......
mUte National Plan -
Next Generation
Multiband
$49.
500
INCLUDED
3~lkb Addt'l Data Charge
40~/min Addt'l Airtime
OO~/min Long Distance
20~/min Off Network
Domestic Long Distance
69~/min Nalional Roaming
Rate
$36_00 Activation Fee
1 or2Years With a 12monthora24
month signed contract you
receive:
200 Additional Anytime
Minutes each month
Unlimited Niqht and
Weekend Minutes per
month
900
INCLUDED
3~lkb Addt'JPataCharge
35~/minAddt'l Airtime
OOWminLong Distance
20~/min Off Net",!ork
Domestic Long.Distarice
69~/miriNatiorialRoaming ,
Rate
' .
$36.00.ActivationFee
----"'-""'-""""""""""""'..----------.-..-..
1200
INCLUDED
mUte National Plan.
Next Generation
Multiband
$99.
3~lkb Addt'l Data Charge
30~/min Addt'l Airtime
OO~/min Long Distance
20~/min Off Network
Domestic Long Distance
69~/min National Roaming
Rate
$36.00 Activation Fee
or2 Years With a 12month or a'
monthsigneci contract you
receive:
200 Additional Anvtime
Minutes each month
Uniimited Niqht and
Weekend'Minutes per
month
.-.----.---
1 or 2 Years With a 12 month ora24
month signed contract you
receive:
200 Additional Anytime
Minutes each month
Unlimited Niqht and
Weekend Minutes per
month
Attachment B
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 3 oflI
AT&T Wireless - All Plans hup://www.shopattwireless.com/webcode/displayall/p lans .asp? Sessio...
3~lkb Addt'l Data Charge
30~/min Addt'l Airtime
OO~/min LbngQista,nce
20~/ininOff NetW()rkDbrnesticJor'jgDista~Ce
69~/min National Roaming
Rate
$36.00 Activation Fee
1 or 2 Years. With a12 month or a 24
mbnthsigned contract you
receive:
200 Additional Anvlime
Mil1uteseach month
Unlirnited Niqht and
Weekend Minutes oer
month
mUle National Plan"
Next Generation
Multlband
$199.
3000
INCLUDED
3~lkb Addt'l Data Charge
25~/mln Addt'l Airtime
OO~/min Long Distance
20~/min 011 Network
Domestic Long Distance
69~/min National Roaming
Rate
$36.00 Activation Fee
1 or 2 Years With a 12 month or a 24
month signed contract you
receive:
200 Additional Anvtime
Minutes each month
Unlimited Niqht and
Weekend Minutes per
month
"-.-.,,..- -- -....-..........-.... ......... .........----.............".... .....-.-..-...-....... - ..--............ ....--- .----............-......"....-........-.--...-...-.-......- ---.- -- -... -...- -'-"'---""""'-"'.-.....
mLffe National Plan -
Next Generation
Multiband
$299;99
4500
INCLUDED
3~lkbAddt'l Data Charge
25~/min Addt'l Airtime
OO~/min Long Distance
20~/min 011 NetWork
Domestic Long Distance
69~/min National Roaming
Rate
$36.00.Activation Fee
1 or2Years. With a 12 month or a24
. month signed contract you
receive:
200 Additional Anvlime
Minutes each month
Unlimited Niqhtand
Weekend.Minutesoer
month
'Explanation of Rates and Charqes
-.--....-........-....-.----.---.....--.-...........-......... -. -'--...............--.-.......----............... ....-....-..-... - ....-.---...- ----..-......-.... .......... ....-......... ...... .......--
en Espanol I Free E..mail Updates I Careers I Newsroom I Investor Relations I
192003 AT&T Wireless. All Rights Reserved. We.b...ryige.s....a.nc:fAccePta.b.l.e...l,.I.e../I.9re.emen! I priYacy..p,qHcY
2 of2
Attachment B
Case No. QWE-02-
Staff's 2nd Response to Qwest
04/16/03 Page 4 of
AT&T Wireless - All Plans h ttp://www.shopattwireless.comlwebcode/displayall/plans. asp? Sessi 0...
Chance your shoppina zip code
Current zip code:&nbsp83709mUte Digital One Rate Plan - Next
Generation multi-band
The mUle Digital One Rate Plan offers no roaming or nationwide long distance charges across the United States. From
New York to Miami to Honolulu-just about anywhere-all calls are like local calls
. Every call within the U.S. is like a local call (Click lor coveraae map)
. No roaming or domestic long distance charges across all 50 states
. Compatible Multi-Band device and minimum one-year contract required
. $175.00 Cancellation Fee
Free Features Upon Request: AT&T Voice Mail Three-Way Callina Call Forwardina
Included Features: AT&T Caller ID Call Waitina Detailed Billina Text Messaainq Irom AT&T Wireless
3~lkb Addt'pataCharge
45~/min Addt'l.Airtirrie
oO~/';'in L()ng Dist~nce
oM/miD NationaJRoiu:ningRate
$36.00 Activation Fee
mLite Digital One Rate - 650Next Generation INCLUDEDMultiband
$79.
3~/kb Addt'l Data Charge
40~/min Addt'l Airtime
OO~/min Long Distance
OO~/min National Roaming
Rate
$36.00 Activation Fee
1 or 2 Years
1 or 2 YearsmLile Digital One Rate' !:IOONext Generation INCLUDEDMultiband
$99.
3~lkb Addt'l Data Charge
40~jmin.Addt'!Airtirrie
OO~/min Long Distance
OO~/min National Roaming
Rate
$36;00 Activation Fee
mLile Digital One Rate- 1100Next Generation INCLUDEDMuitiband
$119.
3~lkb Addt'l Data Charge
35~/min Addt'l Airtime
OO~/min Long Distance
OO~/min National Roaming
Rate
$36.00 Activation Fee
---
1or2Years
.------.-- -'- ...----.. -........--... -...-.. ...........................- --- -- .......-...... -....--....-..----- ------
1 or2YearsmL~eDigitaIOneRate- 1500Next Generation INCLUDEDMultiband
$149.
3~lkb Addt'! Data Charge
30#min Addt'! Airtime
OO~/minLongDistance
OO#miri National Rdaming
Rate
$36.00 Activation Fee
1 or 2 YearsmLite Digital One Rate - 2000Next Generation INCLUDEDMultiband
$199.
3~lkb Addt'l Data Charge
30~/min Addt'l Airtime
OO~/min Long Distance
OO~/min National Roaming
Rate
$36.00 Activation Fee
mLitepigital One Rate: 3000NextG"neration INCLUDEDMultiband
$299.
3~/kbAddt'l Data Charge
3~1k" Apdt'! Data Roaming
Rat,nn th"U,S,
25~/rriiiJAddt'l Airtime
OO~/rriinLong Distance
OO~/minNationalRoaming
Rate
$36,OpAptivationFee
..---......--..---...
Explam:\tionol Rates and Charaes
en Espanol I Free E-mail Updates I Careers I Newsroom I Investor Relations I
(92003 A T& T Wireless. All Rights Reserved. \II1ebServir.:e"_enc:!Ac..c..eP!?PJ.e..Y"_AgLe.er:D.eDJ I f"riYac:V.J"9Jir.:Y.
2 of2
Attachment B
Case No. QWE-02-
Staffs 2nd Response to Qwest
04/16/03 Page 5 of
AT&T Wireless - All Plans http://www.shopattwireless.com/webcode/displayall/plans. asp? Sessio...
Shoppinq cart I Order status I Store locator I Send a text message-
Shop online
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.'."""'."',."""'.
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" "."."""""""*"""".",,,,.."
features and ~ervite5 ! Dnline customer service i business 5o!utions about us ! search: .
mUfe Local Plans
Next Generation
Multi-Band
Diqital
mLife National Plans
Next Generation
Multi-Band
Diqital
mLife Digital One Rate
Plans
Multi-Band
Diqilal
Special Plans
mUle Silared Plans
Prepaid
Attachment B
Case No. QWE-O2-
Staffs 2nd Response to Qwest
04/16/03 Page 6 of
1 of 2
mUt ona ext rati Chanqe vour shoppinq zip code
Current zip code:&nbsp83709
mUfe National Plans are the ideal solution, offering coverage to select cities, while paying no roaming or domestic long
distance when calling within your Home Coverage Area.
. AT&T Wireless Next Generation Network is your Home Service Area (Click for coveraqe map)
. Compatible Next Generation device and minimum one-year contract required
. $175.00 Cancellation Fee
Free Features Upon Request A T& T VoiceMaii Call FolWardinq Three-Wav Callinq
Included Features; Toll Free USA from Home Service Area AT&T Caller 10 Call Waitinq Detailed Billinq Text
Messaqinq from AT&T Wireless
3~!kb Addt'IData Charge
45~/min Addt'EAirtime
OO~/min Long Distance
20~/min .Qff Network
DomesticLong Distance
69~/min.National'Roaming
Rate
' .
$36.00 ActivationFee
3~/kb Addt'l Data Charge
45~/min Addt'l Airtime
OO~/min Long Distance
20~/min Off Network
Domestic Long Distance
69~/min National Roaming
Rate
$36.00 Activation Fee
mUte National Plan -
Next Generation
$29.
200
INCLUDED
3~/kbAddt'l Data Charge
40~/minAddt'l Airtime
oo~/minLong Distance
20~/min Off Network
Domestic Longbistance
69~/min NationalRoaming
Rate
$36.00 Activation Fee
350
INCLUDED
1 or 2 Years With a 12 month or a 24
month signed contract you
receive:
100 Additional Anytime
Minutes each month
Unlimited Niqht and
Weekend minutes per
month
mUte National Plan -
Next Generation
$49.
500
INCLUDED
3~!kb Addt'l Data Charge
40~/min Addt'l Airtime
OO~/min Long Distance
20~/min Off Network
Domestic Long Distance
69~/min National Roaming
Rate
$36.00 Activation Fee
3~/kb Addt'l Data Charge'
35~/min Addt'IAirtime .
OO~lmin Long Distance
20~/minQff Netwo'rk
DornesticLong DisJanc
69~/rTliri National RoainingRate' .
$36:00Activatlon Fee
1 or 2 Years With a 12 month or a 24
month signed contract you
receive:
200 Additional Anvtime
Minutes each mcnth
Unlimited Niqhl and
Weekend Minutes per
month
or2YearsW~ha12 month ora24
morithsignedcontract you
receive:
200 Additional Anvtime
Minutes each month
UnlirniiedNiqht and
ekendMinutes per
nionth
mUte National Plan -
Next Generation
$99.
1200
INCLUDED
3~/kb Addt'l Data Charge
30~/min Addt'l Airtime
OO~/min Long Distance
20~/min Off Network
Domestic Long Distance
69~/min National Roaming
Rate
$36.00 Activation Fee
............................................................
mLijeNatibnal Plan -
Next Generation
$149.
2000
INCLUDED
....................................................... .............
3~!kbAddtTData Charge
30tlrninAddt'l Airtime '
OotirninLongDistance
20tlniinQffNetwork
DomesticLong Distance
69~/min National Roaming
Rate
$36.00 Activation Fee
1 or 2 Years With a 12 month or a 24
month signed contract you
receive:
gQQ ,'I,ddition"J.1illY!iDl.."-Minutes each month
Unlimited Niqht and
Weekend Minutes per
mont~
1 or 2 Years.With"a12 month or a 24
rnonthsignooeontractyou
receive:
200 Additional Anvtime
Minuteseachmonlh
Unlirnited Niqht and
Weekend Minutes per
month
2/20/03 9:52 AM
AT&T Wireless - All Plans h up://www.shopattwireless.com/webcode/displayall/p lans .asp ?Sessio. ..
mLite National Plan -
Next Generation
$199.
3000
INCLUDED
3~/kb Addt'l Data Charge
25~/min Addt'l Airtime
OO~/min Long Distance
20~/min Off Network
Domestic Long Distance
69~/mln National Roaming
Rate
$36.00 Activation Fee
1 or 2 Years With a 12 month or a 24
month signed contract you
receive:
200 Additional Anytime
Minutes each month
Unlimited Niahl and
Weekend Minutes per
month
mL~e National Plan-
Next Generation
$299.
4500
INCLUDED
3~/kb Addt'.lData Charge
25~/minAddt'l Airtime
OO~/min Long Distance
20~/min Off Network
Domestic Long Distance
69~/ri1in National Roaming
Rate
$36.00 Activation Fee
or2Years With a 12 month ora24
mo~th.signedcontract you
receive:
200 Additional AnV1ime
Minutes each month
Unlimited Niaht and
Weekend MinUtes per
month
................................................................................................... ........
-Ex lanation of Rates and Char
en Espanol I Free E-mail Updates I Careers I Newsroom I Investor Relations I
r92003 AT&T Wireless. All Rights Reserved. 'Nel:J..~e!yiQ.e"~r1qAQ".ept~I:J.lel!se..Agreern..eO.t. I Priy.
"y_
pgliW
2 of2
Attachment B
Case No. QWE-02-Staff's 2nd Response to Qwest
04/16/03 Page 7 of
AT&T Wireless - All Plans http://www.shopattwireless.comlwebcode/displayal1/plans. asp? Sessio...
SlloppinQ cart I Order status I Store locator I Send a text messaQe-
shOp online
"'" """"","'.
'"m",,""",,""",,"b""""..'i"U,,"".
""'""""" '
. """,m"",m"""'.."1"'mm""""""",,",.u;',"'mm.,m,,~'m",,"m,m"m' ',mbM_. "". .W',""'L, , '" m
fe8.ture$ and $ervice$. , online customer $ervice i business solution$. I about u$ I search: :
Next Generation
Multi-Band
Diqitai
mUte National Plans
Next Generation
Multi-Band
Diqital
mUte Digital One Rate
!Plans
Multi-Band
Diqital
Special Plans
mUte Shared Plans
Prepaid
Attachment B
Case No. QWE-02-25
Staffs 2nd Response to Qwest !
04/16/03 Page 8 of
lof2
mUte Local Plan - Next Generation
multi-band
mUte Local Plans are ideal if you make mostly local calls, want lots of minutes, and rarely travel outside your local area.
Chanqe your shoppinq zip code
Current zip code:&nbsp83709
. Expanded Home Service Area on our Next Generation Network (Click for coyeraqe map)
. Compatible Multi-Band device and minimum one-year contract required
. 175.00 Cancellation Fee
Included Features: AT&T Caller ID Call Waitinq Detailed Billinq Text Messaqinq from AT&T Wireless
Free Features Upon Request: AT&T VoiceMaii Three-Wav Callinq Cali Fof\'Vardinq
mUte Local Plan - Next
Generation Multiband
$29.
250
INCLUDED
'--""""--",""""
"..-....-..m...-....
"-"""""-"'-",--"""",--,-,,,,,......-............-.......-.......
0;3~/kbAddt'l Data Charge
45~/min Addt'l Airtime
20~/minLong Distance
20~/min Off Network
Domestic Long Distance
9~/min National.Roaming
Rate
$36.00 Activation Fee
3~/kb Addt'l Data Charge
45~/min Addt'l Airtime
OO~/min Long Distance
20~/min Off Network
Domestic Long Distance
69~/min National Roaming
Rate
$36.00 Activation Fee
1 or 2 Years With a 12monthora24month
signed contract you receive:
100 Additional Anytime
Minutes each month
Unlimited Niaht and
Weekend minutes per
month
Nationwide Lonq Distance
each month
mLifeLocalPlan - Next
Generalion Multiband
$39~99
400
INCLUDED
....-...... -- -- ----.......- --.. - -...... -... - -. -- -..-.. - ----... --- _.....--------- .......,
3~/kb Addt'l Data Charge
40~/min Addt'l Airtime
OO~/minLong Distance
20~/min Off Network
Domestic Long Distance
69~/min National Roaming
Rate
$36.00 Actiyation Fee
1 or 2 VearsWith a 12 month or a24 month
signed contract yoLireceive:
200 Additional AnYlime
Minutes.each'month
Unlimited Niqht and
Weekend minutes per
month
Nationwide Lono Distance
each month
mUte Local Pian. Next
Generation Multiband
$49.
600
INCLUDED
3~/kb Addt'l Data Charge
40~/min Addt'l Airtime
OO~/min Long Distance
20~/min Off Network
Domestic Long Distance
69~/min National Roaming
Rate
$36.00 Activation Fee
1 or2Years With a 12 monlh ora 24 month
signed contract you receive:
gQ.Q. Adg,!!Lonal AOY.time
Minules each month
Unlimited Niqhl and
Weekend minutes per
!!19D.Jb.
Nationwide Lona Distance
each month
1000
INCLUDED
""""--""'--"'-'-'- - -- --.- .--...........-.... .....-..-.....-... ....--- -........ -- - .-..-- ---_. --...--....-..-...-....-.....-......-...... --- --- ----.........-.-..-
O;;3~!kt~ Addt'Data Charge
35#min Addt'IAirtime
OO~/minLong Distanc
20t/minQffNetwork
Domestic Long Distance
6fj~/minNationid.Roaming
Rate
$36;00 Activation
1 or2 Years Witn.a 1o2month '' a 24 month
signedcontraclyou receive':
200 Additional Anvtirrte
Minutes each month
Unlimited Niqht and
Weekend' minutes pet
month
Nationwide Lonq Distance
each month
mUte Local Plan - Next
Generation Mulliband
$99.
1400
INCLUDED
3~/kb Addt'l Dala Charge
30~/min Addt'l Airtime
OOt/min Long Distance
20~/min Off Network
Domestic Long Distance
69~/min National Roaming
Rate
$36.00 Activation Fee
1 or 2 Years With a 12 month or a 24 month
signed contract you receive:
200 Additional Anytime
Minutes each month
Unlimited Niaht and
Weekend minutes per
month
Nationwide Lonq Distance
each month
--...-..--..-.....-..--....--.--- .-------...- ...-..--" .-.........-,-- -... ---------....-.....--....--.. - -_. -... -...- - --'--'---"'-
2120/03 9:34 AM
AT&T Wireless - All Plans
mute Local Plan - Next
Generation Multiband
$149.
h ttp://WWW . shopattwireless .comlwebcode/ display all/p lans. asp ?Sessio...
2200
INCLUDED
3~lkb Addt'l Data. Charge
30~/minAddt'l Airtime
OO~/minLong Distance
20~/rnin Oft Network
Domestic Long Distance
69~/minNational Roaming
Rate
$36.00 Activation Fee
1 or 2 Years With a 12 month or a 24 month
signed contract you receive:
200 Additional Anvtime
Minutes each rnonth
Unlimited Niallt and
Weekend minutes per
month
Nationwide Lona Distance
each month
mUte Locai Pian - Next
Generation Multiband
$199.
.........................................................."....--....
mUle Locai Plan" Next
Generation Multiband
$299.
-...
3200
INCLUDED
3~/kb Addt'l Data Charge
25~/min Addt'l Airtime
OO#min Long Distance
20~/min Oft Network
Domestic Long Distance
69~/min National Roaming
Rate
$36.00 Activation Fee
1 or 2 Years With a 12 month or a 24 month
signed contract you receive:
200 Additionai Anvtime
Minutes each month
Uniimited Niaht and
Weekend minutes per
month
Nationwide Lono Distance
each month
4800
tNCLUDED
.. .-.-----...-----............"........."............ .............."-.................".............."........".............,,........--.....-...............
3~/kbAddt'l Data Charge
25~/min Addt'l Airtime
OO~/min Longpistance
20~/min Oft Network
Domestic Long Distance
69~/minNational Roaming
Rate
$36.00 Activation Fee
........................"..........................--....--.....---....."
Explanationof Rates and Charqes
"""""""'-""""""""""""...................'--'-""""'"
1 or 2 Years With a12 month or a 24 month
signed contract you receive:
200 Additional AnViime
Minutes each month
Unlimited Niaht and
Weekend minutes per
month
Nationwide Lono Distance
each rnonth
..............................--............-....--................"......-................."
en Espanol I Free E"mail Updates I Careers I Newsroom I Investor Relations I
~O03 AT&T Wireless. All Rights Reserved. W.!'b..!'rv.c!'.s...a.n.d.Acc!'Ptab.!!'...v.se...Ame!'r:D.emt I Pr.i\!a,Y..I"oJicv
2 of2
Attachment B
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 9 of
2/20/039:34 AM
AT&T Wireless - All Plans http://www.shopattwireless.com/webcode/display all/plans .asp? Sessio...
Shoppinq cart I Order status I Store locator I Send a text messaqe-
shop online
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,""",."""'""""",.,%,,,
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W, ",w, '
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features and !iervice$ i online customer $ervice ! business $olution$ I O1hout U$ ! search:
mLife Local Plans
Next Generation
Multi-Band
Diqital
! mUte National Plans
Next Generation
Multi-Band
Diqital
mUte Digital One Rate
Plans
Multi-Band
Diqital
Special Plans
mUte Shared Plans
Prepaid
lof2
mUt ocal Plan - Di Chanqeyourshoppinq zip codes
Current Zip code:&nbsp83709
mUfe Local Plans are ideal if you make mostly local calls, want lots of minutes, and rarely travel outside your local area.
. Large Home Service Area on our Digital Network (Click for coveraqe map)
. Compatible Digital device and minimum one-year contract required
. $175.00 Cancellation Fee
Free Features Upon Request: AT&T Voice Mail Three-Way CallinG Call Forwardinq
Included Features: AT&T Caller ID Call WaitinQ Detailed Billinq Text Messaqinq from AT&T Wireless
mUte Local Plan - Digital 45INCLUDED
$19.
45~/minAdd!'1 Airtime
20~/min Long Distance
20#miaOff Network
Dornestic Long Distance
69#min National Roaming
Rate
$36;00 Activation Fee
45~/min Add!'1 Airtime
OO~/min Long Distance
20~/min Off Network
Domestic Long Distance
69~/min National Roaming
Rate
$36.00 Activation Fee
mUte Local Plan - Digital 250
$29.99 INCLUDED
---....---...---------.--..----.-.-.....-...
1 or 2 Years
1 or 2 Years With a 12 month or a 24 month
signed contract you receive:
100 Additional Anytime
Minutes each month
Unlimited Niqht and
Weekend minutes per
month
Nationwide Lonq Distance
each month
.. -...-..- -....-..
.... - ___m______...-.....-
........-.....-..-
-.... .-...-...........- ..m_..____....m....m
"__"--,-"-"",,, -... ..--
mUte Local ptan - Digital 400$39:99 INCLUDED
40~/min Addt'l Airtime
OO~/min Long Distance
20~/rnlnOff Network
Domestic Long Distance
69~/minNaticmal Roaming
Rate
$36,00 Activation Fee
lor2 Years Wrtha 12 month or a 24 month
signed contract you receive:
200 Additional Ariytime
Minutes each month
UnlimiledNiqht and
Weekend minutesper
month
Natioawide LonqDistance
each rnonth
mUte Local Plan - Digital 600
$49.99 INCLUDED
40~/min Add!'1 Airtime
OO~/min Long Distance
20~/min Off Network
Domestic Long Distance
69~/min National Roaming
Rate
$36.00 Activation Fee
1 or 2 Years With a 12 month or a 24 month
signed contract you receive:
200 Additionai Anvtime
Minutes each month
Unlimited Niqht and
Weekend minutes per
month
Nationwide Lonq Distance
each month
1000
INCLUDED
--______m_..__m_....m -
....-....... -........ -...-_.....-....- - -...- - ...-..
-- .._m_..- - .......-.._...._...._m_.._._-
-- -...-- - -.... ------. -......- -.. -.... - ...-... -- ---
35~/min Addt'l Airtime
OO~/min Long Distance
20~/min Off Netwo.rk
Dorne~ticLongDistanca
~/minNatipn~1 Roaming
Rate
$36.00ActiviHion Fee
1 or2 Years With a 12mcmthora 24 month
signed contract you receive: .
200 Additional Anytime
Minutes .each rnonth
Unlimited Niqhtand
Weekend rninutes per
rnonth
Nationwide lonqDistance
ea.ch,monJh
mUte Local Plan - Digital 1400
$99.99 INCLUDED
30~/min Add!'1 Airtime
OO~/min Long Distance
20~/min Off Network
Domestic Long Distance
69~/min National Roaming
Rate
$36.00 Activation Fee
1 or 2 Years With a 12 month or a 24 month
signed contract you receive:
200 Additional Anytime
Minutes each month
Unlimited Niqht and
Weekend minutes per
month
Nationwide Lonq Distance
each month
---....-.... -.-- _m_" __m_...
-.--- - - - ----"""--"""'-'---
--... __"'..m_m.__.. ...__..m_.._m___..._..._.._m__.._
_'-"----"'-- ......... -------.......
Attachment B
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 10 of 2120/03 9:53 AM
AT&T Wireless - All Plans h ttp://www.shopattwireless.com/webcode/display all/plans .as p ?Sessio...
2200
INCLUDED
30~/minAddl'l Airtime
OO~/min Long Distance
20~/mln Off Network
Domestic Long Distance
6S~/min National HoamingRate
$36.00 Activation Fee
mute Local Pian - Digital 3200$199.99 INCLUDED
25~/min Addt'i Airtime
OO~/min Long Distance
20~/min Off Network
Domestic Long Distance
6S~/min National Roaming
Rate
$36.00 Activation Fee
.-...-.--.....-.....--.......-..............
1 or 2 Years With a 12 month or a 24 month
signed contract you receive:
200 Additionai Anvlime
Minutes each month
Unlimited Nioht and
Weekend minutes per
month
Nationwide Lonq Distance
each month
............ ............. ...-..... -....-................-...."........- -..-- --....".............--........... -.......... ".
m.......
_'" -.............. ............-... -..-.- --"..-......-...-... ....--..
mUfe.LocalPlan "Digital 4800
$299.99 INCLUDED
25~/minAddt'IAirtime
OO~/min LongDistance
20~/min Off Network
DomesticLOng Distance
6S~/minNational Roaming
Rate
$36.00 Activation Fee
.Explanation of Rates and CharQes
....-..---..-..............-....-.........-.... """"""""'."""""""""""'-""---""""""'-'---"--,-",-",,-,--,........-."...........
10r 2 Years Wrtha 12 month"or a 24 month
signed contract you receive:
200 Additional Anytime
Minutes each month
Unlimited Nidhlanct'
Weekend minutes rier
month
Nationwide Lona Distance
each month
......--..-.-..--"....-.........-.----..-.......--.-."....-...--...
en Espanol I Free E..mail Updates I Careers I Newsroom I Investor Relations I
192003 AT&T Wireless. All Rights Reserved. W~p.
::;.
~!yic~sand..AcgePtaQlel,Jse.Agre~men.\ I PriYaW.f'.ol.lcv
2 of2
Attachment B
Case No. QWE-02-
Staffs 2nd Response to Qwest
04/16/03 Page 11 of
Get More Plus
~ T-Mobile USA home
~.~.
" .Mobile-
Products
Page 1 of
See all T-Mobile International sitl
Get more from life.
Plans Coverage Company info.Help My T-Mobile
National rate plaIls n Select a new location
)-)- My cart
)-)- Check Order StatusFirst, select a plan to begin building your wireless package.
)-)- National coverage map
To use a T-Mobile product you must
be in a T-Mobile coverage area.
See the map to be sure you are
located in a coverage area before
buying or using a T-Mobile product.
Get More Plus plan
Great for: people who travel and spend up to 40 minutes per work
day on the phone.
Get More Plus plan
C )-j, ),lI.dd to package J
Price $59.
CD Whenever minutes
(per month)
800 minutes
CD Weekend minutes
(per month)
Unlimited
CD T-Mobile minutes
(per month)
N/A
(?) Additional minutes/MB
(per minute)
40~
Optional Services to enhance your national rate plan (you can
add these later during the package process)
Mobile Internet plans - Plans support occasional to frequent or
heavy Internet access. Starting from $2.99 per month.
Two-way text messaging - 500 inbound and outbound messages
for connecting to friends, family and colleagues. $2.99 per month.
Unlimited Nights - Receive unlimited minutes on all calls
originating from 9:00pm to 6:59am. This is in addition to the
unlimited weekends you already receive!
BuddyTime - For just $1 O.OO/month you can add the BuddyTime
feature to any Nationwide rate plan ($19., $29., $39.
$59., $99.99 also, includes Sidekick Plans) and get Unlimited
Mobile to Mobile and Unlimited Text Messaging!
)-)- See more about these optional services
Mobile USA: (f)2002-3 T-Mobile USA, Inc. : Terms of Use: Terms & Conditions: Privacy Policy: Jobs: Developer Center: Site Map: Contac
Mobile International: Austria: Czech Republic: Germany: Netherlands: Poland: Russia: United Kingdom
Attachment C
Case No. QWE-02-
Staff's 2nd Response to Qwest
04/16/03 Page 1 of20
http://www.t-mobile.com/plans/nationaVplus.asp 2/1912003
Basic
~ T-Mobile USA home
~ ~
~.. .rvlobi1e~
Products
Page 1 of
See all T-Mobile International sib
Get more from life'
Plans Coverage Help My T-MobileCompany info.
National rate plans )0)0 Select a new location
)0)0 My cart
)0)0 Check Order StatusFirst, select a plan to begin building your wireless package.
)0)0 National coverage map
To use a T-Mobile product you must
be in a T-Mobile coverage area.
See the map to be sure you are
located in a coverage area before
buying or using a T-Mobile product.
Basic
Great for: Budget-conscious customers and students, and those who
need a phone for light daily use and emergencies.
Basic plan
( )0)0) ,lI.ddtopackage)
Price $19.
rJ) Whenever minutes
(per month)
60 minutes
Weekend minutes
(per month)
500
CD T-Mobile minutes
(per month)
N/A
(?) Additional minutes/MB
(per minute)
45~
(D Data Transfer
(per month)
N/A
This plan includes the following services
50 IncomingText Messages, Built-in Paging, Caller 10, Conference
Calling, Call Waiting and Call Hold, Customer Care , Directory
Assistance, Emergency Calls, Detailed Billing
))0 See more about these services
Optional Services to enhance your national rate plan (you can
add these later during the package process)
Mobile Internet plans - Plans support occasional to frequent or
heavy Internet access. Starting from $2.99 per month.
Two-way text messaging - 500 inbound and outbound messages
for connecting to friends, family and colleagues. $2.99 per month.
)0)0 See more about these optional services
Mobile USA: ~2002-3 T-Mobile USA, Inc. : Terms of Use: Terms & Conditions: Privacy Policy: Jobs: Developer Center: Site Map: Contac
Mobile International: Austria: Czech Republic: Germany: Netherlands: Poland: Russia: United Kingdom
Attachment C
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 2 of20
http://www.t-mobile.com/plans/national/basic.asp 2/19/2003
Verizon Wireless - Plans and Pricing: Promotional Page 1 of 2
ven Olfwiret.(ess
Shop
Customer Service
Plans and Pricing
. Hot Deals
. America s Choice
. Promotional America
Choicesm Family
SharePlan
. America s Choice
Family SharePlan
. National SingleRate
. Express Networksm
. Unlimited Express
Networksm
. Express Networksm
Megabyte
. Promotional
. Promotional Family
SharePlan
. Local DigitalChoice
. Local DigitalChoice
Family SharePlan
. Accessories
. PREPAY Service
. Refill / (REUPj MinutesEquipment
Calling Features
Internet and Data
Send a Text Message ))
Enter New Zip Code
Attachment C
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 3 of20
Home I FAQs I Contact Us I Store Locator I About Us I News I
Plans and Pricing: Promotional Plans
Service for: Boise, 10 Shopping GAudiovoxCDM9500
Fit!:.!:. Case &0 eattefY
549...~.rj!lj" .
'""
;rficr SHlfr11lilil-in reh~i!8
1 Choose your ~
Select your p~
Select additioaccessories
4 Add more call
features
Get everything you need in one simple plan.
omoticmal Ma
Local Mobile to Mobile Ma
!FREE Shipping
;,~=~:~
5 Preview and!
your order
Plan
Choices
Monthly Per
Monthly Airtime Minute
Access Allowance Rate after
(in minutes) allowance
Promotion RoamingLong
Distance
Unlimited Nights &
Weekends
AND
1000 Local Mobile to
Mobile Minutes
Unlimited Nights &
Weekends
AND
1000 Local Mobile to
Mobile Minutes
Domestic long distance is included for calls from within your home airtime rate area (airtime charges
Domestic roaming is 69"/minute (includes domestic long distance charges). Call delivery charge of
20"/minute may apply to calls received while roaming. Requires COMA tri-mode phone with specific:
and preferred roaming list as programmed by Verizon Wireless. Two- year agreement required. No a
fee on two-year agreements. $175 early termination fee applies. Calling plans not available in all are;
Anytime
700 $0.45 Included$49.700
Anytime
1000 $0.40 Included$64.1000
Night hours 9:01 PM - 5:59 AM, Monday - Friday, Weekend hours 12:00 AM Saturday - 11 :59 PM Sl
Weekend/Night & Weekend and Mobile to Mobile promotional offers are not available in all areas. If y
a plan or promotion that is not available in your area, you will be notified by us bye-mail of alternativE
and offers available to you.
Important Customer Information:
Calling plans, features and services are subject to the Customer Agreement, which applies to aliline~
account. Please read and understand them before activating service. Our liability is significantly limitE
Service subject to credit approval. Billing, shipping, and end-user address must be within the Verizon
licensed and service areas where the wireless phone number is issued.
Failure to program your tri-mode phone in accordance with the directions included with your phone m
the roam indicator to display inaccurately. Although the accuracy of the roam indicator on your phone
cannotbe guaranteed, the charges for the calls you make and receive will be based on the cell sites L
make or receive your call as reflected in our billing system. Rates do not apply to credit card or opera
assisted calls, which may be required in certain areas. Automatic roaming may not be available in all
Monthly allowance minutes may be used only in your home airtime rate area. Any minutes used abov
monthly allowance are billed at your selected calling plan rates. Usage rounded up to next full minute
allowance minutes lost. Calls made or received outside your home airtime rate area incur roaming ch
Charges for calls start when you press :JSENDCI or the call connects to the system. Charges stop wI-
call disconnects from the system, which may be a few seconds after you press LIENDIJ or the call is I
http://www.verizonwireless.com/ics/plsq1/plan detail.intro?p - hdr _id= 11744 7192&p --'plan - catego...2/21/2003
Verizon Wireless - Customize Your Service
lien. ORI'vireJess
Shop
Customer Service
Plans and Pricing
. Hot Deals
. America s Choice
. Promotional America
Choicesm Family
SharePlan
. America s Choice
Family SharePlan
. National SingleRate
. Express Networksm
. Unlimited Express
Networksm
. Express Networksm
Megabyte
. Promotional
. Promotional Family
SharePlan
. Local DigitalChoice
. Local DigitalChoice
Family SharePlan
. Accessories
. PREPAY Service
. Refill/ (REUPJ MinutesEquipment
Calling Features
Internet and Data
Send a Text Message
Enter New Zip Code
Sign up for email updates.
~!:!~L~~~~~~~~~
Attachment C
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 4 of20
Page I of 2
Home I FAQs I Contact Us I Store Locator I About Us I News
Plans and Pricing
Service for: Boise, 10
----..........-..............
Plans for just about everyone. We cover more towns, cities and
places than anyone else and connect more people than any
other wireless service provider in the nation.
Audiovox CoMe:I'Rt.t: Case & Batte
'49...~~rtli~"her S100 l11~il-
. Browse the plan descriptions.
. Select one of the plan types to continue
Please note: Existing customers who wish to upgrade their
service should visit their nearest Verizon Wireless Stor~
Service upgrades are not yet available online.
National Plans
Plan Type
National
SingleRate
Local Plans
Plan Type
Map Description
Monthly Per
Monthly Airtime Minute
Access Allowance Rate aftel
(in minutes) allowancE
$35-
$300 150- 3 000
Compare America s Choicesm with National SingleRate
$0.20-
$0.45
$0.20-
$0.40
$0.20-
$0.45
$0.20-
$0.40
Monthly Per
Monthly Airtime MinuteAccess Allowance Rate aftel
(in minutes) allowancE
$49.99- 700- 1 000
$64.99
$49.99- 700-000$64.
$29.99-
$154.99 300- 2 200
http://www.verizonwireless.com/ics/plsq1lcustomize.intro?p - section= PLANS - PRI CIN G
Call anywhere from anywhere on
A ., Ch. sm View the America s Choice network $39.99- 300- 3 000menca s olce M~p with no roaming or long distance $204.99
charges.Promotional Buy one Audiovox CDM-8300
America s Choicesm yjew phone and get other one free. $39.99-
Family Map Share the value. One account. $204.99 300- 3 000
SharePlansm One monthly bill.
America s Choicesm .F .View Share the value. One account. $39.99- 300-000
~~::Plan M~P One monthly bill. $204.
Perfect if you talk and travel
View around the country. Domestic
MaR roaming and domestic long
distance included.
Map Description
Get everything you need in
View one simple plan.Click "select plans" to view the
MQQ Promotional Anytime Minute
Plans!
Get everything you need in
.. one simple plan.romo lona ami y View Sh PI sm IC se ec pans 0 view eare an MQQ Promotional Family SharePlan
Anytime Minute Plans!
Y..ie.w. Great if you do most of your
M~p calling close to home.
Promotional
Local
DigitalChoice
Local Offers you and your family a
$0.40-
$0.45
$0.40-
$0.45
$0.25-
$0.45
2/21/2003
Verizon Wireless - Customize Your Service
Attachment C
Case No. QWE-02-
Staffs 2nd Response to Qwest
04/16/03 Page 5 of20
DigitalChoice
Family
SharePlan
V' simple, inexpensive way to keep $49.99-
d~W in touch. Share the value. One 154.99 500- 2 200
~p account. One monthly bill.
Express Network Plans
Plan Type Map Description
Page 2 of 2
$0.25-
$0.40
Per
Monthly Monthly Minute
Access Allowance Rate after
allowance
$35-
$300
$99.
$35-
$75
http://www.verizonwireless.com/ics/plsq1/customize.intro?p - section= PLANS - PRI CIN G
Now there s wireless Internet
access using technology that
allows speeds bursting up to
sm View 144 kbps! New calling plansExpress Network M~R offer airtime allowance for voice
calls and data sessions.
Express Network device
required.
Unlimited Express
Networksm
For just $99.99 a month, get
unlimited access to Express
Y..i~YX Network for your wireless data
l\iIap needs. (See right for voice and
non-Express Network data per
minute rates)
These plans charge by the
amount of data you use.
sm V' Express Network MegabyteExpress Network ~'to' allowances start at 10MB for
Megabyte Map just $35 monthly access. (See
right for voice and non-Express
Network data per minute rates)
Voice &
Non-
Express
Network
Data:
$0.
home
area
$0.
roaming
Express
Network:
Express 005-
twork: 008/KB0 40 MB Voice/Non
Express
Netwrk
Data:
$0.25
home
area
$0.
roaming
150- 3 000
Express
Network:
unlimited
Voice &
Non-
Express
Network
Data: No
Allowance
Voice &
Non-
Express
Network
Data: No
Allowance
$0.20-
$0.40
The service and equipment offered on this Web site are subject to the terms of the Custom
Agreement and price plan selected. Please read and understand it before ordering and acti
Verizon Wireless' calling areas , rates , agreement provisions, business practices, procedure
policies are subject to change as specified in the Customer Agreement. Our liability is signi'
limited.
Home FAQ~ I~QD1actl,.J~ I $tQf~LQc;;:ItQJ I About Us I New~ I Searc;1
Affiliat ErogHLIT! I RYllgbt~Z_QQ~VeIi?QnWjJ~les~ I Eri\lQ9'-SJ;:It~m~n11 gQLNQtic;e~ I
Customer Agreement Customer Information Overview Return Policy Worry Free GuarantE
2/21/2003
Verizon Wireless - Plans and Pricing: Local DigitaIChoice(R) Family SharePlan(sm)Page 1 of 4
n onl'/ire.r.ess
Shop
Customer Service
Plans and Pricing
. Hot Deals
. America s Choicesrn
. Promotional America
Choicesrn Family
SharePlansrn
. America s Choicesrn
Family SharePlansrn
. National SingleRatesrn
. Express Networksm
. Unlimited Express
Networksrn
. Express Networksrn
Megabyte
. Promotional
. Promotional Family
SharePlansrn
. Local DigitalChoice
. Local DigitalChoice
Family SharePlan
. Accessories
. PREPAY Service
. Refill! (REUPj MinutesEquipment
Calling Features
Internet and Data
Send a Text Message ))
Enter New Zip Code
Attachment C
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 6 of20
Home I FAQs I Contact Us I Store Locator I About Us I News I
Plans and Pricing: Local DigitalChoiceR Family SharePlan
Plans
Service for: Boise, 10 AudiovoxCDM9500
FREE Case & Batre.fYc
$49'
Shopping G
1 Choose your ~
2' Select your p~
Select additioaccessories
.Add more call
features
Preview and!
your order
Family SharePlansrn offers you and your family
a simple, inexpensive way to keep in touch.
Less home airtime minutes go unused because
you share a monthly home airtime allowance.
Here s how it works:
. Activate a primary line on any calling plan
shown below and add up to three additional
lines for a monthly access of $20 each.
. The primary lines monthly home airtime
allowance determines how many minutes the
group will share. Once the group s monthly
home airtime allowance is depleted, you pay for
additional home airtime minutes as shown in the
table below.
aHer
FRE~ Shi:pping
r;m
:':~.:.~~:~~
Local DigitalChoice Family SharePlan
Local Mobilel(LM_bile Ma
Monthly Per
Plan Choices Monthly Airtime Minute Long Promotion Roaming NulAccessAllowanceRate after Distance
(in minutes)allowance
Local 500 Shared 1000 Local
DigitalChoice Anytime Minutes Mobile to Mobile
Family $49.PLUS $0.40 Included AND
SharePlan 150 Shared Shared
500 -Bonus Anytime Unlimited Night
Primary Line Minutes & Weekends
Local
DigitalChoice
Family $20 Shared $0.40 Included SharedSharePlan
500 -
2nd Line
Local
DigitalChoice
Family $20 Shared $0.40 Included SharedSharePlansrn
500 -
3rd Line
Local
DigitalChoice
Family $20 Shared $0.40 Included SharedSharePlansrn
500 -
4th Line
Plan Choices MonthlyAccess
Monthly
Airtime
Allowance
Roaming NulPer LongMinute Distance
Rate after
Promotion
http://www.verizonwireless.com/ics/plsql/plan - detail. intro ?p - hdr jd=11744 7192&p --'plan - catego...2/2112003
Verizon Wireless - Plans and Pricing: Local DigitaIChoice(R) Family SharePlan(sm)Page 2 of 4
(in minutes)allowance
Local 650 Shared 1000 Local
DigitalChoice Anytime Minutes Mobile to Mobile
Family $59.PLUS $0.40 Included AND
SharePlan 150 Shared Shared
650 -Bonus Anytime Unlimited Night
Primary Line Minutes & Weekends
Local
DigitalChoice
Family $20 Shared $0.40 Included SharedSharePlan
650 -
2nd Line
Local
DigitalChoice
Family $20 Shared $0.40 Included SharedSharePlan
650 -
3rd Line
Local
DigitalChoice
Family $20 Shared $0.40 Included SharedSharePlan
650 -
4th Line
Monthly Per
Plan Choices Monthly Airtime Minute Long Promotion Roaming NuAccessAllowanceRate after Distance
(in minutes)allowance
Local 1000 Shared 1000 Local
DigitalChoice Anytime Minutes Mobile to Mobile
Family $79.PLUS $0.Included ANDSharePlan500 Shared Shared1000 -Bonus Anytime Unlimited Night
Primary Line Minutes & Weekends
Local
DigitalChoice
Family $20 Shared $0.Included SharedSharePlan
1000 -
2nd Line
Local
DigitalChoice
Family $20 Shared $0.Included SharedSharePlan
1000 -
3rd Line
Local
DigitalChoice
Family $20 Shared $0.Included SharedSharePlan
1000 -
4th Line
Monthly Per
Plan Choices Monthly Airtime Minute Long Promotion Roaming NuAttachment C Access Allowance Rate after Distance
Case No. QWE-02-(in minutes)allowance
Staff s 2nd Response to Qwest 1400 Shared 1000 Local
04/16/03 Page 7 of 20 Local Anytime Minutes Mobile to Mobile
DigitalChoice
http://www.verizonwireless.com/ics/plsqllplan detail.intro?p - hdr _id= 11744 7192&p -plan - catego...2/21/2003
Verizon Wireless - Plans and Pricing: Local DigitaIChoice(R) Family SharePlan(sm)Page 3 of 4
Family PLUS AND
SharePlan $104.600 Shared $0.Included Shared
1400 -Bonus Anytime Unlimited Night
Primary Line Minutes & Weekends
Local
DigitalChoice
Family $20 Shared $0.Included SharedSharePlan
1400 -
2nd Line
Local
DigitalChoice
Family $20 Shared $0.Included SharedSharePlan
1400 -
3rd Line
Local
DigitalChoice
Family $20 Shared $0.Included SharedSharePlan
1400 -
4th Line
Monthly Per
Plan Choices Monthly Airtime Minute Long Promotion Roaming NuAccessAllowanceRate after Distance
(in minutes)allowance
Local 2200 Shared 1000 Local
DigitalChoice Anytime Minutes Mobile to Mobile
Family $154.PLUS $0.Included ANDSharePlan800 Shared Shared2200 -Bonus Anytime Unlimited Night
Primary Line Minutes & Weekends
Local
DigitalChoice
Family $20 Shared $0.Included SharedSharePlan
2200 -
2nd Line
Local
DigitalChoice
Family $20 Shared $0.Included SharedSharePlan
2200 -
3rd Line
Local
DigitalChoice
Family $20 Shared $0.Included SharedSharePlan
2200 -
4th Line
Domestic long distance is included for calls from within your home airtime rate area (airtime charges
Domestic roaming is 69st/minute (includes domestic long distance charges). Call delivery charge of
20#minute may apply to calls received while roaming. Requires COMA tri-mode phone with specific
and preferred roaming list as programmed by Verizon Wireless. One- or two- year agreement requirE
activation fee per line on one-year agreements. No activation fee per line on two-year agreements. $
early termination fee applies to each line on the account. Calling plans not available in all areas. The
Attachment C line s long distance and roaming rates apply to the secondary line(s).
Case No. QWE-02-
Staff's 2nd Response to Qwest Night hours 9:01 PM - 5:59 AM, Monday - Friday, Weekend hours 12:00 AM Saturday - 11 :59 PM SL
04/16/03 Page 8 of 20
http://www.verizonwireless.com/ics/plsq1/plan detail.intro?p - hdr - id= 11744 7192&p ~lan - catego...2/21/2003
Verizon Wireless - Plans and Pricing: Local DigitaIChoice(R) Family SharePlan(sm)Page 4 of 4
. ;Cloor Ordol1if
Weekend/Night & Weekend and Mobile to Mobile promotional offers are not available in all areas. If y
a plan or promotion that is not available in your area , you will be notified by us bye-mail of alternativE
and offers available to you.
Important Customer Information:
Subject to Customer Agreement and Local DigitalChoice Calling Plan. Please read and understand tt
before activating service. Our liability is significantly limited. Service subject to credit approval. Althou
accuracy of the roam indicator on your phone cannot be guaranteed,the charges for calls you make
receive will be based on the cell site used to make or receive your call as reflected in our billing syste
service, features and promotions are not available in all areas and may not follow you across the enti
DigitalChoice rate area and may be limited to the Verizon Wireless digital network.
Minimum of 2 lines required. Only one line can be the primary line and the other(s) must be additiona
All lines must be activated on the same billing account. All lines on account will share the primary line
monthly allowance minutes and will not be carried over to the next billing cycle. Monthly home airtime
allowance minutes will be applied depending ~n first usage.
Local mobile to mobile minutes apply to calls made between Verizon Wireless subscribers with Veriz(
Wireless numbers activated within the same local mobile to mobile rate area. All parties must be with;
designated local mobile to mobile airtime rate area and on the Verizon Wireless network at the time tl
originates. Local mobile to mobile requires that Caller ID be present on each line. If Caller ID is not pr
local mobile to mobile will apply to outgoing calls only.
Not available in all Verizon Wireless markets. Any local mobile to mobile minutes used above your ml
allowance are billed at calling plan rates. Usage rounded up to next full minute. Unused allowance
Monthly home allowance minutes may be used only in your home airtime rate area. Charges for calls
when you press "SEND" or the call connects to the system. Charges stop when your call disconnects
system, which may be a few seconds after you press "END" or the call is otherwise terminated. On in
calls, charges begin when the call connects to the system , which may be before the phone rings or b(
answer it.
Local mobile to mobile calls are subject to long distance, taxes, tolls and other charges. Rates do not
credit card or operator assisted calls , which may be required in certain areas. See map for local mobi
mobile home airtime rate area details. Local mobile to mobile is not available with fixed wireless devic
usage substantially from a single cell site.
When you make or receive a call , the minutes are applied as follows: Any mobile to mobile calls will d
your mobile to mobile allowance first, even if call is placed on a night or weekend. Based on specific
promotion, the order of how minutes are applied may vary. In such case, see promotional brochure fc
Verizon Wireless calling plans, rate areas, rates, agreement provisions, business practices , procedur
policies are subject to change as specified in the Customer Agreement. Other restrictions apply.
Home FAQs Contact Us Store Locator About Us News Search
Affiliate Program Copyright (g) 2003 Verizon Wireless Privacy Statement Legal Notices
Customer Agreement Customer Information Overview Return Policy Worry Free GuarantE
Attachment C
Case No. QWE-02-Staffs 2nd Response to Qwest
04/16/03 Page 9 of
http://www.verizonwireless.com/ics/plsq1/plan detail.intro?p - hdr - id= 11744 7192&p --plan - catego...2/21/2003
Verizon Wireless - Plans and Pricing: Promotional Family SharePlan(sm)
'lien on~'AroJess
Shop
Customer Service
Plans and Pricing
. Hot Deals
. America s Choice
. Promotional America
Choicesm Family
SharePlan
. America s Choice
Family SharePlan
. National SingleRate
. Express Networksm
. Unlimited Express
Networksm
. Express Networksm
Megabyte
. Promotional
. Promotional Family
SharePlan
. Local DigitalChoice
. Local DigitalChoice
Family SharePlan
. Accessories
. PREPAY Service
. Refill / (REUPj MinutesEquipment
Calling Features
Internet and Data
Send a Text Message
Enter New Zip Code
Attachment C
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 10 of
Page 1 of 3
Home I FAQs I Contact Us I Store Locator I About Us I News I
Plans and Pricing: Promotional Family SharePlansm
!~~
Service for: Boise, 10
Family SharePlansm offers you and your family
a simple, inexpensive way to keep in touch.
Less home airtime minutes go unused because
you share a Monthly Home Airtime Allowance.
Here s how it works:
. Activate a primary line on any calling plan
shown below and add up to three additional
lines for a monthly access of $20 each.
. The primary lines monthly home airtime
allowance determines how many minutes the
group will share. Once the group s Monthly
Home Airtime Allowance is depleted, you pay
for additional home airtime minutes as shown in
the table below.
AudiovoxCD'M9S00
FRiEOEO Case &. Batrery
$49.
iFREE Shlpplng
:.:~~~~~
M~mthly Per
Monthly Airtime Minute Long
Access Allowance Rate after Distance
(in minutes) allowance
Promotion
Shared
Unlimited Nights
& Weekends
AND
1000 Local
Mobile to Mobile
Minutes
Shared
Unlimited Nights
& Weekends
AND
1000 Local
Mobile to Mobile
Minutes
Shared
Unlimited Nights
& Weekends
AND
1000 Local
Mobile to Mobile
Minutes
Shared
Unlimited Nights
& Weekends
AND
1000 Local
Mobile to Mobile
Minutes
Promotion
Shopping G
'I Choose your ~
2: Select your p~
Select additio
accessories
4 Add more call
features
Preview and!
your order
Roaming Nu
Roaming Nu
. http://www.verizonwireless.com/ics/plsql/plan detail.intro?p - hdr _id= 11744 7192&p -plan - catego...2/21/2003
P romot ionalEamH y. Shar~P!aJl~m~R
Local Mobile to Mobile Map
Plan Choices
Promotional Family
SharePlansm 700 -
Primary Line
Promotional Family
SharePlansm 700 -
2nd Line
Promotional Family
SharePlansm 700 -
3rd Line
Promotional Family
SharePlansm 700 -
4th Line
Plan Choices
$49.$0.45700
$20 Shared $0.45
$20 Shared $0.45
$20 Shared $0.45
Included
Included
Included
Included
Monthly Monthly Per LongAccess Airtime Minute Distance
Allowance Rate after
Verizon Wireless - Plans and Pricing: Promotional Family SharePlan(sm)Page 2 of 3
allowance
(in minutes)
Shared
Unlimited Nights
Promotional Family & Weekends
SharePlansm 1000 -$64.1000 $0.40 Included AND
Primary Line 1000 Local
Mobile to Mobile
Minutes
Shared
Unlimited Nights
Promotional Family & Weekends
SharePlansm 1000 -$20 Shared $0.40 Included AND
2nd Line 1000 Local
Mobile to Mobile
Minutes
Shared
Unlimited Nights
Promotional Family & Weekends
SharePlansm 1000 -$20 Shared $0.40 Included AND
3rd Line 1000 Local
Mobile to Mobile
Minutes
Shared
Unlimited Nights
Promotional Family & Weekends
SharePlansm 1000 -$20 Shared $0.40 Included AND
4th Line 1000 Local
Mobile to Mobile
Minutes
Domestic long distance is included for calls from within your home airtime rate area (airtime charges
Domestic roaming is 69#minute (includes domestic long distance charges). Call delivery charge of
20q;/minute may apply to calls received while roaming. Requires CDMA tri-mode phone with specific
and preferred roaming list as programmed by Verizon WIreless. One- or two- year agreement requirE
activation fee per line on one-year agreements. No activation fee per line on two-year agreements. $
early termination fee applies to each line on the account. Calling plans not available in all areas. The
line s long distance and roaming rates apply to the secondary line(s).
Night hours 9:01 PM - 5:59 AM, Monday - Friday, Weekend hours 12:00 AM Saturday - 11 :59 PM Sl
X .CINf Orq(if
Weekend/Night & Weekend and Mobile to Mobile promotional offers are not available in all areas. If y
a plan or promotion that is not available in your area, you will be notified by us bye-mail of alternativE
and offers available to you.
Important Customer Information:
Subject to Customer Agreement and Local DigitalChoice Calling Plan. Please read and understand
before activating service. Our liability is significantly limited. Service subject to credit approval. Althou
accuracy of the roam indicator on your phone cannot be guaranteed, the charges for calls you make;
receive will be based on the cell site used to make or receive your call as reflected in our billing syste
service, features and promotions are not available in all areas and may not follow you across the enti
DigitalChoice rate area and may be limited to the Verizon Wireless digital network.
Minimum of 2 lines required. Only one line can be the primary line and the other(s) must be additiona
All lines must be activated on the same billing account. All lines on account will share the primary line
monthly allowance minutes and will not be carried over to the next billing cycle. Monthly home airtime
allowance minutes will be applied depending on first usage.
Attachment C
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 11 of20
Local mobile to mobile minutes apply to calls made between Verizon WIreless subscribers with Veriz(
WIreless numbers activated within the same local mobile to mobile rate area. All parties must be with:
designated local mobile to mobile airtime rate area and on the Verizon WIreless network at the time tl
originates. Local mobile to mobile requires that Caller ID be present on each line. If Caller ID is not pr
local mobile to mobile will apply to outgoing calls only.
http://www.verizonwireless.com/ics/plsq1/plan detail.intro?p - hdr _id= 11744 7192&p --'plan - catego...2/21/2003
Verizon Wireless - Plans and Pricing: Promotional Family SharePlan(sm)Page 3 of 3
Not available in all Verizon Wireless markets. Any local mobile to mobile minutes used above your m!
allowance are billed at calling plan rates. Usage rounded up to next full minute. Unused allowance lo~
Monthly home allowance minutes may be used only in your home airtime rate area. Charges for calls
when you press "SEND" or the call connects to the system. Charges stop when your call disconnects
system, which may be a few seconds after you press "END" or the call is othelWise terminated. On in
calls, charges begin when the call connects to the system , which may be before the phone rings or b(
answer it.
Local mobile to mobile calls are subject to long distance, taxes, tolls and other charges. Rates do not
credit card or operator assisted calls , which may be required in certain areas. See map for local mobi
mobile home airtime rate area details. Local mobile to mobile is not available with fixed wireless devic
usage substantially from a single cell site.
When you make or receive a call, the minutes are applied as follows: Any mobile to mobile calls will c
your mobile to mobile allowance first, even if call is placed on a night or weekend. Based on specific
promotion , the order of how minutes are applied may vary. In such case, see promotional brochure fc
Verizon Wireless calling plans, rate areas, rates, agreement provisions, business practices, procedur
policies are subject to change as specified in the Customer Agreement. Other restrictions apply.
HQrn~ I FAQ~ ICQnJgGtV~ IStQr~LqG!;\tQr I About l,.L~ I ~~Ws I Search
,t\1flHgt~LPIQgr;;Jm IC_QPYrigbt~2QQ_~\leri?qnW1rele~ I Privacy Stat~m~nt I gm Notices
CIJstQmerl\9Ieement Ic.IJ_lome.L lnforl11gtjQD_Qvervtew I RetIJLn Policy Worry Free Guarante
Attachment C
Case No. QWE-02-
Staff's 2nd Response to Qwest
04/16/03 Page 12 of20
http://www.verizonwireless.com/ics/plsqVplan detail.intro?p - hdr - id= 11744 7192&p -ylan - catego...2/21/2003
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Generation
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Attachment C
Case No. QWE-02-
Staff's 2nd Response to Qwest
04/16/03 Page 17 of20 2/20/03 9:22 AM
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Attachment C
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 19 of20 2120/03 9:29 AM
, Spotty service angers cell phone users
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By t't~
Wireless
m;,3.i1 this story Su b.xri be b the newspat)er Sian-up f.;x a-m;,3.il ne-ws
12/13/2001 - Updated 08:25 AM ET
Spotty service angers cell phone users
By Andrew Backover, USA TODAY
Tom Bavolek's family is in cell phone hell. The three cell phones his
family bought from Sprint PCS rarely work within 3 miles of their
Southlake, Texas, home in the center of DallaslFort Worth. Calls are
dropped or rarely go through. That means no free long-distance calls-
one of the perks Sprint PCS used to win his business. Bavolek's daughter
can t use her cell phone to call home when she s late. His wife can t reach
him to expand his honey-do list. Sprint PCS says it's trying to add cell
towers to increase coverage. But that will likely take months. Bavolek
feels trapped. His contract, with more than a year left, has an early-out
fee of $250. He also feels duped.
Read more below
Audio MaoY.G~U.Rhone users al')gered by coverage
Page 1 of 6
Despite advertisements that tout
connectivity any time, anywhere
customers say the nation s wireless firms
Attachment D
Companies try Case No. QWE-02-
to improve service Staff's 2nd Response to Qwest
Phone companies are 04/16/03 Page 1 of
http://www.usatoday .com/tech/columnist/leonardfischer/200 1/12/13/spotty-cell-phone-servi... 1/7/2003
Related
coverage
Cell phone free minutes drying up
Cell phones may get own area codes
There was absolutely no mention that there was anyplace in and around
DallaslFort Worth where you couldn t get coverage " Bavolek says.
You can consider it a type of fraud by omission. They know there are
issues, and they don t make you aware of them. "
Bavolek's displeasure is part of a wave of unrest rippling through the
USA's estimated 127.5 million cell phone customers, a total that has
nearly doubled in 3 years.
Spotty service angers cell phone users
Attachment D
Case No. QWE-O2-
Staff s 2nd Response to Qwest
04/16/03 Page 2 of 6
aren t delivering. They re tired of dropped
calls and busy signals caused by
overburdened networks. They re angry at
having to pay high "roaming" charges
even if they re in their own neighborhoods
because of network dead spots or weak
signals. They often can t even 'get service
in heavily populated areas. And, they
shocked by such hassles, because maps
and other advertising used by wireless
firms don t always show network holes or
high-traffic areas that disrupt service.
They give people the impression that you
have a ubiquitous service, just like a land-
line phone " says telecom analyst Tom
Friedberg. "It's just not true, and it
probably won t be for 5 years.
Wireless phone companies are expanding
networks to handle more traffic, quicker
in old and new markets (story, below
right). "re in there fighting to get cell
sites on the air " says Dennis Huber
Sprint PCS senior vice president. He says
local zoning laws can hold up the
installation of cell sites for up to 16
months.
Yet some consumer advocates and
legislators say the industry should be more
accountable for its shortfalls. States are
taking action.
Last year, Sprint PCS clarified its ads after
New York State Attorney General Eliot
Spitzer raised concerns that they were
misleading. Spitzer objected to Sprint'
claim to a nationwide network when its
digital network didn t cover parts of New
York City and other big cities. Sprint has
since tweaked the ads to say that its digital
network covers more than 300
metropolitan areas.
Page 2 of 6
improving wireless service by:
. Adding capacity. Companies
increased the number of cell
sites, which handle cell phone
traffic, nationwide by 19%
between mid-2000 and mid-
2001. They haven t stated plans
for next year. Capacity will also
rise as they secure the right to
use more airwaves to build out
networks that cover more than
160 million people in major
markets.
VoiceStream Wireless for
example, plans to launch
service next year in Cleveland
Buffalo and Richmond, Va. It
also is building its own networks
in California and Nevada, so it
doesn t have to use someone
else s. And it plans to expand in
North Carolina and South
Carolina.
. Staying ahead of demand.
Earlier this year, Sprint PCS
curbed advertising in Chicago
for 4 months after it couldn
keep up with demand. Cingular
is using mobile cell sites to
handle rising traffic on college
campuses. Verizon Wireless
has a fleet of cars that test its
network for congestion
problems, so it can fix them.
. Keeping customers
informed. Sprint PCS typically
updates its coverage maps four
times a year and uses its Web
site to list cities where service is
available. AT&T Wireless
provides similar information.
. Allowing test runs. Although
carriers charge $150 to $200 if
consumers break contracts
early, some let customers test
phones and calling plans before
contracts kick in. That way,
customers can discover their
calling patterns, find the right
plan and gauge service quality
before they are locked in. Sprint
PCS gives customers 14 days.
Verizon Wireless customers
have 15 days. VoiceStream
customers get 3 days.
By Andrew Backover
Sprint customers might have received
service outside the digital network but only at the more expensive
analog roaming rate. Phones may go into "roam" mode when their users
travel off the carrier s network and pick up service from another
company s network. Roaming calls cost 25 cents to 45 cents a minute
http://www.usatoday.com/tech!colurnnist/leonardfischer/200 1 /12/ 13/ spotty -cell- phone-servi...1/7/2003
Spotty service angers cell phone users Page 3 of 6
Attachment D
Case No. QWE-02-
Staffs 2nd Response to Qwest
04/16/03 Page 3 of6
compared with 10 cents to 15 cents a minute for regular calls, says
Yankee Group analyst Knox Bricken.
Other carriers could face similar challenges. In March, 22 states
including Connecticut, Tennessee, Nevada and Colorado, asked Verizon
Wireless, the nation s No. I carrier; No.4 Sprint PCS; and at least one
more carrier for information about their advertising and billing practices.
Legislative action
S. Rep. Anthony Weiner, D-, was so peeved by dropped cell
phone calls that he reintroduced legislation this year to require the
Federal Communications Commission to publish complaint statistics by
company and market. That way, he says, consumers could judge
wireless firms on quality as well as cost.
They got so many people signing up, they were completely unready in
spots around the country," Weiner says.
The legislation has stalled, in part because of an anti-regulatory climate
but also because Congress is focused on terrorism and the economy.
At Weiner s request, the U.S. General Accounting Office is studying the
problem. "This is the kind of thing that more consumers are going to ask
for " Weiner says.
For the most part, though, disgruntled consumers have few places to
turn. Federal regulators dole out wireless spectrum but have no oversight
of service quality. The FCC only recently started keeping in-depth
statistics on wireless complaints. State regulators do so sporadically.
Consumers, though, register their displeasure on Web sites such as
PlanetFeedback.com. Nearly 80% ofletters PlanetFeedback gets about
wireless fmns are complaints. The average for other industries is 62%.
Three ofthe site s 20 worst-rated companies are Voice Stream Wireless
Sprint PCS and WorldCom Wireless. The letters drip with frustration.
The sky-high expectations set by the wireless carriers are a recipe for
consumer disappointment " says PlanetF eedback founder Pete
Blackshaw.
Behind the frustration:
. High traffic. The falling cost of cell phone service has sparked huge
growth in cell phone users and cell phone use. The number of
subscribers is 18 times what it was 10 years ago. The average monthly
cell phone bill as ofmid-2001 was $45.56. It was $74.56 in mid-1991.
From mid-2000 to mid-2001 , carriers added 19% more cell towers
which handle traffic. But subscribers grew 22%. Wireless minutes
jumped more than 75%.
http://www.usatoday .com/tech/colunmist/leonardfischer/200 1/12/13/spotty-cell-phone-servi... 1/7/2003
~potty service angers cell phone users Page 4 of 6
Attachment D
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 4 of
Verizon Wireless, for one, says demand will exceed capacity in some
big markets within 3 years so it is trying to acquire more airwaves to
expand service. If not, the result would be more call delays and dropped
calls.
Consumers already suffer.
After he signed up with Cingular Wireless last year, Simone Gaddini
says 80% of the calls from his Berkeley, Calif., home or neighborhood
didn't go through.
Despite Cingular s efforts to boost capacity, Gaddini says his phone
works only half the time near his house, almost never inside it.
It is still well below the standard that I expect " says Gaddini, founder
of Firenze Antica, a Tuscan walking-tour company.
Jonas Geronimo endures network congestion almost daily during rush
hour. The Anaheim, Calif., resident often dials 10 times before a call
gets through on his Cingular service.
Can you imagine the level of frustration if you are on the freeway and
you are running late for a meeting?" the health plan case manager asks.
Cingular admits to problems in California especially in Los Angeles
and San Francisco. It has seen big demand in response to heavy
marketing, and it's adding cell sites.
In some ways, we have been a victim of our own success " says Ed
Reynolds, Cingular s president of network operations.
. Networks filled with holes. None of the major carriers has a
nationwide network. Each has areas it can t yet serve or won
because it costs too much.
People expect (phones) to work everywhere " V erizon spokeswoman
Nancy Stark says. "You are not going to get service in the Grand
Canyon or on top of a mountain.
AT&T Wireless, for example, doesn t offer any service not even
roaming in parts of Colorado, Nebraska, North Dakota and South
Dakota.
It would cost too much because "there s too much territory," says Greg
Slemons, an AT&T Wireless executive.
Don t miss the fine print
Yet, consumers often miss the fine-print warnings when they see ads
hawking national calling plans.
http://www.usatoday .com/tech/colunmist/leonardfischer/200 1/12/13/spotty-cell-phone-servi... 1/7/2003
Spotty service angers cell phone users
Attachment D
Case No. QWE-02-
Staff's 2nd Response to Qwest
04/16/03 Page 5 of
Page 5 of 6
Voice Stream Wireless brochures and ads tout
, "
Whenever, Wherever.
But that doesn t extend to such cities as Cleveland; Buffalo; Springfield
Mo.; Omaha and Little Rock. V oiceStream has no service in those cities.
Voice Stream spokeswoman Kim Thompson says the information is
disclosed in a detailed map in its brochures. "It doesn t do us any good to
mislead customers. If they are not happy, they will leave us.
Other consumers get confused by popu1ar new flat-rate plans with no
roaming charges. Carriers call them "nationwide" rate plans. But
consumers often take that to mean they get nationwide coverage.
Verizon s Web site says its National SingleRate plan is "perfect if you
talk and travel around the country." Promotional literature shows a map
of the USA with no gaps. Below the map, a disclaimer warns that it
does not depict service availability just where the rate is in effect.
Verizon doesn t produce service area maps for consumers, because they
are obsolete as soon as they are printed, spokesman Brian Wood says.
Customers can get better information from sales agents, who should
know about dead zones and problems, he says.
Verizon customer Mike Silver of Phoenix found such gaps in the
foothills about 7 miles from the city's downtown.
They sell it as if there is nowhere you are not going to receive
coverage " says Silver, a sales manager at computer-memory maker
Southland Micro Systems. "It's a bit of a misnomer.
Phone companies define network size by the number of people they
reach, not by land mass. Sprint PCS won t reveal its geographic reach.
Its coverage, including affiliates, is largely in bigger cities and along
major highways and reaches 85% ofthe population.
Verizon says it doesn t have geographic statistics. Its network reaches
about 80% of the population, it says.
. Roaming hassles. If customers go outside their carrier s network, they
might not get service. Or, customers with versatile phones can roam on
someone else s network. With Sprint PCS, for example, the cost of
roaming can be huge.
Frequent business traveler Debi Fuller of Vancouver, Wash., a trainer
for software firm Information Associates, says she was surprised to learn
last year that her Sprint PCS phone worked only in analog roam mode
when she was in Santa Barbara, Calif., which has a population of more
than 90 000.
Expensively for me, my teenage daughter picked that particular week to
http://www.usatoday.com/tech!columnist/leonardfischer/200 1/12/13/ spotty -cell- phone-servi... 1/7/2003
. Spotty service angers cell phone users Page 6 of 6
need extra TLC from her mom " Fuller says. Sprint PCS says digital
coverage in Santa Barbara is still"not built out as well as we would like
it... due to serious zoning issues.
Most big carriers have reduced customer fears of roaming charges with
plans that don t charge for roaming within designated calling areas.
V erizon, for one, has a 400-minute-a-month national plan without
roaming or long-distance charges for $55 a month.
A 400-minute plan that allows free roaming and long-distance in a 14-
state region costs $45.
Roaming even at home
There is yet another hassle: Roaming often renders features such as
Caller ID and voice-mail alerts useless.
What's more, cell phones may go into roam mode even though their
users are in their local calling areas. That can happen if the digital
signals are too weak, so the phone jumps to older analog networks or
another carrier s digital network. High traffic also can bump a phone into
roam mode.
Dan Finch of Raleigh, N., says his phone goes into analog roam in
parts of his home, or he can t get any signal at all. That's a problem
because he works from home. The manager for computer reservations
service Amadeus sometimes walks his dog, Mollie, to the corner of his
block to get a signal.
Such quirks infuriate Finch when he sees Sprint ads hyping its network:
Every time I see that commercial, my blood boils.
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Attachment D
Case No. QWE-02-
Staff's 2nd Response to Qwest
04/16/03 Page 6 of6
http://www.usatoday.com/tech/colUlllnist/leonardfischer/200 1 /12/13/spotty-cell-phone-servi... 1/7/2003
Wireless Cellular Data F AQs Page 1 of 4
Cellular Data Products
. Wireline .Products
. Celll..ll",rP"'taFAQ1i
What is CeliFlex?
Cellular Checklist
. Ser.vJl:e Proviper Info
. TechnoloQie1i At WQrk
Attachment E
Case No. QWE-02-
Staffs 2nd Response to Qwest
04/16/03 Page 1 of?
WIRELESS CELLULAR DATA FAQ
What is Wireless Cellular Data?
Who Uses Ositecb's Wireless Jnter:net SolutioJls?
What is CeliFlex?
How Is Cell Flex Useful To Me?
What .Is Dual lIIIo.de I)ata?
IIIIY.PhoneIsNolD Ya I l1li0 de ,JlVi Il0sitech'sCellElexProduc t sStil1 JIVorkE or
Me?
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Will 0 s it ec h 's K i ngo f club sand K ingofHea rtswo r k with a desktop
computer?
How Do I_Use Osltech's Cellular Data Kit to get 0 ntheInt e r net?
Are the re.a nYe xtra... c ostsf r o. m. .0 .sj tech to ..u. se . .yo. ur PIodu. ct on. ceJ'
purc.hase.d..it?
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access.. thr OM. gh... my..cell pho. ne...
What do GSIIII,T DMA, CD M A a ndAMPS .Mean?
M. YCo nn ec ti!mS peemd 5 Seem I?articularl Y 1..0 w ,Ho wD 01 Geta Stronger
Data.. connection.
hyDoJA I ways Seem to Get Di connect edDyring m YCel1 MIa r DataC all?
Why am I not Getting 56K Cellular Data Connections?
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Ca. Ill... Use..m YC u rr.en llntem et.. .Service... Proyid e r... (IS P)...wit h... Os! tech.' 5
Products?
Below are some Frequently Asked Questions regarding Wireless Cellular Data
and Cellular connections.
What Is Wireless Cellular Data?
...
. Wireless cellular data is the technical description for making calls from your
computer to another computer using your cell phone. The "Data" refers to the
fact that you are not sending voice over the phone lines, but actual computer
information.
Who Uses Ositech's Wireless Internet Solutions?
...
. \NJdegeOgIgphlccQYeIgQe and ease-of-use are two of the key reasons why
Ositech's CeliFlex TM technology is being used during various activities, such as
RVing , trucking, storm chasing, boating, emergencies and business. For more
applications, please visit Ositech's Technologies At Work page.
What Is CeliFlex?
...
http://www.ositech.com/CellData/FAQ.htm 41712003
Wireless Cellular Data F AQs
Attachment E
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 2
Page 2 of 4
. CellFlex is an exclusive Ositech technology that allows cellular data
connections to be made in either a digital or an analog calling area. Unlike
other cellular internet kits, which allow connections through only digital or
analog network (not both), Ositech'Cell Flex technology allows connections
through either type of network, with Ositech's unique active cable actually
detecting the network type in which you re trying to place your call and
configuring your Ositech PC Card to connect accordingly.
How Is Cell Flex Useful To Me?
...
If you travel around at all, moving from one calling area to another, ceJJfJex
allows for total connectivity. You need never be separated from your
important information on business trips or while you travel recreationally.
ceJJFlex is also a technology for the future. While there are networks in North
America that currently support Dual Mode Data, even more will be made
available soon. With Ositech'Cell Flex solution , you don t have to buy one
Analog solution now (if you don t have digital coverage where you
live/travel), and a second digital solution later, PLUS, you get the added
bonus of being able to connect wherever you travel no matter what coverage
you have at home.
What Is Dual Mode Data?
. Dual Mode Data , like Dual Mode cellular phones, is a data connection
technology which allow your cellular PC Card to switch , along with your
phone, between analog and digital modes allowing connections under either
network.
My Phone Is Not Dual Mode, Will Ositech'CeliFlex
Products Still Work For Me?
. Yes and no. If you have an analog-only phone, you can use Ositech'
celJFlex-capable products, but they will only allow you to make analog
connections (as you would make with any Cellular Internet solution). Your
phone, since it is not Dual Mode itself, will not be able to tap into the added
power of Dual Mode Data. The advantage to getting a CeliFlex capable
product, even if you only have an analog phone at present, is that it
technology for the future, and you will be able to use its full capabilities if you
ever upgrade to a dual mode phone, or if you ever move into a digital-
capable area.
I have a Dual Mode Cellular Phone, yet I cannot make Digital Data Calls - why not? IiliIiIIiIIIiaI
Digital data calls require different services on the network than those present
during a Digital voice call. Even if your Dual Mode phone can make Digital
voice calls on your cellular network, you may not be able to make Digital data
calls. This is of particular note on AT&T's network , as Digital Data service is
not readily available anywhere in the United States. AT&T have yet to activate
Digital Data services for the majority of their customers. Ositech's products
will work in Analog mode on AT&T's network, but you will not be able to make
a Digital data call using AT&T's network. In addition , some cellular service
providers require that you subscribe to a Digital Data Plan, prior to making
digital data calls.
How are the King of Hearts and King Of Clubs Different?
. Both Trumpcards are cellular modem PC cards with Cell Flex (Dual ModeData). The KingotHearts and the KingotCtubs cellular connection kitsinclude everything that you need to set up and start accessing the Internetand email wirelessly. Both products provide wide geographic coverage andeasy-to use installation software and manuals. The y difference between
them is that the KinQotHearts has the provision for connecting to a regular
phone line using its wireline (Iandline) modem , whereas the King of Clubs
does not.
Which one is right for you?
You may want to choose the King of Hearts Cellular Connection Kit if you
want to access the Internet wirelessly and through a landline at your home or
office, and1) If your laptop does not already have a modem , or
http://www.ositech.com/CellData/FAQ.htm 4/7/2003
Wireless Cellular Data F AQs
Attachment E
Case No. QWE-02-
Staffs 2nd Response to Qwest
04/16/03 Page 3
Page 3 of 4
2) If you want to upgrade your current modem , or
3) If you want to have a back-up modem in case the one in your laptop fails.
You may opt for the King of Clubs Cellular Connection Kit if you only wantto access the Internet wirelessly. If you would also like to have online access
through a land line at your home or office, you must have a laptop with an
internal modem or you must choose the King of Hearts Trumpcard
Will Ositech'King of Clubs or King of Hearts work with
desktop computer?
. Yes, after you install a PCMCIA reader in your desktop. This can be purchased
from a computer retailer.
How Do I Use Ositech's Data Kit To Get On The Internet?
All you need is a laptop and a cell phone, once you purchase Ositech'King
Hearts or Kin9otCJubs Cellular Data kit - you ll have all you need to get
online. Ositech's documentation shows you how to set up the most common
Internet Dial-Up packages so that you can log on to your Internet Service
Provider and begin surfing the web.
Are there any extra costs from Ositech to use your
product once I've purchased it?
. No. Ositech is a manufacturer and supplier of PC Cards and Wireless Mobile
Data solutions. We do not operate a network which would require users to
purchase time from us at any point. While there will likely be costs from a
service provider in order to use their Digital Data network, there are no
costs/charges from Ositech once you have purchased one of our data
products.
Is a separate Digital Data plan required with my provider
for digital data access through my cell phone?
. Yes. While many Digital Cellular plans encompass both Digital and Analog
VOICE minutes, most service providers require a separate Digital Data plan
be subscribed to in order to use their Digital Data networks.
What Do GSM, TDMA, CDMA And AMPS Mean?
. GSM , TDMA, CDMA and AMPS are all forms of Wireless communication
technologies. Each provides a different method of carrying data (or voice)
from its source phone or computer to its destination phone or computer. Each
is explained in some detail below:
GSM (Global System for Mobile communication)
GSM is a digital mobile telephone system that is widely used around the world
(especially in Europe). GSM uses a variation of TDMA and is the most widely
used of all three digital wireless telephone technologies. GSM digitizes and
compresses data, then sends it down a channel with two other streams
user data, each in its own time slot
TDMA (Time Division Multiple Access)
TDMA (used in GSM, above) is a technology which divides each cellular
channel into three slots in order to increase the amount of data that can be
carried on a particular channel at a particular time.
CDMA (Code Division Multiple Access)
CDMA, unlike TDMA and GSM, after digitizing data , spreads it out over the
entire bandwidth available to it (unlike GSM and TDMA which place the calls
side by side in three streams). Multiple calls are then overlapped on top
each other, and each is assigned a unique sequencing code to "unlock" the
information only when and where it should be unlocked.
AMPS (Advanced Mobile Phone System)
AMPS is the original standard for cellular products. All AMPS phones should
work in almost any region across Canada or the United States.
http://www.ositech.com/CellData/FAQ.htm 4/7/2003
Wireless Cellular Data F AQs Page 4 of 4
My Connection Speeds Seem Particularly Low, How Do I
Get A Stronger Data Connection?
. Wireless Data connections are slower than their landline counterparts. This is
a factor of the existing Wireless Network infrastructure. Staying in one
location during a cellular data connection can ensure a more constant signal
and help avoid interference with your connection. If you are inside a building,
try to locate yourself as close to a window as possible, position yourself as far
away from large metal objects (such as elevators) as possible, also, try to
avoid sitting too close to fluorescent lights as they can provide "noise" which
can interfere with cellular data signals. In terms of simple solutions; Digital
connections will tend to yield faster speeds than their Analog counterparts, so
positioning yourself in a Digital Data area may help ensure you obtain the
optimal data connection possible with your phone and provider.
Why Do I Always Seem To Get Disconnected During MyCellular Data Call? IIIIIIII
. There are a number of factors that may cause a cellular data call to end
prematurely. Firstly, always ensure you have a strong charge in your
batteries. A weak charge may result in the phone shutting down mid-call. If
you are using a flip phone, always ensure the flip is kept open , otherwise the
phone assumes it is no longer in use and will shut down (thereby
disconnecting your call). Call waiting can also cause connection problems. If
you have call waiting, you should disable it before dialing out to make a data
call. Incoming calls can disrupt your data flow and disconnect your data call.
Contact your local phone company for instructions on how to disable call
waiting on a call by call basis.
Why Am I Not Getting 56K Cellular Data Connections? 1IIIIIIII
. While Ositech sells 56K PC Card modems, these fast speeds are only
attainable through regular phone line connections. When making a cellular
data call, interference and atmospheric conditions make cellular phones
unable to establish high speed (over 14.4K) connection speeds. Ositech
Wireless Cellular Modems will provide you with the optimum data connection
possible within the confines of the limitations and resources available on the
cellular network in your area.
Will . Ositech's Wireless Cellular Data Kit Work On My-
Macintosh Computer?
. Technically, yes. While Ositech does not officially support Macintosh
computers, testing has shown that Ositech's Wireless Cellular Data kit can be
successfully used on Macintosh machines.
Can I Use my Current Internet Service Provider (ISP) III!!II!!IIR!!I
with Ositech's Wireless Data Products?
. While you should be able to continue using your current ISP with Ositech'
products, you will have to be sure of a few things. As Cellular data generally
provides a slower form of connection than traditional landline modems, you
will have to confirm that your ISP will accept low speed dial-up connections
(below 19 200 for Digital and below 9600 for Analog). As long as your ISP
can handle lower speed connections, you should have no difficulty making
Wireless Data connections without switching Dial-Up providers. Please contact
your ISP for clarification.
If you have further questions not answered above, check out our Edycation
Page or e-mail theWebma$ter.
6ack..tQthetop
Attachment E
Case No. QWE-02-
Staffs 2nd Response to Qwest
04/16/03 Page 4
. (92003, Ositech Communications Inc.
For more copyright information and our legal disclaimer, please click hS!IS!.
Please send questions & inquiries to Q$!1:g~hJ!Ilgbmi:!$tgr
_DF.VIil.- ACT..1Jl..WEB
."......
http://www.ositech.com/CellData/FAQ.htm 4/7/2003
Q5: What if! want to connect to the Internet wirelessly?Page I of 4
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6 Questions and Answers on Buying
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Q5: What if I want to connect to the Internet
wirelessly?
Heard of WAP, the wir:ele~
InterneI, WAP, the wireless
web , Wireless data
connectivity or even Fax
through a cell phone? Let'
sort it out:
More of this Feature
Introduction
. Ql: Analoq o ...Qlgital?.~.Qy:the-second bililngreally bet!:J;U
. Ql.: Prepaid or Monthly.J\HJ.
. .
Q4.
....
Ce.
...
ph9nei:Js lJniq!Je
number?
05: Wireless Internet Access?
06: Where to buy?WAP and the Wireless
Web
Related Resources
3 Easy Steps to Choosing Your
Phone and Plan
Learn About the Most
Common Cell Phone Features
.See.theJ"i'ltestPbQD..e~
This refers to browsing a
stripped-down version of the
Web right on the screen of
your cell phone. This can be
usefull for retrieving web
email, checking stock quotes
and placing orders or looking up movies or restaurant
listings, for example.
If that is what you want to do, then you should go for
a phone that has what we call a "minibrowser" -- the
special kind of broser used for surfing the net on a
small cell phone screen. I have a list of such phones
right here.
For more info, also check out my full section on WAP
and the wireless Web.
Wireless Data and Fax
An increasing number of digital phones can be used
if they were a modem, Therefore, with a data cable
you can use your phone and a laptop to connect to
your usual Internet Service Provider (ISP) while on the
road. These phones can also usually be used for
receiving faxes, as long as the laptop has a fax
software application,
http://cellphones.aboutcom/library/bl wireless - data.htm
c:ingular'
fit$ you b41Et
Enter your zip code to
. find calling plans in your
area
J .
............~
Attachment E
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 5 of?
4/7/2003
Q5: What if I want to connect to the Internet wirelessly?
Subject Library
AIl.article$.QnJl'!i$
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If you want to do that, you need to check the three
following essential things:
1- does the phone you want to buy have data or/and
fax capability?
~ he c k QJJtmv_IJ.st...9J...hQoes with d9t9.90d
fax capability
2- does your service provider offer that function?
Most do, but still , you have to make sure
that option is offered with the service plan
you have in mind. For example, most
prepaid plans don t include data
connectivity. There is usually a low
monthly cost associated with the data
service.
3- what speed can be reached over the network you
want to subscribe to?
This is a very important question because
not all types of networks allow for the
same data speeds. GSM and TOMA
networks (such as VoiceStream or AT&T),
for example, will usually not allow speeds
of more than 9.6 kbps , while COMA
networks (such as Sprint PCS) can reach
up to 14.4 kbps.
Also , thanks to new compression systems such as
Venturi, some networks, including Verizon wireless and
Sprint PCS , can provide you with a software that will
allow for even higher speeds of up to (but rarely)
kbps, depending on the type of document that you
need to view. In addition to that, using dedicated data
services such as Ricochet, you can go as quickly as
128 kbps.
Check out my section on wireless data for links and
much more
Next page
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http://cellphones.about.com/library/bl wireless data.htm
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How
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MORE fROM 'CNET
----
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Attachment E
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 6
4/7/2003
Q5: Wb.at if I want to connect to the Internet wirelessly?
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and
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http://cellphones.about.com/library/bl wireless data.htm
Page 3 of 4
Attachment E
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 7
Search About
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Cellular
Phone
Antenna
Section
Links
Adapt~.rs
Amplifiers
NEW
(BDA)
Glas~MOllnl
Ant~nnas
Magnet Mount
Ant~llJLas
Body Mount
Ant~nna..s
Panel - Planar
Antennas
Antenna
CQJ:1Jl~GtQIS
Nokia Car
Kits
Motorola Car
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Simplified DJtgram of et/Mar Reception (ffg. 1)
Key (fig 1):
A = Cellular Carrier Cell Site (your connection to the world)
B = Portable phone within view of Cell Site
(good reception)
Attachment F
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 1 of6
http://www.criterioncellular.com/htmilbasics.htmi 4/812003
Ho~' to Improve Reception - Basics of Wireless Page 2 of 3
Planas
Cables
Back w ..Ind.. A
Cellular
Phone
Antenna
Adapter
Pages:
Audiovox
EricssQn
KYQ~cra-
Qualcomm
MQ1QrQla
NEC
Nokia
PanasoniG
Samsung
Sanyo
C = Car Phone or Portable with an external antenna on vehicle
within view of Cell Site
(good reception)
D = Portable phone inside a vehicle with signal obstructed by roof
of vehicle
(poor reception)
E = Portable or Car Phone with signal obstructed by building
(poor reception)
F = Represents a building, mountain , overpass or structure
blocking reception.
G = Parking Garage below ground encased in steel and concrete
(No Reception)
We have a problem. . . I can t see YOU!
Cellular signals are "line of sight". In other words , if the Cell Site
(A) can see your phone (B)(C) then you will get good reception.
Cellular signals can be blocked or decreased by certain
obstructions -- Metal , concrete , Brick, lead and masses of earth
(such as a hill or mountain) are a few. The metal body of a car (D)
and the concrete and steel of a building (F) are examples of this
signal blocking. Did you ever notice that you get no reception
when you park in underground parking?
Notice how the vehicle (D) is in plain sight of the Cell Site (A) and
yet reception is decreased. The metal body of the vehicle is
blocking the line of sight.
Today s Phones - Better?
To add to the problem , most Handheld/Portable phones have a
maximum output power of 0.6 watts and some only 0.2 watts. The
Car Phones of old had 3.0 watts of power. This explains why
cellular users noticed a difference in reception converting from a
car phone to a portable phone. Not only did they decrease the
power of their phone but they lost their external antenna with the
portable.
Continue to next
...
1E3------- Links for this Antenna Section Here Attachment F
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 2 of6
http://www.criterioncellular.comlhtmllbasics.htmi 4/8/2003
Hov' to Improve Reception - Basics of Wireless Page 3 of 3
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Attachment F
Case No. QWE-02-
Staff's 2nd Response to Qwest
04/16/03 Page 3 of
http://www.criterioncellular.com/htmilbasics.htmi 4/8/2003
COMMON QUESTION REQUIRES SIMPLE ANSWER Page 1 of 3
"",,",," ~~
~:i Attachment F
Case No. QWE-02-
a;(2)I!'I)i)(g)I!'Qij~~(Q)UiJ Staff s 2nd Response to Qwest
Order Online 24/7 or by Telephone [phone]am-4pm EST M.04/16/03 Page 4 of6
COMMON QUESTION:
TECH SUPPORT
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Main Page
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ntenna Ada ters
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I don t understand it...1 get bars outside my house or 100 feet
down the street, or in town, or on the hill, but when am inside my
house 1 can t make call!
This is the typical question the we constantly get asked at Cell Antennc
Tech Support. People are able to make a call from somewhere neal
their home or office but inside the house..nothing.
How does this happen? Simple. Radio waves are not the most reliable
things on this earth and that only leads to the cell phone not bein~
reliable either. For any call to take place using a cell phone 2 thing~
must happen. First , your cell phone must receive a proper signal frolT
the cell tower , and second , the cell tower must have a proper signa
from your cell phone.
But get bars, and why can make call?' That's because yoU!
little signal strength meter on your cell phone only measures the signa
coming from the cell tower. It does not give you an indication of the
strength of your signal at the tower. Think about it. You can have
bars from the powerful cell tower, but the tower doesn t hear YOL
because your cell phone only transmits 1/1 OOth of the energy of the
tower.
But when / go down the driveway of my house can make call.
my house can That is because the cellular signal loses strength
it goes through solid objects like brick walls, cedar shakes , etc.
Sometimes the pigment of the brick has metal in it and that reflects the
microwave signals. Some homes have an aluminum vapor barrier, anc
this metal doesn t help either. Another explanation can be that the cel
tower is broadcasting in a certain direction and you just miss the edge
of it....by 100 feet. All of these can drive you crazy. More importantl)
they reduce your ability to get your signal out to the cell tower.
It really doesn t matter which brand of cell phone you have. We have
found that some brands put out a little more power than the others, bu
overall they are all within 10% of each other. However, when a cel
phone has a long battery life, this usually indicates that the cell phone
does not transmit at the maximum permissible levels. The only wa)
you can save on battery life, is to lower the power of the cell phone
(Nokia 8200 or 3300 series).
That is why we are in business. We have several solutions to increase
the apparent power of your cell phone so that the cell tower pay~
attention to your conversation. Unlike the Internal Cell Phone Antennc
EralJg~' All of them involve real solutions that are based on sounc
http://www.cellantenna.com/common questionJequires simple.htm 4/9/2003
COMMON QUESTION REQUIRES SIMPLE ANSWER Page 2 of 3
Telular Base Stations
hat Connector do you
need or have? Click here
IFAQ
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Attachment F
Case No, QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 5 of
electrical engineering principles and not hocus pocus.
All solutions involve hooking up your cell phone
one way or another to a cable that connects to an 81 ~ ~3:
external antenna. Most cell phones have a small
1/4" plug located at the back of or beside the
antenna. When you pull this plug it exposes a socket that the cell
phone companies use for testing purposes. Our external cell phone
adapters fit into this socket. The adapter then connects to a cable that
goes to the antenna. When using our amplifiers, you install it between
the adapter and the antenna cable. When there is no plug available
we have a passive adapter or loop that fits over the existing antenna
and captures its signal. On some phones like the smaller Nokia , we
have a passive coupler that fits around the back of the cell phone.
Here is a link to our adapters: (CelL:ehQ!)~_xternal AJ:l(),:p~rs)
Here are some of our recommendations to improve the quality of your
signal and lessen the dropped calls.
Add an External Antenna
We have magnetic and glass mount antennas that can work in
your home or car that can double your signal strength. These
antennas are great for mobile use of the cell phone and have
gains ranging from 3 dB to 9 dB. In city or mountainous areas, we
recommend using antennas no greater than 5 dB on gain. Where
you are on water, or flat landscape, you can use the 7 or 9dB
magnetic mount antennas for improvement. (Click here for magnetic /
Portable Antennas). Some people use only our glass mount attached to
their home window and experience good results. Click here for Glass
Mount Antennas)
Where your cell phone is in a stationary use such as
the home or office, you can use our Fiberglass
Vagi and Panel antennas that provide gains of 7 to
10 dB. That translates into signal strength increase
of between 300 and 450%. This works both ways as well. The antenna
focuses the energy of your cell phone and beams it in the direction of
the tower, just like cupping your hands around your mouth can extend
the range of your voice. Vagi and panel antennas require them to be
installed higher up on your roof and pointed at the cell tower. It is not
difficult. All you do is hook up your cell phone to the Vagi antenna and
rotate the antenna until you see full strength on your cell phone signal
strength meter. (S~~__Y(;lgiJmd_~(;l.ll~LDir~G1iQn(;llAl.1..t~illJ,(;l~_5 bars and your
looking great! If you use our Fiberglass Cellular antennas , you do not
need to point them. They are placed straight up and gather signal from
360 degrees. (Fibergl1!!?~J21!al Ji(;l!!CLC~nul(;lL9qJtQ(;lj.llAntennas
Add a Signal Booster Amplifier
We carry 3 different amplifiers. The BST300 is used with the 824-896
MHz range of cellular providers. These include A TT, Cingular, Verizon.
The BST301 handles Nextel and Southern Link that use the frequency
range of 806-866 MHz. The amplifiers bring the power of your cell
phone from a maximum of .6 watts to a full 3 watts, which is the legal
http://www.cellantenna.com/common question _requires _simple.htm 4/9/2003
COMMON QUESTION REQUIRES SIMPLE ANSWER Page 3 of 3
limit.
The DA4000 amplifies the 824-896 MHz cellular
range and also the 1850-1990 MHz PCS band.
This amplifier works with every cellular service
except for Nextel and Southern Link. It works with
ATT, Verizon , Cingular, metroPCS, Sprint
Voicestream. It amplifiers the power of your cell
phone from .6 watts to 3 watts in the cellular 824-896Mhz range, and
to 2 watts in the PCS 1850-1990 MHz range.
Both of these amplifiers provide real power to the antenna system and
can take a very weak signal and give you full bars. However, if there is
no signal present, there is no way to amplify it. Click here for the
booster information: cell phone Signal Boosters
Why can t you simply hook up a Yagi to an antenna that you mount
inside your home on the ceiling? You can , only when the signal
strength in your area is strong enough. If it is strong enough , chances
are you wouldn t need an antenna anyways!
By using our antennas and amplifiers, you stand to have the best
chance of using your cell phone at longer distances and for longer
periods of time. You can reduce calls, and increase the reliability of
your service. However, there is no way that anyone can guarantee that
you will never ever have a dropped call or that in any situation you can
be guaranteed to have cell phone reception. After all , what can you
expect from a device that has less power than a small penlight
flashlight. !
comments or questions? howard~cellantenna.com
Copyright (9 2002, Cell Antenna Corporation
All rights reserved. No reproduction of this article of any kind is allowed without the express written
permission of its author, Howard Melamed or Cell Antenna Corporation. Contact
!:!.oward~cellantj;!nnc;!,.c_Qm for more details.
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Attachment F
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 6 of6
http://www.cellantenna.com/common questionJequires simple.htm 4/9/2003
CONTRACT FOR PROFESSIONAL SE;RVICES
This contract is entered into by and between the IDAHO PUBLIC UTILITIES
COMMISSION (Commission), whose principal office is located ~t 472 West Washington Street
Boise, Idaho , and Ben Johnson Associates, Inc. (Consultant), with offices at 2252 Killearn
Center Blvd., Tallahasssee, Florida 32308.
1. Purpose. Case No. QWE- T -02-25 currently is before the Commission for the
purpose of determining whether prices for Qwest's basic local service should be deregulated in
seven urban exchanges. Qwest has filed evidence to support its position that the presence of
wireless service in the exchanges meets the statutory standards for "effective competition
requiring price deregulation.The Commission believes that Consultant has the necessary
professional expertise to assist Staff to analyze and prepare testimony on Qwest's case, and
enhance the Commission s ability to evaluate whether wireless telephone service is competitive
with Qwest's wireline service in the seven exchanges. This Contract for Professional Services
establishes the terms by which Consultant will provide professional services to the Commission
Staff in Case No. QWE-02-25.
2. Scope of Work.Idaho Code 9 62-622(3) requires the Commission to cease
regulating basic local exchange rates upon a showing by an incumbent telephone corporation that
effective competition exists for basic local exchange service throughout the local exchange
calling area. The statute provides that effective competition may exist when there is
functionally equivalent, competitively priced local services reasonably available to both
residential and small business customers from a (different providerJ.Consultant is uniquely
qualified by education, experience and training to analyze and present data relevant to the issues
established by the statutory standards for deregulation. Consultant will assist Staff in preparation
of its case, including by proposing discovery requests and responses (if necessary), and
preparation and presentation of expert testimony. In greater detail, the Consultant's
responsibilities shall include:
a. Preparation of direct testimony, attendance at hearings, and analysis of
other parties ' testimony. The Consultant's testimony will discuss whether
wireless service is functionally equivalent. to and competitively priced
with Qwest's basic local service in Idaho , and the possible effect of price
deregulation on customers in Idaho. Unless otherwise approved by the
CONTRACT
Attachment G
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 1 of
Commission Staff, the presentation of evidence by Consultant may only
be provided by Dr. Johnson.
The schedule for delivery of work product submitted by the Consultant to the
Commission Staff will be reached by mutual agreement within the scheduling confines of the
case. Consultant will provide to the Commission Staff written testimony and exhibits in a form
and quality that will enable them to be submitted by Staff in Commission Case No. QWE-02-
25. The Commission Staff shall have the sole and unrestricted discretion to decide whether the
Consultant's work product will be presented in Case No. QWE-02-25.
3. Compensation.Compensation for preparation by Consultant of work product and
all related expenses shall not exceed $50 000 without written approval of the Commission. The
Consultant shall invoice the Commission on a monthly basis for services provided and expenses
incurred during the previous calendar month. Amounts billed will be based upon actual time and
expenses, based upon professional fees set out in the Consultant's rate schedule. The billed
amount for services will be paid upon satisfactory completion and delivery of the work product.
No payment shall be made until the Consultant provides the Commission with a completed W-
form. A balance of ten percent (10%) of the amount due for monthly services will be withheld
until satisfactory completion of the work product, delivery and acceptance of the testimony and
exhibits, and completion of the hearing in Case No. QWE-02-25.
Contact and direction relating to the contract will4. Contact and Direction.
primarily be with Joe Cusick or Weldon Stutzman on behalf of the Commission Staff and Ben
Johnson on behalf of Consultant.
5. Term.The term of this contract shall commence upon execution of this contract.
The contract shall expire upon the completion of consultant responsibilities hereunder or six (6)
months after the date of this contract, whichever occurs first.
The Commission may terminate, for its6. Termination for Convenience.
convenience, this contract in whole or in part upon fifteen (15) calendar days written notice to
the Consultant. If such termination is affected, the Commission shall provide payment to the
Consultant for work performed and, services rendered prior to the termination. Upon receipt of a
termination notice, the Consultant shall promptly discontinue all services affected unless the
notice directs otherwise.
CONTRACT
Attachment G
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 2 of
7. Termination for Default.In addition to any termination of this contract in
accordance with the preceding paragraph, the Commission may, by written Notice of
Termination served upon the Consultant, terminate this contract in whole or in part because of
the failure of the Consultant to fulfill its obligations.If this Contract is terminated, the
Commission shall provide payment to the Consultant for work successfully performed a~d
services satisfactorily completed prior to the termination. Upon receipt of a termination notice
the Consultant shall promptly discontinue all services unless the notice directs otherwise.
8. Amendment.This contract may be modified only by, written amendment signed
by the Commission and the Consultant.
9. Assignment.The contract shall not be assigned by either party without the prior
written consent of the other.
10. Best Efforts: Indemnification.The Consultant's work will be on a best effort
basis. The Consultant's liability to the Commission , if any, for any damages direct or
consequential resulting from breach of this contract will be limited to the amount paid the
Consultant hereunder. The Consultant agrees to hold the Commission and the State of Idaho
harmless from liability for injury to persons or to property which may result from Consultant's
performance of this contract.
11. Proprietary Rights.The parties to this contract hereby mutually agree that, if any
patentable, copyrightable material or article, or technical data should result from work described
herein, all rights accruing from such material or article, or technical data, shall be public
property, and shall not be the sole property of the Consultant.
12. Not Employment Contract. It is understood between the Commission and
Consultant that Consultant shall at all times remain an independent contractor, and that this
agreement does not create an employer/employee relationship. Consultant shall be responsible
for paying all employment-related taxes and benefits, such as federal, state and local income tax
withholdings, social security contributions, unemployment insurance premiums, health and life
insurance premiums, pension contributions and similar items.
13. Confidential Information.During the course of this contract, the Consultant may
gam access to confidential or trade secret information provided by public utilities. The
Consultant may be required to sign a protective agreement before gaining access to confidential
or trade secret information, and the Consultant shall be bound by the terms of any such
Attachment G
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 3 of29CONTRACT
protective agreement. Confidential information forwarded to the Consultant shall be protected
from unauthorized disclosure and shall be returned, if necessary, to the providing party at the
completion of the project. The confidentiality obligation contained in this section or in a
protective agreement shall survive termination of this contract.
14. Compliance With Laws.In performing this contract, Consultant shall comply
with all applicable laws and all rules, regulations and determinations of Idaho government
agencIes.
15. Governing Law.Both parties agree that this contract shall be governed by and
construed in accordance with the laws of the State of Idaho. Parties hereby consent to the
jurisdiction of the courts of Ada County in the State of Idaho in the event of any dispute with
respect to this contract.
16. Severability.The parties agree that if any term or provision of this contract is
declared by a court of competent jurisdiction to be illegal or in conflict with any law, the validity
of any remaining terms and provisions shall be construed and enforced as if the contract did not
contain the particular term or provision held to be invalid.
17. Waiver.The failure of the Commission to enforce any provision ofthiscontract
shall not constitute a waiver by the Commission of any and all remedies available to it for a
subsequent breach or default.
18. Entire Agreement.This contract constitutes the entire agreement between the
parties. This contract supersedes all prior agreements or understandings between the Consultant
and the Commission.
19. Execution in Counterparts.This contract may be executed in counterparts, each
of which shall be deemed an original and all of which together shall be considered one and the
same contract.
20. Mediation.Should any dispute arise between the parties to this contract, it is
agreed that the dispute will be submitted to a mediator, agreed to and compensated equally by
both parties, prior to commencement of litigation. Mediation will be conducted in Boise, Idaho.
Both parties agree to exercise their best efforts in good faith to resolve all disputes in mediation.
11. Attorneys ' Fees. In the event a legal proceeding is filed by eitHer party to
enforce this contract or recover damages resulting from breach of this contract, the prevailing
CONTRACT
Attachment G
Case No. QWE-02-
Staffs 2nd Response to Qwest
04/16/03 Page 4 of
party shall recover reasonable attorneys ' fees and all costs and disbursements incurred in such
proceeding.
22. Tax ID.The Consultant's tax identification number is !31-lq43rJ7!j
The parties by the signature below of their authorized representatives, hereby
acknowledge that they have read this contract, understand it and agree to be bound by its terms
and conditions.
..J-
DATED at Boise, Idaho this t- day of January 2003.
IDAHO PUBLIC UTILITIES COMMISSION
By:
BEN JOHNSON ASSOCIATES, INC.
By:
---
Reviewed & Approved
D. Hattaway
,,~
R. Lobb
M :contract- benjohnson - ws _2003
CONTRACT
Attachment G
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 5 of29
PRINCIPAL OFFICES:
2252 KILLEARN CENTER BLVD,
TALLAHASSEE, FLORIDA 32309
850-893-8600
FAX [phone]
ECONOMIC RESEARCH
AND ANALYSIS
6070 HILL ROAD
BOISE, IDAHO 83703
208-342- J 700
FAX [phone] J
VISIT OUR WEBSITES:
benjo h nsonass ociates, com
utilityregulation,com
ELEcrRONIC MAIL:
sta ffCQ! be njo hnsonassoci a te s, com
Ben Johnson(B)AssociatesJnc
CEIVEO
FilED
2693 APR 14
(j)
AM 8;
!OMit) PUBLIC
UTILITiES COMMISSION
April 4, 2003
Joe Cusick
Idaho Public Utilities Commission
472 W. Washington
State House Mail
Boise, Idaho 83702
RE: Qwest Deregulation
Statement No. 84903
Dear Mr. Cusick
Enclosed is the billing statement for the work performed during the month of March
2003.
Please call me if you have any questions.
Sincerely,
Ben Johnson, Ph.
President and Consulting Economist
BJ:ekb
Enclosure
Attachment G
Case No, QWE-02-
Staffs 2nd Response to Qwest04/16/03 Page 6 of
PLEASE REMIT TO:
2252 KILLEARN CENTER BLVD,
TALLAHASSEE, FLORIDA 32308
850-893-8600
ECONOMIC RESEARCH
AND ANALYSIS
DATE:
CLIENT:
NUMBER:
CASE:
TERMS:
STATEMENT
Ben Johnson(IDAssociates,lnc
April 3 , 2003
Idaho Public Utilities Commission
84903
Qwest Deregulation
Net due in 20 davs
For work performed during the month of March 2003.
Hours Rate Amount
Consulting Economist
Johnson, Ben 19.20 $150.880.
Research Consultant
Nesmith, John 55.$125.975.
Senior Research Associate
Hooper, Michael $110.34.751.00
Senior Research Assistant
Birdwell, Elizabeth $35.1.70 $59.
Attachment G
Case No. QWE-02-
Staff's 2nd Response to Qwest
04/16/03 Page 7 of29
Research Assistant
Groves, Laura 2.20
Research Assistant
Potter, Cameron
$25.$55.
$25.$22.50
Amount Due:$13 743.
Attachment G
Case No. QWE-02-
Staffs 2nd Response to Qwest
04/16/03 Page 8 of29
Consulting Economist
Johnson , Ben
3/5/03
3/7/03
Total daily hours: 2.
Preparation oftestimony outline
Total daily hours: 0.
Planning
Telephone conference with client
3/1 0/03 Total daily hours:0.50
Preparation of testimony
3/12/03 Total daily hours:
Preparation ?ftestimony
3/13/03 Total daily hours:10.
Preparation oftestimony
3/14/03 Total daily hours:1.30
Preparation oftestimony
3/17/03 Total daily hours: 0.
Review/analyze Staff draft testimony
TOTAL:19.
Attachment G
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 9 of
Research Consultant
Nesmith , John
3/3/03
3/4/03
3/5/03
3/6/03
3/7/03
Total daily hours: 5.40
Review/analyze discovery responses
Total daily hours: 9.
Preparation for/attendance at hearing outline
Preparation of outline
Review/analyze case materials
Total daily hours: 4.40
Project management
Review/analyze case materials
Total daily hours: 4.
Review/analyze case materials
Total daily hours: 6.
Telephone conference with NRRI
Preparation of testimony
Project management
3/1 0/03 Total daily hours:
Preparation oftestimony
3/11/03 Total daily hours:
Preparation of testimony
3/12/03 Total daily hours:
Preparation of testimony
3/13/03 Total daily hours:5.40
Preparation oftestimony
3/14/03 Total daily hours:
Preparation of testimony
3/17/03 Total daily hours:1.20
Project management
3/20/03 Total daily hours:
Project management
Attachment G
Case No. QWE-02-
Staff's 2nd Response to Qwest
04/16/03 Page 10 of
3/25/03 Total daily hours:
Project management
TOTAL:55.
Attachment G
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 11 of29
Senior Research Associate
Hooper , Michael
3/4/03
3/5/03
3/6/03
3/7/03
3/10/03
3/11/03
3/12/03
Total daily hours:
Planning
Review/analyze testimony
Review/analyze workpapers
Preparation ofworkpapers
Review/analyze discovery responses
Review/analyze discovery questions
Total daily hours:
Planning
Telephone conference with Wayne Hart
Document handling & control
Review/analyze workpapers
Review/analyze discovery responses
Review/analyze discovery questions
Total daily hours: 1.60
Planning
Review/analyze discovery responses
Review/analyze case materials
Total daily hours: 1.20
Review/analyze case materials
Total daily hours: 4.
Preparation oftestimony
Review/analyze case materials
Total daily hours:
Planning
Preparation oftestimony
Review/analyze case materials
Total daily hours: 7.
Planning
Preparation of testimony
Review/analyze case materials
Attachment G
Case No. QWE-02-
Staff's 2nd Response to Qwest
04/16/03 Page 12 of29
3/13/03 Total daily hours:
Planning
Preparation of testimony
Document handling & control
Review/analyze case materials
3/14/03 Total daily hours:0.20
Document handling & control
TOTAL:34.
Senior Research Assistant
Birdwell , Elizabeth
3/3/03 Total daily hours: 0.40
Document handling & control
3/11/03 Total daily hours: 0.40
Assistance with preparation of testimony
3/14/03 Total daily hours: 0.
Assistance with preparation of testimony
TOTAL:1.70
Attachment G
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 13 of
Research Assistant
Groves , Laura
3/3/03 Total daily hours:0.10
Document handling & control
3/4/03 Total daily hours:
Document handling & control
3/6/03 Total daily hours:0.10
Document handling & control
3/14/03 Total daily hours:
Document handling & control
3/17/03 Total daily hours:0.20
Document handling & control
3/20/03 Total daily hours:1.00
Document handling & control
3/24/03 Total daily hours:0.20
Document handling & control
TOTAL:
Attachment G
Case No. QWE-02-
Staffs 2nd Response to Qwest
04/16/03 Page 14 of29
Research Assistant
Potter , Cameron
3/7/03 Total daily hours:0.40
Document handling & control
3/11/03 Total daily hours:
Document handling & control
3/12/03 Total daily hours:
Document handling & control
3/17/03 Total daily hours:
Document handling & control
TOTAL:
Attachment G
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 15 of29
PRINCIPAL OFFICES:
2252 KILLEARN CENTER BLVD,
TALLAHASSEE. FLORIDA 32309
850-893-8600
FAX [phone]
ECONOMIC RESEARCH
AND ANALYSIS
6070 HILL ROAD
BOISE IDAHO 83703
208-342-1700
FAX[phone]
VISIT OUR WEBSITES:
benj ohnsonassaciates, com
utilityregulation.com
ELECTRONIC MAIL:
staff(gJ be n johns onassociates. com
" "" ",
RECElv.t~
FiLED
Ben JohnsonCIDAssociatesJnc
ZDf13 HAt?
~'
""'mt1d ",,,j:J
" ,
UTILi ;ES COf"1!~J:!SSiGri
March 5 , 2003
, '"'.,,,;
Joe Cusick
Idaho Public Utilities Commission
472 W. Washington
State House Mail
Boise, Idaho 83702
~ ~ tl
J-
RE: Qwest Deregulation
Statement No. 83503
Dear Mr. Cusick
Enclosed is the billing statement for the work performed during the month of
February 2003.
Please call me if you have any questions.
Sincerely,
Ben Johnson, Ph.
President and Consulting Economist
BJ:ekb
Enclosure
Attachment G
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 16 of29
PLEASE REMIT TO:
2252 K/LLEARN CENTER BLVD,
TALLAHAS~EE, FLORIDA 32308
850-893-8600
ECONOMIC RESEARCH
AND ANALYSIS
DATE:
CLIENT:
NUMBER:
CASE:
TERMS:
STATEMENT
Ben Johmon(IDAssodatesJnc
March 4, 2003
Idaho Public Utilities Commission
83503
Qwest Deregulation
Net due in 20 davs
For work performed during the month ofF ebrumy 2003.
Hours Rate Amount
Consulting Economist
Johnson, Ben $150.$615.
Research Consultant
Nesmith, John 35.$125.412.
Senior Research Associate
Hooper, Michael $110.$154.1.40
Research Assistant
Groves, Laura $25.$52.
Attachment G
Case No. QWE-02-
Staff's 2nd Response to Qwest
04/16/03 Page 17 of29
Research Assistant
Potter Cameron 0.40 $10 .$25.
Amount Due:244.
Attachment G
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 18 of29
Consulting Economist
Johnson , Ben
2/17/03
2/18/03
2/20/03
Total daily hours:
Planning
Total daily hours:
Planning
Telephone conference with client
Review/analyze Qwest testimony
Review/analyze issues outline
Total daily hours: 0.
Review/analyze functional equivalence
TOTAL:
Attachment G
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 19 of29
Research Consultant
Nesmith , John
2/3/03
2/4/03
Total daily hours: 1.90
Preparation of discovery questions
Total daily hours: 2.
Preparation of discovery questions
2/5/03 Total daily hours:0.30
Project management
2/10/03 Total daily hours:
Project management
2/11/03 Total daily hours:
Preparation of testimony
2/12/03
2/13/03
2/14/03
2/17/03
2/18/03
2/19/03
2/20/03
Total daily hours: 1.
Preparation of discovery questions
Total daily hours: 4.
Preparation of discovery questions
Review/analyze case materials
Total daily hours: 1.20
Preparation of discovery questions
Total daily hours: , 2.
Review/analyze case materials
Total daily hours: 5.
Telephone conference with client
Research concerning competition
Review/analyze list of issues
Preparation of outline
Total daily hours: 4.
Research concerning wireless
Total daily hours: 2.
Research concerning yellow pages
Attachment G
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 20 of29
2/21/03 Total daily hours:
Preparation of testimony
2/24/03 Total daily hours:
Project management
2/26/03 Total daily hours:
Project management
2/27/03 Total daily hours:
Project management
TOTAL:35.
Senior Research Associate
Hooper , Michael
2/18/03 Total daily hours: 1.40
Research concerning FCC report
Research concerning wireless articles
Research concerning discovery responses
TOTAL:1.40
Attachment G
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 21 of29
" '
I f
Research Assistant
Groves , Laura
2/11/03
2/12/03
2/18/03
2/19/03
2/24/03
2/25/03
Total daily hours:
Document handling & control
Total daily hours:
Document handling & control
Total daily hours:
Document handling & control
Total daily hours: 1.00
Document handling & control log in and online search
Total daily hours: 0.
Document handling & control
Total daily hours: 0.
Document handling & control
TOTAL:
Research Assistant
Potter , Cameron
2/19/03 Total daily hours: 0.40
Document handling & control
TOTAL:0.40
Attachment G
Case No. QWE-02-
Staffs 2nd Response to Qwest
04/16/03 Page 22 of29
PRINCIPAL OFFICES:
2252 KILLEARN CENTER BLVD,
TALLAHASSEE, FLORIDA 32309
, 850-893-8600
FAX [phone]
ECONOMIC RESEARCH
AND ANALYSIS
6070 HILL ROAD
BOISE IDAHO 83703
208-342-1700
FAX [phone]
VISIT OUR WEBSITES:
benjohnsonassociates, com
utilityregulation,com
ELECTRONIC MAIL:
staff(g)benjohnsonassociates, com
RctElVED rEf
fLED
lITfi3 FEB 12 Ar'\ 8: 52
Ben Johnson (B)
Associates,lnc
luAHf1i ,PtJ\BtH;:'
lrnu TIE j C u!'/i'f'HS ::iHJN
""""""'"~"'~-"""_.""'-"""",",
C""
"""""""","""
February 5 2003
Joe Cusick
Idaho Public Utilities Commission
472 W. Washington
State House Mail
Boise, Idaho 83702
RE: Qwest Deregulation
Statement No. 81803
Dear Mr. Cusick
Enclosed is the billing statement for the work performed during the month of
January 2003.
Please call me if you have any questions.
Sincerely,
Ben Johnson, Ph.
President and Consulting Economist
BJ:ekb
Enclosure
Attachment G
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 23 of29
PLEASE REMIT TO:
2252 KILLEARN CENTER BLVD.
TALlAHASSEE, FLORIDA 32308
850-893-8600
ECONOMIC RESEARCH
AND ANALYSIS
DATE:
CLIENT:
NUMBER:
CASE:
TERMS:
STATEMH~T
Ben Johnson(IDAssodates,lnc
February 4, 2003
Idaho Public Utilities Commission
81803
Qwest Deregulation
Net due in 20 davs
For work performed during the month of January 2003.
Hours Rate Amount
Consulting Economist
Johnson, Ben $150.$315.
Research Consultant
Bouchelle, Lee $125.$875.
Research Consultant
Nesmith, John $125.225.25.
, Senior Research Assistant
, Birdwell, Elizabeth $35.$21.00
Attachment G
Case No. QWE-02-
Staffs 2nd Response to Qwest
04/16/03 Page 24 of
Research Assistant
Groves, Laura 3.25
Research Assistant
Potter Cameron
$25.
$25.
Amount Due:
$81.25
$2.
519.
Attachment G
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 25 of
Consulting Economist
Johnson , Ben
1/1 0/03
1/27/03
1/29/03
Total daily hours: 1.50
Telephone conference with client
Review/analyze Qwest testimony
Total daily hours:
Planning
Research Consultant
Total daily hours:
Planning
Bouchelle , Lee
1/9/03
1/10/03
1/29/03
TOTAL:
Total daily hours: 3.
Review/analyze testimony
Review/analyze case materials
Total daily hours: 3.
Telephone conference with Client
Review/analyze case materials
Total daily hours: 0.
Document handling & control
TOTAL:
Attachment G
Case No. QWE-02-
Staff's 2nd Response to Qwest
04/16/03 Page 26 of
Research Consultant
Nesmith , John
1/10/03
1/11/03
1/13/03
1/20/03
1/21/03
1/22/03
1/24/03
1/28/03
1/29/03
1/31/03
Total daily hours:
Project management
Total daily hours:
Project management
Total daily hours: 0.40
Telephone conference with client
Total daily hours: 3.
Review/analyze case materials
Total daily hours: 4.
Review/analyze case materials
Total daily hours: 4.
Re-view/analyz;e case materials
Total daily hours: 4.
Review/analyze case materials
Total daily hours:
Review/analyze testimony
Total daily hours:
Review/analyze testimony
Total daily hours: 1.30
Preparation of discovery questions
TOTAL:25.
Attachment G
Case No. QWE-02-
Staff s 2nd Response to Qwest
04/16/03 Page 27 of29
Senior Research Assistant
Birdwell , Elizabeth
1/29/03 Total daily hours: 0.
Document handling & control
TOTAL:
Research Assistant
Groves , Laura
1/8/03 Total daily hours:
Document handling & control
1/9/03 Total daily hours:1.00
Document handling & control
1/21/03 Total daily hours:
Document handling & control
1/29/03 Total daily hours:1.00
Document handling & control
1/30/03 Total daily hours:
Document handling & control
TOTAL:3.25
Attachment G
Case No. QWE-02-
Staffs 2nd Response to Qwest
04/16/03 Page 28 of29
Research Assistant
Potter , Cameron
1/27/03 Total daily hours: 0.
Document handling & control
TOTAL:
Attachment G
Case No. QWE-02-
Staffs 2nd Response to Qwest
04/16/03 Page 29 of29
ATTACHMENT H
COMMISSION STAFF'S RESPONSE TO
QWEST'SECOND INTERROGATORIES
AND REQUESTS FOR PRODUCTION
OF DOCUMENTS
ELECTRONICALLY FILED
APRIL 16, 2003
ATTACHMENT I
COMMISSION STAFF'S RESPONSE TO
QWEST'SECOND INTERROGATORIES
AND REQUESTS FOR PRODUCTION
OF DOCUMENTS
ELECTRONICALLY FILED
APRIL 16, 2003
ATTACHMENT J
COMMISSION STAFF'S RESPONSE TO
QWEST'SECOND INTERROGATORIES
AND REQUESTS FOR PRODUCTION
OF DOCUMENTS
ELECTRONICALLY FILED
APRIL 16, 2003
ATTACHMENT K
COMMISSION STAFF'S RESPONSE TO
QWEST'SECOND INTERROGATORIES
AND REQUESTS FOR PRODUCTION
OF DOCUMENTS
ELECTRONICALLY FILED
APRIL 16, 2003
ATTACHMENT L
COMMISSION STAFF'S RESPONSE TO
QWEST'SECOND INTERROGATORIES
AND REQUESTS FOR PRODUCTION
OF DOCUMENTS
ELECTRONICALLY FILED
APRIL 16, 2003
ATTACHMENT M
COMMISSION STAFF'S RESPONSE TO
QWEST'SECOND INTERROGATORIES
AND REQUESTS FOR PRODUCTION
OF DOCUMENTS
ELECTRONICALLY FILED
APRIL 16, 2003
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 16TH DAY OF APRIL 2003
SERVED THE FOREGOING STAFF RESPONSE TO QWEST'S SECOND
INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS,
IN CASE NO. QWE-02-, BY MAILING A COpy THEREOF, POSTAGE
PREP AID, TO THE FOLLOWING:
MARY S HOBSON
STOEL RIVES LLP
SUITE 1900
101 S CAPITOL BLVD
BOISE, ID 83702
ADAM L SHERR
QWEST
1600 7TH AVE, ROOM 3206
SEATTLE, WA 98191
CONLEY WARD
GIVENS PURSLEY LLP
277 N 6TH ST, SUITE 200
PO BOX 2720
BOISE, ID 83701-2720
CLAY R STURGIS
MOSS ADAMS LLP
601 W RIVERSIDE, SUITE 1800
SPOKANE, W A 99201-0663
DEAN J MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE, ID 83701
BRIAN THOMAS
TIME WARNER TELECOM
223 TAYLOR AVE NORTH
SEATTLE, WA 98109
SUSAN TRAVIS
WORLDCOM INC.
707 17TH STREET, SUITE 4200
DENVER, CO 80202
MARY JANE RASHER
AT&T COMMUNICATIONS OF THE
MOUNTAIN STATES INC.
10005 S GWENDEL YN LANE
HIGHLANDS RANCH, CO 80129-6217
MARLIN D ARD
WILLARD L FORSYTH
HERSHNER, HUNTER, ET AL
180E 11TH AVE POBOX 1475
EUGENE, OR 97440-1475
DEAN RANDALL
VERIZON NORTHWEST INC.
17933 NW EVERGREEN PKWY
BEA VERTON, OR 97006-7438
JOHN GANNON
ATTORNEY AT LAW
1101 W RIVER, SUITE 110
BOISE, ID 83702
BEN JOHNSON
BEN JOHNSON ASSOCIATES INe.
2252 KILLEARN CENTER BLVD
TALLAHASSEE, FL 32308
~~
Jo T Y
CERTIFICATE OF SERVICE