200305089th Request of Commission.pdf

WELDONB. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 3283
I:ECEIVED
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2003 MAY -8 AM 9: 31
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UTILITiES COMt11SSION
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
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-
NINTH INTERROGATORY /
PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
QWEST CORPORATION
The Staff of the Idaho Public Utilities Commission by and through its attorney of record
Weldon B. Stutzman, Deputy Attorney General, requests Qwest Corporation (Qwest) provide the
following documents and information, pursuant to Commission Rule of Procedure 225 , IDAP A
31.01.01.225, on or before Thursday, May 22, 2003.
This Production Request is to be considered as continuing, and Qwest is requested to
provide, by way of supplementary responses, additional documents and information that it or any
person acting on its behalf may later obtain that will augment the documents and information
produced. For each request, please state the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness who can sponsor the answer at hearing.
responses include workpapers or spreadsheets, please provide the responses on computer media
(3.5" diskette or CD) using Lotus 123 (4.0) or Excel 5.0 language.
NINTH INTERROGATORY/
PRODUCTION REQUEST
TO QWEST MAY 8, 2003
DEFINITIONS and INSTRUCTIONS
The words "the Company" and "Qwest" refer to Qwest Corporation
Document" includes any written or recorded or graphic matter, however produced or
reproduced, including but not limited to correspondence, telegrams, contracts
agreements, notes in any form, memoranda, diaries, voice recording tapes, microfilms
microfiche, pictures, data processing cards or discs, computer tapes and other computer-
generated and stored information or data base, work papers, calendars, minutes of
meetings or any other writings or graphic matter, including copies containing marginal
notes or variations of any of the foregoing, now or previously in your possession.
(1)
(2)
In the event that any document called for is to be withheld on the basis of a claim
of privilege, identify the item being withheld as follows: addressor; addressee;
indicated or blind copies; and all persons to whom distributed, shown, or
explained. Also identify the nature and legal basis of the privilege asserted.
In the event that any document called for by this request has been destroyed or
transferred beyond the control of the Company, (a) state the identity of the person
by whom it was destroyed and person authorizing destruction and the time, place
and method of, and reasons for its destruction, and if destroyed or disposed of by
operation of a retention policy, state the retention policy; and, if transferred, the
person authorizing transfer and the time, place, and method of, and reason for, its
transfer, and (b) identify it as follows: addressor; addressee; indicated or blind
copies; dates; subject matter; number of pages, attachments or appendices; and all
persons to whom distributed, shown, or explained.
Identify,
" "
Identity," or "Identification " when used in reference to an individual person
means to state that person s full name and residence address, including zip code and
phone number, if known, and present or last known business position and duties and
business address, if known.
Identify,
" "
Identity," or "Identification " when used in reference to a document, means to
state the type of document (e., computer-stored information, microfilm, letter
memorandum, policy circular, minute book, telegram, chart, etc.), or some other means of
identifying it, and its present location and custodian. If any such document was, but is no
longer, in your possession or subject to your control, state what disposition was made of
, and if destroyed or disposed of by operation of a retention policy, state the retention
policy.
Identify,
" "
Identity," or "Identification " when used in reference to a number or other
specific information, means to identify the document containing this information or some
other means of identifying it, and to specify the approximate location of the requested
information within that document.
NINTH INTERROGATORY/
PRODUCTION REQUEST
TO QWEST MAY 8, 2003
Identify,
" "
Identity," or "Identification " when used in reference to a business
organization, means to state the corporate name or other names under which said
organization does business, and location of its principal place of business.
Note: to the extent the specific information requested herein is not available, but analogous or
reasonably comparable information is available, please provide that information instead, and
explain any differences between what was requested and what has been provided. To the extent
the information requested herein is not available in the exact format requested, but the
information can be more easily provided in a different format, please provide your response in
the more readily available format, but explain any differences in format. Please provide an
electronic copy of the requested information in Excel spreadsheet or compatible format.
Request for Production No. 35: Please provide copies of the following references cited
in Mr. Shooshan s rebuttal testimony:
Michael L. Katz and Harvey S. Rosen Microeconomics, Second Edition
(Boston: Richard Irwin Inc., 1994) at 32-63.
Stephen Martin, Advanced Industrial Economics (Blackwell: 1993) at 261.
F. M. Scherer and David Ross The Welfare Economics of Competition and
Monopoly, Industrial Market Structure and Economic Performance (Houghton
Mifflin Company, Boston: 1990) at 52
J. M. Clark
, "
Toward a Concept of Workable Competition The American
Economic Review Vol. XXX, No., June 1940.
The 2003 Telecom Industry Review: An Anthology of Market Facts and
Forecasts
, "
The INSIGHT Research Corporation (January 2003).
Mobile Communications Report, Warren Publishing, Inc. (November 2002).
Interrogatory No. 27: On page 20, lines 12 through 15 of his rebuttal testimony, Mr.
Shoo shan indicates Staff was unable to identify any studies showing wireless customers in Idaho
had problems in reaching 911. Please identify any studies, reports or evidence Qwest is aware of
showing that wireless customers in Idaho seldom or never experience problems when dialing
911?
NINTH INTERROGATORY/
PRODUCTION REQUEST
TO QWEST MAY 8, 2003
Request for Production No. 36: Please produce the subscriber records for all customers
who added DSL service between June 2000 and June 2002 that were analyzed for the claim on
lines 3-11 on page 26 of Mr. Souba s testimony. This should include a listing of all subscriptions
to primary or additional lines, plus any orders for changes to those services.
Request for Production No. 37: Please provide copies of the following references cited
in Dr. Lincoln s rebuttal testimony:
Economics, Robert B. Ekelund, Jr. and Robert D. Tollison , Little, Brown
and Company, 1986 , p. 74.
Heritage Foundation Reports, Local Telephone Competition: Unbundling
the FCC's Rules , February 10, 2003.
Market-Based Management- Strategies for Growing Customer Value and
Profitability, ed. by Roger Best, Prentice-Hall , 2003 , p. 87.
Heather Harreld
, "
USPS: Fighting for survival", Federal Computer Week, Falls
Church, Jun 5 , 2000.
Interrogatory No. 28: Starting on line 11 of his rebuttal testimony, Dr. Lincoln indicates
that his survey instrument was pre-tested with 40 individuals and that 96% of them said they
understood the terms used in the survey. Did Dr. Lincoln determine whether each individuals
understanding of the terms was the same as the other individuals? If so, how was that done?
Interrogatory No. 29: On page 10 of Dr. Lincoln s rebuttal testimony, he states that his
survey was "to determine the degree to which the Idahoans who would be affected by price
deregulation believed that effective competition existed in their area . Do you believe customers
understood they were giving an opinion on whether "effective competition existed in their area?"
If so , please explain.
Interrogatory No. 30: On page 13 of Dr. Lincoln s rebuttal testimony, he indicated that
the 876 consumers "tell us exactly what functional equivalence meant to them?" Do you believe
the survey respondents understood they were providing an opinion on whether wireless and
wireline services are functionally equivalent? If so, please explain.
NINTH INTERROGATORY/
PRODUCTION REQUEST
TO QWEST MAY 8 , 2003
Interrogatory No. 31: On page 13 of Dr. Lincoln s rebuttal testimony, he states that
these Idahoans told us that products are functionally equivalent when they can do the same
thing . Which question asked of the 800 survey respondents supports Dr. Lincoln s conclusion
that the survey respondents "(told) us exactly what functional equivalence meant to them?"
Request for Production No. 38: Please provide copies of the following references cited
in Mr. Teitzel's rebuttal testimony:
Bear Steams, Wireline Services. New Opportunities, New Challenges, March
2002.
Heritage Foundation Reports, Local Telephone Competition: Unbundling the
FCC's Rules , February 10, 2003.
The INSIGHT Research Corporation, The 2003 Telecom Industry Review: An
Anthology of Market Facts and Forecasts, January 2003.
International Data Corporation, Scott Ellison , IDC Study #29018, Wireless
Displacement of Wire line Access Lines Forecast and Analysis, 2002-2006 , page
, October, 2002.
International Data Corporation , IDC Study #28707, Top 10 U. S. Wireless
Services Issues in 2003 , pages 7-, January 2003.
ISP- Planet, The Broadband and Wireless Revolution by Michael Pastore
January 30 2002.
International Data Corporation, IDC Study #28355, Wireless Users Who
Displace Wireline Access Lines: A Survey Study and Analysis, November
2002.
International Data Corporation, IDC Study #26994 Soaring Wireline
Displacement and Highest Interest in Location-Based Services: U. S.
Wireless Household Survey Results, 2002, May 2002.
Rocky Mountain News, Look Ma, No Wires!; More Consumers Replacing
Home Lines with Mobile Phones, November 14, 2002.
NINTH INTERROGATORY/
PRODUCTION REQUEST
TO QWEST MAY 8, 2003
The New York Times, When the Cellphone Is the Home Phone, August 29, 2002.
United Press International Think tanks wrap-up, January 31 2003.
http://www. sltrib. com, visited April 7 ,2003.
Bell & Howell Information and Learning, ABI/INFORM , Cato Institute A
somewhat better connection Summer, 2002.
The Associated Press, Cell Phone Industry Nears 411 Info Service March 19
2003.
The complete CIT-PriMetrica study scheduled to be released in April, 2003
which is referenced in the article at: http://theregister.com/content/68/29779.html
visited 3/20/03.
M2 communications Ltd., EuropeMedia, Bucket pricing: way forward to fixed-
mobile substitution November 19 2002.
Request for Production No. 39: Please provide electronic copies of the spreadsheets
used for Exhibits 19 20 and 21 , with all underlying formulas visible.
Interrogatory No. 32: Please identify all features that are included in the total feature
revenue that was used in the calculation of the average cost of features used in Exhibit 19.
Request for Production No. 40: Please provide copies of studies that identify call hold
times from 1980 to the most recent available.
Interrogatory No. 33: Was the impact of the expanded local calling areas implemented
after 1996 factored in to the call holding times used in the preparation of Exhibit 21? If so, what
was the relative weight given to the impact of the expanded calling areas?
NINTH INTERROGATORY/
PRODUCTION REQUEST
TO QWEST MAY 8, 2003
Interrogatory No. 34: Was the increased use of calling centers and their tendency to put
callers on hold factored in to your analysis of the call holding times used in the preparation of
Exhibit 21 ? If so, what was the relative weight given to the increased use of calling centers?
Interrogatory No. 35: On lines 6 and 7 of page 9 ofMr. Teitzel's rebuttal testimony, he
quotes a T-Mobile advertising claim that it's network provides service quality that is "near parity
with wire lines . Is Qwest aware of any independent research that indicates wireless quality as
being at parity with wireline?
Interrogatory No. 36: Is Qwest aware of any studies that show that wireless quality of
service in Idaho does not experience the same type or frequency of problems that are experienced
nationally with wireless service? If so, please identify and provide a copy.
Interrogatory No. 37: Please identify the "comparable plans" referred to in footnote 21
ofMr. Teitzel's rebuttal testimony (the shared plans that include 3 phones and 600 shared
anytime minutes for $50 per month, the price point cited in the CIT-PriMetrica study on Pages 70
and 71 ofMr. Teitzel's rebuttal testimony).
Interrogatory No. 38: Are you aware of any wireless companies providing service in
Idaho that offer a shared plan that includes 3 phones and 2000 shared anytime minutes for $130
per month, also cited in the CrT -Primetrica study? If so, please identify.
Interrogatory No. 39: Does Qwest have any evidence ofthe usage by Idaho customers
of Ascendent's PBX product, identified on page 64 ofMr. Teitzel's rebuttal testimony? If so
please identify and provide to Staff.
Interrogatory No. 40: Is the Possio wireless fax device identified on page 67 ofMr.
Teitzel's rebuttal testimony available in Idaho. Does it work with all wireless carriers? How
many wireless customers in Idaho are using it?
NINTH INTERROGATORY/
PRODUCTION REQUEST
TO QWEST MAY 8, 2003
Interrogatory No. 41: Please identify the "several options for sending and receiving
faxes via wireless service" that are referred to on line 15 and 16, page 67 of Mr. Teitzel's rebuttal
testimony.
Interrogatory No. 42: On page 18 of his rebuttal testimony, Mr. Teitzel claims wireless
internet access is now available at speeds that are comparable to dial-up wireline speeds. Please
identify any wireless carriers serving these seven exchanges that currently provide complete
internet access (not just access to selected features or specially formatted sites) at comparable
speeds to that available for dial-up. Please also identify the charges for such services. Please
also identify each of the seven exchanges in which the services are provided.
Interrogatory No. 43: Starting on page 18 of his rebuttal testimony, Mr. Teitzel
identifies various problems with the methodology used by Staff witness Hart to estimate the
percentage of Idaho Internet users that access the Internet via dial up on a voice grade line. Does
Qwest have an estimate for the percentage of Idahoans that access the Internet via dial up that is
substantially different than Mr. Hart's? If so, what are those estimates and what is the source of
these estimates?
Interrogatory No. 44: Would the 911 legislation (HB363) that allows Idaho counties to
impose 911 fees on wireless customers impact the results shown in Exhibit 19 and Exhibit 20?
, what would be the impact?
Interrogatory No. 45: If and when wireless carriers implement local number portability,
is it reasonable to expect that they will experience increased costs that will be passed through to
their customers? Would the amount shown in Exhibit 20 for Qwest's Federal Portability charge
$0.43 , and reflected in the amounts shown in Exhibit 19, be a reasonable estimate for the per
customer amount of such a charge? Is it possible that wireless company costs for implementing
number portability will be higher than those of wireline companies?
Interrogatory No. 46: Do the usage amounts identified in Exhibit 20, and reflected in
Exhibit 19, include any minutes of long distance usage?
NINTH INTERROGATORY/
PRODUCTION REQUEST
TO QWEST MAY 8 , 2003
Interrogatory No. 47: On page 32 of his rebuttal testimony, Dr. Lincoln refers to the
average number of hours per week of internet use from a UCLA study and calculates the average
minutes of dial up use based upon that value. Does the UCLA study include both dial-up and
broadband users in its calculation of the average number of hours online? Is there any evidence
that dial-up users are not online as much as broadband users? If so, would that impact Dr.
Lincoln s calculation?
Interrogatory No. 48: Do wireless customers incur per minute charges for incoming
long distance minutes, either through per minute fees or through a decrease in the number of
minutes remaining in a bucket of minutes provided with the calling plan to which they are
subscribed?
Interrogatory No. 49: Do wireless customers incur per minute charges for originating
long distance minutes, either through per minute fees or through a decrease in the number of
minutes remaining in a bucket of minutes provided with the calling plan to which they are
subscribed?
DATED at Boise, Idaho, this 8(-L day of May 2003.
Weldon B. Stutzman
Deputy Attorney General
Technical Staff: Joe Cusick
Wayne Hart
i: umisc :prodreq/ qwetO225 _9thProductionRequest
NINTH INTERROGATORY/
PRODUCTION REQUEST
TO QWEST MAY 8, 2003
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 8TH DAY OF MAY 2003
SERVED THE FOREGOING NINTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO QWEST, IN CASE NO. QWE-02-, BY MAILING A
COpy THEREOF, POSTAGE PREPAID, 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, WA 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
WORLD COM 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
180Ell AVE POBOX 1475
EUGENE, OR 97440-1475
DEAN RANDALL
VERIZON NORTHWEST INc.
17933 NW EVERGREEN PKWY
BEAVERTON, OR 97006-7438
JOHN GANNON
ATTORNEY AT LAW
1101 W RIVER, SUITE 110
BOISE, ID 83702
BEN JOHNSON
BEN JOHNSON ASSOCIATES INC.
2252 KILLEARN CENTER BLVD
TALLAHASSEE, FL 32308
0J~~.SECRETARY
CERTIFICATE OF SERVICE