200506211st Qwest requests to Level 3.pdf

Mary S. Hobson
STOEL RIVES LLP
101 S Capitol Boulevard - Suite 1900
Boise, ill 83702-5958
Telephone: [phone]
Facsimile: [phone]
mshobson(fYstoel.com
Thomas M. Dethlefs
Senior Attorney
Qwest Services Corporation
1801 California Street - 10th Floor
Denver, CO 80202
Telephone: [phone]
Facsimile: [phone]
Thomas. DethlefS(fYqwest. com
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN TIlE MATTER OF LEVEL 3
COMMUNICATIONS, LLC'S PETITION
FOR ARBITRATION PURSUANT TO
SECTION 252(B) OF TIlE COMMUNICA-
TIONS ACT OF 1934, AS AMENDED BY
TIlE TELECOMMUNICATIONS ACT OF
1996, AND TIlE APPLICABLE STATE
LAWS FOR RATE, TERMS, AND
CONDITIONS OF INTERCONNECTION
WITH QWEST CORPORATION
CASE NO. QWE-05-
QWEST CORPORATION'S FIRST SET
OF INTERROGATORIES AND
REQUESTS FOR PRODUCTION OF
DOCUMENTS TO LEVEL 3
COMMUNI CA TI 0 NS, LLC
Qwest Corporation ("Qwest") requests that Level 3 Communications, LLC ("Level 3"
submit answers to the following interrogatories and requests for production of documents
(hereinafter collectively referred to as "data requests ) by serving the same on its undersigned
counsel within 28 days, as required by Idaho Public Utilities Commission (IPUC) Rule of
Procedure 225.03.
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INSTRUCTIONS
Pursuant to Idaho Rule of Civil Procedure 26( e), these data requests shall be
deemed continuing in nature, and any answer to a data request must be supplemented when
additional information responsive to the data request comes to your attention or the attention of
your attorneys or other representatives while this docket is pending.
Each data request should be answered fully and independently. If it is not
possible to provide a complete answer to a data request, or portion of a data request, the
remaining part of the data request should be answered and a reason should be stated why only
part of the data request has been answered.
All words used in their singular form shall include the words in their plural form
and all words in their plural form shall include the words in their singular form.
The use of the past tense shall include the present tense, and the use of the present
tense shall include the past tense.
If you contend that you are entitled to withhold any information requested herein
on a claim of privilege, then for each such item of information:
(a)
(b)
Identify the character of the information that is claimed to be privileged;
State the date and place of any communication which contained the
information;
(c)Identify each person who sent, participated in, overheard, or received the
communication or who now has possession, custody, or control of any documents relating
thereto;
(d)
(e)
Describe the subject matter of the privileged information;
State the number of pages of any privileged document;
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(f)State the basis upon which you contend that you are entitled to withhold
the information.
Any objection that you raise should be confined to that portion of the data request
for which you claim a privilege or objection and shall not excuse you from answering the
remaining part of the data request.
If any document requested has been lost or destroyed, state the circumstances of
such loss or destruction and identify each person having knowledge of such loss or destruction.
For any data request answered, identify the person or persons answering the data
request.
DEFINITIONS
As used in these data requests, the term "Level 3" shall refer to the Level 3
Communications, LLC (the Petitioner in this matter), its principals and predecessors in interest
and any person acting on behalf of any of them, including but not limited to their past or present
officers, directors, shareholders, agents, representatives, employees, attorneys, accountants, and
investigators.
As used in these data requests, the term "Qwest" shall refer to Qwest Corporation
its principals and predecessors in interest, including U S WEST Communications, Inc., and the
Mountain States Telephone and Telegraph Company, and any person acting on behalf of any of
them, including but not limited to their past or present officers, directors, shareholders, agents
representatives, employees, attorneys, accountants, and investigators.
The term "data request" or "request" includes an interrogatory, request for
admission, and request for production of documents, as applicable.
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The term "document" is defined to be synonymous in meaning and equal in scope
to the usage of this term in Idaho Rule of Civil Procedure 34 (a) and includes the original and all
non-identical copies (whether different from the original because of notes made on or
attachments to such copies or otherwise) of all "writings" and "recordings" as defined in Rule
1001 of the Idaho Rules of Evidence. The term "document" as used herein also includes
without limitation, papers, books, letters, journals, photographs, correspondence, telegrams
cables, telex messages, facsimile copies, brochures, memoranda, notes, notebooks, work papers
data sheets, bulletins, instructions, tape recordings, video tapes, transcripts, minutes or other
records of meetings or conferences, reports, agendas, affidavits, studies, financial statements
press releases, contracts, pamphlets, catalogues, calendars, desk calendars, appointment books
diaries, time records, telephone logs, expense reports, and drafts of all of the above. The term
document" further includes tapes, disks, and all other computer, electronic, photographic
magnetic, laser, or mechanical means of storing and recording information, together with
program and program documentation necessary to use or retrieve such information, and printouts
of such information.
The words "and" and "" shall be construed conjunctively or disjunctively as
necessary to make the requests inclusive rather than exclusive.
The word "including" shall be construed to mean without limitation.
The term "communication" means any oral or written statements, conversations
meetings, speeches, discussions, remarks, questions, answers, telephone calls, letters
memoranda, correspondence, electronic transmissions, or other transmittal of information by
writing or by other means.
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The terms "relating to" or "regarding" means constituting, comprising,
containing, consisting of, evidencing, setting forth, proposing, showing, disclosing, describing,
discussing, explaining, summarizing, concerning, reflecting, authorizing, referring to, or in any
way pertinent to that subject matter, either directly or indirectly.
The term "identify," or words of similar import:
(a)When used in reference to a document, shall mean to describe the
document with sufficient specificity to enable it to be requested in a subpoena duces tecum
including, but not limited to, the type of document, its author (and, if different, its signer or
signers), its date, its present or last known location, and its present or last known custodian.
(b)When used in reference to a natural person shall require the person s full
name, present or last known residence address, present or last known place of employment, and
present or last known occupation or job title.
10.The term "person" means any individual, firm, corporation, association
partnership, joint venture, governmental agency, or any other form of entity, together with any
officers, directors, partners, trustees, employees, representatives, or agents.
11.To "state the factual basis" for a claim, denial or defense means to provide a
reasonably detailed statement of the facts, information and matters which you presently believe
support or tend to support that claim, denial or defense. Your summaries should include, where
applicable, references to dates, times, persons and documents.
12.The term "Petition" shall refer to the Petition filed by Level 3 Communications
LLC in this docket.
13.The term "the Act" shall refer to the federal Telecommunications Act of 1996.
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14.The term "this state" or "state " when the context indicates that the request is
referring to one of the fifty states, shall refer to the state of Idaho.
DATA REQUESTS
DATA REQUEST NO.Identify by state and case number each section 252
arbitration case or docket that Level 3 has filed against a LEC other than Qwest and each case in
which a LEC filed for arbitration against Level 3 within the past three years in which contract
language regarding any of the following issues was at issue:
(a)
(b)
(c)
(d)
(e)
(f)
(g)
(h)
(i)
single point of interconnection with a LATA;
financial responsibility for transport facilities used by ILECs to deliver
traffic to the POI of the CLEC;
commingling of switched access traffic with other types of traffic on local
interconnection service (LIS) trunks;
relative use factors with regard to ISP-bound traffic;
intercarrier compensation for ISP-bound traffic;
the definition of Voice over Internet Protocol (VoIP) service or traffic;
intercarrier compensation for VoIP traffic;
the appropriate categorization of VoIP traffic under the 1996 Act;
the definition of any of the following terms:
(1)
(2)
(3)
(4)
(5)
(6)
(7)
Automated Message Accounting;
Switch Technology;
Basic Exchange Telecommunications Service;
Call Record;
Exchange Access;
Interconnection;
Interexchange Carrier;
(8) IntraLA T A toll traffic;
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(j)
(k)
(1)
(m)
(n)
(0)
(P)
(9)Local Interconnection Service;
(10)LIS Entrance Facility;
(11)Telephone Exchange Service; or
(12)Telephone Toll Service.
deposits related to forecasts of facilities;
the use of jurisdictional allocation factors to identify compensation for
various types of traffic;
the FCC's 3:1 ratio related to ISP-bound traffic;
the proper use of signaling information;
disclaimers with regard to special construction charges;
the use of "Originating Line Indicator" as defined in Level 3 's proposed
contract language, SS7 parameter, or any other signaling parameter for the
identification of VoIP traffic; or
Call Record Information (CRI) signaling parameter.
DATA REQUEST NO.For each case or docket identified in the prior request
identify the other LEC involved in the case or docket, the state commission, the docket number
of the case, its current status, whether an order has been issued (if so, when), whether the order is
on rehearing or appeal, the current status of rehearing or appeal, and, if appealed to a court, to
which court the appeal was made (including case number of the appeal).
DATA REQUEST NO.How many Points of Interconnection ("PO Is ) presently
exist between Qwest and Level 3 in Idaho for the exchange of traffic and what are their
locations?
DATA REQUEST NO.Does Level 3 have any affiliates that operate in Idaho? If so
identify each such affiliate.
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DATA REQUEST NO.For each affiliate identified in the prior request, identify any
and all types of Level 3 network facilities (i.e. switching, routing and transport) that are shared
with Level 3 affiliates in Idaho.
DATA REQUEST NO.Provide on a quarterly basis, beginning in January 2004
through the most recent quarter, the number of minutes of use (MOUs) of each type of traffic
(e., IntraLATA toll traffic, InterLATA toll traffic, ISP-bound traffic, Local/EAS traffic
Feature Group traffic, Transit Traffic, VoIP traffic) that Level 3 delivered to Qwest in Idaho.
DATA REQUEST NO.For each type of traffic described in the previous question
does Level 3 compensate Qwest for terminating such traffic? Describe the method of
compensation for each type of traffic
DATA REQUEST NO.Describe all technical limitations that would prevent Level 3
from routing both its local and toll traffic to Qwest over a Feature Group D trunk group. Provide
all documents evidencing any such limitations.
DATA REQUEST NO.Identify each product or service offered by Level 3 that
generates IP-enabled traffic in Idaho (e.
, "
(3) VoIP Enhanced Local Service
" "
(3)Tone
Business Service
" "
(3)VoIP Toll Free Service
" "
(3)VoIP Inbound Service
" "
(3)Voice
Termination Service
" "
(3) Connect Modem " etc.). For each product or service, provide:
(a)An explanation of how calls are or will be routed from Level 3 to Qwest
including network diagrams and call flow diagrams that illustrate the
product or service;
(b)Documents that describe and illustrate the location of other carriers (e.
CLEC, Wireless, IXC, ILEC), enhanced service providers, information
service providers, ISPs, and cable providers in the call flow, where such
entities are integral to the respective Level 3 product or service; and
(c)The location of the IP or TDM (Time Division Multiplexed/circuit-
switched format) gateways, i.e., the equipment that performs the protocol
converSIon.
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DATA REQUEST NO. 10:For each Level 3 product or service identified in the
previous request, identify the total volume of traffic (separately for each direction) exchanged
between Level 3 and Qwest in Idaho. Provide the information on a quarterly basis from January
, 2004 to the present.
DATA REQUEST NO. 11:Does Level 3 contend that it is not required to pay recurring
or nonrecurring rates set forth in Qwest's access services catalogs on file with the IPUC when
Level 3 delivers interexchange traffic to Qwest for termination? If the answer is yes, please
describe in full the circumstances in which Level 3 contends it is not required to pay the filed
recurring or nonrecurring rates.
DATA REQUEST NO. 12: Assume for purposes of this request that Level 3 has a
single POI for the Boise LATA with Qwest and assume that Level 3' s proposed contract
language were ordered to be placed in the agreement by the IPUC. Under these assumptions
what compensation, if any, either under the interconnection agreement or Qwest tariff or catalog,
would Qwest receive for the following calls:
(a)
(b)
For a Qwest customer located in Boise who calls a Level 3 customer with
a telephone number whose NP A/NXX relates to a wire center within the
same local calling area (LCA) as the calling party (i., the numbers relate
to the same LCA and the physical locations of the customers are within
the same LCA), what compensation would Qwest receive for originating
and transporting the call to Level3's POI in Boise?
F or a Qwest customer located in Boise who calls a Level 3 customer
physically located in Idaho Falls with a telephone number whose
NP A/NXX relates to a wire center in Idaho Falls (i., the numbers do not
relate to the same LCA and the physical locations of the customers are not
within the same LCA), what compensation would Qwest receive for
originating and transporting the call to Level 3' s POI in Boise?
(c)For a Qwest customer located in Boise who calls a Level 3 customer
physically located in New York City with a telephone number whose
NPA/NXX relates to a wire center in New York City (i.e., the numbers do
not relate to the same LCA and the physical locations of the customers are
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(d)
(e)
not within the same LCA or LATA), what compensation would Qwest
receive for originating and transporting the call to Level 3' s POI in Boise?
For a Qwest customer located in Boise who receives a call from a Level 3
customer physically located in Boise with a telephone number whose
NPA/NXX relates to a wire center in Boise (i., the numbers relate to the
same LCA and the physical locations of the customers are within the same
LCA), what compensation would Qwest receive for transporting the call
from Level3's POI in Boise and terminating it with Qwest's customer?
For a Qwest customer located in Boise who receives a call from a Level 3
customer physically located in Idaho Falls with a telephone number whose
NP A/NXX relates to a wire center in Idaho Falls (i., the numbers do not
relate to the same LCA and the physical locations of the customers are not
within the same LCA), what compensation would Qwest receive for
transporting the call from Level3's POI in Boise and terminating it with
Qwest's customer?
(f)For a Qwest customer located in Boise who receives a call from a Level 3
customer physically located in New York City with a telephone number
whose NPA/NXX relates to a wire center in New York City (i., the
numbers do not relate to the same LCA and the physical locations of the
customers are not within the same LCA or LATA), what compensation
would Qwest receive for transporting the call from Level 3' s POI in Boise
and terminating it with Qwest's customer?
DATA REQUEST NO. 13: Using the same assumptions as the previous request, under
the six scenarios listed therein, what compensation would Level 3 be entitled to receive from
Qwest for transporting, terminating or originating the call? Provide a separate response for each
scenano.
DATA REQUEST NO. 14:Using the same assumptions as the previous two requests
under the six scenarios listed therein, what compensation would Qwest be entitled to receive
from Level 3 for transporting, terminating or originating the call, if instead of the Qwest
customer being located in Boise, the Qwest customer is located in Twin Falls, Idaho? Provide a
separate response for each scenario.
DATA REQUEST NO. 15:Using the same assumptions as the previous three requests
under the six scenarios listed therein, what compensation would Level 3 be entitled to receive
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from Qwest for transporting, terminating or originating the call, if instead of the Qwest customer
being located in Boise, the Qwest customer is located in Twin Falls, Idaho? Provide a separate
response for each scenario.
DATA REQUEST NO. 16:Using the same assumptions as the previous four requests
under the six scenarios listed therein, what compensation would Qwest be entitled to receive
from Level 3 for transporting, terminating or originating the call, if instead of the Level 3
customer being located within the LCA associated with its assigned NP A/NXX, Level 3'
customer was actually physically located in a different LCA than New York City, Boise, Idaho
Falls, or Twin Falls? Provide a separate response for each scenario.
DATA REQUEST NO. 17:Assume that a Qwest customer in Idaho Falls frequently
calls an ISP through a local number associated with Idaho Falls, but the ISP's modems (either
owned and operated by the ISP or provided by Level 3) and Level 3' s PO I are both located in
Boise. Assume that the Idaho Falls customer is connected to the ISP for calls that average 1 000
minutes per month.
(a)Under Level 3' s proposed interconnection agreement language, what
amount would Qwest be required to pay Level 3 for terminating those
minutes?
(b)Assuming that Qwest's Idaho Falls customer pays for his or her local
service on a flat rated basis, would Qwest receive any additional revenues
for originating this traffic and delivering it to Level3's POI in Boise?
(c)Under Level 3' s proposed interconnection agreement language, would
Level 3 have any financial responsibility for the transporting of the call
from the end office serving Qwest's Idaho Falls customer to Level3's POI
in Boise?
DATA REQUEST NO. 18:Assume the same scenario as the prior request, except that
instead of the calls going to an ISP in Boise, the calls are routed to a VoIP customer whose VoIP
Provider POP is located in Boise and the VoIP Provider receives service from Level 3 , whose
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POI is also located in Boise. Assume that the Idaho Falls customer makes 1 000 minutes of calls
directed to the VaIP customer, but that the customer accesses the VoIP provider via a local
number provided to the VoIP customer that has an NP A/NXX associated with the Idaho Falls
LCA.
(a)
(b)
(c)
Under Level 3' s proposed interconnection agreement language, what
amount would Qwest be required to pay Level 3 for terminating those
minutes?
Assuming that Qwest's Idaho Falls customer pays for his or her local
service on a flat rated basis, would Qwest receive any additional revenues
for originating this traffic and delivering it to Universal's POI in Boise?
Under Level 3' s proposed interconnection agreement language, would
Level 3 have any financial responsibility for the transporting of the call
from the end office serving Qwest's Idaho Falls customer to Level3's POI
in Boise?
DATA REQUEST NO. 19:With regard to the definition of "VoIP" proposed by Level
3 (Issue 16):
(a)Has any state commission adopted that definition or one that is
substantially similar to it (e., one that includes Level3's proposed
separate sub-definitions of "ISP-bound VNXX traffic
" "
VoIP VNXX
traffic " and "Circuit Switched VNXX traffic.)? If so, identify the state
commission, the docket number of the case, and the date of the order.
(b)Has any state commission rejected that definition or one that is
substantially similar to it (e., one that includes Level3's proposed
separate sub-definitions of "ISP-bound VNXX traffic
" "
VoIP VNXX
traffic " and "Circuit Switched VNXX traffic.)? If so, identify the state
commission, the docket number of the case, and the date of the order.
DATA REQUEST NO. 20:Does Level 3 agree that in order for a call to qualify as a
VoIP call it must be originated by the calling party in Internet Protocol (IP) using IP- Telephone
handsets, IP adapters, CPE-based IP Telephone (IPT) Management "plug and play" hardware
IPT application management and monitoring hardware or such similar equipment? If not, please
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explain what portion of the foregoing Level 3 does not agree is part of an accurate definition of
VoIP or describe other requirements that should be met for a call to qualify as a VoIP call.
DATA REQUEST NO. 21:IfLevel3's answer to the first sentence in the preceding
request is yes, does Level 3 agree that a VoIP call must be transmitted over a broadband
connection to the VoIP Provider? If not, please describe the types of connections that may exist
between the calling party (i., the VoIP customer) and the VoIP Provider and have the traffic
between them still considered to be VoIP traffic.
DATA REQUEST NO. 22:As used by Level 3 in its definition of "VoIP" in this
docket, please state Level 3' s definition of the term "broadband connection.
DATA REQUEST NO. 23:Qwest's proposed definition ofVoIP requires that VoIP
traffic must be "transmitted over a broadband connection to the VoIP provider." (Emphasis
added) Level 3' s definition states that VoIP traffic must be "transmitted over a broadband
connection to or from the VoIP provider." (Emphasis added).
(a)Does the addition of the phrase "or from" mean that VoIP traffic must be
transmitted to the VoIP Provider on a broadband connection and that the
VoIP provider must also transmit the traffic to the public switched
telephone network (PSTN) on a broadband connection in order for the call
to qualify as VoIP?
(b)If that is not the meaning to be given to the addition of "or from" to the
definition, please explain its meaning and provide an example of traffic
from" the V oIP provider.
DATA REQUEST NO. 24:Is it Level3's proposal in this docket that compensation in
the amount of $.0007 per minute of use (MOD) be paid on all VoIP traffic, regardless of where it
originates, where the VoIP Provider POP is physically located, and where the called party is
physically located? Ifnot, please describe and distinguish the VoIP traffic that Level 3 proposes
be subject to $.0007 per MOU and the VoIP traffic that Level 3 proposes (1) should not be
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subject to compensation, or (2) should be subject to compensation, but at a different rate than
0007 per MOU.
DATA REQUEST NO. 25:Does Level 3 agree that, for purposes of determining
whether compensation at the rate of $.0007 per MOU applies to VoIP traffic, the physical
location of the VoIP Provider POP should be one of the two physical locations used to determine
the originating and terminating points of the specific call? Ifnot, please explain why not.
DATA REQUEST NO. 26:Assuming hypothetically that the IPUC were to determine
that intercarrier compensation for VoIP traffic will be determined based on the physical
origination point of the call and physical termination point, should the physical location of the
person originating the call or the physical location of the VoIP Provider POP be used as the
originating point of the call? If neither, what physical point would Level 3 propose be used by
the IPUC?
DATA REQUEST NO. 27:If the VoIP Provider POP for a VoIP Provider served by
Level 3 and the called party (assume for purposes of this question that the called party is a Qwest
customer) on a VoIP call are not physically located within the same local calling area (as defined
by the Commission):
(a)Does Level 3' s proposed contract language require Qwest to transport the
call from the Level 3/Qwest POI to the end office serving the called party
at no cost to Level 3?
(b)Once the call reaches the end office of the called party, does Level3'
proposed contract language require Qwest to terminate the call in the local
calling area at no cost to Level 3?
(c)Does Level 3' s proposed contract language require Level 3 to pay Qwest
intercarrier compensation of any kind for the call? If so, describe the type
of compensation and how it would be applied.
(d)If the answer to c. is that Level 3 would pay Qwest intercarrier
compensation, does Level 3 propose that Level 3 would pay Qwest for
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(e)
(f)
transporting the call from the POI to the end office serving the called
party? If not, why not?
Does Level 3' s proposed contract language require Qwest to transport the
call from the POI to the end office serving the called party over Local
Interconnection Service ("LIS") trunks? Ifnot, what type of trunks does
Level 3' s language propose be used to transport such a call?
With regard to (e), does Level 3 propose that Level 3 should bear any
financial responsibility for transporting such a VoIP call from the POI to
the end office of the called party? If so, in what manner and at what rates
should Level3's financial responsibility be determined?
DAT A REQUEST NO. 28:Does Level 3 consider a call that originates in Time
Division Multiplex ("TDM"), is converted into Internet Protocol (IP), and then is terminated in
TDM (commonly referred to as a TDM-IP-TDM call) a VoIP call for purposes of the
interconnection agreement in this case?
DATA REQUEST NO. 29:Does Level 3 consider a call that originates in TDM and
terminates with a VoIP called party in Internet Protocol (commonly referred to as a TDM-
call) a VoIP call for purposes of the interconnection agreement in this case?
DATA REQUEST NO. 30:Does Level 3 provide "(3) VoIP Enhancedsm Local Service
or a service similar to it in Idaho?
(a)
(b)
If not, does it plan to do so in the near future?
Does Level 3 provide this service to end user retail customers?
(c)Does Level 3 provide this service on a wholesale basis to VoIP or IP-
enabled service providers?
DATA REQUEST NO. 31:Does Level 3 provide any other services with similar
functionalities as "(3) VoIP Enhancedsm Local Service ? If so, identify and describe the services.
DATA REQUEST NO. 32:Based on the diagram of "(3) VoIP EnhancedsM Local
Service" (attached hereto as Exhibit A), it appears that this service allows call origination from
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analog phones. When a call is initiated using an analog phone per that diagram, does Level 3
consider the call to be a VoIP call?
DATA REQUEST NO. 33:On Exhibit A attached hereto, Level 3 states that it is
( c Jommitted to customer enablement, Level 3 will not compete against our (3)VoIP Enhanced
Local customers in the retail market." Does this mean that Level 3 does not provide VoIP
services to retail end user customers? If not, please describe the VoIP services that Level 3
provides to end user retail customers.
DATA REQUEST NO. 34:Does Level 3 provide "(3)Voice~ Termination" or similar
service in Idaho?
(a)
(b)
If not, does it plan to do so in the near future?
Does Level 3 provide this service to end user retail customers?
(c)Does Level 3 provide this service on a wholesale basis to VoIP or IP-
enabled service providers?
DATA REQUEST NO. 35:Is Level 3 providing any other VoIP services in Idaho
either in a retail or wholesale capacity? If so, please describe each service, and state as to each
whether it is a service to retail end user customers or to VoIP or IP-enabled service providers.
DATA REQUEST NO. 36:Is Level 3 a VoIP provider to end user customers in Idaho?
If not, does Level 3 plan to do so after the interconnection agreement is approved in this docket?
DATA REQUEST NO. 37:Does Level 3 consider itself to be an enhanced service
provider (ESP) in connection with the provision ofVoIP services? If so, please explain the basis
for its conclusion that it is an ESP.
DATA REQUEST NO. 38:Does Level 3 consider third party wholesale customers that
provide VoIP services that are enabled by Level 3 services such as "(3) VoIP EnhancedsM Local
Service" or similar services to be ESPs?
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DATA REQUEST NO. 39:Does Level 3 require carriers or businesses purchasing its
(3)VoIP Local Inbound Service" or similar services to physically locate their equipment in the
same local calling area in which Level 3 provides telephone numbers to them for such service?
If so, provide documents relating to such requirements.
DATA REQUEST NO. 40:With regard to the definition of"VNXX traffic" proposed
by Level 3 (Issue 3B):
(a)
(b)
Has any state commission adopted that definition or one that is
substantially similar to it (e., one that includes Level3's proposed
separate sub-definitions of "ISP-bound VNXX traffic
" "
VoIP VNXX
traffic " and "Circuit Switched VNXX traffic.)? If so, identify the state
commission, the docket number of the case, and the date of the order.
Has any state commission rejected that definition or one that is
substantially similar to it (e., one that includes Level 3's proposed
separate sub-definitions of "ISP-bound VNXX traffic
" "
VoIP VNXX
traffic " and "Circuit Switched VNXX traffic.)? If so, identify the state
commission, the docket number of the case, and the date of the order.
DATA REQUEST NO. 41:On a monthly basis for all types of traffic for the past two
years, what percent of traffic from Qwest customers in Idaho that is delivered to Level 3 has
been ISP-bound traffic?
DATA REQUEST NO. 42:Taking all telecommunications traffic (as defined in the
FCC's reciprocal compensation rules) exchanged between Qwest and Level 3 in Idaho for the
past two years:
(a)What percentage of that telecommunications traffic has been delivered by
Qwest to Level 3?
(b)What percentage of that telecommunications traffic has been delivered by
Level 3 to Qwest?
DATA REQUEST NO. 43:As a CLEC in Idaho, does Level 3 provide local exchange
service to end user retail customers? If so, what percent of total minutes exchanged by Qwest
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and Level 3 in Idaho in the past two years is represented by minutes originating from retail end
user customers served by Level 3?
DATA REQUEST NO. 44:In Idaho, does Level 3 obtain local telephone numbers from
NANP A (North American Numbering Plan Administrator) for the use by Level 3' s ISP
customers so that customers of that ISP may call a local number in order to obtain access to the
ISP, even though that ISP has no physical facilities located in the local calling area (as defined
by the Commission) associated with such telephone numbers?
DATA REQUEST NO. 45:In Idaho identify each LATA and local calling areas for
which Level 3 has obtained telephone numbers from NANP
DATA REQUEST NO. 46:For each of the local calling areas identified in the response
to the prior question provide:
(a)the NP A NXXs that Level 3 has obtained (including pooled or ported
numbers) ;
(b)
(c)
the number of Level 3 subscribers that Level 3 provides with local service;
the number of Level 3 subscribers that are ISPs;
(d)
(e)
the number of Level 3 subscribers that are not ISPs; and
the description of any Level 3 subscribers that are not included in sub-
questions c and d.
DATA REQUEST NO. 47:Provide the industry standard or any other documentation
reference that Level 3 relies upon for the proposition that Qwest has an obligation to always
populate the Originating Line Information parameter.
DATA REQUEST NO. 48:Provide the industry known definition for "Originating Line
Indicator" and provide a description of the difference between "Originating Line Indicator " and
the "Originating Line Information" (as defined in the SS7 Protocol).
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DATA REQUEST NO. 49:Provide the industry known definition for "Other Company
Number" and provide a description of the difference between "Other Company Number" and the
Operating Company Number" (as defined in the LERG).
DATA REQUEST NO. 50:Provide the industry standard, or any other documentation
reference that Level 3 relies upon, that requires Qwest or any other company to always provide
either the "Other Company Number" or the "Operating Company Number" for purposes of:
(a)
(b)
intercarrier compensation of local traffic; or
intercarrier compensation of non-local traffic.
DATA REQUEST NO. 51:Is Level3's network switching/routing infrastructure
capable of accurately and reliably populating the Charge Number SS7 parameter for local traffic
routing to Qwest?
DATA REQUEST NO. 52:Is Level3's network switching/routing infrastructure
capable of accurately and reliably populating the Charge Number SS7 parameter for non-local
traffic routing to Qwest?
DATA REQUEST NO. 53:Is Level3's network switching/routing infrastructure
capable of accurately and reliably populating the Calling Party Number SS7 parameter for local
traffic routing to Qwest?
DATA REQUEST NO. 54:Is Level3's network switching/routing infrastructure
capable of accurately and reliably populating the Calling Party Number SS7 parameter for non-
local traffic routing to Qwest?
DATA REQUEST NO. 55:Produce all industry standards and vendor documentation
that defines the "Call Record Information" signaling parameter.
DATA REQUEST NO. 56:Exhibit B is a page from Level3's website related to a
service entitled "(3)Connect~ Modem" service. It states that "Level 3 takes care of setting up a
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local Internet dial-up network, securing local numbers, deploying modems, and staffing a round-
the-clock operations center to manage the network and hardware so you can do what you do best
- service your end user customers." Please respond to the following questions with regard to
that service (or with regard to other services of Level 3 whereby Level 3 obtains local numbers
for ISPs and provides the functionalities of modems and routers for the ISP):
(a)
(b)
(c)
(d)
Does Level 3 provide "(3 )Connect~ Modem" service to ISP customers that
provide dial-up service in Idaho?
Does Level 3 maintain "modems to collect traffic" or "managed routers
that are physically located in any local calling areas in Idaho? If so, please
identify the local calling areas in Idaho in which Level 3 maintains such
modems to collect traffic" or "managed routers.
When Level 3 serves an ISP through Level3's "(3)Connect Modem
service or similar service, what equipment is the ISP required to maintain
to communicate with Level 3?
Describe how the customer validation process is conducted to determine if
the calling party is a valid customer of the ISP served by Level 3? What
specific equipment must the ISP have in order to conduct the validation
process?
(e)Assume hypothetically that a Qwest customer is also a dial-up customer of
an ISP served by Level 3 through Level. 3' s "(3 )Connect~ Modem" service
or similar service.
(1)When that customer dials the local number provided by Level 3 to
access the ISP, where is the call answered? (For example, is it
answered by the modems provided by Level 3 for the ISP or by
some other piece of equipment provided by Level 3?)
(2)Are there any circumstances in which the call is answered by the
ISP's equipment? If so, describe the circumstances under which
the ISP answers the call and the type of equipment used to do so.
(f)Whether the equipment is provided by Level 3 for its ISP customers or by
the ISP on its own behalf for a dial-up Internet session, please describe:
(1)the specific piece or pieces of equipment that retains the ongoing
connection to the end user during the course of the call; and
(2)the specific piece or pieces of equipment that directs the call to
websites selected by the end user during the course of the call.
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(g)
(h)
(i)
(j)
Would it be fair to characterize Level3's "(3)Connect Modem" service
as a service by which Level 3 provides ISPs with basic functionalities
related to access to the Internet (e., modems and routers) on a wholesale
basis so that the ISP need not perform those functions on its own behalf?
If not, please accurately describe Level3's characterization of its
relationship with its ISP customers to whom it provides "(3)Connect
Modem" service.
Before reaching the modems and routers provided by Level 3 as part of its
(3)Connect~ Modem" service or similar service, does the traffic go
through a switch owned or operated by Level 3? If so, provide the
addresses of any such switches in Idaho.
Does Level 3 require an ISP purchasing Level3's "(3) Connect Modem
service or any other similar dial-up ISP product to physically locate its
equipment in the same local calling area in which Level 3 assigns dial-up
telephone numbers for the ISP's customers to call? If so, provide
documents relating to such requirements.
Does Level 3 require an ISP purchasing Level3's "(3) Connect Modem
service or any other similar dial-up ISP product to physically locate its
equipment in the same state in which Level 3 assigns dial-up telephone
numbers for the ISP's customers to call? If so, provide documents relating
to such requirements.
DATA REQUEST NO. 57:The following set of questions relate to situations where
instead of Level 3 providing modems and routers for its ISP customers, the ISPs obtain local
telephone numbers through Level 3 and traffic is gathered from Qwest by Level 3 on behalf of
such ISPs, but the ISPs provide their own modems and routers for themselves.
(a)Does Level 3 provide service as described above to any ISP that provides
service to customers in Idaho? If so, how many ISPs that provide service
to customers on that basis provide service to customers in Idaho?
(b)How many ISP customers identified in the previous subpart, physically
locate their modems and routers in Idaho and how many physically locate
their modems and routers in other states?
(c)When Level 3 provides service to ISP customers as described in this
question, does the traffic go through a Level 3 switch before being
delivered to the ISP's modems and routers? Ifnot, does the traffic go
through any Level 3 equipment between its POI and the modems and
routers of the ISP? If so, describe all such equipment.
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(d)When Level 3 provides service to ISP customers as described in this
question, how does Level 3 connect its equipment to the routers and
modems of the ISP (e., high-capacity circuit, over the Internet)?
DATA REQUEST NO. 58:Based on Qwest's reading ofLevel3's proposed definition
ofVNXX Traffic (Issue 3B), Level3's proposed language for section 7.3.4.1 (Issue 4), and
Level3's proposed language for section 7.6.1 (Issue 3C), there appears to be an inconsistency
in the application of inter carrier compensation for different types of traffic. For example, Level
, 3's proposed 7.3.1 and the definition ofVNXX traffic suggest that all ISP-bound traffic and
VoIP traffic will be subj ect to reciprocal compensation without limitation, while section 7.3 .4.
states that "intercarrier compensation" for all "section 251 (b )( 5) traffic" will be based on
whether the "originating and terminating NPA-NXX codes correspond to rate centers located
within defined local calling areas (including ISP-bound and VoIP Traffic)." In light of the
foregoing, please respond to the following:
(a)
(b)
(c)
Describe all specific types of traffic Level 3 includes in its definition of
section 251(b)(5) traffic.
What is Level 3' s definition of the term "intercarrier compensation" as
used in its proposed language for section 7.3.4.1? Is that the same
definition used whenever that term is used in other places in Level3'
proposed language? If not, identify the sections in which the term has a
different meaning and state the definition as used in those sections.
Is it Level3's position that compensation at $.0007 per minute for all
traffic destined for the Internet should be required in the interconnection
agreement? If so, what is the purpose for the language of section 7.3.4.
that suggests that compensation will paid only when the NP A/NXXs of
the called and calling parties correspond to rate centers located within
defined Qwest local calling areas?
(d)Is it Level3's position that compensation at $.0007 per minute for all
VoIP traffic should be required in the interconnection agreement? If so
what is the purpose for the language of section 7.3.4.1 that suggests that
compensation will paid only when the NP A/NXXs of the called and
calling parties correspond to rate centers located within defined Qwest
local calling areas?
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(e)Level 3' s language for section 7.3 .4.1 omits any mention of "EAS/Local"
traffic. How does Level 3 propose to treat that category of traffic for
intercarrier compensation purposes?
DATA REQUEST NO. 59:With regard to section 252 arbitration proceedings in which
Level 3 has been a party, identify each state commission (by case name, docket number, and date
of order) that has adopted or agreed with Level3's contention that "federal ISP-bound traffic
compensation regime applies to all ISP-bound traffic.
DATA REQUEST NO. 60:With regard to section 252 arbitration proceedings in which
Level 3 has been a party, identify each state commission (by case name, docket number, and date
of order) that has rejected or disagreed with Level3's contention that "federal ISP-bound traffic
compensation regime applies to all ISP-bound traffic.
DATA REQUEST NO. 61:Does Level 3 consider VoIP traffic to be "ISP-bound
traffic
DATA REQUEST NO. 62:Does Level 3 collect and remit state universal fund
surcharges to the Idaho Universal Service Fund (USF) for any services, including VoIP services
that Level 3 provides to its customers? To the extent VoIP services are provided by third party
provider customers of Level 3, state whether Level 3 is aware whether those third party providers
collect and remit universal fund surcharges to the Idaho USF.
DATA REQUEST NO. 63:Under Level 3's proposal, how would a terminating carrier
other than Qwest be provided with call records or otherwise compensated for traffic that Level 3
routes through a portion of Qwest's network for termination with that terminating carrier?
Dated this 21 st day of June, 2005 ~L-
Mary S. bson
Stoel Rives LLP
Attorneys for Qwest Corporation
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CERTIFICATE OF SERVICE
I hereby certify that on this 21 st day of June, 2005 , I served the foregoing QWEST
CORPORATION'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR
PRODUCTION OF DOCUMENTS TO LEVEL 3 COMMUNICATIONS, LLC upon all
parties of record in this matter as follows:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ill 83720-0074
i i ewell(fYpuc.state.id. us
Weldon Stutzman
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ill 83720-0074
Telephone: [phone]
weldon. stutzman(fYpuc.Idaho. gov
Dean J. Miller
McDevitt & Miller LLP
420 West Bannock Street
O. Box 2564
Boise, ill 83702
Erik Cecil
Regulatory Counsel
Level 3 Communications, LLC
1025 Eldorado Boulevard
Broomfield, CO 80021
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
&an?V~A~
Brandi L. Gearhart
Legal Secretary
Stoel Rives LLP
QWEST CORPORATION'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF
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EXHIBIT A
V'\
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(3)VoIP EnhancedSN local Service
~Y.~.(3)"
For information about L~~/3 s~rvic:rs. "isit our Web sitt at wwwoltVt/3.com C'1004-1005l~veI3 Enhanced Srrvic~s. Uc. All rights r~5~M!do
VOIP SERVICES FOR WHOLESALE CUSTOMERS
(3)VoIP Enhanced Local service enables service providers to offer
Voice over IP (VolP) services via their consumer Internet broadband
connections - complete with local phone numbers and E-911.
This wholesale VolP service is available in over 300 markets, with
approximately 60 percent of the U.S. population addressable using
this service.
With (3)VolP Enhanced Local service, cable operators, lXCs, enhanced
service providers, and other companies can launch IP-based local and
long-distance communications services to consumers via any
broadband connection.
Level 3's unmatched proprietary Softswitch platform makes the
service extremely efficient, enabling providers to cost-effectively
accelerate their deployment of high-quality VolP services.
WHAT YOU CAN 'OFFER YOUR CONSUMER BASE
With (3)VolP Enhanced Local service, wholesale customers can offer
their broadband Internet end-users:
. Local and long distance phone service with the ability to make and
receive calls worldwide using either an existing analog
touchtone telephone or a digitallP telephone
. Freedom from the need for traditional telephone service (their
broadband Internet connection - cable, DSL, etc. - is used instead)
. E-911 service for emergency phone calls, with the same routing
used by standard telephone service providers
. Local numbers and Local Number Portability (LNP) with Port-
and Port-out capability
. Operator assistance, directory listings, and directory assistance
. Any number of other features that your company might choose to
add With (3)VoIP Enhanced Local service, you manage and operate
your own Class-5 Softswitch, giving you full control over the
features available to your consumers.
(3)VoIP Enhanced Local
- -~..~-- - -- - ---- ---- - -- - --..
THE CONTROL YOU NEED - WITH SIMPUCITY
With (3)VoIP Enhanced Local service, you obtain the essential
building blocks required to offer VolP phone service - including
network trunking, local numbers, local number portability, E-911,
operator assistance, directory listings, and directory assistance.
But you don t have to stop there. Because you manage your own
switching, you have total control over the features used by the end
user, with minimal involvement in complex interconnection issues.
You can add competitive features and emerge on top of the industry.
All end-user billing and customer equipment is managed by your
company as well.
TECHNICAL OVERVIEW
. Coverage: Provides local phone numbers, LNP, and local trunking
to over 1,500 rate centers with local calling - all available today.
VolP coverage reaches over 300 markets and approximately 6QO.b
of the u.S. population.
. Local network: Offers low-cost, nationwide access with Level 3'
CLEC status in 48 states (with 1.4 million voice-capable trunks).
. Regulatory compliance: Meets E-911 emergency service and Local
Number Portability requirements.
. Neutral, wholesale voir strategy: Committed to customer
enablement, Level 3 will not compete against our (3)VolP Enhanced
Local customers in the retail market.
LEVEL 3 AND VOIP
Level 3 has proven its VolP leadership and expertise since 1999, when
we introduced (3)Voice~ Termination, the industry's first PsrN-
quality VolP service requiring no special dialing by the end user. Our
patented, proprietary Softswitch is now processing more minutes per
month than many traditional long distance and local carriers.
Th~ Level 3 logo end (3JVuia /J~ ~giskml smricr maries, tmd (3JVoIP Enlranctd is II smrict
mam of inri 3 CornmllJlimrions. Inc. in tIt~ lhllled SIBks and/or otIttr cvuntrirs.
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. Local and long distance calling
with access to the PSTN
. local ~one numbers
. Operator assistance
. Directory listings and assistance
. E911 emergency ~rvic:es
. Local number portability
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EXHIBIT B
Level 3 Communications, Inc. - Managed Modem Page 1 of I
Level ': Sul'ilh P,jr:II::'CmtUlr1tl~, 1t1l'l-~t,-,l';I ; ~"
. '' .
(3)Connect(ID Modem
If you require an end-to-end, dial-up solution, our (3)Connect Modem service
is your answer. (3)Connect Modem, which supports the top 10 dial-up ISPs
in the U., allows you to concentrate on marketing your products, while
remaining confident that your end users can access a high-quality network.
Level 3 takes care of setting up a local Internet dial-up network, securing
local numbers, deploying modems, and staffing a round-the-dock operations
center to manage the network and hardware so you can do what you do
best - service your own end-users.
Our rapidly expanding (3)Connect Modem service covers more than 15,500
local calling area rate centers and 2,458 total unique rate centers. Service is
sold on a per-port basis for a flat monthly fee or on a metered basis based on
the total number of hours used. The monthly charge includes local dial-
numbers, complete network coverage for a specific region, modems to collect
the incoming traffic, and managed routers.
Our Nationwide Access Service combines a toll-free (800) number with
Level 3's Transit service to provide access to the Level 3 dial access network
to calls originating anywhere in the United States, Guam, Puerto Rico, U.
Virgin Islands, and the Commonwealth of the Northern Mariana Islands
(CNMI).
, '
TOP Hil
92 Data Standard
Level 3 provides value to our customers through our increased investment in
our dial-up services. While the majority of providers have placed new
technology implementation and standards on hold due to market uncertainty,
Level 3 continues to focus on customer needs, the introduction and graceful
implementation of new technologies to fill those needs, and increasing the
coverage and scope of our dial-up services.
One such technology is V.92, the newest data standard in modem
technology. V.92 narrows the gap between dial-up and broadband services
by delivering a better Internet experience to analog modem users. Level 3
has implemented, and is now offering, V.92 to customers.
Customers who support V.92 technology benefit by:
Becoming more competitive by enabling their network to offer the
latest technology to their subscribers and exceeding the service
offerings of other ISPs
Generating more revenue and decreasing customer churn by offering
subscribers tiers of services or by charging more for V.92 features
like Modem On Hold
Using Quick Connect and V.44 compression to decrease usage
costs and improve subscriber experience
92 presents key enhancements to the V.90 56K technology, including
Modem On Hold, V.44, Quick Connect, and PCM Upstream. Each of these
enhancements represents a push forward to a more user-friendly
dial-up experience.
TOP Ii)
(g 1999-2005 by Level 3 Communications, Inc. All rights reserved. I Legal Conditions, Terms of Use, and Tariffs! Acceptable Use Poli.
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