200507081st Qwest response to Level 3.pdf

Mary S. Hobson (ISB. No. 2142)
Stoel Rives LLP
101 South Capitol Boulevard
Suite 1900
Boise, ill 83702-7705
Tel: [phone]
Fax: [phone]
mshobson~stoe1.com
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Thomas M. Dethlefs
Senior Attorney
Qwest Services Corporation
1801 California Street - 10th Floor
Denver, CO 80202
Telephone: [phone]
Facsimile: [phone]
Thomas. Dethlefs~qw est. com
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF LEVEL 3
COMMUNICATIONS, LLC'S PETITION
FOR ARBITRATION PURSUANT TO
SECTION 252(B) OF THE COMMUNICA-
TIONS ACT OF 1934, AS AMENDED BY
THE TELECOMMUNICATIONS ACT OF
1996, AND THE APPLICABLE STATE
LAWS FOR RATE, TERMS, AND
CONDITIONS OF INTERCONNECTION
WITH QWEST CORPORATION
CASE NO. QWE- T -05-
QWEST CORPORATION'S RESPONSES
TO LEVEL 3 COMMUNICATIONS
LLC'S FIRST SET OF
INTERROGATORIES AND REQUESTS
FOR PRODUCTION OF DOCUMENTS
Qwest Corporation, through its undersigned attorneys, hereby files the attached responses
to Level 3 Communications, LLC's First Set of Interrogatories And Requests for Production of
Documents.
QWEST CORPORATION'S RESPONSES TO LEVEL 3 COMMUNICATIONS
LLC'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION
OF DOCUMENTS Page 1
Boise-185523.l 0061273-00018
DATED this ay of July, 2005
Respectfully submitted
Thomas M. Dethlefs
Senior Attorney
Qwest Services Corporation
1801 California Street, 10th Floor
Denver, CO 80202
Tel: [phone]
Fax: [phone]
Thomas .Dethl efs~qw est. com
QWEST CORPORATION
By:
~~
Mary S. Hobs (ISB. No. 2142)
Stoel Rives LLP
101 South Capitol Boulevard
Suite 1900
Boise, ill 83702-7705
Tel: [phone]
Fax: [phone]
mshobsoncmstoel.com
Ted D. Smith
Stoel Rives LLP
201 South Main Street
Suite 1100
Salt Lake City, UT 84111
Tel: [phone]
Fax: [phone]
tsmith~stoe1.com
QWEST CORPORATION'S RESPONSES TO LEVEL 3 COMMUNICATIONS
LLC'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION
OF DOCUMENTS Page 2
Boise-185523.l 0061273-00018
CERTIFICATE OF SERVICE
I do hereby certify that a true and correct copy of the foregoing QWEST CORPORATION'
RESPONSES TO LEVEL 3 COMMUNICATIONS LLC'S FIRST SET OF INTERROGATORIES
AND REQUESTS FOR PRODUCTION OF DOCUMENTS was served on the J:!!?day of July, 2005
by first class mail, postage prepaid on the following individuals:
Jean Jewell, Secretary Hand DeliveryIdaho Public Utilities Commission U. S. Mail
472 West Washington Street Overnight DeliveryO. Box 83720 Facsimile
Boise, ill 83720-0074 Email
i i ewell~puc.state.id. us
Weldon Stutzman
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ill 83720-0074
Telephone: [phone]
weldon.stutzman~puc .Idaho.gov
Erik Cecil
Regulatory Counsel
Level 3 Communications, LLC
1025 Eldorado Boulevard
Broomfield, CO 80021
Henry T. Kelly
Joseph E. Donovan
Scott A. Kassman
Kelley Drye & Warren LLP
333 West Wacker Drive
Chicago, Illinois 60606
[phone] (telephone)
[phone] (facsimile)
Dean J. Miller
McDevitt & Miller LLP
420 West Bannock Street
O. Box 2564
Boise, ill 83702
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
Stacy L. S ers
Legal Secretary
Stoel Rives LLP
QWEST CORPORATION'S RESPONSES TO LEVEL 3 COMMUNICATIONS
LLC'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION
OF DOCUMENTS Page 3
Boise-185523.l 0061273-00018
Idaho
Case No. QWE-05-
L3C 01-0021
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0021
For each person that Qwest intends to call as a witness in this proceeding,provide the following:
that witness' name, address and business affiliations;b. copies of all documents relied upon by the witness in preparation of
their testimony;c. copies of all documents prepared by the witness that reference, refer or
relate to the issues in thisproceeding.d. a statement describing the opinions held by the witness that are
relevant to this proceeding.e. if the person has previously appeared as a witness in any regulatory
proceeding, under the 1996 Act, provide
copies of all testimony that the person has submitted in each suchproceeding.
RESPONSE:
. Larry Brotherson, 1801 California St., Denver, CO
William Easton, 600 7th Avenue, Seattle, WA 98191
Phil Linse , 700 W. Mineral Ave., Littleton, CO 80120
80202
b. Qwest objects to this subpart on the basis that it is overly broad and
necessarily calls for speculation since Qwest has not yet prepared itstestimony. Qwest further objects that it is duplicative of other, more
narrowly drafted requests.c. Qwest obj ects to this subpart to the extent that it seeks documents that
are subject to the work product or attorney/client privilege. Qwest further
objects that it is overly broad and burdensome, and that it is seeks
information that is not relevant. Qwest finally obj ects that the subpart
does not appear reasonably calculated to lead to the discovery of admissibleevidence.d. Qwest objects to this subpart on the grounds that it violates IPUC Rule225.01. a. and that it calls for speculation since it is not known how the
issues will be framed and what opinions held by Qwest I s witnesses may berelevant.e. Qwest obj ects to this subpart on the basis that it is overly broad andburdensome. Qwest further obj ects that it is seeks information that is not
relevant, and that the subpart does not appear reasonably calculated to lead
to the discovery of admissible evidence. By way of further obj ection, Qwest
notes that to the extent its witnesses have previously filed testimony in
other regulatory proceedings, that information is a matter of public record
and may be obtained from the regulatory agencies in which such testimony wasfiled.
Idaho
Case No. QWE-05-
L3C 01-0031
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0031
Please provide the following data:a. By LATA, the number of Qwest local calling areas in each LATA in thestate;
The number and locations of Qwest I s end offices in state;
The number and locations of Qwest' s tandem offices in state, as well
as the tandem type (access, local , access/local);
The number of access lines (loops) in the state, broken out by type
such as analog, DSO, DS1, etc, by business and residence.
The number of local calls and local minutes of use per month and per
year for business and residential end user customers in the state. If
Qwest does not classify calls or minutes into a category denominated"local,1I please so state and identify the categories into which Qwest
classifies its traffic. If Qwest does classify calls and/or minutes
into a category denominated 'I local," please use that definition to
respond to this question, and also explain how Qwest determines what
traffic to classify as "local.
RESPONSE:
a. Publ ic information regarding each individual Qwest exchange's local
calling area can be found in Qwest' s Exchange and Network Services
Tariffs/Price Lists/Price Schedules/Catalogs. The information can be found
electronically by clicking on Tariffs at www. Owest. com Extended Area
Service varies by state.
b. The number and locations of Qwest' s end offices in state can be obtained
by going to Qwest' s ICONN Website athttp: / /www .qwest. com/cgi-bin/iconn/iconn tandem.pl ?function=2
c. These switches can be obtained by going to Qwest' s ICONN Websi te athttp: / /www. awest. com/cqi-bin/iconn/iconn tandem. pI ?function=2
d. Please see Confidential Attachment A. Qwest will provide Confidential
Attachment A to those who have signed the appropriate non-disclosures,
pursuant to the Parties' Protective Agreement.
e. Qwest obj ects to this subpart on the basis that it does not maintain the
information requested and that to attempt to compile the requested
information, if that were possible, would require Qwest to undertake special
studies that would be overly burdensome and unreasonably expensive.
Without waiver of the previously filed objection, Qwest responds that Qwest
does not collect this data for local calls.
Respondent:Ryan Gallagher, Qwest Manager
Idaho
Case No. QWE-05-
L3C 01-0041
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0041
Does Qwest have an affiliated Internet Service Provider (II ISP") that offers
Internet access services in the state? If so , please identify the
affiliates, and state the number of end user and wholesale customers in the
state for each Qwest ISP affiliate.
Please identify each telephone company end office in the state in which
the Qwest affiliate ISP has collocated equipment such as modem banks,
DSL equipment, routers, ATM switches or other equipment. Please identify
the telephone company that owns/operates each such end office.b. Please list each local calling area wi thin the state in which the
affiliate maintains a physical presence.
RESPONSE:
Qwest objects to the request that it "state the number of end user and
wholesale customers in the state for each Qwest ISP affiliate" on the basis
that the information requested constitutes a trade or business secret and is
highly confidential and proprietary. Qwest further obj ects that the
information requested is not relevant and that it does not appear the request
is reasonably calculated to lead to the discovery of admissible evidence.
Notwithstanding its objections, Qwest responds that two of its affiliates
offer Internet access services in Idaho: Qwest Communications Corporationand Qwest !nterprise America, Inc.
Respondent:Mary LaFave
Idaho
Case No. QWE-05-L3C 01-0051
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0051
Does Qwest or any affiliate of Qwest offer Voice over Internet Protocol
("VoIP") to end users in this state? If so,
a. Please identify the specific entity that offers the service and explain
that entity s relationship to Qwest.
Please state how many end use customers and how many wholesale customers
in the state the Qwest VoIP provider has.c. Please list each local calling area within the state in which the
affiliate maintains a physical presence.
Please identify each telephone company end office in the state in which
the Qwest affiliate VoIP provider has collocated equipment such as media
gateways, DSL equipment, routers, ATM switches of any other related
equipment necessary for providing VoIP service. Please identify the
telephone company that owns/operates each such end office.
Does Qwest purchase any wholesale VoIP services from any other
provider? If so, please name the provider (s) and the state (s) in whichsuch service (s) is/are purchased.
RESPONSE:b. Qwest obj ects to this subpart that it II state how many end use and how
many wholesale customers in the state the Qwest ISP VoIP provider has II on the
basis that the information requested constitutes a trade or business secret
and is highly confidential and proprietary. Qwest further obj ects that the
information requested is not relevant and it does not appear the request is
reasonably calculated to lead to the discovery of admissible evidence.d. Qwest obj ects to this subpart to the extent that its seeks information
concerning Qwest I s affiliates I network configurations in territory not served
by Qwest as the incumbent LEC.e. Qwest obj ects to this subpart to the extent that it seeks information
concerning Qwest' s purchases of services outside the state of Idaho and
outside the 14 -state terri tory in which Qwest operates as an incumbent LEC.
This request is overly broad and burdensome and seeks information that isirrelevant. Furthermore, the subpart does not appear to be reasonably
calculated to lead to the discovery of admissible evidence.
Subj ect to and without waiving the foregoing obj ections, Qwest responds:
a. Qwest Communications Corporation (QCC) offers VoIP in the state of Idaho.
QCC is an affiliate of QC, both of which are owned by Qwest ServicesCorporation.
See previously filed obj ection.
c. QCC has a physical presence in the Boise, Caldwell, Meridian and Nampa
exchanges in the Boise EAS region and in the Pocatello and Idaho Falls
exchanges in the Eastern Idaho EAS region.
d. QCC, as a provider of VoIP , operates as an Enhanced Service Provider
(ESP); accordingly, it does not collocate any equipment in a Qwest central
office or any other central office of a local exchange carrier in Idaho.
See previously filed obj ection.
Respondent:Mary LaFave
Idaho
Case No. QWE-05-
L3C 01-0081
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0081
Of those VoIP traffic minutes provided in response to the question above,
please provide the total number of VoIP traffic minutes that Qwest or
Qwest's affiliates carried to or from their own customers in this State
in 2002 and 2003.
RESPONSE:
Qwest obj ects to this request on the basis that the information concerning
the volumes of use of Qwest' s customers and those of Qwest I s affiliates
constitute trade or business secrets and are highly confidential andproprietary. Qwest further objects that the request does not appear
reasonably calculated to lead to the discovery of admissible evidence.
Subject to and without waiving the foregoing objections, Qwest responds that
QCC did not begin to offer its retail VoIP product offerings until 2004. In
addition, QCC does not track its VoIP traffic by individual states.
Respondent:Mary LaFave
Idaho
Case No. QWE-05-
L3C 01-0101
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0101
What IP voice products do Qwest or Qwest I s affiliates offer to customers in
the state? Please describe and provide all related relevant documentation
regarding how Qwest provides any VoIP, IP enabled, Voice embedded IP
communications, or enhanced services to its end user or enhanced service
provider customers or affiliates such as using PRIs or some otherarchi tecture a. Please describe the architecture by which Qwest provides these serviceswithin the state.b. Please describe the architecture by which Qwest provides these services
wi thin the state, but outside of Qwest' s incumbent LEC operating territory.
RESPONSE:
Qwest obj ects to this request to the extent that the information concerning
products and services provided by Qwest to the public is readily available
from public sources and, therefore, may be readily obtained by Level 3
wi thout resort to the discovery process.b. Qwest obj ects to this subpart on the basis that the arrangements Qwest
may have with other carriers in geographical areas outside the area in which
it acts as the incumbent LEC are not relevant. Qwest further objects that the
subpart does not appear to be reasonably calculated to lead to the discovery
of admissible evidence.
Subj ect to and without waiving the foregoing obj ections, Qwest responds that
Qwest Corporation does not offer any VoIP products or services; QCC offers a
variety of VoIP products to consumer and business customers. In addition,
QCC also offers a wholesale VoIP termination product. A description of these
product offerings can be found at www. qwest . com
As stated earlier, VoIP that originates in IP over a broadband connection,
using unique CPE is an information service and QCC, as a VoIP offeror is an
enhanced service provider (ESP). Under current federal law and regulations,
ESPs are deemed end users and not telecommunications carriers.
a. Purchasers of QCC's retail VoIP offering must purchase a broadbandconnection, e.g., cable modem , DSL or dedicated Internet Access (DIA) as well
as CPE (such as an adapter or SIP customer premises equipment). When
customer originates a VoIP call, it goes out over the broadband connection to
the Internet/QCC's IP backbone where it is routed either to another VoIP end
user or to an end user on the PSTN. In the latter case, the call is routed
to the POP closest to the local calling area associated with the calledpartys number. At the POP , the call is converted from IP to TDM and routed
over a primary rate ISDN circuit (PRI) purchased from a LEC for terminationto the PSTN. If the called party is outside the local calling area in which
the POP and PRI are located, then the call is handed to the IXC II picked" to
the PRI for call completion.
Traffic associated with QCC's wholesale VoIP termination product is
terminated to the PSTN via Feature Group D trunks and access charges are paid
on this traffic.
See description in II a. II above.
Respondent:Mary LaFave
Idaho
Case No. QWE-05-
L3C 01-0151
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0151
Does Qwest believe that it will receive materially more or less intercarrier
compensation from Level 3 if Qwest prevails in its proposal to require Level
3 to establish multiple or separate trunking facilities for Transit Traffic,
InterLATA traffic, and any non-local or non-intraLATA traffic (see Petition,
Tier I, Issues 2 and 4)? If your answer is anything other than an unqualified
no, II please explain in detail the basis for your answer, including all
workpapers underlying any calculations involved in supporting that answer.
RESPONSE:
Qwest obj ects to this request on the basis that it calls for speculation and
is impossible to answer without making assumptions concerning volumes and
traffic mix that are not contained in the record. Qwest further obj ects the
request appears to seek opinion or policy not previously written or published
in violation IPUC Rule 225.01. a.
Wi thout waiving its obj ection , Qwest states:
It is the category of the traffic exchanged, not the trunk the traffic is
exchanged on , that determines the compensation rate. Putting the traffic on
the correct trunk enables accurate tracking and billing but does not change
the category of the call. Assuming Level 3 has been accurately identifying
and routing traffic there should be no change in compensation if the types
traffic remain the same. Qwest can I t predict whether Level 3 I S traffic willbe local , toll or transit, or whether that mix and volume will change.
Respondent: Larry Brotherson
Idaho
Case No. QWE-05-
L3C 01-0201
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0201
Does Qwest contend that the costs it incurs in originating a call to a Level
3 customer differ in any respect whatsoever based upon the physical location
of the Level 3 customer? If Qwest responds to the above question with
anything other than an unequivocal "No, II please provide a detailed
explanation of how the location of Level 3 I s customer on Level 3' s side
the POI could affect Qwest' s costs. Include in that explanation all cost
studies and any other documentation in your possession that you believeprovides support for your position.
RESPONSE:
Qwest objects to this request on the basis that it is overly broad, unduly
burdensome, ambiguous and not reasonably calculated to lead to the discovery
of admissible evidence.
Without waiving its objection, Qwest responds:
No. The costs Qwest incurs do not vary based upon the physical location the Level 3 customer. Qwest I s overall costs incurred to complete a callhowever, vary depending on the originating voice caller's location and the
location of the Level 3 POI.
Respondent:Larry Brotherson
Idaho
Case No. QWE-05-L3C 01-0211
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0211
Does Qwest offer any kind of foreign exchange ("FX"service
state? If so, please provide a service description (including,
limited to, tariff pages) for each such service.
in this
but not
RESPONSE:
Qwest obj ects to this request on the basis that its tariffs/catalogs are on
file with the Idaho Commission and are, therefore, readi ly avai lable to Level3 wi thout resorting to burdensome discovery.
Without waiving its objection Qwest responds:
Yes. Qwest offers Foreign Exchange (FX) service in northern Idaho. Qwest
does not actively promote or advertise FX service, therefore there is no
additional material available for FX, other than the tariff. Please refer to
the Northern Idaho Exchange and Network Services Tariff, which is provided as
Attachment A, for the service description of foreign exchange service. Please
note that the northern Idaho tariff will be converted to catalog on or about
August 1, 23005. Foreign Exchange service in Southern Idaho was discontinued
as of April 13, 1979.
Respondent: Larry Brotherson
Qwest CorporationExchange and Network
Services Tariff
IDAHO
Case No. QWE- T -05-
L3C 01-0211SECTION 5 Attachment APage 5
Release 1
Effective: 5-31-02
5. EXCHANGE SERVICES
Replaces Page 5
NORTHERN IDAHO
Issued: 5-
1.4
EXCHANGE AREAS (Cont'
FOREIGN EXCHANGE SERVICE
A. Description
Foreign Exchange Service is a service furnished within a LATA (Local Area and
Transport Area) from an exchange other than the exchange from which thecustomer would nonnally be served.
B. Definitions
Local Access and TranspoI1 Area
geographic area established by the Company for the prOVISIon and
administration of communications service. It encompasses designated exchanges
which are grouped to serve common social, economic and other purposes.
Local Exchange
As used in this Tariff means the exchange in which the main access line is located.
Foreign Exchange
As used in this Tariff means the exchange from which the service is rendered.
C. Terms And Conditions
1. Rates for local service includes service without additional charge to all accesslines receiving service from the exchange from which the foreign exchange
service is furnished.
2. The interexchange rates applicable in connection with toll service over foreignexchange lines will be as shown in the interexchange tariff provisions of theforeign exchange.
ADVICE No. 02-10-
Replaces Page 6
NORTHERN IDAHO
Issued: 5-
Qwest CorporationExchange and Network
Services Tariff SECTION 5
Page 6
Release 1
Effective: 5-31-02!
5. EXCHANGE SERVICES
EXCHANGE AREAS1.4 FOREIGN EXCHANGE SERVICE
C. Terms and Conditions (Cont'
3. Additional1istings and lines of information will be furnished to foreign exchange
customers in local or foreign directories and the rates in effect for the directory
containing the additional listing or line of information will apply.
4. Except as provided, services furnished in the local exchange will be available in
connection with foreign exchange service at rates shown in the tariff provisions
of the local exchange.
5. Except as provided, foreign exchange service will be furnished subject to thesame conditions as those applicable in connection with local residence serviceregarding the use of the service by anyone other than the customer or members of
the customer s household.
6. Foreign exchange service will not be provided for Smart PAL use.
7. Foreign exchange mileage rates for service furnished in a contiguous exchange as
shown under D., following, are applicable to the air-line distance between thecustomers main access line and the nearest point on the common boundary of the
foreign and local exchange areas.
8. Foreign exchange mileage rates for business service furnished in non-contiguous
exchanges as shown under D ., following, are applicable to the interexchangemileage measured between the rate centers of the foreign and local exchanges.
9. A suburban exchange access line shall not be located within the base rate area.
ADVICE No. 02-10-
Replaces Page 7
NORTHERN IDAHO
Issued: 5-
Qwest CorporationExchange and Network
Services Tariff SECTION 5
Page 7
Release 1
Effective: 5-31-
5. EXCHANGE SERVICES
EXCHANGE AREAS
FOREIGN EXCHANGE SERVICE
C. Tenns and Conditions (C6nt'
10. Four-party residence foreign exchange service is available from the followingexchanges only to a customer having such service either ordered or in service at a
premises on the date shown below.
Customers to suburban residence service may elect to subscribe to four-party
residence service after the date shown below, at the time that the Companychanges a base rate area to include these suburban customers' premises.
EXCHANGE DATE
Grangeville February 1 , 1971
11. A Foreign Exchange line may be utilized with customer-provided tenninalequipment, protective circuitry, PBX and key telephone systems which areconnected to the exchange telephone service associated with such lines. Also, seeSection 8 of this Tariff.
12. Where foreign exchange service furnished under D., following, is provided bymeans of a circuit crossing the exchange area boundary, the following applies:
a. Where extensions of plant are required in the foreign or local exchange they willbe made at the charges and under the conditions of 4., Line ExtensionCharges.
13. Foreign exchange service over any route is available under the conditions, ratesand charges specified in this section, when facilities and operating conditionspennit.
14. When the Company establishes a new central office or revises a central office or
exchange area boundary, additions or increases in mileage increments are not
applicable to existing customers as long as these services are retained withoutchange by the same customer at the same premises.
ADVICE No. 02-10-
Replaces Page 8
NORTHERN IDAHO
Issued: 5-
Qwest CorporationExchange and Network
Services Tariff SECTION 5
Page 8
Release 1
Effective: 5-31-
5. EXCHANGE SERVICES
1.4
EXCHANGE AREAS
FOREIGN EXCHANGE SERVICE (Cont'
D. Rates and Charges
1. Business Foreign Exchange
a. The following charge applies to each one-half mile or fraction thereof for
business service furnished in contiguous exchanges.
NON-
RECURRING FIRST SECOND OVER
CHARGE MILE MILE Two MILES
. Each premium flat
rate or PBX exchange
access line( 1)$25.$3.$6.$9.
b. The following charge applies to each mile or fraction thereof for business
service furnished in non-contiguous exchanges.
NONRECURRING
CHARGE
EACH MILE OR
FRACTION THEREOF
. Each premium flat
rate or PBX exchange
access line( 1 )$25.$6.
(1)In addition, rates and charges for the associated access line also apply.
AOVICENo. 02-10-
Replaces Page 9
NORTHERN IDAHO
Issued: 5-
Qwest CorporationExchange and Network
Services Tariff SECTION 5
Page 9
Release
Effective: 5-31-02
5. EXCHANGE SERVICES
EXCHANGE AREAS
FOREIGN EXCHANGE SERVICED. Rates and Charges (Cont'
2. Residence Foreign Exchange
The following rates and charges apply to residence service furnished in
contiguous exchanges for each one-quarter mile or fraction thereof.
NONRECURRING
CHARGE
MONTHLY RATEFIRST BEYOND
ONE-HALF FIRST ONE-MILE HALF MILE
. Each Exchange Access
Line ( 1)
- Individualline
- Two-party line
- Four-party line
- Suburban line
$25.
25.
25.
25.
$1.
1.00
$1.50
1.25
1.00
(1)In addition, the rates and charges for the associated access line also apply.
AOVICENo. 02-10-
Replaces Page 10
NORTHERN IDAHO
Issued: 5-
Qwest CorporationExchange and Network
Services Tariff SECTION 5
Page 10
Release I
Effective: 5-31-02,
5. EXCHANGE SERVICES
EXCHANGE AREAS1.4 FOREIGN EXCHANGE SERVICED. Rates and Charges (Cont'd)
3. Off-Premises Extension Station Lines and PBX Station Lines Foreign Exchange
Service
Where foreign exchange service is offered in D.l. and D., preceding, an off-
premises extension line or private branch exchange station line from a mainstation line in the exchange from which foreign exchange service is offered, may
be furnished in the contiguous exchange at the following rates:
MONTHLY
RATE
a. Each one-quarter mile or fraction thereof, air-line
measurement, from the extension station line or
private branch exchange station line or private
branch exchange station line to the nearest
point on the common exchange boundary.
b. Each one-quarter mile or fraction thereof
air-line measurement, from the nearest point
on the common exchange boundary to the
main station line.
$1.50
1.25
c. The total mileage charge is the sum of the charges determined above.
ADVICE No. 02-10-
Idaho
Case No. QWE-05-L3C 01-0251
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0251
With respect to Qwest 1 s FX and FX-Like services:
a. Please explain the circumstances under which calls from a subscriber to
Qwest FX or FX-like service are rated as local versus toll, and provide
all documentation supporting your answer.
RESPONSE:
Qwest obj ects to this request and its subparts on the basis that the terms
"toll" and "local" are not defined and may be ambiguous in this context.
Qwest further obj ects on the basis that the request is overly broad and
therefore not reasonably calculated to lead to the discovery of admissibleevidence.
Without waiving its objection, Qwest states:
a. Foreign Exchange (FX) service is a combination of rate elements from the
Local Exchange tariffs and Private Line Transport tariffs and/or catalogs.
The subscriber purchases an FX connection in the local calling area in which
the subscriber seeks a local number. As to the persons making the call, all
calls to and from other subscribers in the same local calling area where the
FX subscriber purchased a connection are treated as local. All calls to and
from subscribers outside the local calling area where the FX subscriber
connection was purchased are treated as toll calls. The additional transport
for carrying calls from the local calling area where the connection was
purchased, to the FX customer I s location, are ordered as private lineservices. Documentation for charges are identified in the Exchange and
Network Services and the Private Line Transport Services tariffs for northernIdaho. Please note these tariffs will be converted to catalog on or about
August 1, 2005.
Respondent:Larry Brotherson
Idaho
Case No. QWE-05-L3C 01-0261
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0261
Please state whether Qwest or any Qwest affiliate has ever billed or demanded
paYment of access charges from an incumbent LEC for calls originated by
Qwest I s end user to an incumbent LEC' s FX or FX-Like customer.
RESPONSE:
Qwest objects to this request on the basis that it is not limited to the
state of Idaho and is otherwise overly broad, unreasonably burdensome, and
does not appear reasonably calculated to lead to the discovery of admissibleevidence.
Wi thout waiving this obj ection Qwest states:
If the call was placed to an incumbent LEC's subscriber who had purchased a
physical connection in the same local calling area as the calling party, the
call would be treated as a local call. If the call was made from outside thelocal calling area, access charges would be paid by the toll carrier.
Respondent:Larry Brotherson
Idaho
Case No. QWE-05-
L3C 01-0271
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0271
Please state whether Qwest has ever billed or received reciprocal
compensation or other terminating compensation for calls received from an
incumbent LEC or any CLECs for termination to Qwest I s FX or FX-like
customers? Please explain your answer, including but not limited to (a) the
dates upon which you first began billing incumbent LECs or CLECs for suchcompensation; (b) the amount of compensation received from incumbent LECs and
CLECs; and (c) describe any changes you may have made to your billing
policies with respect to calls terminating to your FX or FX-like customers.
RESPONSE:
Qwest objects to this request on the basis that it is not limited to the
state of Idaho and is otherwise overly broad, unreasonably burdensome, and
does not appear reasonably calculated to lead to the discovery of admissibleevidence.
Without waiving this objection, Qwest states:
The local calling area in which the Qwest FX customer purchases a connection
to the local network is the point for determining whether a call is local.
ILEC calls to a Qwest FX customer who purchases a connection in the same
local calling area that the call originated in are generally treated as bill
and keep. CLEC calls originating in the local calling area where the FX
customer purchased a local connection are billed local reciprocalcompensation.
Respondent:Larry Brotherson
Idaho
Case No. QWE-05-L3C 01-0281
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0281
Are there any circumstances in which Qwest has paid access charges to the
originating carrier for a call originated by another carrier and terminated
to a Qwest FX or FX-like customer? If your answer is anything other than anunequivocal "no, II please describe all circumstances under which Qwest has
made such paYments.
RESPONSE:
Qwest objects to this request on the basis that it is not limited to the
state of Idaho and is otherwise overly broad, unreasonably burdensome, and
does not appear reasonably calculated to lead to the discovery of admissibleevidence.
Without waiving this objection, Qwest states:
If the call originated outside the local calling area, the toll carrier pays
access charges. When Qwest is the toll carrier , and the call originates in a
non-Qwest exchange Qwest pays originating access.
Respondent:Larry Brotherson
Idaho
Case No. QWE-05-
L3C 01-0291
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0291
Please state whether
independent LEC wi
Service that permits
be assigned a numberarea.
Qwest knows, or has reason to believe, that any
whom Qwest has EAS arrangements provide FX or FX-Like
customers physically located in another rate center to
that is local to the rate center included in Qwest I S EAS
RESPONSE:
Qwest objects to this request on the basis that it is not limited to the
state of Idaho and is otherwise overly broad and unreasonably burdensome.
Qwest further obj ects that the service offerings of independent LECs in Idaho
are available from said LECs and are filed as a matter of public record with
the IPUC where they are as readily available to Level 3 as to Qwest.
Without waiving this objection, Qwest states:
Qwest is not aware if any Independents in Idaho offer FX or FX-like services
to their end-users. If they do, they are likely to be described in their
tariffs on file with the Idaho Public Utilites Commission.
Respondent:Larry Brotherson
Idaho
Case No. QWE-05-
L3C 01-0301
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0301
Please provide Qwest' s definition of FX ervice and provide the source for
that definition. Is it true that Qwest I s FX Service allows the customer to
make calls to an exchange outside of the Qwest customer I s home exchange
without incurring a toll charge? If not, please explain.
RESPONSE:
See Attachment A to Data Request No. 21 for the service description of
Foreign Exchange service. Foreign Exchange (FX) service is a combination ofrate elements from the local exchange tariffs catalogs and private line
transport tariffs and/or catalogs. In each instance, the toll revenues that
would otherwise be billed to the calling parties as toll are recovered fromthe called party as a toll replacement charge. The additional transport
costs that Qwest incurs for routing calls beyond the local calling area overthe private line network are recovered through tariff and/or catalogservices. Documentation for charges are identified in the tariffs
catalogs for each service.
Respondent: Larry Brotherson
Idaho
Case No. QWE-05-
L3C 01-0311
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0311
Does Qwest treat FX service associated with Broadband Data, and FX service
associated with voice service, differently? If yes, please explain why there
are two such differences.
RESPONSE:
The question is unclear because there are different characteristics for
transmitting each type of call. For example, a voice capable loop is
different than a broadband capable loop. If Qwest assumes these transmission
characteristics are irrelevant to the question, the answer is II no"The
services are offered in a similar manner and treated the same.
Respondent:Larry Brotherson
Idaho
Case No. QWE-05-
L3C 01-0321
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0321
Please provide Qwest I s def inition of II interexchange II service when assessing
charges to local exchange customers for such a call , and provide the source
for such definition.
RESPONSE:
Generally, inter-exchange means between two exchanges. The boundaries of the
exchanges are described in maps, tariffs, rate schedules, price lists and
other descriptive material filed with the Idaho Commission , and calls from
one exchange to another exchange are inter-exchange.
Respondent: Larry Brotherson
Idaho
Case No. QWE-05-
L3C 01-0331
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0331
Is it Qwest I s position that access charges should apply to all interexchange
services? If not, please explain.
RESPONSE:
Access charges apply to interexchange services when the exchanges are not
located within the same local calling area. Access charges do not apply
between multiple exchanges when the exchanges are located within the samelocal calling area.
Respondent:Larry Brotherson
Idaho
Case No. QWE-05-L3C 01-0341
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0341
Please provide Qwest' s definition of a II local II call when assessing charges
(such as message unit or similar charges) to local exchange customers forsuch a call, and provide the source for this def ini tion.
RESPONSE:
A local call is a call which physically originates and terminates within the
same local calling area. It is the geographical area wi thin which calls are
permitted as part of the local exchange rate paid by the subscriber.
Respondent: Larry Brotherson
Idaho
Case No. QWE-05-
L3C 01-0351
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0351
Please provide Qwest' s definition of a II toll II call when assessing charges to
local exchange customers for such a call , and provide the source for thisdefinition.
RESPONSE:
A toll call is a call which goes outside the defined geographical boundary of
the local calling area for which a subscriber is entitled to place localcalls.
Respondent:Larry Brotherson
Idaho
Case No. QWE-05-L3C 01-0361
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0361
Please describe the facilities (switches, optical fiber, multiplexer, etc.
that Qwest uses or expects to use in delivering traffic from its end users to
Level 3. Assume for purposes of this question that Level 3 and Qwest
interconnect at a single POI in a LATA and that Qwest is responsible for
delivering its originated traffic to that POI.
RESPONSE:
Qwest obj ects to this request on the basis that the phrase "uses or expects
to use" calls for Qwest to speculate about possible future conditions. Qwest
further obj ects that this request is ambiguous such that Qwest cannot
determine what specific information Level 3 is seeking. This request may
also be overbroad and unduly burdensome depending on what detailed
information Level 3 is seeking.
Subj ect to and without waiving the foregoing obj ections Qwest responds, Qwest
currently may utilize circuit switch facilities, fiber optic transport, and
multiplexing equipment, as well as copper facilities in the exchange
traffic with Level 3 for the delivery of Qwest end-user traffic to Level
Respondent: Daniel Collins, Staff Advocate.
Idaho
Case No. QWE-05-
L3C 01-0381
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0381
Please describe the facilities (switches, optical fiber , multiplexer, etc.
that Qwest uses or expects to use in delivering traffic from Level 3 to
Qwest I s end users. Assume for purposes of this question that Level 3 and
Qwest interconnect at a single POI in a LATA and that Level 3 is responsible
for delivering its originated traffic to that POI.
RESPONSE:
Qwest obj ects to this request on the basis that the phrase "uses or expectsto US~I' calls for Qwest to speculate about possible future conditions. Qwest
further obj ects that this request is ambiguous such that Qwest cannot
determine precisely what information Level 3 is requesting.
Subj ect to and without waiving the foregoing obj ections, Qwest responds withthe following:
Qwest currently may utilize circuit switch facilities, fiber optic transport,
and multiplexing equipment , as well as copper facilities in the exchange of
traffic with Level 3 for the delivery of Level 3 toll traffic and Level 3
local traffic to Qwest.
Respondent: Daniel Collins, Staff Advocate.
Idaho
Case No. QWE-05-
L3C 01-0401
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0401
With how many CLECs in Idaho does Qwest exchange traffic (that is, CLECs with
their own switches, as opposed to resellers)?
RESPONSE:
Qwest does not track CLEC switches and therefore does not have a count to
provide to Level 3. However, Qwest exchanges traffic with numerous CLECs inIdaho.
Respondent:Cindy Hentschel