20050720Supplemental Qwest responses.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~stoel.com
Thomas M. Dethlefs
Senior Attorney
Qwest Services Corporation
1801 California Street - 10th Floor
Denver, CO 80202
Telephone: [phone]
Facsimile: [phone]
Thomas. Dethlefs~qwest. com
, ,~ ?'.
r "
' ,,~ j
r"
' ,
i\'VL '
...",....,"
r"=
"'..
tuGS JUL 19 rrl h,: 31
ID tm PUBLIC
1."'- t
"'" ('
I!I
j."
,Ir.""'
\..,;, ...
L.'.J V oJ' I I
...;
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 ST ATE
LAWS FOR RATE, TERMS, AND
CONDITIONS OF INTERCONNECTION
WITH QWEST CORPORATION
CASE NO. QWE-05-
QWEST CORPORATION'
SUPPLEMENTAL RESPONSES TO
LEVEL 3 COMMUNICATIONS LLC'
FIRST SET OF INTERROGATORIES
AND REQUESTS FOR PRODUCTION
OF DOCUMENTS
Qwest Corporation, through its undersigned attorneys, hereby files the attached
supplemental responses to Level 3 Communications, LLC's First Set of Interrogatories and
Requests for Production of Documents.
DATED this 19th day of July, 2005.
QWEST CORPORATION'S SUPPLEMENTAL RESPONSES TO LEVEL 3 COMMUNICATIONS LLC'
FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS Page 1
Boise-185813.10061273-00018
Respectfully submitted
Thomas M. Dethlefs
Senior Attorney
Qwest Services Corporation
1801 California Street, 10th Floor
Denver, CO 80202
Tel: [phone]
Fax: [phone]
Thomas .Dethlefs~qw est. com
QWEST CORPORATION
By: ~42)
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~stoel.com
QWEST CORPORATION'S SUPPLEMENTAL RESPONSES TO LEVEL 3 COMMUNICATIONS LLC'
FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS Page 2
Boise-185813.10061273-00018
CERTIFICATE OF SERVICE
I do hereby certify that a true and correct copy of the foregoing QWEST CORPORATION'
SUPPLEMENTAL RESPONSES TO LEVEL 3 COMMUNICATIONS LLC'S FIRST SET OF
INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS was served on
the 19th 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
iiewell~puc.state.id.
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
erik.cecil~leve13 .com
--X.
Henry T. Kelly
Joseph E. Donovan
Scott A. Kassman
Kelley Drye & Warren LLP
333 West Wacker Drive
Chicago, illinois 60606
[phone] (telephone)
[phone] (facsimile)
hkelly~kelleydrye.com
Dean J. Miller
McDevitt & Miller LLP
420 West Bannock Street
O. Box 2564
Boise, ill 83702
oe~mcdevi tt -miller .com
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
bt;l~ Brandi L. Gearhart
Legal Assistant
Stoel Rives LLP
QWEST CORPORATION'S SUPPLEMENTAL RESPONSES TO LEVEL 3 COMMUNICATIONS LLC'
FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS Page 3
Boise-185813.l 0061273-00018
Idaho
Case No. QWE-OS-ll
L3C Ol-O36ISl
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:036ISl
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 lIuses or expects
to use II 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 of
traffic with Level 3 for the delivery of Qwest end-user traffic to Level
Respondent: Daniel Collins, Staff Advocate.
SUPPLEMENTAL RESPONSE dated 7/18/05:
Wi thout waiving its obj ections, Qwest states:
As Qwest' s network evolves in the future and new technologies become
available, the response to this question could change. However, for purposes
of this response, Qwest assumes that the request is seeking information about
the facilities in Qwest I s network as it currently exists. With thatassumption (and without identifying each specific component in Qwest I
network), the following types of facilities are likely to be used to deliver
traffic to Level 3: Currently, Qwest may use circuit switch facilities, fiber
optic transport, multiplexing equipment, and copper facilities in delivering
traffic to Level 3 from Qwest end users.
Respondent:Legal
Idaho
Case No. QWE-OS-
L3C 01-037I81
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:037 I81
Please state whether the facilities Qwest uses or expects to use in
delivering traffic from its end users to Level 3 as stated above differ in
any way based on whether the traffic is classified as IIlocal" or "toll." If
your answer is anything other than an unqualified "no, II please explain
detail the basis for your answer.
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 precisely what information Level 3 is requesting.
SUPPLEMENTAL RESPONSE DATED 7/18/05:
Wi thout waiving its obj ection, Qwest states:
Based on the assumptions in the response to Request No. 36S1, the same
general types of facilities described in response to Request No. 3681 would
be used to deliver traffic to Level 3, whether the traffic is ultimately
local or toll (i. e., interexchange). Qwest, of course, has never assertedthat different "types" of facilities may be used to deliver IIlocal" trafficand IItollll traffic to a Level 3 POI, or to the POI of another CLEC, IXC, or
CMR8 carrier. However, it should be noted that different switch ports may be
used and the routing to the Level 3 POI may be over different transport
facilities depending on how the facility connections are configured. An
interexchange call may also involve routing the traffic through different
switches to deliver the call to the Level 3 POI than a local call.
Both state and federal regulatory authorities have a long history of treating
traffic in different ways depending on whether it is local or toll (i. e. ,
local calls tend to be priced on a flat-rated basis, while toll calls havebeen usage sensi ti ve) and likewise of placing different kinds of traffic
under different intercarrier compensation regimes. Among these differences
are local calling areas and EA8 areas established by state commissions and
the identification of various varieties of traffic in the federal Act, FCC
rules, and FCC orders. These differences continue to be reflected in
interconnection agreements approved by state commissions that are entirely
consistent with the federal Act.
Respondent:Legal
Idaho
Case No. QWE-OS-
L3C 01-038IS1
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:038 IS1
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 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 precisely what information Level 3 is requesting.
Subject to and without waiving the foregoing objections, 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
local traffic to Qwest.
Respondent: Daniel Collins, Staff Advocate.
SUPPLEMENTAL RESPONSE dated 7/18/05:
Wi thout waiving its obj ections, Qwest states:
See response to L3C 01-036IS1. Currently, Qwest may use circuit switch
facilities, fiber optic transport, multiplexing equipment, and copper
facilities in delivering traffic from Level 3 to Qwest end users.
Respondent:Legal
Idaho
Case No. QWE-OS-
L3C 01-039IS1
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:039IS1
Please state whether the facilities Qwest uses or expects to use in
delivering traffic from Level 3 to Qwest' s end users as stated above differ
in any way based on whether the traffic is classified as "local II or "toll.
If your answer is anything other than an unqualified "no, II please explain
detail the basis for your answer.
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 precisely what information Level 3 is requesting.
SUPPLEMENTAL RESPONSE DATED 7/18/05:
Wi thout waiving its obj ections, Qwest states:
See response to Request No. 38IS1. It should be noted that different switch
ports may be used and the routing to Qwest end users from the Level 3 POI may
be over different transport facilities depending on how the facility
connections are configured. An interexchange call may also involve routing
the traffic through different switches to deliver the call to the Qwest enduser than a local call.
Respondent:Legal
Idaho
Case No. QWE-O5-L3C 01-040IS1
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:040IS1
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
SUPPLEMENTAL RESPONSE DATED 7/18/05:
As of May 31, 2005, there were 12 CLECs with LIS trunks in service for Idaho.
The presence of LIS trunks usually indicates the CLEC connecting with Qwest
through those trunks uses its own switching.
Respondent:Cindy Hentschel