20050817Qwest responses to 2nd set.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
Thomas M. Dethlefs
Senior Attorney
Qwest Services Corporation
1801 California Street - 10th Floor
Denver, CO 80202
Telephone: [phone]
Facsimile: [phone]
Thomas .Dethlefs~qwest. com
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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-05-
QWEST CORPORATION'S RESPONSES
TO LEVEL 3 COMMUNICATIONS
LLC'S SECOND SET OF
INTERROGATORIES, REQUESTS FOR
PRODUCTION OF DOCUMENTS, AND
REQUESTS FOR ADMISSIONS TO
QWEST CORPORATION
Qwest Corporation, through its undersigned attorneys, hereby files the attached responses
to Level 3 Communications, LLC's Second Set of Interrogatories, Requests for Production of
Documents, and Requests for Admissions to Qwest Corporation.
QWEST CORPORATION'S RESPONSES TO LEVEL 3 COMMUNICATIONS LLC'
~ECOND SET OF INTERROGATORIES, REQUESTS FOR PRODUCTION OF DOCUMENTS
AND REQUESTS FOR ADMISSIONS TO QWEST CORPORATION
Boise-186552.1 0061273-00018
PAGEl
DATED this 17th day of August, 2005.
Respectfully submitted
QWEST CORPORATION
By:~ffz;~
Mary S. Ho n (ISB. No. 2142)
Stoel Rives LLP
101 South Capitol Boulevard
Suite 1900
Boise, ill 83702-7705
Tel: [phone]
Fax: [phone]
msbobsoncmstoel.com
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
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'
SECOND SET OF INTERROGATORIES, REQUESTS FOR PRODUCTION OF DOCUMENTS
AND REQUESTS FOR ADMISSIONS TO QWEST CORPORATION
Boise-186552.10061273-00018
PAGE 2
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 SECOND SET OF INTER-
ROGATORIES, REQUESTS FOR PRODUCTION OF DOCUMENTS, AND REQUESTS FOR
ADMISSIONS TO QWEST CORPORATION was served on the 17t1t day of August, 2005 by first
class mail, postage prepaid on the following individuals:Jean D. Jewell
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ill 83702
Telephone [phone]
Facsimile: [phone]
11 ewell~puc. state .id. us
John Antonuk
Liberty Consulting Group
65 Main Street
O. Box 237
Quentin, P A 17083
antonuk~l ibertyconsul tinggro up. com
Erik Cecil
Level 3 Communications LLC
1025 Eldorado Boulevard
Broomfield, CO 80021
Telephone: [phone]
Facsimile: [phone]
erikcecil(q2leve13 .com
Dean J. Miller (ISB #1968)
McDevitt & Miller LLP
420 West Bannock Street
O. Box 2564
Boise, ill 83701
Telephone: [phone]
Facsimile: [phone]
loe~mcdevitt-miller.com
Attorneys for Level Communications
Hand Delivery
U. S. Mail
Overnight Delivery
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Email
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Email
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Email
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Email
~R~
Brandi L. Gearhart
Legal Secretary
Stoel Rives LLP
QWEST CORPORATION'S RESPONSES TO LEVEL 3 COMMUNICATIONS LLC'
SECOND SET OF INTERROGATORIES, REQUESTS FOR PRODUCTION OF DOCUMENTS
AND REQUESTS FOR ADMISSIONS TO QWEST CORPORATION
Boise-186552.1 0061273-00018
PAGE 3
Idaho
Case No. QWE-05-
L3C 02-0011
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0011
What features are provided with Feature Group D service?
RESPONSE:
Qwest obj ects to Interrogatory No. 02 - 001 on the ground that it is
ambiguous.
Subject to and without waiving the foregoing objection, Qwest responds withthe following:
See tariff:http: / /tariffs. uswest. com: BOOO/docS/TARIFFS/FCC/FCC1/fcc1 s006p061.pdf#USW-TO
COOO025
As provided in Qwest's proposed language, Level 3 can avail itself of the
added function of using Feature Group D Service to route its local traffic to
Qwest.
Respondent: Daniel Collins, Staff Advocate
Idaho
Case No. QWE-05-11
L3C 02 - 002 I
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0021
Which of these features are necessary for local exchange traffic?
RESPONSE:
Qwest obj ects to Interrogatory No. 02 - 0 02 on the ground that it isambiguous. Subject to and without waiving the foregoing objections, Qwest
responds with the following:
Feature Group D service is not a local exchange service offering. However,
Qwest has developed the capability to receive local traffic routed overFeature Group D trunks.
Respondent: Daniel Collins, Staff Advocate
Idaho
Case No. QWE-05-
L3C 02-0031
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0031
Is the PIC feature, that allows the selection of an IXC on interexchange
traffic originated by a Qwest customer, needed for the termination of
interexchange traffic?
RESPONSE:
Qwest objects to Interrogatory No. 02-003 on the grounds that it isambiguous. Subject to and without waiving the foregoing objections, Qwest
responds with the following:
Yes. The PIC feature is required for a Qwest customer to originate
interexchange traffic so that traffic may be routed to the customer's chosenIXC. This routing is required using the customer s Carrier IdentificationCode ("CIC") so that the call may then be appropriately received by thecustomers PIC and ultimately routed for termination.
Respondent: Daniel Collins, Staff Advocate
Idaho
Case No. QWE-05-
L3C 02-0041
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0041
If Level 3 has no PIC code, isn't it true that Qwest switches would not be
required to switch interexchange traffic to Level
RESPONSE:
Qwest obj ects to Interrogatory No. 02 - 0 04 on the grounds that it isambiguous. Subj ect to and without waiving the foregoing obj ections, Qwest
responds with the following:
Qwest is assuming that Level 3 is referring to a Carrier Identification Code("CIC"). Level 3 does have an assigned CIC (i.e. CIC 6330, 5062) and
therefore, Qwest switches would be required to switch interexchange traffic
to Level
Respondent: Daniel Collins, Staff Advocate
Idaho
Case No. QWE-05-
L3C 02 - 0051
INTERVENOR:Level 3 Communications, LLC
REQUES T NO:0051
Please describe in exact detail the distinction that Qwest is making between
a POI that is physically located on Qwest I s network and a POI that is located
within a Qwest central office.
RESPONSE:
Qwest objects to Interrogatory No. 02-005 on the ground that it isambiguous. Subj ect to and without waiving the foregoing obj ections, Qwest
responds with the following:
The Level 3 proposed language suggests that the POI may be located n on"
Qwest's network (which may be interpreted as a POI that is integrated within
Qwest's network). A POI that is located wi thin a Qwest central off ice with
Collocation is not integrated with Qwest' s network.
Respondent: Daniel Collins, Staff Advocate
Idaho
Case No. QWE-05-
L3C 02-0061
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0061
What is the difference between a connection that is physically on the
Qwest network and a cross connection to the Qwest network?
RESPONSE:
Qwest objects to Interrogatory No. 02-006 on the grounds that it isambiguous. Subj ect to and without waiving the foregoing obj ections, Qwest
responds with the following:
A connection that is physically on the Qwest network assumes integration with
Qwest's network. A cross connect provides the necessary separation between
networks to assure the ability of both Level 3 and Qwest to maintain orcontrol the performance of their respective networks (e.g. an electrically
protected and testable cross connection between Qwest' s network and Level 3' Collocation)
Respondent: Daniel Collins, Staff Advocate
Idaho
Case No. QWE-05-
L3C 02-0071
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0071
Please provide a complete list of all tandems in the state and indicate
which of these switches have the following functions: local, intraLATA
toll, InterLATA toll, BOO, operator services, other.
RESPONSE:
Qwest obj ects to Interrogatory No. 02 - 007 on the grounds that it is
overbroad and calls for information that is not within Qwest I s control.
Subject to and without waiving the foregoing objections, Qwest responds withthe following:
This information is available to all carriers and may be found in the Local
Exchange Routing Guide ("LERG").
Respondent: Daniel Collins, Staff Advocate
Idaho
Case No. QWE-T-05-
L3C 02-00BI
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:OOBI
Please describe in detail why a Qwest switch that has both local and toll
functionality does not have the capability of routing and delivery of tolltraffic.
RESPONSE:
Qwest objects to Interrogatory No. 02-00B on the ground that it isambiguous. Subject to and without waiving the foregoing objections, Qwest
responds with the following:
All Qwest's switches that are programmed for the routing of toll traffic do
have the capability of routing toll traffic.
Respondent: Daniel Collins, Staff Advocate
Idaho
Case No. QWE-T-05-11
L3C 02-0091
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0091
If a tandem switch has connectivity to a given end office, is there any
technical reason why it can not connect either a local call or a toll call
to any phone number that is homed to that end office?
RESPONSE:
Qwest objects to Interrogatory No. 02-009 on the grounds that it is
ambiguous and harassing since Level 3 has agreed to establish trunking to
Qwest's tandem in the testimony of Mr. Ducloo in Colorado Docket No.
05B-210-
Subject to and without waiving the foregoing objections, Qwest responds withthe following:
It would be illogical and inefficient to establish toll trunking to a local
tandem for delivery of toll traffic to those end offices that subtend a local
tandem when a similar connection may be established at an access tandem for
completion of toll traffic to all end offices that subtend that access tandem
in addition to the end offices that subtend the local tandem. The only
purpose for a CLECs desire to establish toll trunking to a local tandem would
be to avoid access charges by wrongfully exploiting Qwest's limited ability
to record traffic at the local tandem.
Respondent: Daniel Collins, Staff Advocate
Idaho
Case No. QWE-05-11L3C 02-0101
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0101
Please cite the authority whereby the FCC has limited interconnection
facilities to DSI and DS3 facilities.
RESPONSE:
Qwest obj ects to Interrogatory No. 02 - 010 on the grounds that it calls for
a legal conclusion and may call for materials protected by the attorney
work product privilege. Subj ect to and without waiving the foregoing
obj ections, Qwest responds with the following:
Qwest does not contend that the FCC has limited interconnection facilities to
DS1 and DS3 facilities. DS1 and DS3 facilities are facilities that are
typically used for interconnection with Qwest. Qwest's language provides
Level 3 the ability to request other technically feasible means of
interconnection as is provided in the Qwest proposed language at section
7 .1 .2 and as explained in Mr. Linse s testimony in Colorado Docket No.
05B-210-
Respondent: Daniel Collins, Staff Advocate
Idaho
Case No. QWE-05-L3C 02-0111
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0111
Does Qwest believe that it is more efficient for a CLEC to provision two
networks rather than one network for a given amount of traffic?
RESPONSE:
Whether it is more efficient for a CLEC to provision one network rather than
two under depends on multiple variables not contained in the question.
Efficiency depends on the totality of circumstances. Nevertheless, something
that may be more efficient for one party can create inefficiency and
substantially increased costs for another party. For example, routing all
traffic over a LIS trunk group creates billing inefficiencies because it
would require extensive reworking of Qwest' s billing systems. Thus, to
determine true efficiency the impact on all parties must be taken intoaccount.
Furthermore, abstract notions of "efficiency" must be placed in the context
of existing rules, regulations and requirements. For example, interexchange
switched access traffic is governed by FCC and state rules and Qwest access
tariffs/catalog, whereas local interconnection is governed by the ICAs and
Qwest's Wholesale interconnection tariffs.
Respondent: Daniel Collins, Staff Advocate
Idaho
Case No. QWE-05-
L3C 02-0121
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0121
If accurate PLU/PIU factors are generated by each company, what would prevent
the companies from providing each other with accurate billing statements?
RESPONSE:
Qwest objects to Interrogatory No. 02-012 on the grounds that it is
ambiguous and calls for speculation. Subj ect to and without waiving the
foregoing objections, Qwest responds with the following:
To the extent PLU/PIU factors are based on prior period traffic studies and
then applied on a prospective basis, they provide only an estimate of the
appropriate jurisdiction of the traffic.
Respondent:William Easton
Idaho
Case No. QWE-T-05-11
L3C 02-0131
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0131
Should Level 3 be concerned where, geographically, Qwest I s local customers
are physically located?
RESPONSE:
Qwest objects to Interrogatory No. 02-013 on the ground that it is
ambiguous and requires Qwest to speculate about what may or may notconcern Level 3.
Idaho
Case No. QWE-05-
L3C 02-0141
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0141
When a CLEC customer originates a locally dialed call, does Qwest expect
the CLEC to pass the call to Qwest at the POI, without charging Qwest? On
that same call, does Qwest expect the CLEC to pay transport and
termination to Qwest?
RESPONSE:
Qwest objects to Interrogatory No. 02-014 on the grounds that it is compoundand ambiguous. Subj ect to and without waiving the foregoing obj ections,
Qwest responds with the following:
On a truly local call (i. e., where the called and calling party are
physically located within the same local calling area), if the CLEC customer
originated the call, the CLEC is not entitled to paYment from Qwest for thecall. If the call terminates to Qwest, the CLEC is financially responsible
to deliver it to the POI and Qwest would be entitled to reciprocal
compensation. If the call transits through Qwest and terminates to another
Carrier, transport charges may apply to the originating Carrier.
Respondent:Guy Duncan
Idaho
Case No. QWE-05-
L3C 02 - 0151
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0151
Is it Qwest' s position that the establishment of a single POI per LATA
is not allowed? If yes, please explain in detail.
RESPONSE:
Qwest objects to Interrogatory No. 02-015 on the grounds that it isambiguous. Subject to and without waiving the foregoing objections, Qwest
responds with the following:
No.
Respondent: Daniel Collins, Staff Advocate
Idaho
Case No. QWE-05-
L3C 02-001A
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:001A
Please admit that in the Qwest network, for local/EAS traffic originated by
Qwest customers and terminated to Qwest customers, it is true that:
a tandem switch may be used for completion of the call, and
b. the tandem that is used may not be physically located in the same
local/EAS area as the two end offices
If your response is anything less than an unqualified admission to the
above, identify: a. each fact upon which you base your response; b. each
person having knowledge of those facts; and c. each document that supportsyour response.
RESPONSE:
Qwest objects to Request for Admission No. 02-001 on the grounds that it is
compound, ambiguous, overbroad, unduly burdensome and not reasonably
calculated to lead to the discovery of admissible evidence.
Subject to and without waiving the foregoing objections, Qwest responds withthe following:
Admitted.
Denied. In the Qwest network, for local/EAS traffic originated by Qwest
customers and terminated by Qwest customers, the tandem that is used is
located in the same local/EAS area as the two end offices.
Respondent: Daniel Collins, Staff Advocate
Idaho
Case No. QWE-05-
L3C 02-002A
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:002A
Please admit that for the completion of local calls, when a tandem switch
needed for completion of the call, it does not matter from a technical point
of view where the tandem switch is geographically located? If your response
is anything less than an unqualified admission, identify: a. each fact upon
which you base your response b. each person having knowledge of those facts
and c. each document that supports your response.
RESPONSE:
Qwest objects to Request for Admission No. 02-002 on the ground that it isambiguous. Subj ect to and wi thout waiving the foregoing obj ections, Qwest
responds with the following:
Admitted. However, it DOES matter where the traffic originates and
terminates, because the origination and termination points determine whether
the call is a local or an interexchange call. Accordingly, Qwest does not
believe it matters where the Level 3 switch is located, since the appropriate
manner of determining whether traffic is local or interexchange in nature is
the location of the calling and called parties. Furthermore, it DOES matter
that Level 3 is providing what it erroneously attempts to characterize as a
local service to the calling party when in fact the customer being called is
neither located in the same local calling area as the calling party nor
bearing financial responsibility to transport the traffic to another local
calling area.
Respondent: Daniel Collins, Staff Advocate
Idaho
Case No. QWE-05-
L3C 02-003A
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:003A
Please admit that Level 3 has agreed to provision direct trunks when the 512
CCS threshold has been exceeded? If your response is anything less than an
unqualified admission, identify: a. each fact upon which you base your
response; b. each person having knowledge of those facts; and c. each
document that supports your response.
RESPONSE:
Denied. The sentence referred to by Level 3 says: "Qwest may request CLEC to
order a direct trunk group to the Qwest End Office Switch.Level 3 has
removed the sentence that says: "CLEC shall comply with that request.
Respondent: Daniel Collins, Staff Advocate
Idaho
Case No. QWE-05-
L3C 02-004A
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:004A
Please admit the following: In a competitive market (as defined by Qwest) an
increase in Qwest I s cost of providing service will not necessarily result in
an increase in Qwest retail consumer and/or business rates. If your response
is anything less than an unqualified admission, identify: a. each fact upon
which you base your response b. each person having knowledge of those facts
and c. each document that supports your response.
RESPONSE:
Qwest objects to Request for Admission No. 02-004 on the basis it constitutes
an incomplete hypothetical and requires speculation. Subj ect to and withoutwaiving the foregoing obj ections, Qwest responds with the following:
Denied. Although the statement may be true in the short run, in the long
run, companies must recover their costs in order to stay in business.
Respondent: William Easton
Idaho
Case No. QWE-05-
L3C 02-005A
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:005A
Please admit the following: Qwest has used billing factors for billing other
carriers for decades. If your response is anything less than an unqualified
admission, identify: a. each fact upon which you base your response; b. each
person having knowledge of those facts; and c. each document that supportsyour response.
RESPONSE:
Qwest objects to Request for Admission No. 02-005 on the grounds that it isoverbroad and ambiguous. Subj ect to and without waiving the foregoing
objections, Qwest responds with the following:
Denied. Qwest has not used such factors for decades for local traffic.
Qwest has used these only where necessary to jurisdictionalize for the
separation of interstate and intrastate access traffic.
Respondent: Daniel Collins, Staff Advocate
Idaho
Case No. QWE-05-
L3C 02-006A
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:006A
Please admit that when Qwest receives a locally dialed call from an
Independent Local Exchange Carrier end user customer, Qwest does not know
the physical location of the Independent Local Exchange Carrier end user
customer. If your response is anything less than an unqualified admission,
identify: a. each fact upon which you base your response; b. each person
having knowledge of those facts; and c. each document that supports yourresponse.
RESPONSE:
Qwest objects to Request for Admission No. 02-007 on the grounds that it isambiguous. Subject to and without waiving the foregoing objections, Qwest
responds with the following:
Denied. Qwest customers typically have a toll relationship with independent
company customers and only in limited circumstances are locally dialed calls
exchanged between Qwest and independent companies. Those limited
circumstances include situations in which Qwest and independent companies
have requested state commissions to allow Extended Area Service ("EAS")
arrangements where the costs of provision of EAS are recovered through the
retail rates of both carriers so that the customers of each carrier appear to
have local calling. Qwest has relationships with independent carriers where
the independent companies operate their switches and provide service based on
similar geographic boundaries as Qwest and where their local traffic
originates and terminates within the same local calling area. Qwest has no
reason to believe that customers of independent companies are in physical
locations outside the local calling area of the central office with which the
customers' phone numbers are associated.
Respondent: Daniel Collins, Staff Advocate
Idaho
Case No. QWE-05-11
L3C 02 - 0 07A
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:007A
Please admit that Qwest switches route calls based upon information contained
in the local exchange routing guide ("LERG") database. If your response is
anything less than an unqualified admission, identify: a. each fact upon
which you base your response; b. each person having knowledge of those facts;
and c. each document that supports your response.
RESPONSE:
Admitted. In addition, the LERG contains geographic associated information
such as Rate Centers.
Respondent: Daniel Collins, Staff Advocate
Idaho
Case No. QWE-T- 05 -L3C 02-00BA
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:OOBA
Please admit that Qwest I s circuit switches do not route calls based upon
specific addresses contained within the switches. If your response is
anything less than an unqualified admission, identify: a. each fact upon
which you base your response; b. each person having knowledge of those
facts; and c. each document that supports your response.
RESPONSE:
Qwest objects to Request for Admission No.02-009 on the grounds that it isambiguous. Subject to and without waiving the foregoing objections, Qwest
responds with the following:
See Qwest' s response to Level 3' s First Set of Admissions, Number 021A.
Respondent: Daniel Collins, Staff Advocate
Idaho
Case No. QWE-05-
L3C 02-009A
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:009A
Please admit that when a customer of Qwest' s One Voice Service purchase a
virtual number" as defined by Qwest that the physical location of the called
and calling parties does not determine the nature of compensation. If your
response is anything less than an unqualified admission, identify: a. each
fact upon which you base your response; b. each person having knowledge of
those facts; and c. each document that supports your response.
RESPONSE:
Qwest obj ects to Request for Admission No. 02 - 009 on the grounds that it isambiguous. Subj ect to and without waiving the foregoing obj ections, Qwest
responds with the following:
Denied
a. Appropriate compensation associated with termination of an information
service such as VoIP to the PSTN is governed by the ESP Exemption, as
properly applied. Under the ESP Exemption, access charges are not applicable
when an information service is terminated to the PSTN provided that the ESP
POP and the called party are in the same local calling area. If the ESP
Exemption does not apply, then the existing rules governing intercarrier
compensation, including access charges, for call termination apply.
b. The facts are based on knowledge of the ISP Remand Order, which is
available for everyone to read and network principles that are generally
known within the industry. Larry Brotherson and Phil Linse are the Qwest
witnesses that have knowledge of these facts.
c. Order, In the Matter of Amendments of Part 69 of the Commission's Rules
Relating to Enhanced Service Providers, 3 FCC Red 2631, ~ 2, n.(19BB) ("ESP
Exemption Order"). See also id. ~ 20, n. 53 ("Thus, the current treatment of
enhanced service providers for access charge purposes will continue. At
present, enhanced service providers are treated as end users and thus may use
local business lines for access for which they pay local business rates and
subscriber lines charges. To the extent that they purchase special access
lines, they also pay the special access surcharge under the same conditions
as those applicable to end users.
") .
Respondent:Larry Brotherson, Staff Director
Mary LaFave, Staff Director