20060224QWE supp responses L3C requests.pdf

STOEL
~~,
?J ;';; L,:
101 S. Capilol Boulevard. Suite 1900
Boise. Idaho 83702
main 208.389.9000
fax [phone]
ATTORNEYS AT LAW
. .
iiUTiES CD! ,
;;:~;
~;iU;:
WWIV.sloel.com
February 23 , 2006
MARY S, HOBSON
Direct [phone]
mshobson(iYstoel.com
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, ill 83702-5983
RE:Docket No. QWE-O5-
Dear Ms. Jewell:
Enclosed for filing with this Commission is an original and three (3) copies of QWEST
CORPORATION'S SUPPLEMENTAL RESPONSES TO LEVEL 3
COMMUNICATIONS LLC'S INTERROGATORIES, REQUESTS FOR PRODUCTION
OF DOCUMENTS, AND REQUESTS FOR ADMISSIONS TO QWEST
CORPOR.i\TION,
If you have any questions, please contact me. Thank you for your cooperation in this matter.
Very truly yours/t(luI
Mary S. H6bson
:blm
Enclosurescc: Service List
Oregon
Washington
C a I I r a r n i a
U I a h
Boise-193000,10061273-00018 Idaho
Mary S. Hobson (ISB. No. 2142)
Stoel Rives LLP
101 So).lth 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
; -
; i
: ~.
~ l'L:= 5 \
, ,. ,,
)T:L;T:L:~~; CUi ;ii;SS!Cl:
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'
SUPPLEMENTAL RESPONSES TO
LEVEL 3 COMMUNICATIONS LLC'
INTERROGATORIES, REQUESTS FOR
PRODUCTION OF DOCUMENTS, AND
REQUESTS FOR ADMISSIONS TO
QWEST CORPORATION
Qwest Corporation, through its undersigned attorneys, hereby files the attached
supplemental responses to Level 3 Communications, LLC's Interrogatories, Requests for
Production of Documents, and Requests for Admissions to Qwest Corporation.
QWEST CORPORATION'S SUPPLEMENTAL RESPONSES TO LEVEL 3
COMMUNICATIONS LLC'S INTERROGATORIES, REQUESTS FOR PRODUCTION
OF DOCUMENTS, AND REQUESTS FOR ADMISSIONS TO QWEST CORPORATION -
Boise-186552,20061273-00018
PAGEl
DATED this 23rd day of February, 2005.
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: flfll~
Mary S. H son (ISB. No. 2142)
Stoel Rives LLP
101 South Capitol Boulevard
Suite 1900
Boise, ill 83702-7705
Tel: [phone]
Fax: [phone]
mshobson~stoel.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 SUPPLEMENTAL RESPONSES TO LEVEL 3
COMMUNICATIONS LLC'S INTERROGATORIES, REQUESTS FOR PRODUCTION
OF DOCUMENTS, AND REQUESTS FOR ADMISSIONS TO QWEST CORPORATION -
Boise-186552,20061273-00018
PAGE 2
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'
INTERROGATORIES, REQUESTS FOR PRODUCTION OF DOCUMENTS, AND REQUESTS
FOR ADMISSIONS TO QWEST CORPORATION was served on the 23rd day of February, 2006 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]
iiewell~puc.state.id.
Weldon Stutzman
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ill 83702
Telephone [phone]
Facsimile: [phone]
John Antonuk
Liberty Consulting Group
65 Main Street
O. Box 237
Quentin, P A 17083
an ton uk~l i bertyconsul tinggro up. 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
Erik Cecil
Level 3 Communications LLC
1025 Eldorado Boulevard
Broomfield, CO 80021
Telephone: [phone]
Facsimile: [phone]
erik.cecil~leve13 .com
Dean J. Miller (ISB #1968)
McDevitt & Miller LLP
420 West Bannock Street
O. Box 2564
Boise, ill 83701
Telephone: [phone]
Facsimile: [phone]
i oe~mcdevitt-miller .com
Attorneys for Level Communications
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
QWEST CORPORATION'S SUPPLEMENTAL RESPONSES TO LEVEL 3
COMMUNICATIONS LLC'S INTERROGATORIES, REQUESTS FOR PRODUCTION
OF DOCUMENTS, AND REQUESTS FOR ADMISSIONS TO QWEST CORPORATION -
Boise-186552.20061273-00018
PAGE 3
Rick Thayer
Level 3 Communications LLC
Rick. Thaver~Leve13 .com
Attorneys for Level Communications
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
6ttUtdt~ #I~
Brandi L. McMahon
Legal Assistant to Mary S. Hobson
Stoel Rives LLP
QWEST CORPORATION'S SUPPLEMENTAL RESPONSES TO LEVEL 3
COMMUNICATIONS LLC'S INTERROGATORIES, REQUESTS FOR PRODUCTION
OF DOCUMENTS, AND REQUESTS FOR ADMISSIONS TO QWEST CORPORATION -
Boise-186552.20061273-00018
PAGE 4
Idaho
Case No. QWE-05-
L3C 01-004IS1
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:004IS1
Does Qwest have an affiliated Internet Service Provider (" 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 within the state in which the
affiliate maintains a physical presence.
RESPONSE:
Qwest obj ects 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 Corporation
and Qwest !nterprise America, Inc.
Respondent:Mary LaFave
SUPPLEMENTAL RESPONSE dated 2/23/06:
a. Qwest Corporation does not collocate in its own end offices. There is no
Qwest affiliate that has collocated modem banks, DSL equipment, routers, and
ATM switches in Qwest Corporation end offices in Idaho.
Respondent: Ryan Gallagher , Staff Advocate
b. QCC has purchased PRI in the following Idaho exchanges: Boise, Idaho
Falls, Ketchum, and Twin Falls.
Respondent:Mary LaFaveCatherine Barrett
Idaho
Case No. QWE-05-L3C 01-005IS1
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:005IS1
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 which
such service (s) is/are purchased.
RESPONSE:b. Qwest objects to this subpart that it "state how many end use and how
many wholesale customers in the state the Qwest ISP VoIP provider has " 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' 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 I s purchases of services outside the state of Idaho and
outside the 14-state territory 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 objection.
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 objection.
Respondent:Mary LaFave
SUPPLEMENTAL RESPONSE dated 2/23/06:
No.
Respondent:Mary LaFave
Idaho
Case No. QWE-OS-11
L3C 01-012IS1
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:012IS1
Please identify every state in which Qwest combines local and toll traffic
(including either interLATA or intraLATA toll traffic, or both, as the case
may be) on the same trunk group at any point in Qwest I s transmission of
traffic. For each such state, please indicate which of the following
situations apply:a. Local and toll traffic combined on a direct trunk group between two endoffices;b. Local and toll traffic combined on a trunk group between a Qwest end
office and a Qwest tandem;
Local and toll traffic combined on a trunk group between a Qwest end
office and a third party carrier (CLEC, ILEC, IXC) switch;
Local and toll traffic combined on a trunk group between a Qwest tandem
and a third party (CLEC, ILEC, IXC) switch; and/ore. Local and toll traffic combined on a trunk group between two Qwesttandems.
For purposes of this question, please use Qwest' s own definitions of "local"and toll" traffic, but provide a brief explanation of how Qwest classifies
traffic into those categories.
RESPONSE:
Qwest objects to this request to the extent that it seeks information about
states other than Idaho and is so over broad as to include states in whichQwest is not the incumbent LEC. Qwest further obj ects that the request is
overbroad, unduly burdensome, seeks information that is not relevant to the
subj ect matter in the pending action, and is not reasonably calculated to
lead to the discovery of admissible evidence.
SUPPLEMENTAL RESPONSE dated 2/22/06:a. Qwest does not combine Qwest local and Qwest toll traffic on a direct
trunk group between two Qwest end offices.b. Qwest does not combine Qwest local and Qwest toll traffic on a single
trunk group between a Qwest end office and a Qwest tandem.
c. Regarding CLECs and ILECs For Qwest switched access traffic, Qwest
does not combine local and toll traffic on a trunk group between a Qwest end
office and a CLEC/ILEC carrier switch.
Reqarding IXCs For Qwest terminatinq switched access traffic , local and
toll traffic may be combined on a Feature Group D ("FGD") trunk group between
a Qwest end office and an IXC switch. For Qwest oriqinated switched accesstraffic, Qwest does not combine local and toll traffic on a FGD trunk group
between a Qwest end office and an IXC switch.
d. Regarding CLECs Jointly provided switched access and CLEC local
traffic may be combined on the same trunk group between a Qwest access tandem
and a CLEC.
Regarding ILECs Qwest does not combine jointly provided switched access and
Qwest local traffic on the same trunk group between a Qwest access tandem andan ILEC swi tch.
Regarding IXCs For Qwest terminating switched access traffic , local and
toll traffic may be combined on a Feature Group D ("FGD") trunk group between
a Qwest access tandem and an IXC switch. For Qwest oriqinated switched
access traffic , Qwest does not combine local and toll traffic on a FGD trunk
group between a Qwest access tandem and an IXC switch.e. No. Qwest does not combine local and toll traffic on a trunk group
between two Qwest Tandems.
Respondent:Ryan Gallagher, Staff Advocate
Idaho
Case No. QWE-05-
L3C 01- 013 IS1
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:013IS1
In which states, and in which local calling areas in those states, do
Qwest's CLEC affiliates combine their own local and toll (IntraLATA and
InterLATA) traffic on a single trunk?
RESPONSE:
Qwest objects to this request to the extent that it seeks information about
the activities of Qwest affiliates in states other than Idaho and is so over
broad as to include states in which Qwest is not the incumbent LEC. Qwest
further obj ects that the request is burdensome, seeks information that is not
relevant to the subject matter in the pending action, and is not reasonably
calculated to lead to the discovery of admissible evidence.
SUPPLEMENTAL RESPONSE dated 2/22/06:
Nei ther Qwest Communications Corporation nor Qwest nterprise America, Inc.
combine both local and toll (IntraLATA and InterLATA) traffic on a single
trunk group with Qwest Corporation.
Respondent:Ryan Gallagher, Staff Advocate
Idaho
Case No. QWE-T-OS-L3C 01-014IS1
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:014 IS1
In which states does Qwest combine CLEC local and toll (IntraLATA
and InterLATA) traffic on a single trunk?
Please provide a list of all CLECs for whom Qwest combines, or has
combined, local and toll (IntraLATA and InterLATA) traffic on a singletrunk.
Please provide the month and year when Qwest started to combine traffic
in each state where Qwest combines CLEC local and toll (IntraLATA and
InterLATA) traffic.
RESPONSE:
Qwest objects to this request to the extent that it seeks information about
states other than Idaho and is so over broad as to include states in whichQwest is not the incumbent LEC. Qwest further objects that the request is
overbroad, unduly burdensome, seeks information that is not relevant to the
subject matter in the pending action, and is not reasonably calculated tolead to the discovery of admissible evidence. Qwest also obj ects to this
request to the extent it requests that Qwest identify individual wholesale
customers and to disclose information that said customers may considerproprietary.
SUPPLEMENTAL RESPONSE dated 2/22/06:
The following response relates to Qwest operations in Idaho:
Qwest does not combine switched access and local traffic on a single trunk
group to any CLEC. Qwest mav combine jointly provided switched access and
local traffic to a CLEC on a single trunk group.
Respondent:Ryan Gallagher, Staff Advocate
Idaho
Case No. QWE-O5-
L3C Ol-O16ISl
INTERVENOR:Level 3 Communications LLC
REQUEST NO:O16ISl
For each state in which Qwest operates as an ILEC please identify each CLECwith which Qwest (a) exchanges local and toll (IntraLATA and InterLATA)
traffic on a single trunk group and (b) uses a a Percent Local Use (PLU) or
similar method of establishing the apportionment of local vs. toll traffic
on the combined trunk group.
RESPONSE:
Qwest objects to this request on the basis that it seeks information about
Qwest operations in states other than Idaho. Qwest further obj ects that the
request appears to seek information about specific Qwest wholesale customers
that is not relevant and may not be appropriately disclosed in this case.
Finally Qwest obj ects that the request seeks information that is not
relevant to the subject matter in the pending action and is not reasonably
calculated to lead to the discovery of admissible evidence.
SUPPLEMENTAL RESPONSE dated 2/22/06:
Qwest responds with the following regarding its operations in Idaho:
Qwest does not combine switched access and local traffic on a singletrunk group and does not use a Percent Local Use ("PLU") or similar
method of establishing the apportionment of local verses toll traffic
on a combined trunk group with any carrier. However Qwest and a CLEC
may apply a PLU factor to No-CPN traffic to address the absence of
CPN.
Respondent:Ryan Gallagher Staff Advocate
Idaho
Case No. QWE-O5-L3C Ol-Ol7ISl
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:O17ISl
For each state in which a Qwest CLEC affiliate combines local and toll(IntraLATA and InterLATA) traffic on a single trunk group, please statewhether Qwest' s CLEC affiliate uses a Percent Local Use (PLU) or similar
other method of establishing the apportionment of local vs. toll traffic on
the combined trunk group.
RESPONSE:
Qwest objects to this request on the basis that it seeks information about
Qwest I s affiliate I s operations in states other than Idaho. Qwest further
that the request seeks information that is not relevant to the subj ect matter
in the pending action and is not reasonably calculated to lead to the
discovery of admissible evidence.
SUPPLEMENTAL RESPONSE dated 2/22/06:
Nei ther Qwest Communications Corporation nor Qwest nterprise America, Inc.
combine both local and toll (IntraLATA and InterLATA) traffic on a single
trunk group with Qwest Corporation.
Respondent:Ryan Gallagher, Staff Advocate
Idaho
Case No. QWE-05-
L3C 01-022IS2
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:022IS2
Unless your answer to Question #21 above was an unqualified "no," pleaseidentify:a. the number of customers in this state who subscribe to or purchase
Qwest I s FX service;
the number of FX lines that Qwest provides in this state;
how long FX service has been available from Qwest; and,
the number of ISPs to whom Qwest provides such service.
RESPONSE:
Qwest obj ects to this request in so far as it seeks information about the
volumes of Qwest I s retail business, on the basis that such information
constitutes a trade or business secret and is confidential and proprietary toQwest. Qwest further obj ects on the basis that it does not retain
information about the business purposes of its retail customers and that such
information may be proprietary to Qwest I s customers.
SUPPLEMENTAL RESPONSE dated 8/04/05:
Without waiver of the previous objection, Qwest responds:
a. Qwest does not track FX service by the number of customers purchasing theservice. Qwest tracks FX service by the number of FX lines in service.
Qwest has 140 FX lines in Idaho.
FX service has been available in Idaho since as early as 1954.
d. Qwest does not track FX service by the type of customer (ISP) thatpurchases the service.
Respondent:Larry Brotherson
SUPPLEMENTAL RESPONSE dated 2/22/06:
As previously noted, Qwest does not maintain information as to the type of
business each of its end users engage in. For purposes of responding to thearbitrator I s order, Qwest has reviewed the FX customer names and, based on
that review, it does not appear that any FX customers are ISPs. In addition,
FX service was discontinued and grandfathered in southern Idaho in 1954;
therefore there should be no ISPs in southern Idaho using FX service since
there were no ISPs in 1954.
Qwest recently identified errors in the reporting of the total number of FX
lines in Idaho. The total number of FX lines for both northern and southern
Idaho is 192.
Respondent:Larry Brotherson
Idaho
Case No. QWE-05-L3C 01-023IS1
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:023IS1
Please state whether Qwest offers any FX-Like Service, other than service
specifically described as Foreign Exchange. If the answer is anything otherthan an unqualified "no," please state the name of each such FX-Like Service
and provide service descriptions (including, but not limited to, tariff
pages) for each such FX-like service.
RESPONSE:
Qwest objects to this request to the extent that it seeks information
concerning Qwest I s product offerings in states other than the state of Idaho.
SUPPLEMENTAL RESPONSE dated 2/22/06:
Pursuant to the description provided by Level 3, "FX-like" means any product
or service under which a customer is assigned a telephone number with an NXX
that is not associated with the rate center where the customer is physicallylocated.
Qwest's Market Expansion Line ("MEL") has, in the past, been erroneously
characterized as an FX-like service. It does not, however, meet the
definition set forth above because MEL is simply a remote call forwarding
"feature" for business customers that allows the customer to call forward
their service to a different location without the need for a physicallocation in that area. Calls to a MEL service are forwarded automatically
from the central office to another telephone number of the customer s choice,
either within the LCA or to another LCA, but if the number to which it is
forwarded is outside the LCA of the central office serving the MEL line, full
retail toll charges apply to the MEL customer. MEL service is no different
than any other customer that subscribes to "call forwarding" forwarding their
line to another location.
Primary Rate Service (PRS-Integrated Services Digital Network) is a
high-capacity local service (DS1 and higher) that allows business customers
to receive and terminate calls within a LCA. When PRS is combined with an FX
service option it also has been characterized as an FX like service. A PRS
customer can receive dial tone from a switch other than the switch in the
central office that serves the customer's physical location by requesting PRS
with Foreign Central Office (FCO). That combination is often referred to as
PRS-FCO. The PRS-FCO customer pays Intrastate DS1 (or higher) mileage rates
between the central offices.
Level 3 inaccurately describes Qwest Communications Corporation ("QCC"),
Qwest's Affiliate company, Wholesale Dial and OneFlexTM product offerings as
"FX-like" services. Wholesale Dial is a product that QCC offers to ISPs.
QCC purchases tariffed or catalog services from Qwest (the ILEC) and then
packages those tariffed or catalog services for ISPs. In particular, QCC
purchases catalog Primary Rate ISDN services. This means that Wholesale Dial
customers pay catalog private line transport rates to haul calls from the LCA
where the dial tone is provided to the location of the ISP.
QCC also offers OneFlexTM to ISPs. Level 3 may view this service as similar
to its VNXX service, or "FX-like , in that virtual numbers are assigned.
However, these numbers honor the LCA guidelines and calls to or from these
numbers from outside the LCA where the VoIP POP is located are not local
calls, as Level 3 advocates. No VNXX calls are permitted with OneFlexTM
because calls are exchanged between the POP and the caller within the sameLCA. OneFlexTM does not assign VNXX number to ISP customers outside of the
LCA.
For a description of the ISP service offerings see:
http: / /tariffs. qwest. com: 8000/Q Tariffs/QT Tariff State Page/index. htmli
Local ISP Products and Services
http: / /www.qwest.com/wholesale/industrysolution/isp.htmli
Wholesale Dial
http: / /www.qwest.com/pcat/large business/product/1, 1016, 2098 28, 00. html)
National ISP Products and Services
http: / /www.qwest.com/wholesale/industrysolution/isp.htmli
OneFlex (
http: / /www.qwest. com/pcat/large business/product/1, 1016,2106 28,00. html)
Respondent:Larry Brotherson
Idaho
Case No. QWE-OS-11
L3C 01-024IS1
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:024IS1
Unless your answer to Question #23 above was an unqualified "no," please
identify:
the number of customers in this state who subscribe to or purchase each
of the FX-Like Services identified in response to the precedingquestions;
the number of lines in this state over which Qwest provides each of the
FX-Like Services identified in response to the preceding questions;
how long each FX-Like Service has been available from Qwest; and,d. the number of ISPs who purchase each of the FX-Like Services identified
in response to the preceding questions.
RESPONSE:
Qwest objects to this request and its subparts in so far as it seeks
information about the number of customers and lines it is serving, on the
basis that such information constitutes a trade or business secret and isconfidential and proprietary to Qwest. Qwest further objects on the basis
that it does not retain information about the business purposes of its
customers and that such information may be proprietary to Qwest I s customers.
SUPPLEMENTAL RESPONSE dated 2/22/06:
Pursuant to agreement of the parties, the definition of "FX-like service"
shall mean "any product or service under which a customer is assigned atelephone number with an 'NXX' that is not associated with the rate center
where the customer is located.a. Qwest does not maintain the information necessary to identify the numberof "customers"b. Qwest does not quantify the number of MEL customers who forward their
calls beyond the LCA in which they are located. Likewise, Qwest does not
uniquely identify customers with the PRS-FCO combination and cannot,
therefore, quantify the specific number of such services.c. MEL has been available since at least 1982 and Qwest began offering
PRS-FCO as early as 1990 in most states within Qwest's territory.d. Qwest does not track FX or FX-like service by the type of customer
(including whether the customer is an ISP) that purchases the service.
Therefore, Qwest does not have the information necessary to respond to thisquestion.
Respondent: Larry Brotherson
Idaho
Case No. QWE-05-L3C 01-041IS1
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:041IS1
How many physical POls exist in Idaho between Qwest and CLECs?
RESPONSE:
Qwest objects to this request on the basis that it is unreasonably burdensome
and that response would require a special study. Qwest further obj ects that
the request does not appear reasonably calculated to lead to the discovery of
admissible evidence.
SUPPLEMENTAL RESPONSE dated 2/22/06:
Twenty-eight (28) POls exist in Idaho between Qwest and CLECs.
Respondent: Ryan Gallagher, Staff Advocate
Idaho
Case No. QWE-05-
L3C 01-043IS1
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:043IS1
How many CLECs in Idaho connect to Qwest I s network by means of (a) a
Qwest-supplied entrance facility running between Qwest I s network and a CLECswitch; (b) a CLEC-supplied facility delivered to Qwest I s network at or near
a Qwest central office building; or (c) some other means?
RESPONSE:
Qwest objects to this request on the basis that it is unreasonably burdensome
and that response would require a special study. Qwest further obj ects that
the request does not appear reasonably calculated to lead to the discovery of
admissible evidence.
SUPPLEMENTAL RESPONSE dated 2/22/06:
a. Without performing a special study, Qwest can report that there are 12
CLECs in Idaho, including Level 3, that purchase entrance facilities.
b. Without performing a special study, Qwest can report that there are 7
CLECs in Idaho, including Level 3, that purchase collocation in Qwest I s
switches. There are no CLECs that purchase Midspan Meet POI as an
interconnection option in the state of Idaho.
c. Without performing a special study, Qwest is not aware of CLECs in Idaho
that are interconnecting using some other means than those described in this
response to subsections a. and
Respondent: Ryan Gallagher, Staff Advocate