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Home My WebLink About20060306Qwest supplemental responses.pdf- ' Mary S. Hobson Attorney & Counselor 999 Main, Suite 1108 Boise, ID 88706 208-885-8666 -c. \Li: no . I . . " ".. j ,- , ;LI':~~. CL:: ,i ,j:::;~'iU, March 6, 2006 VIA HAND DELIVERY Jean D. Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Boise, ill 83702-5983 RE:Docket No. QWE-OS- Dear Ms. Jewell: Enclosed for filing with this Commission are 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 CORPORATION. If you have any questions, please contact me. Thank you for your cooperation in this matter. Very truly yours )tAfi1J fb h,-~ Mary S. rJobson Enclosurescc: Service List Boise-1930oo.10061273-oo018 Mary S. Hobson (ISB. No. 2142) 999 Main, Suite 1103 Boise, ill 83702 Tel: 208-385-8666 mary .hobson (g)qwestcom Thomas M. Dethlefs Senior Attorney Qwest Services Corporation 1801 California Street - 10th Floor Denver, CO 80202 Telephone: (303) 383-6646 Facsimile: (303) 298-8197 Thomas. Dethlefs (g)qwestcom .. ": . , , c- I) : -- () r- :: Lj: 0 : ,' . . ..:! "- c:::" . .' :._, , '~ '' ', , i I ...; V , 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 LA WS FOR RATE, TERMS, AND CONDITIONS OF INTERCONNECTION WITH QWEST CORPORATION CASE NO. QWE-05- QWEST CORPORA TIO~' 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-l 86552.2 0061273-00018 PAGE 1 DATED this 6th day of March, 2006. Respectfully submitted Thomas M. Dethlefs Senior Attorney Qwest Services Corporation 1801 California Street, 10th Floor Denver, CO 80202 Tel: 303-383-6646 Fax: 303-298-8197 Thomas.Dethlefs (g) qwestcom QWEST CORPORATION By: ~~~ Mar S. Hob n (ISB. No. 2142) 999 Main. Suite 1103 Boise, ill 83702 Tel: 208-385-8666 mary .hobson (g) Qwest.com Ted D. Smith Stoel Rives LLP 201 South Main Street Suite 1100 Salt Lake City, UT 84111 Tel: 801-578-6961 Fax: 801-578-6999 tsmith (g) stoel.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-l 86552.2 0061273-00018 PAGE 2 CERTIFICATE OF SERVICE I do hereby certify that a true and correct copy of the foregoing QWEST CORPORATION' SECOND SUPPLEMENTAL RESPONSES TO LEVEL 3 COMMUNICATIONS LLC'S INTERROGATORIES, REQUESTS FOR PRODUCTION OF DOCUMENTS, AND REQUESTS FOR ADMISSIONS TO QWEST CORPORATION was served on the 6th day of March, 2006 on the following individuals: Jean D. Jewell Idaho Public Utilities Commission 472 West Washington Street O. Box 83720 Boise, ill 83702 Telephone (208) 334-0300 Facsimile: (208) 334-3762 iiewell (gJpuc.state.id. ..x.. Weldon Stutzman Idaho Public Utilities Commission 472 West Washington Street O. Box 83720 Boise, ill 83702 Telephone (208) 334-0300 Facsimile: (208) 334-3762 ..x.. John Antonuk Liberty Consulting Group 65 Main Street O. Box 237 Quentin, P A 17083 antonuk (gJ libertyconsultinggroup.com ..x.. ..x.. Erik Cecil Level 3 Communications LLC 1025 Eldorado Boulevard Broomfield, CO 80021 Telephone: (720) 888-1319 Facsimile: (720) 888-5134 erik.cecil (gJ leve13 .com ---X Dean J. Miller (ISB #1968) McDevitt & Miller LLP 420 West Bannock Street O. Box 2564 Boise, ill 83701 Telephone: (208) 343-7500 Facsimile: (208) 336-6912 ioe (gJmcdevitt -miller .com Attorneys for Level Communications ..x.. 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 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-l 86552.2 0061273-00018 PAGE 3 Rick Thayer Level 3 Communications LLC Rick. Thayer(g) Level 3 .com Attorneys for Level Communications Hand Delivery U. S. Mail Overnight Delivery Facsimile Email..x.. :!:s~~ 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-l 86552.2 0061273-00018 PAGE 4 Idaho Case No. QWE-OS-L3C 01-041IS2 INTERVENOR:Level 3 Communications, LLC REQUEST NO:041IS2 How many physical POIs exist in Idaho between Qwest and CLECs? RESPONSE: Qwest obj ects 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) POIs exist in Idaho between Qwest and CLECs. Respondent: Ryan Gallagher, Staff Advocate SUPPLEMENTAL RESPONSE dated 3/3/06: Based on further analysis, eleven (11) POIs exist in Idaho between Qwest and CLECs Respondent: Ryan Gallagher, Staff Advocate Idaho Case No. QWE-05- L3C 01-043IS2 INTERVENOR:Level 3 Communications, LLC REQUEST NO:043IS2 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 objects 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 b. Respondent: Ryan Gallagher, Staff Advocate SUPPLEMENTAL RESPONSE dated 3/3/06: Based on further analysis, Qwest hereby updates its responses to a - a) Qwest interprets question "" to be asking for the number of entrance facilities that are provided by Qwest as described in Qwest' s interconnectionagreement. Therefore the answer to question "a" is 5. b) Qwest interprets question "b" to be asking for the number of CLEC Collocations at Qwest I s central offices that require CLEC provided facilities at Qwest' s central office as described in Qwest I s interconnection agreement. Therefore the answer to question "b" is 6 c) Qwest interprets question "c" to be asking for the number of Midspan Meet POIs that are provided by Qwest as described in Qwest I s interconnectionagreement. Therefore the answer to question "c" is 1. Respondent: Ryan Gallagher, Staff Advocate