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Integra Telecom
6160 Golden Hils Dr
Golden Valley, MN 55416
ww.integratelecom.com
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September 30, 2009
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, ID 83702-5983
Via Overnight Delivery
Re: In the matter of the Petition of Qwest Corporation Requesting Authorization to
Withdraw its Statement of Generally Available Terms and Conditions
Docket No. QWE-T-08-04
Dear Ms. Jewell:
Enclosed are three copies ofIntegra Telecom's First Information Requests to
Qwest Corporation fied with the Commission on September 24,2010, in connection with
the above-referenced matter.
Sincerely,~Kim K. Wagner
Legal and Regulato Administrator
Integra Telecom
763'-745-8468 (Direct)
763-745-8459 (Dept. Fax)
Kim. Wagnerrßintegratelecom.com
Enclosures
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSIONRECEIVED
,DIOSE? 24 AH8: 27
In Re WITHDRAWAL of QWEST CORPORATION'S
STATEMENT OF GENERALLY AVAILABLE
TERMS AND CONDITIONS
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Case No. QWEUl"tL~¥f~lt'
INTEGRA TELECOM'S FIRST INFORMATION REQUEST
To: Qwest Corporation and its attomey(s) of record:
You are hereby requested to provide written answers to the following information
requests and produce responsive documents by October 20,2010.
DEFINITIONS
The word "Qwest," as used in these information requests, refers to each of the "Qwest
Operating Companies," individually identified in the Petition in this matter. Accordingly, you
are requested to respond separately for each Qwest Operating Company to the extent any request
applies to such Company and your answer varies by Company.
INSTRUCTIONS
These information requests are intended to be continuing in natue. The paries
responding to these information requests are asked to promptly supplement their responses to the
extent they become aware of information that makes any response inaccurate or incomplete.
For each of the following information requests, provide the names, titles and employer of
the persons preparing the responses. Also, provide the requested information in native,
executable format (e.g., Excel, Word) to the extent possible.
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Information Request NO.1: Please provide to Integra a copy of your response to any
information request served by any other party in this docket.
Information Request NO.2: (Amended Petition, ii 20, Wiliams Direct, p. 5) Please
provide a list of CLECs in Idaho that have the QP AP as par of their curent interconnection
agreement.
Information Request NO.3: (Wiliams Direct, p. 11) Please provide a history of anual
Tier 1 and Tier 2 QPAP payments from the inception of the QPAP in Idaho. Please break down
these payments by PID and product.
Information Request NO.4: Please provide all of work papers and support documents
used to create the char on page 7 (ii 17) of the Amended Petition of Qwest Corporation, July 30,
2010. Please provide this information in an electronic format (such as Microsoft Excel or
Access) so that the data in the char can be recreated.
Information Request NO.5: (Amended Petition, ii 21) Please provide all written or
verbal communications with CLECs to support the statement that some CLECs believed the
QP AP is not needed.
Information Request No.6: (Amended Petition, ii 22) For CLECs who have opted into
the QPAP, please provide a copy of the language contained in CLEC interconnection agreements
that "recognize the possibility of a regulatory determination affecting the continuing availability
or content of the PAP."
Information Request NO.7: (Amended Petition, ii 24, Wiliams Direct, p. 27) Please
provide a redline comparison of the current Idaho QPAP and the "QPAP II" proposed by Qwest.
Information Request NO.8: (Amended Petition, ii 24) Please admit that the "standard,"
for parity measures, by which Qwest's performance is measured in the QPAP, is not Qwest's
actual retail performance, but instead a deviation from retail performance as determined by a
statistical test.
Information Request NO.9: (Wiliams Direct, pp. 1-2) Please provide a list of all
testimony filed by Mr. Wiliams related to performance assurance plans on performance
indicators. Please provide the docket number and date each piece of testimony was filed.
Information Request No. 10: (Wiliams Direct, p. 2) As used in the testimony of Mr.
Wiliams on page 2, please define "superior performance" for measures involving a benchmark.
Information Request No. 11: (Wiliams Direct, p. 3) Please provide individual CLEC
performance results, as well as aggregate-CLEC performance results in Idaho for the past three
years. Please mask the name of the individual CLECs in order to protect the confidentiality of
those CLECs.
Information Request No. 12: (Wiliams Direct, p. 6) Please provide a list of all PIDs and
products that currently have a retail parity standard, but where Qwest believes the retail parity
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standard is not an "apples-to-apples comparison." For example, Mr. Willams provided the
generic example of unbundled loops.
Information Request No. 13: (Wiliams Direct, p. 6) Were all benchmark standards
currently contained in the Idaho PAP negotiated prior to Qwest s fiing of its 271 FCC
applications? If not, please indicate which benchmark standards were ordered by commissions
or negotiated after Qwests FCC 271 application.
Information Request No. 14: (Willams Direct, p. 9) Please provide the total number of
resale and unbundled loops as well as Qwests retail access lines used to calculate the "nearly 25
percent" cited in Mr. Wiliams testimony. In addition, please provide the source of the data used.
Information Request No. 15: (Willams Direct, p. 11) Please provide a list of the 10
CLECs that had opted into the QPAP in 2003 and the 57 CLECs that had opted into the QPAP in
2009.
Information Request No. 16: (Wiliams Direct, p. 11) Please provide a list of the 81
CLECs with interconnection agreements in 2009.
Information Request No. 17: (Wiliams Direct, pp. 11-12) Of the 10 CLECs that opted
into the PAP in 2003, how many collected payments? What percent of total payments did the
top three CLECs (in terms of Tier 1 payments from Qwest) comprise?
Information Request No. 18: (Wiliams Direct, pp. 11-12) Of the 57 CLECs that opted
into the PAP in 2009, how many collected payments? What percent of total payments did the
top three CLECs (in terms of Tier 1 payments from Qwest) comprise?
Information Request No. 19: (Wiliams Direct, p. 12) Please provide all work papers and
supporting documentation to support the statement in Mr. Wiliams direct testimony, p. 12, lines
22-25. If not readily apparent from the documentation, please explain how Qwest arrived at the
result from the information provided.
Information Request No. 20: (Wiliams Direct, p. 13-14) Please provide all work papers
and supporting documentation to support the statement in Mr. Willams direct testimony, p. 13,
lines 14-18 and page 14, Table 1. If not readily apparent from the documentation, please explain
how Qwest arrived at the result from the information provided.
Information Request No. 21: (Wiliams Direct, p. 14) Please explain why Section 13.3
(and subpars) ofthe Idaho PAP does not alleviate Qwests concerns regarding its "due process
rights."
Information Request No. 22: (Wiliams Direct, p. 15) Please explain how Qwests
statement that "a handful of the PIDs and products represent the vast majority (e.g., over 90
percent) of the payment issues" "underscores the fact" that the PIDs are unecessarily complex?
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Information Request No. 23: (Willams Direct, p. 16) Please reconcile Qwests statement
on page 16, that $30,000 in payments were generated in 2009, with Qwests statement on page
11 that $14,000 in payments were generated in 2009.
Information Request No. 24: (Willams Direct, p. 16) Please provide all supporting
documentation and work papers that demonstrate that half of the PIDs that met their standards
were significantly better than standard as stated by Mr. Wiliams on page 16, lines 9 - 14 of his
testimony.
Information Request No. 25: (Wiliams Direct, p. 16) Please provide all supporting
documentation and work papers that demonstrate that 27 percent of parity measures in 2009
indicated superior performance as claimed by Mr. Willams on page 16, lines 22-23 of his
testimony.
Information Request No. 26: (Wiliams Direct, p. 16-17) Please identify the one percent
of benchmark measures that failed the standard and generated over $17,000 in payments in 2009.
Information Request No. 27: (Wiliams Direct, p. 17) Does Mr. Wiliams understand the
concept of Type 1 and Type 2 errors? If so, please explain the difference.
Information Request No. 28: (Wiliams Direct, p. 17-18) Is Mr. Wiliams' testimony on
pages 17 and 18 discussing Type 1 or Type 2 statistical errors? Does Mr. Wiliams' testimony
discuss Type 2 statistical errors?
Information Request No. 29: (Willams Direct, p. 20) Please provide all documentation
and work papers that supports the statement that the cost to maintain the measurement and
monitoring ofPIDs is over $1 millon dollars a year.
Information Request No. 30: (Wiliams Direct, p. 20) Please provide an estimate of the
amount of expense of maintaining and monitoring the PIDs that would be avoided if Idaho were
to adopt Qwests "QPAP II" proposal.
Information Request No. 31: (Wiliams Direct, p. 25) Please provide all work papers and
calculations used to determine the "superior" benchmark standards contained in QPAP II.
Information Request No. 32: (Wiliams Direct, pp. 27-28) Please explain the differences
between the Idaho PAP and "QPAP II" for each section identified in Table 2 of Mr. Wiliams'
direct testimony.
Information Request No. 33: (Wiliams Direct, pp. 28-29) Please provide a redlined copy
of the changes in the PIDs Qwest is proposing as a par of "QPAP II" as summarized in Table 3
of Mr. Wiliams' direct testimony.
Information Request No. 34: (Wiliams Direct, p. 30) Please provide calculations ofPID
results and payments for the past three years assuming Qwest's proposed "QPAP II" were in
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place. Please provide all background fies so that the differences measures and payment results
can be replicated by Integra.
Information Request No. 35: (Wiliams Direct, p. 32) Under Qwests proposed "QPAP
II" can performance credits apply across PIDs? (For example, can a performance credit in
installation be applied against a performance payment in repair?)
Information Request No. 36: (Wiliams Direct, p. 32) Under Qwests proposed "QPAP
II" can performance credits apply across 2-wire digital loops and DS 1 loops?
Information Request No. 37: (Willams Direct, p. 32) Under Qwests proposed "QPAP
II" can performance credits apply between resale and unbundled product sets? (For example,
can credits in resale digital services offset performance payments for 2-wire digital loops?)
Information Request No. 38: (Wiliams Direct, p. 33) Please explain the rationale for
placing sub-loop unbundling in the "analog" category.
Information Request No. 39: (Wiliams Direct, p. 36) Please identify all PIDs and
products for which there exist Tier 2 payment possibilities under the curent Idaho PAP, but for
which there are no Tier 1 payment possibilities. For each PID identified, please explain how
Qwest treats this PID in its proposed "QPAP II" and the rationale for treating it this way.
Information Request No. 40: (Wiliams Direct, p. 40) Please provide all documentation
and work papers to support the statement in Mr. Wiliams' direct testimony, p. 40, "In the seven
years since the PIDs began, these distinctions have not been found to be significant."
Information Request No. 41: (Willams Direct, p. 40) When Mr. Wiliams states these
distinctions have "not been found," who specifically is he referring to that has made this
determination? If Mr. Willams is referring to a state Commission or FCC, please provide a
reference to the order to which Mr. Willams refers.
Information Request No. 42: (Wiliams Direct, p. 40) Please explain why a statistical
weighting of results is necessary. Why can't results simply be aggregated into a single measure?
Information Request No. 43: (Wiliams Direct, pp. 41-42) Please provide monthly
payment results, for the past three years, for each product contained in the PIDs listed in Table 4
of Mr. Wiliams direct testimony, that would have resulted had Qwests proposed aggregations
been in place during that timeframe.
Information Request No. 44: (Wiliams Direct, p. 45) Would any ofthe PIDs in the
reinstatement / removal process have generated a payment in Idaho, during the time the
reinstatement / removal process has been in place, if the PIDs were included in the Idaho PAP,
but not par of a reinstatement / removal process? If so, please identify the PID(s), the payment
it would have generated, and the month in which the payment would have been made.
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Information Request No. 45: (Wiliams Direct, pp. 51-52) For the past three years, please
provide the monthly totals for numbers ported from Qwest to CLECs and from CLECs to Qwest.
Information Request No. 46: (Wiliams Direct, pp. 51-52) For the past three years, please
provide the monthly totals for LIS trunks ordered from Qwest by CLECs and the number of
trunks ordered from CLECs by Qwest.
Information Request No. 47: (Wiliams Direct, p. 58) Please provide the monthly
payments that would have occurred, for the past three years, assuming Qwest s proposal to use
"Res and Bus POTS" as the retail analog instead of "ISDN-BRI" for the "OP-n" and "MR-n"
measures.
Information Request No. 48: (Wiliams Direct, p. 58) Please provide the monthly
payments that would have occurred, for the past three years, assuming Qwest s proposal for MR-
8 were in place.
Information Request No. 49: (Wiliams Direct, Exhibit No.1, § 1.3) What is the purpose
ofthe restriction listed as (1) in § 1.3 of Qwests proposed "QPAP-II?" What CLECs that have
curently opted into the QPAP would this provision eliminate QPAP-II's availability?
Information Request No. 50: (Wiliams Direct, Exhibit No.1, § 2.3) If the Idaho
Commission were to approve Qwests QPAP-II proposal, how long does Qwest estimate it
would take to fully implement the measurements in attachment I?
Information Request No. 51: (Wiliams Direct, Exhibit No.1, § 2.4.2 and subpars) Are
"superior service" credits eared for PIDs that are currently not payment eligible, but subject to
the reinstatement/removal process?
Information Request No. 52: (Willams Direct, Exhibit No.1, § 3.1.1.1) Can
performance credits from one market category be used to offset performance payments from
another market category?
Information Request No. 53: (Wiliams Direct, Exhibit No.1, § 3.3.1.2) Please provide
an example using a benchmark measure of how this calculation would work.
Information Request No. 54: (Wiliams Direct, Exhibit No.1, § 3.3.1.3) Does the last
sentence of this section mean that the one allowable miss provision only applies for OP-5A and
OP-5B when there is exactly one order with trouble?
Information Request No. 55: (Willams Direct, Exhibit No.1, § 3.3.2.4) Does the section
describing the permutation test describe how Qwest actually performs the test today under the
Idaho PAP?
Information Request No. 56: (Wiliams Direct, Exhibit No.1, § 3.3.3.2) What is the
rationale for using a Z value of 1.645 rather than the z-values in table I?
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Information Request No. 57: (Willams Direct, Exhibit No.1, § 3.3.3.2) Ifthe
benchmarks are "substitutes for conformance thresholds that would otherwise be represented by
critical-z values," (Wiliams Direct, p. 24) what is the rationale for using the benchmark +/- 2 *
critical value, rather than +/- 4 * critical value?
Information Request No. 58: (Wiliams Direct, Exhibit No.1, § 3.5.1.3, Table 2) Please
explain the difference between "Per Measurement Cap, Measurement Group" as used in the
Idaho PAP, table 2 and "Per-PID Caps" as used in the Qwest proposed "QPAP II" table 2.
Information Request No. 59: (Wiliams Direct, Exhibit No.1, § 3.5.2, Table 2A) In
Qwests proposed "QPAP II" can Qwest generate credits for BI-3A?
Information Request No. 60: (Wiliams Direct, Exhibit No.1, § 3.5.3.1) If a CLEC
requests a specific collocation due date and does not desire collocation be delivered on an earlier
date, what benefit is it to the CLEC for Qwest to attempt to deliver the collocation earlier? In
other words, why should Qwest get bil credits for situations that do not provide superior service
to the CLEC?
Information Request No. 61: (Wiliams Direct, Exhibit No.1, § 4.1.2) How can the "%
difl' be greater than 100%?
Information Request No. 62: (Willams Direct, Exhibit No.1, § 5.4) What is Qwests
rationale for withholding QP AP II payments for unpaid biling related to disputed amounts?
Information Request No. 63: (Wiliams Direct, Exhibit No.1, § 5.5) What is Qwests
rationale for proposing to adjust UNE biling in non-Idaho states for payments related to Idaho?
Information Request No. 64: (Wiliams Direct, Exhibit No.1, § 6.4) Please explain
Qwests definition of "dumping" as used in par (2) of § 6.4. How wil Qwest measure this?
How does Qwest intend to implement this section of the QP AP?
Information Request No. 65: (Wiliams Direct, Exhibit No.1, §§ 6.2.2 & 6.5) Please
explain how the statement that Qwests proposed "QPAP II" "is not intended to foreclose other
non-contractual legal and non-contractual regulatory claims and remedies" (§ 6.2.2) is consistent
with the provision which states, "CLEC waives any causes of action based on a contractual
theory of liability, and any right of recovery under any other theory ofliabilty..." (§ 6.5).
Information Request No. 66: (Wiliams Direct, Exhibit No.1, § 7.2) Is it Qwests
position that the Idaho Commission has to approve elimination or replacement of the "QPAP II"
upon expiration of the term?
Information Request No. 67: (Willams Direct, Exhibit No.1, Attachment 1) For each
measure in attachment 1, please identify if the measure is different from the measure in the Idaho
PAP. If the measure is different, please provide three years of monthly data contrasting the
QPAP II measured PID to the Idaho PAP measured PID.
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Information Request No. 68: (Wiliams Direct, Exhibit No.1, Attachment 1, GA-l)
Please explain the rationale and impact of the "scheduled up time" bullet under "description." If
this impacts the PID measurement, provide three years of monthly data contrasting the QPAP II
measurement to the Idaho PAP measurement.
Information Request No. 69: (Wiliams Direct, Exhibit No.1, Attachment 1, PO-2) Are
"service/element (product) codes" (QPAP II) the same as "product codes" (Idaho PAP)?
Information Request No. 70: (Wiliams Direct, Exhibit No.1, Attachment 1, PO-3)
Please explain the rationale and impact of the change to the "with hours: minutes reporting"
bullet under "description" of QPAP II compared with the Idaho PAP. If this impacts the PID
measurement, provide three years of monthly data contrasting the QPAP II measurement to the
Idaho PAP measurement.
Information Request No. 71: (Wiliams Direct, Exhibit No.1, Attachment 1, PO-3) Is it
correct that in QP AP II, Qwest is eliminating auto rejections from the measure?
Information Request No. 72: (Wiliams Direct, Exhbit No.1, Attachment 1) Please
provide a redline comparison of 14-State 271 PID Version 9.0 and Exhibit No.1, Attachment 1.
If a redline comparison is not available, please list every change in PID between these two
documents.
Information Request No. 73: (Wiliams Direct, Exhibit No.1, Attachment 1, PO-5)
Please explain the rationale and impact ofthe change in the purose to eliminate ASRs in QP AP
II. If this impacts the PID measurement, provide three years of monthly data contrasting the
QP AP II measurement to the Idaho PAP measurement.
Information Request No. 74: (Willams Direct, Exhibit No.1, Attachment 1, PO-20)
What is the difference between "Services and Elements Reporting" as used in QP AP-2 and
"Product Reporting" as used in the current PIDs?
Information Request No. 75: (Wiliams Direct, Exhibit No.1, Attachment 1, OP-3) What
is the value to the CLEC of having Qwest deliver a service prior to the CLEC requested due
date? What is the rationale for counting service delivered early to a CLEC, who does not desire
early delivery, as part of the equation for "superior service?"
Information Request No. 76: (Wiliams Direct, Exhibit No.1, Attachment 1, OP-3)
Please explain the rationale for changing 4-wire loops from a parity measure in "QPAP II" from
a benchmark measure in the current PIDs?
Information Request No. 77: (Wiliams Direct, Exhibit No.1, Attachment 1, OP-4)
Please explain the rationale for changing 4-wire loops from a parity measure in "QP AP II" from
a benchmark measure in the current PIDs?
Information Request No. 78: (Wiliams Direct, Exhibit No.1, Attachment 1, MR-8)
Please explain the rationale for adding the four bullets ("Non Qwest caused troubles..,"
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"Installation reports..," "Repeat Reports..," and "Repair trouble reports..." to the Exclusions of
MR-8. Explain the impact of each exclusion and provide thee years of monthly data contrasting
the QPAP II measurement to the Idaho PAP measurement of this PID.
Dated: September 20,2010
/s/ Douglas Denney
Douglas Denney
Company Representative
1201 NE Lloyd Blvd, Suite 500
Portland, OR 97232
Telephone: [phone]
Fax: [phone]
dkdenneyiiintegratelecom.com
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