20090414Staff 1-12 to QWE.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 3283
RECEI
iong APR 14 PM 2: 41
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
QWEST CORPORATION FOR APPROVAL
OF NON-IMPAIRED WIRE CENTER LISTS
PURSUANT TO THE TRIENNIAL REVIEW
REMAND ORDER
)
) CASE NO. QWE-T-08-7
)
) FIRST PRODUCTION
) REQUEST OF THE
) COMMISSION STAFF TO
) QWEST CORPORATION
)
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Weldon B. Stutzman, Deputy Attorney General, requests that Qwest Corporation (Company;
Qwest) provide the following documents and information on or before TUESDAY, MAY 5, 2009.
This Production Request is to be considered as continuing, and Qwest is requested to
provide, by way of supplementar responses, additional documents that it or any person acting on
its behalf may later obtain that wil augment the documents produced.
For each item, please indicate the name of the person(s) preparing the answers, along with
the job title of such person(s) and the witness who can sponsor the answer at hearing.
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF TO QWEST 1 APRIL 14, 2009
Request No.1: For Qwests Boise Main and Boise West wire centers in Idaho, please
provide a detailed list of each collocated Competitive Local Exchange Carrer (CLEC) as of
Januar 31, 2009.
Request No.2: For each of the CLECs identified in Request No.1, please identify all
services provided by Qwest as of Januar 31,2009, including but not limited to QPP, QLSP,
Unbundled loops (DSO, DS1, DS3) and EELs.
Request No.3: For each CLEC identified in Request No.2, please provide the circuit
identification for each Unbundled Loop and each EEL
Request No.4: Based upon Qwests response to Request No.1, please describe the
collocation(s) that it has in the Boise Main and Boise West wire centers for each:
a) Type of collocation
b) Equipment in the collocation
Request No.5: Please provide ready-for-service dates for each collocation in Request
NO.4.
Request No.6: Based upon answers to Request No.2, please provide a detailed list (by
wire center) of all fiber loops (including dark fiber).
Request No.7: Is there a commercial agreement curently available to Idaho CLECs for
TELRIC-based interoffce dark fiber on routes for which Qwest has requested forbearance?
Request No.8: If the answer to Request NO.7 is "yes", wil TEL RIC-based dark fiber
agreements be made available to all CLECs if Qwest is granted forbearance?
Request No.9: For each CLEC listed in Request No.1, is there an active electrical power
supply available and being used in each wire center? Are there any CLECs that are not actively
plugged into the electrical equipment in either wire center? If "yes", please provide, by wire
center, a list of those CLECs that are not plugged into the electrical equipment.
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF TO QWEST 2 APRIL 14, 2009
Request No. 10: Please provide, by CLEC, a list of all collocation agreements that have
been cancelled over the past two years. Please list, by CLEC, the number of collocation
agreements entered into for the Boise Main and Boise West wire centers in the past two years?
Request No.1 1: In your initial fiing with the Commission, in footnote 9, you indicate
that you are using December 2003 ARMIS Report 43-08 data for switched business access line
information. Please update all data contained in this, and any subsequent fiings, to reflect Januar
2009 CLEC information, line counts and products purchased.
Request No. 12: Please list by CLEC all unbundled and resold loops.
DATED at Boise, Idaho, this '~ay of April 2009.
n~
Weldon B. Stutzman
Deputy Attorney General
Technical Staff: Carolee Hall
i :umisc:prodreq/qwet08. 7swch
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF TO QWEST 3 APRIL 14, 2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 14TH DAY OF APRIL 2009,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO QWEST CORPORATION, IN CASE NO. QWE-T-08-7,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
MARY S HOBSON
QWEST CORPORATION
999 MAIN ST, STE 1103
BOISE ID 83702
E-MAIL: mary.hobson(igwest.com
ALEX DUARTE
CORPORATE COUNSEL
QWEST CORPORATION
421 SW OAK STREET, STE 810
PORTLAND OR 97204
E-MAIL: alex.duare(igwest.com
MICHEL SINGER-NELSON
ASSOCIATE GENERAL COUNSEL
360NETWORKS (USA) INC
867 COAL CREEK CIRCLE, STE 160
LOUISVILLE CO 80027
E-MAIL: mnelson(i360.net
DOUGLAS K DENNEY
DIRECTOR COSTS & POLICY
INTEGRA TELECOM
730 SECOND AVE SOUTH, STE 900
MINEAPOLIS MN 55402
E-MAIL: dkdenney(iintegratelecom.com
Jo~SECRETAR -=
CERTIFICATE OF SERVICE