20090427Integra to QWE 1-5.pdf

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TELECOM ;q EC:E li Ld r,
Integra Telecom
6160 Golden Hills Drive
Golden Valley, MN 55416
ww.integratelecom.com
iOßq ~PR 21 ~t~ 9: 38
April 24, 2009
Via Overnight Delivery
Jean D. Jewell, Secretar
Idaho Public Utilties Commission
472 West Washington
Boise, ID 83702-5983
RE: Docket No. QWE- T -08-07
Dear Ms. Jewell:
Enclosed for filing per IPUC Rule of Procedure 229, are thee copies of Integra's First
Set of Discovery Responses to Qwest. The highly confdential material will be provided
directly to Qwest, consistent with the Protective Agreement in this matter.
Please feel free to contact me should you have any questions.
Sincerely,
~-- %w€hpL
Æ~~. KowalczykLegal Secreta an Reguatry Assistt
Integra Telecom
763-745-8465 (Direct)
763-745-8459 (Dept. Fax)
j ili.kowalczyk(ßintegratelecom.com
Enclosures
cc: See Attched Certificate of Service
CERTIFICATE OF SERVICE
I hereby certify that three tre and correct copies of the foregoing Integra's~~Set of
Discovery Responses to Qwest were filed on April 24, 2009, with: b PR 27 Ar, 9: 38
VIA OVERNGHT MA:
Jean D. Jewell
Idao PUC
472 West Washington Street
Boise, il 83702
Telephone: [phone]
Fax: [phone]
and served on April 24, 2009 upon the individuals listed below. (Highly Confidential
information is being separately served via overnight delivery on any Qwest individual(s) that
have signed the relevant protective agreement signatue page.)
VI EMAL:
Mar S. Hobson
999 Main, Suite 1103
Boise, il 83702
Telephone: [phone]
Mary.hobsonfaqwest.com
Adam L. Sherr
Corporate Counsel
Qwest Corporation
1600 7th Avenue, Room 3206
Seattle, WA 98191
Adam.sherr(iqwest.com
Michel Singer-Nelson
Associate General Counsel
360networks
867 Coal Creek Circle, Suite 160
Louisvile, CO 80027
mnelson(a360.net
Weldon Stutzan
Deputy Attorney General
Idao Public Utilties Commission
472 West Washington
P.O. Box 83720
Boise,ID 83720-0074
Weldon.stutzmanfapuc.idaho.gov
Alex Duare
Alex. Duartecægwest.com
:dn.
. Kowalczyk
egal Secreta and Regulatory Assistat
Integra Telecom
.':¡-t"""d j
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSiOPU9 APR 27 AM 9: 38
IN THE MATTER OF QWEST
CORPORATION'S PETITION FOR
APPROVAL OF NON-IMP AID WI
CENTER LISTS PURSUANT TO THE
TRIENNIAL REVIEW REMA ORDER
Case No. QWE- T -08-07
Integra's First Set of Discovery Responses
to Qwest
GENERA OBJECTIONS TO ALL DATA REQUESTS
i. Integra objects to the Requests to the extent they are vague, over-broad
and/or unduly burdensome.
2. Integra objects to the Requests to the extent they seek information subject
to the attorney-client privilege, work product doctrie, or any other privilege recogned
by the State of Idao and inormation tht is tre secret, confdential, sensitive,
competitive in natue or proprieta.
3. Integra objects to the Requests to the extent that they seek inormation that
is not relevant or reasonably calculated to lead to the discovery of adssible evidence.
4. Integra objects to the Requests to the extent that they seek a legal
conclusion.
ADDITIONAL OBJECTIONS
Subject to, and without waiving, the foregoing objections, Integr provides the
following additional question specific objections.
Integra's Responses to Qwest's i st Set Data Requests - i -
DATA REQUESTS
1. For each data request issued by Qwest in ths case, identify (as defied above) the
person or persons responsible for the answer/response to the request.
Response:
Douglas Denney is the respondent to all data requests below.
Integra's Responses to Qwest's 1 st Set Data Requests - 2-
2. As of December 31, 2007, please provide the followig pert to your any of
your business operations in Idaho:
(a) a detaled list of all servces obtaed from Qwest that were connected and in
service on that date includig but not limited to QPP, QLSP, Unbundled loops (DSO,
DSl, DS3), and EELs; and
(b) the Qwest wire center in which the services identified in Request 2(a) were
located.
Additional Objection (4/10/2009):
(a) Integra objects to ths request as it is unduly burdensome, seeks inormation
that should aleady be in Qwest's possession (Qwest should know what it sells
to Integra), and requests an anysis tht has not been performed at ths tie.
(b) Integra objects to ths request as it is unduly burdensome, seeks information
that should already be in Qwest's possession (Qwest should know where it
sells to Integra), requests a work product that does not exist at ths time, and
requests inormation that is irelevant to ths proceeding.
Response (4/24/2009):
Subject to and without waiving the above objections, as a result of Qwests diect
testimony filing tht for the fit time in ths matter attempts to rely solely upon business
lines to support a clai of non-impaient for DS3 loops in the Boise Main
(BOISIDMA) wire center, Integra has underten an analysis that is in par responsive to
ths request. In the two wie centers at issue in ths case, Boise Main (BOISIDMA) and
Boise West (BOISIDWE), Integra has confed tht it purchaed 2-wie loops, and DSI
loops to serve customers in these wie centers. Integra is not aware of purchaing UNE-
Integra's Responses to Qwest's 1st Set Data Requests - 3-
P, QPP, QLSP, DSI EELs, DS3 loops or DS3 EELs to serve customers with these two
wire centers.
Integra's Responses to Qwest's 1 st Set Data Requests - 4-
3. Please provide the circuit id for each Unbundled Loop and each EEL identified in
response to Request 2(a).
Additional Objection (4/10/2009):
Integra objects to ths request as it is unduly burdensome, seeks inormation that should
already be in Qwest's possession (Qwest should know the circuit ID of the elements it
sells to Integra), requests an analysis that has not been pedormed at ths time, and
requests information that is neither relevant nor likely to lead to the discovery of
admssible evidence (e.g. there are only two wie centers at issue in ths proceeding).
Response (4/24/2009):
Subject to and without waiving the above objections, as a result of Qwest's diect
testimony filing tht for the fist time in ths matter attempts to rely solely upon business
lines to support a claim of non-impaient for DS3 loops in the Boise Mai
(BOISIDMA) wie center, Integra has underten an analysis tht is in par responsive to
ths request. Integra is not aware of purchasing EELs to serve cusomers with the Boise
Mai or Boise West wie center. Highy confdential attchment A, "A - Highy
Confdential Circuit Inormation.xls," contas a list of circuit IDs that Integra was able
to identify in the Boise Mai and Boise West wie center. Ths attchment also identifies
the UN associated with these circuit IDs (i.e. 2-wie loop or DS 1 loop) and the wire
center associated with these circuit IDs.
Integra's Responses to Qwest's 1 st Set Data Requests - 5 -
4. Please provide the telephone number for each QPP and each QLSP identified in
response to Request 2(a).
Additional Objection (4/10/2009):
Integra objects to ths request as it is unduly burdensome, seeks inormation that should
already be in Qwests possession (Qwest should know the circuit ID of the elements it
sells to Integra), requests an anysis tht ha not been performed at ths time, and
requests inormtion that is neither relevant nor likely to lead to the discovery of
admissible evidence (e.g. there are only two wie centers at issue in ths proceeding).
Without waiving the objection, should Integra perform ths anysis durg the course of
this case, it will provide the information.
Response (4/24/2009):
Subject to and without waivig the above objections, as a result of Qwest s diect
testimony filing tht for the first time in this matter attmpts to rely solely upon business
lines to support a claim of non-impairent for DS3 loops in the Boise Main
(BOISIDMA) wie center, Integra has underten an anysis tht is responsive to ths
request. Integra is not aware of purchasing QPP or QLSP to serve customers with the
Boise Mai or Boise West wie centers.
Integra's Responses to Qwest' s 1 st Set Data Requests - 6-
Dated this 24th day of April, 2009
Douglas K. Denney
Director, Costs & Policy
6160 Golden Hils Drive
Golden Valley, MN 55416
763-745-8462 (Direct)
763-745-8459 (fax)
Company Representative, Integra
Integra's Responses to Qwest's 1 st Set Data Requests -7 -