20020909_258.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KJELLANDER
CO MMISSI 0 NER SMITH
COMMISSIONER HANSEN
JEAN JEWELL
RANDY LOBB
DON HOWELL
LYNN ANDERSON
CAROLEE HALL
BIRDELLE BROWN
WAYNE HART
DOUG COOLEY
BEVERLY BARKER
RON LAW
GENE FADNESS
TONYA CLARK
WORKING FILE
FROM:JOE CUSICK
DATE:SEPTEMBER 6, 2002
SUBJECT:QWEST TIME-OF-DAY SERVICE
On August 26, 2002, Qwest wrote the Commission requesting that the Company
be relieved of its obligation to provide free time-or-day service throughout the state. The
origin of the obligation to provide time-or-day service is the Commission s Order No.
21782, in Case No. U-1000-, dated February 24, 1988.
COMMISSION DECISION
Does the Commission wish to release Qwest from its obligation to provide free
time-or-day service?
Joec1(~L
udmemos/time of day dmemo
999 Main Street, 11 th Floor
Boise, Idaho 83702
August 26, 2002
ride t 't!?
Qwest.
Jean Jewell
Secretary
Idaho Public Utilities Commission
P. O. Box 83720
Boise, ill 83720-0074
RE: QWEST REQUEST FOR RELIEF FROM TIME-OF-DAY SERVICE
OBLIGATION IN IDAHO PER ORDER NO, 21782
Dear Ms. Jewell
Qwest requests the Idaho Public Utilities Commission relieve it of the obligation to
provide free time-of-day service in its service territory in Idaho. The origin of the
obligation to provide time-of-day service is the Commission s Order No. 21782, in Case
No. U-1000-, dated February 24, 1988.
Current Situation
Qwest has discovered in the normal course of activities associated with replacement of
the Lewiston central office that the time-of-day announcement equipment located in that
switch is nonfunctional and has been inoperable for some number of months. All eight
Qwest exchanges in northern Idaho are affected by this breakdown; calls to the 1-844-
1111 time-of-day number throughout the northern Idaho service area ring without
answer. Despite this inadvertent and, until now, unrecognized failure ofthe equipment
Qwest has not received consumer complaints that would have lead to more rapid focus on
this problem.
Discussion
Ifl1ecessary, Qwest is willing to comply with the Commission s previously ordered time-
of-day service requirement. However, before ordering equipment! and making the
investment to do so, Qwest wishes to reconfirm whether the Commission continues to
believe that it is appropriate to require Qwest to provide this service. The Commission
should be aware that a major hurdle in the ordering and installation of the replacement
hardware (this issue also affects the current inoperable equipment) is the lack of
certification of this equipment under NEB engineering standards. Such certification
! The cost to replace the current hardware is less than the estimated cost to repair
existing hardware. The minimum order interval for the replacement hardware is 30 days
and the installation interval including testing and turn up could be as long as another 3-
weeks.
relates to the safety, noise, heat and other environmental characteristics of the equipment.
The hardware necessary to provide time-of-day service is so rarely installed in RBOC
switches there is, to Qwest's knowledge , no NEB certified hardware available in the
market. Today, any collocated equipment to be placed in a Qwest central office by
CLEC must be NEB certified. This puts Qwest in the uncomfortable posture of
potentially ordering/installing hardware for time-of-day service that it would not allow a
CLEC to collocate. Indeed, Qwest is unaware that any of its fellow RBOCs continue to
support time-of-day service in their territories, although it may well exist in pockets.
Commission Decision Requested
Qwest requests the Commission acknowledge the major changes in the competitive
landscape since 1988 when it determined that telephone company-provided time-of-day
service was necessary. The Commission does not require CLECs to provide such service
and the Company is unaware of any Idaho CLECs that provide it. Qwest is also unclear
as to whether such service is still provided by the other incumbent local exchange carriers
in the state.
In addition, Qwest requests the Commission consider the many alternative means of
getting 'the time' whether it be watches , cell phones, pagers, pda , lap tops, computer
monitors, telephone LCD displays, directory assistance, etc. The lack of complaints over
the months since the service has been inactive in northern Idaho leads one to question
whether consumer demand justifies the considerable expense to provision and maintain
this service going forward.
Qwest respectfully requests that the Commission relieve it of the requirements found in
Order No. 21782 and allow the discontinuation of Qwest-provided time-of-day service inIdaho.
Please direct Staff or Commission questions on this issue to me on 208-385-8666.