STATE OF MINNESOTA LORI SWANSON

BREMER TOWER. SUITE 900 445 MINNESOTA STREET ST. PAUL, MN 55101-2127 TELEPHONE: [651) 297-1075

OFFICE OF THE ATTORNEY GENERAL

ATTORNEY GISNEiKAL

September 9, 2009

Jason D. Topp Qwest Corporation 200 South Fifth Street Minneapolis, MN 55402 Re:

In the Matter of a Petition by Qwest Corporation for Approval of its Alternative Form of Regulation Plan Docket No. P-421/AR-09-790

Dear Mr. Topp: Enclosed herein and served upon you please find the Office of the Attorney General's Information Requests Nos. 11-17. By copy of this letter all panics have been served. An affidavit of service is also enclosed. Sincerely. s/William T. Slamets WILLIAM T. STAMETS Enclosures cc: Parties on Service List

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RE:

In the Matter of a Petition by Qwest Corporation for Approval of its Alternative Form of Regulation Plan Docket No. P-421/AR-09-790

Dr. Burl W. Haar Executive Secretary MN Public Utilities Commission 121 Seventh Place East, Suite 350 St. Paul, MN 55101

Kim Wagner _ Eschelon Telecom, Inc . 730 Second Avenue South Suite 900 Minneapolis, MN 55402

Mark J. Ayotte Briggs and Morgan PA 2200 EDS Center SOS.8th Street Minneapolis, MN 55402

Garth Morrisett Memo Enterprises 693 Delaware Avenue St. Paul, MN 55107

Jason D. Topp Qwest 200 South Fifth Street, Room 2200 Minneapolis, MN 55402

Dan Lipschultz Moss & Barnett 90 South Seventh Street Suite 480 0 Minneapolis, MN 55402

Jeanne Cochran MN Office of the Attorney General 1100 BRM Tower 445 Minnesota Street St. Paul, MN 55101

Anthony S. Mendoza Law Offices of Anthony S. Mendoza. LLC 2088 Randolph Avenue St. Paul, MN 55105

Wauneta Browne AT&T 11425 West 146th Street Olathe, KS 66062

Letty S.D. Friesen AT&T 2535 East 40th Avenue Room B1201 Denver, CO 80205-3601

Linda Chavez MN Department of Commerce 85 Seventh Place East, Suite 500 St. Paul, MN 55101

Jo Ann Hanson Qwest 200 South Fifth Street, Room 220 0 Minneapolis, MN 55402

Adam M. Nathe Gray. Plant, Mooty Law Firm 80 South Eighth Street, Suite 500 Minneapolis, MN 55402

Kevin Saville Citizens/Frontier Communications 2378 Wilshire Boulevard Mound, MN 55364

Julia Anderson Assistant Attorney General 1400 Bremer Tower 445 Minnesota Street St. Paul, MN 55101

James M. Strommen Robert J.V. Vose Kennedy & Graven, Chartered 470 U.s'. Bank Plaza 200 South Sixth Street Minneapolis, MN 55402

Ginny A. Zeller Eschelon Telecom, Inc. Suite 900 730 Second Avenue South Minneapolis, MN 55402

Dennis Ahlers

Joan C. Peterson

Qwest Corporation 200 South Fifth Street, Rm. 2200 Minneapolis, MN 55402

Linda Jensen

Office of the Attorney General 1400 Bremer Tower 445 Minnesota Street St. Paul, MN 55101

Integra Telecom 6160 Golden Hills Drive Golden Vallev. MN 55402

Diane C. Browning, Esq. State Regulatory Affairs Sprint Comm. Co. LP Mailstop KSOPHN 0212-2A411 6450 Spring ParkwayOverland Park, KS 66251 Thomas Bailey Briggs and Morgan 2200 IDS Center 80 S 80th Street Minneapolis, MN 55402

Gregory Merz Gray, Plant, Mooty 500 IDS Center 80 South Eighth Street Minneapolis, MN 55402

VI eg Kearns Churches United in Ministry 102 West Second Street Duluth, MN 55802-2017

Tim L. Lovaasen Communications Workers of America Minnesota State Council 3521 East Lake Street Minneapolis, MN 55406

Julie Tesch Minnesota Agricultural Education Leadership Council 1954 Buford Avenue, Room 320 St. Paul, MN 55108-6197

Shelly L. Eggert Qwest Room 2300 200 S 5th Street Minneapolis, MN 55402

Karen Finstad Hammel Office of the Attorney General 1400 Bremer Tower 445 Minnesota Street St. Paul. MN 55101

Pamela Sherwood TW Telecom Suite 500 4625 West 86 Street Indianapolis, IN 46268

Ron L. Trullinger Qwest Room 2200 200 South 5th Street Minneapolis, MN 55402

Ruth E. Ulvog 9350 Ranch view Lane N Moorhead, MN 55369-4472

Douglas R. Wholey 5 Augusta Lane Dellwood, MN 55110

[email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected]

AFFIDAVIT OF SERVICE RE:

Petition by Qwest Corporation for Approval of its Second Revised Alternative Form of Retail Regulation Plan Docket No. P-421/AR-09-790

STATE OF MINNESOTA COUNTY OF RAMSEY

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I hereby state that on the 9th day of September. 2009, I served Information Requests 1117 of Office of the Attorney General - Residential and Small Business Utilities Division to Qwest Corporation upon all parties listed on the attached service list by email or United States Mail with postage prepaid, and deposited the same in a U.S. Post Office mail receptacle in the City of St. Paul. Minnesota.

s/Rachel Tess Rachel Tess Subscribed and sworn to before me on September 9; 2009 s/JaneJarvincn Notary Public AG:s2506153-v1

OAGNo. 11 State Of Minnesota Office Of The Attorney General Utility Information Request Requested from: JoAnn Hanson Qwest Corporation 200 South Fifth Street Minneapolis, MN 55402

TUC Docket No. P-421/AR-09-790

Requested By: Bill Stamets Telephone: (651) 297-5902

Date of Request: September 9, 2009 Due Date: September 21, 2009

Qwest's Response to INFORMATION REQUEST DOC 001 states that "only customers who do not purchase packages would be impacted by the $1 per month increase." a. Distinguish Qwest's usage of the term "package" and "stand-alone" in its Response to INFORMATION REQUEST DOC 001 and the terms "bundle" (including "customized bundle" or "design your own bundle") and "plan" as used on Qwest's website. b. For purposes of consumers "impacted" by Qwest's proposed rate increase, does usage of the term "package" in Qwest's Response to INFORMATION REQUEST DOC 001 include only local phone service products such as Qwest Choice Home, Qwest Choice Home Plus, Qwest Choice Home 2 Line, and/or Qwest Home Plus 2 Line? c. Describe which (if any) of the following service combinations offered by Qwest would not be "impacted by the $1 per month increase:" i. Basic Phone Service and a Long Distance Plan offered on Qwest's website, ii. Basic Phone Sen-ice and an Internet plan offered on Qwest's website, iii. Basic Phone Service and a Digital TV Package offered on Qwest's website, iv. Basic Phone Service and a Wireless plan offered on Qwest's website.

Response by Title Department Telephone

OAG No. 12

State Of Minnesota Office Of The Attorney General Utility Information Request Requested from: Jo Ann Hanson Qwest Corporation 200 South Fifth Street Minneapolis, iVIN 55402

PUC Docket No. P-421/AR-09-790

Requested By: Bill Stamets (651)297-5902 Telephone:

Date of Request: September 9, 2009 Due Date: September 21, 2009

Qwest's Response to INFORMATION REQUEST DOC 001 states that "only customers who do not purchase packages would be impacted by the $1 per month increase." Does Qwest commit to not increase the price of any packages, plans and/or bundles during the life of the proposed AFOR should the Commission grant Qwest's requested rate increases?

Response by Title Department Telephone

OAG No. 13

State Of Minnesota Office Of The Attorney General Utility Information Request Requested from: JoAnn Hanson Qwest Corporation 200 South Fifth Street Minneapolis, MN 55402

PUC Docket No. P-421/AR-09-790

Requested By: Bill Stamets Telephone: ' (651)297-5902

Date of Request: September 9, 2009 Due Date: September 21, 2009

Recalculate Attachment A to Qwest's Response to INFORMATION REQUEST DOC 001 disaggregating residential line counts into the following categories for the same time periods: a. residential lines subscribing to no Calling Features and no Long Distance Plans. For purposes of this request consider the term "Calling Features" to include Line-Backer. b. residential lines subscribing to Calling Features or Long Distance Plans on an a la carte basis (i.e.. receiving no discounts from Qwest's a la carte rates). c. residential lines subscribing to a Qwest combination offering of local service and Calling Features. d. residential lines subscribing to a Qwest combination offering local service and a Long Distance Plan. e. residential lines subscribing to a Qwest package that contains both Calling Features and a Long Distance Plan. If the total line counts in a. through e. do not match the number of Total Residential lines in Attachment A to Qwest's Response to INFORMATION REQUEST DOC 001, please explain the discrepancy.

Response by Title Department Telephone

OAGNo. 14 State Of Minnesota Office Of The Attorney General Utility Information Request Requested from: JoAnn Hanson Qwest Corporation 200 South Fifth Street Minneapolis, MN 55402

PUC Docket No. P-421/AR-09-790

Requested By: Bill Stamets Telephone: " (651) 297-5902

Date of Request: September 9, 2009 Due Date: September 21, 2009

Does Qwest claim that no customers purchasing local service with Calling Features or a Long Distance Plan on an a la carte basis pay more per month than the consumer would have paid had the customer chosen a Qwest package and/or bundle that includes the relevant elements? For purposes of this request consider the term "Calling Features" to include Line-Backer. If the answer is "no", how many customers have purchased Calling Features or a Long Distance Plan on an a la carte basis that resulted in monthly charges that exceeded a package price offered by Qwest in 2008?

Response by Title Department Telephone

OAG No. 15

State Of Minnesota Office Of The Attorney General Utility Information Request Requested from: Jo Ann Hanson Qwest Corporation 200 South Fifth Street Minneapolis, MN 55402

PUC Docket No. P-421/AR-09-790

Requested By: Bill Stamets Telephone: (651)297-5902

Date of Request: September 9, 2009 Due Date: September 21, 2009

If the Commission approves Qwest1 s proposed rate increases, does Qwest claim that no customers purchasing local service with Calling Features or a Long Distance Plan on an a la carte basis will have new monthly charges that exceed the charges that the consumer would have paid had the customer chosen a currently offered Qwest package and/or bundle? If the answer is "no", how many customers currently purchasing Calling Features or a Long Distance Plan on an a la carte basis would have new monthly charges that exceed a package price offered by Qwest with each allowed $1/month price increase?

Response by Title Department Telephone

OAG No. 16

State Of Minnesota Office Of The Attorney General Utility Information Request Requested from: JoAnn Hanson Qwest Corporation 200 South Fifth Street Minneapolis, MN 55402

PUC Docket No. P-421/AR-09-790

Requested By: Bill Stamets Telephone: (651) 297-5902

Date of Request: September 9. 2009 Due Date: September 21, 2009

Does Qwest proactively inform existing customers when Qwest offers a new service combination (or Qwest reduces rates for an existing combination) that is less expensive than the customer's current service selection (e.g. a la carte pricing)? For purposes of this question, a bill insert describing a package (e.g.. Qwest Home Choice) to all consumers is not considered proactively informing an existing customer.

Response by Title Department Telephone

OAG No. 17

State Of Minnesota Office Of The Attorney General Utility Information Request Requested from: Jo Ann Hanson Qwest Corporation 200 South Fifth Street Minneapolis, MN 55402

PUC Docket No. P-421/AR-09-790

Requested By: Bill Stamcts Telephone: (651) 297-5902

Date of Request: September 9, 2009 Due Date: September 21, 2009

Trade Secret Attachment B to Qwest's Response to INFORMATION REQUEST DOC 001 provides stand-alone residential line counts for each Qwest Minnesota wire center as of June 30, 2009. Provide a revised Attachment B that also includes the total residential lines by wire eenter. Also, please designate each wire center as Metro or Outstate in the revision. Please provide this information in an electronic format appropriate for analysis using Microsoft Excel 2003.

Response by Title Department Telephone