BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF COLORADO

Ruby Ranch Internet Cooperative Association,

Petitioner,

DOCKET NO. 01B-493T

v.

Qwest Corporation,

Respondent.

INTERROGATORIES

The Ruby Ranch Internet Cooperative Association (“Coop”), pursuant to Colorado Commission Rule 77(b), requests that Qwest Corporation (“Qwest”) answer the following interrogatories within ten days. These interrogatories are made with respect to definitions provided herewith.

1. For carriers providing SDSL over copper pairs rented from Qwest, state the number of claims which Qwest has made under Insurance Policies arising out of the provision of SDSL service, and for each such claim give its date and dollar amount and describe the claim and the alleged harm to Qwest’s network.
2. Identify, in technical detail, the alleged risks to Qwest and/or its network allegedly presented by the Proposed Service.
3. Identify, in technical detail, the alleged risks to Qwest and/or its network allegedly presented by the Proposed Service that allegedly exceed the risks to Qwest and/or its network presented by POTS service.
4. Identify, in technical detail, the alleged risks to Qwest and/or its network allegedly presented by the Proposed Service that allegedly exceed the risks to Qwest and/or its network presented by LADS service.
5. Identify, in technical detail, the alleged risks to Qwest and/or its network allegedly presented by the Proposed Service that allegedly exceed the risks to Qwest and/or its network presented by alarm line service.
6. Identify the manufacturer of the Crossbox.
7. Identify the manufacturer of the one-hundred-pair screw terminal blocks within the Crossbox.
8. State Qwest’s present cost for a one-hundred-pair screw terminal of the type found within the Crossbox.
9. State Qwest’s basis for its $1707 Quote Preparation Fee.
10. Identify all cost or other documents, if any, substantiating Qwest’s $1707 Quote Preparation Fee.
11. State Qwest’s basis for its $126 non-recurring charge for installation of a Subloop.
12. Identify all cost or other documents, if any, substantiating Qwest’s $126 non-recurring charge for installation of a Subloop.
13. State Qwest’s basis for its requirement that the Coop purchase an Insurance Policy.
14. Identify all cost or other documents, if any, substantiating Qwest’s requirement that the Coop purchase an Insurance Policy.
15. Identify the person or persons whom Qwest intends to call to give testimony regarding the basis for its $1707 Quote Preparation fee.
16. Identify the person or persons whom Qwest intends to call to give testimony regarding the basis for its $126 non-recurring charge for installation of a Subloop.
17. Identify the person or persons whom Qwest intends to call to give testimony regarding the basis for its requirement that the Coop purchase an Insurance Policy.

____________________

Carl Oppedahl, Director

Ruby Ranch Internet Cooperative Association