Subject: Request to Compel Qwest to Establish Interconnection Per MN Interconnection Agreement on an Expedited Basis

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Curtiss Wikstrom, President 212 South Main Street, Karlstad, MN 56732 (218)436-5242 curtw@wiktel.com Minnesota Public Utilities Commission September 17, 2010 121 7th Place.

1 Curtiss Wikstrom, President 212 South Main Street, Karlstad, MN (218) Minnesota Public Utilities Commission September 17, th Place., Suite 350 Saint Paul, MN Submitted via -Filing Subject: Request to Compel Qwest to stablish Interconnection Per MN Interconnection Agreement on an xpedited Basis Dear Commissioners: Wikstrom Telephone Company, Inc. is a competitive local exchange carrier authorized by the Commission to provide service to number of northern Minnesota communities in Docket No. P-432/NA The Commission approved an interconnection agreement with Qwest in Docket No: P-432,421 /IC Wikstrom requested interconnection with Qwest in Thief River Falls, Minnesota using existing meet point facilities. Trunk groups would be established to the Qwest access tandem and host switch serving the Minnesota exchanges where Wikstrom is authorized to compete. The Qwest switch serving those exchanges is located in Grand Forks North Dakota. Qwest refused to process Wikstrom s interconnection request, claiming an agreement approved by the North Dakota Public Service Commission is required so Qwest might apply ND non-recurring charges. The non-recurring charges in question are worth a few hundred dollars. Wikstrom asks the Commission to compel Qwest to establish interconnection with Wikstrom pursuant to the rates, terms, and conditions of the agreement approved by the Commission. In June, 2010 Wikstrom identified to Qwest the interconnection facilities which would be used to establish local interconnection trunks serving Minnesota exchanges. Qwest refused to process the request stating Wikstrom must first obtain a North Dakota interconnection agreement and explaining ND non-recurring charges would apply because the Qwest switch is located in North Dakota. Qwest rejected Wikstrom s offer to pay the non-recurring charges pursuant to its Minnesota agreement. Qwest also rejected Wikstrom s suggestion that the MN agreement be filed with the ND Commission on an informational basis.

2 Wikstrom Complaint 9/17/10 Page 2 of 2 Wikstrom has repeatedly asked Qwest to provide a legal or regulatory basis or precedent to support its demand that Wikstrom obtain a ND agreement. On August 25 th Qwest acknowledged there is no regulatory issue, rather the issue rests with Qwest practices which require a ND contract to support billing of non-recurring charges for its switch located in North Dakota. Wikstrom believes the Commission retains exclusive authority over Qwest interconnection matters when they relate exclusively to Minnesota customers and Minnesota exchanges, when network interconnection occurs within Minnesota, and irrespective of where the Qwest switch is physically located. Wikstrom asks the Commission to enforce the terms of the Minnesota agreement by compelling Qwest to process Wikstrom s interconnection request without further delay. If you have any questions regarding this matter please call me or Tom Burns at Sincerely, /s Curtiss Wikstrom Curtiss Wikstrom Attachments: (3) cc: Jason Topp (Qwest)

3 Wikstrom Complaint Attachment 1 The following is provided as required by the Commission Rules: In support of Subpart 1: The parties to the complaint : Complainant: Respondent: Wikstrom Telephone Telephone, Inc. Curtiss Wikstrom 212 South Main St Karlstad, MN Qwest Communications Jason Topp 200 South 5 th St. Room 395 Minneapolis, MN The violation: Qwest has violated Section 1.3 of the interconnection agreement ( Agreement ) approved by the Commission by refusing to process Wikstrom s interconnection requests. Section 1.3 states: This Agreement sets forth the terms, conditions and pricing under which Qwest will provide to CLC network Interconnection, and, ancillary services, within the geographical areas in which Qwest is providing local xchange Service at that time, and for which Qwest is the incumbent Local xchange Carrier within the State of Minnesota, for purposes of providing local Telecommunications Services. Qwest states its procedures for establishing billing account numbers require a North Dakota interconnection agreement in order to bill Wikstrom for interconnection at a ND switch, at ND rates, even though the exchanges served are wholly within Minnesota and subject to the Commission. Further, Qwest violated Section 7.4 (Ordering) of the Agreement by refusing to provide Wikstrom with the Carrier Facility Assignment (CFA) identification needed so Wikstrom might place the order for Local Interconnection Service trunks. Qwest processes require Wikstrom to identify the CFA of the facilities to be used. Wikstrom has done so. Qwest processes further require when an ILC meet point facility is used, a new CFA is created (T1UZ CFA) and used as the CFA. Qwest has refused to provide the T1UZ CFA. Since Qwest ordering systems validate the CFA (see Section ), Wikstrom cannot place complete the ASR for LIS trunks. Attachment 2 depicts the requested network interconnection.

4 Wikstrom Complaint Attachment 2 Network Interconnection Requested Qwest and Wikstrom (ILC) networks are interconnected at a fiber splice meet point in Thief River Falls, MN. The Wikstrom Karlstad host switch (KRLSMNXXKDS0) serves the Holt MN exchange (and others). Qwest serves the Thief River Falls exchange (and others) from a switch located in Grand Forks, ND (GDFRNDBC77G). Holt-Thief River Falls AS traffic is exchanged over an AS group between these switches. A second group connects Karlstad to the toll partition GDFRNDBC12T of the switch. Qwest has refused to replicate this arrangement as LIS trunks for Wikstrom pursuant to the Agreement.

5 Wikstrom Complaint Attachment 2 Network Interconnection Requested The above diagram depicts the requested interconnection. Qwest, Wikstrom, CLCs, and wireless carriers serve the Thief River Falls exchange. Wikstrom will establish one group for exchange of Thief River Falls Qwest traffic (LIS Local) and a second group for exchange of traffic with wireless carriers, CLCs, and terminating intralata toll traffic (LIS Toll). The LIS Toll group will also serve other Minnesota exchanges which subtend the Grand Forks access tandem.

6 Attachment 3 AFFIDAVIT OF SRVIC I, Thomas Burns, state that on September 17, 2010, filed this document using eservice () to the following persons: Dr. Burl W. Haar xecutive Secretary Linda Chavez Minnesota Department of Commerce Curt Nelson Assistant Attorney General Jason Topp Qwest Corporation

STATE OF MINNESOTA BEFORE THE PUBLIC UTILITIES COMMISSION

STATE OF MINNESOTA BEFORE THE PUBLIC UTILITIES COMMISSION In the Joint Petition of TCG Minnesota, Inc. ) and Teleport Communications America, LLC. ) Docket No. for Approval for Internal Merger ) I. Introduction