Response to 3rd USW Motion.doc

CHERI C. COPSEY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5142

Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983

Attorney for the Commission Staff

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE INVESTIGATION TO DETERMINE AN APPROPRIATE COST MODEL USING FORWARD-LOOKING ECONOMIC COSTS FOR CALCULATING THE COSTS OF BASIC TELECOMMUNICATION SERVICES IN IDAHO
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CASE NOS. GNR-T-00-2
GNR-T-97-22

STAFF RESPONSE TO THIRD U S WEST MOTION FOR EXTENSION OF TIME AND STAFF REQUEST TO CHANGE CAPTION

IN THE MATTER OF THE INVESTIGATION TO ESTABLISH THE IDAHO NON-RURAL UNIVERSAL SERVICE FUND AS REQUIRED BY IDAHO CODE § 62-610A THROUGH F.
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On December 19, 1997, the Commission opened a docket to analyze cost models and adopt a forward-looking cost model as required by Idaho Code § 62-610F (Case No. GNR-T-97-22). On January 18, 2000, the Commission opened another docket (Case No. GNR-T-00-2) to establish and implement the new Idaho Non-Rural USF (now called the Idaho High Cost Fund by the agreement of the parties) and consolidated it with GNR-T-97-22 for the purpose of hearing and scheduling. Order No. 28261.
On May 17, 2000, in response to a Motion for Extension of Time to File Testimony filed by U S WEST, the Commission issued Order No. 28381 granting an extension and changing the dates.
On June 6, 2000, U S WEST filed a second Motion for Extension of Time to File Testimony. No party objected. On June 20, 2000, the Commission granted U S WEST’s motion and set the date for filing Rebuttal Testimony for all parties as July 12, 2000. Order No. 28416. All other dates remained the same.
On July 6, 2000, U S WEST filed a third Motion for Extension of Time to File Testimony requesting that the date for Rebuttal Testimony be moved to August 7, 2000. U S WEST represented that it had contacted the various parties regarding its motion. In support of its motion, U S WEST stated that there were on-going discussions which may narrow the issues for trial. Staff agrees. Furthermore, U S WEST began its deposition of Staff witness Dr. Ben Johnson on Friday, June 30, 2000, and that deposition is not completed.
The Commission Staff does not object to an extension provided all parties are also granted the same extension.
Rebuttal testimony is presently due July 12, 2000, and the technical hearing is scheduled to begin August 22, 2000. Commission Staff agrees with U S WEST that there is a possibility that the parties may be able to narrow the issues for hearing and, therefore, an extension makes sense and is in the public interest. At this time, it does not appear that a change in the hearing dates is required.
In addition, the Commission Staff requests that the Commission order that the caption for GNR-T-00-2 be changed to reflect the parties’ agreement that this new fund should be called the Idaho High Cost Fund. If the Commission so orders, the new caption would read as follows:
IN THE MATTER OF THE INVESTIGATION TO ESTABLISH THE IDAHO HIGH COST FUND AS REQUIRED BY IDAHO CODE § 62-610A THROUGH F.
Respectfully submitted this day of July 2000.

Cheri C. Copsey
Deputy Attorney General

STAFF RESPONSE TO U S WEST THIRD
MOTION FOR EXTENSION OF TIME AND
REQUEST TO CHANGE CAPTION
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