HomeMy WebLinkAbout971006.docx
October 6, 1997
Eileen Benner
Government Affairs
Asst. Vice President Idaho
6120 Castle Dr.
Boise, ID 83703
Dear Eileen:
I thought I would provide an update of the status of the discussions in the Commission’s review of the emergency petition filed by MCI and AT&T regarding payphone subsidies (Case No. GNR-T-97-5). There has been a considerable amount of data exchanged and a number of conversations between myself and each of the parties, but as most of this has been informal, I thought it best to summarize my understanding of the current status of the discussions.
In response to the data requests of Staff, MCI, AT&T, U S WEST, GTE and most other utilities provided those parties that had signed the necessary agreements with proprietary information. My analysis of that information indicated the payphone operations of all Idaho LECs were either self supporting, or any deficit that was present was so small that changes to access charges were not appropriate at this time. I informally told MCI and AT&T of my findings and they asked me to look at a model developed by MCI, which they claimed provided a more thorough analysis than I had conducted.
I was provided a copy of the model in August, and based upon the analysis for U S WEST included with the model, again concluded no subsidy existed. In early September, I provided U S WEST, MCI and AT&T a copy of a draft report which included my conclusion that no changes to access charges were appropriate at this time. MCI promptly responded with a revised version of the model, which included significantly greater detail. This model did identify a subsidy for U S WEST.
The basic calculations included in the model did not vary considerably from that of my own analysis, but this model used data from ARMIS reports as inputs, rather than the data provided directly by U S WEST. The ARMIS data differed significantly from the U S WEST data in a number of key elements, which is the primary reason for the different conclusion.
Eileen Benner
October 6, 1997
Page 2
With MCI’s permission I provided U S WEST with a copy of the analysis, including the ARMIS input data, and requested a response as to why the data was different between the two sources and whether the conclusion was accurate. One of the more significant discrepancies was the number of company-owned payphones. U S WEST informally indicated a possible explanation may be the ARMIS data included semi-public pay phones, while the data provided by U S WEST did not. U S WEST requested an opportunity to look into it more thoroughly and indicated they would get back to me.
A few days later, U S WEST indicated discussions/negotiations were being conducted between AT&T/MCI and U S WEST on a corporate-wide level (14 states), and that U S WEST was in the process of preparing forward-looking cost studies for those discussions. They preferred to wait until those numbers were available before responding to my request so that the numbers provided to Idaho could be consistent with those provided to the 14-state discussions. These numbers were expected to be available by mid-October. U S WEST indicated these discussions might result in a corporate-wide settlement of this issue.
In light of these discussions, I indicated a willingness to wait for the corporate-wide numbers. I also indicated that if the parties were trying to resolve this dispute among themselves, I wanted to give those discussions an opportunity to succeed. I suggested it may be appropriate to put the Idaho proceedings on the back burner until the corporate-wide discussions are concluded, one way or the other.
As the Commission’s orders approving the April 15 payphone deregulation tariffs left open the possibility of a refund of any overpayments since April 15, should the Commission ultimately find that further rate adjustments were appropriate, I believe the risk of jeopardizing the corporate-wide negotiations exceeds the risk of a delay in this matter. Therefore, unless I am presented with reasons for proceeding otherwise, I intend to defer any further action on this matter for 45 to 60 days, or until I hear the negotiations have concluded.
I hope this update is useful. Please let me know if my understanding of any of the actions in this case needs to be revised.
Sincerely,
Wayne Hart
Telecommunications Analyst
WH:gdk:i:wpfiles/utelcomm/payslow.ltr
October 6, 1997
Greg Harwood
Davis, Wright, Tremaine
999 Main St.
Suite 911
Boise, ID 83702
Dear Greg:
I thought I would provide an update of the status of the discussions in the Commission’s review of the emergency petition filed by MCI and AT&T regarding payphone subsidies (Case No. GNR-T-97-5). There has been a considerable amount of data exchanged and a number of conversations between myself and each of the parties, but as most of this has been informal, I thought it best to summarize my understanding of the current status of the discussions.
In response to the data requests of Staff, MCI, AT&T, U S WEST, GTE and most other utilities provided those parties that had signed the necessary agreements with proprietary information. My analysis of that information indicated the payphone operations of all Idaho LECs were either self supporting, or any deficit that was present was so small that changes to access charges were not appropriate at this time. I informally told MCI and AT&T of my findings and they asked me to look at a model developed by MCI, which they claimed provided a more thorough analysis than I had conducted.
I was provided a copy of the model in August, and based upon the analysis for U S WEST included with the model, again concluded no subsidy existed. In early September, I provided U S WEST, MCI and AT&T a copy of a draft report which included my conclusion that no changes to access charges were appropriate at this time. MCI promptly responded with a revised version of the model, which included significantly greater detail. This model did identify a subsidy for U S WEST.
The basic calculations included in the model did not vary considerably from that of my own analysis, but this model used data from ARMIS reports as inputs, rather than the data provided directly by U S WEST. The ARMIS data differed significantly from the U S WEST data in a number of key elements, which is the primary reason for the different conclusion.
Greg Harwood
October 6, 1997
Page 2
With MCI’s permission I provided U S WEST with a copy of the analysis, including the ARMIS input data, and requested a response as to why the data was different between the two sources and whether the conclusion was accurate. One of the more significant discrepancies was the number of company-owned payphones. U S WEST informally indicated a possible explanation may be the ARMIS data included semi-public pay phones, while the data provided by U S WEST did not. U S WEST requested an opportunity to look into it more thoroughly and indicated they would get back to me.
A few days later, U S WEST indicated discussions/negotiations were being conducted between AT&T/MCI and U S WEST on a corporate-wide level (14 states), and that U S WEST was in the process of preparing forward-looking cost studies for those discussions. They preferred to wait until those numbers were available before responding to my request so that the numbers provided to Idaho could be consistent with those provided to the 14-state discussions. These numbers were expected to be available by mid-October. U S WEST indicated these discussions might result in a corporate-wide settlement of this issue.
In light of these discussions, I indicated a willingness to wait for the corporate-wide numbers. I also indicated that if the parties were trying to resolve this dispute among themselves, I wanted to give those discussions an opportunity to succeed. I suggested it may be appropriate to put the Idaho proceedings on the back burner until the corporate-wide discussions are concluded, one way or the other.
As the Commission’s orders approving the April 15 payphone deregulation tariffs left open the possibility of a refund of any overpayments since April 15, should the Commission ultimately find that further rate adjustments were appropriate, I believe the risk of jeopardizing the corporate-wide negotiations exceeds the risk of a delay in this matter. Therefore, unless I am presented with reasons for proceeding otherwise, I intend to defer any further action on this matter for 45 to 60 days, or until I hear the negotiations have concluded.
I hope this update is useful. Please let me know if my understanding of any of the actions in this case needs to be revised.
Sincerely,
Wayne Hart
Telecommunications Analyst
WH:gdk:i:wpfiles/utelcomm/payslow.ltr
October 6, 1997
Dean J. Miller, P.A.
Attorney at Law
P.O. Box 2564
Boise, ID 83701-2564
Dear Joe:
I thought I would provide an update of the status of the discussions in the Commission’s review of the emergency petition filed by MCI and AT&T regarding payphone subsidies (Case No. GNR-T-97-5). There has been a considerable amount of data exchanged and a number of conversations between myself and each of the parties, but as most of this has been informal, I thought it best to summarize my understanding of the current status of the discussions.
In response to the data requests of Staff, MCI, AT&T, U S WEST, GTE and most other utilities provided those parties that had signed the necessary agreements with proprietary information. My analysis of that information indicated the payphone operations of all Idaho LECs were either self supporting, or any deficit that was present was so small that changes to access charges were not appropriate at this time. I informally told MCI and AT&T of my findings and they asked me to look at a model developed by MCI, which they claimed provided a more thorough analysis than I had conducted.
I was provided a copy of the model in August, and based upon the analysis for U S WEST included with the model, again concluded no subsidy existed. In early September, I provided U S WEST, MCI and AT&T a copy of a draft report which included my conclusion that no changes to access charges were appropriate at this time. MCI promptly responded with a revised version of the model, which included significantly greater detail. This model did identify a subsidy for U S WEST.
The basic calculations included in the model did not vary considerably from that of my own analysis, but this model used data from ARMIS reports as inputs, rather than the data provided directly by U S WEST. The ARMIS data differed significantly from the U S WEST data in a number of key elements, which is the primary reason for the different conclusion.
Dean J. Miller
October 6, 1997
Page 2
With MCI’s permission I provided U S WEST with a copy of the analysis, including the ARMIS input data, and requested a response as to why the data was different between the two sources and whether the conclusion was accurate. One of the more significant discrepancies was the number of company-owned payphones. U S WEST informally indicated a possible explanation may be the ARMIS data included semi-public pay phones, while the data provided by U S WEST did not. U S WEST requested an opportunity to look into it more thoroughly and indicated they would get back to me.
A few days later, U S WEST indicated discussions/negotiations were being conducted between AT&T/MCI and U S WEST on a corporate-wide level (14 states), and that U S WEST was in the process of preparing forward-looking cost studies for those discussions. They preferred to wait until those numbers were available before responding to my request so that the numbers provided to Idaho could be consistent with those provided to the 14-state discussions. These numbers were expected to be available by mid-October. U S WEST indicated these discussions might result in a corporate-wide settlement of this issue.
In light of these discussions, I indicated a willingness to wait for the corporate-wide numbers. I also indicated that if the parties were trying to resolve this dispute among themselves, I wanted to give those discussions an opportunity to succeed. I suggested it may be appropriate to put the Idaho proceedings on the back burner until the corporate-wide discussions are concluded, one way or the other.
As the Commission’s orders approving the April 15 payphone deregulation tariffs left open the possibility of a refund of any overpayments since April 15, should the Commission ultimately find that further rate adjustments were appropriate, I believe the risk of jeopardizing the corporate-wide negotiations exceeds the risk of a delay in this matter. Therefore, unless I am presented with reasons for proceeding otherwise, I intend to defer any further action on this matter for 45 to 60 days, or until I hear the negotiations have concluded.
I hope this update is useful. Please let me know if my understanding of any of the actions in this case needs to be revised.
Sincerely,
Wayne Hart
Telecommunications Analyst
WH:gdk:i:wpfiles/utelcomm/payslow.ltr
October 6, 1997
Tim Gates
MCI
Western Public Policy
707 17th Street
Suite 3600
Denver, CO 80202
Dear Mr. Gates:
I thought I would provide an update of the status of the discussions in the Commission’s review of the emergency petition filed by MCI and AT&T regarding payphone subsidies (Case No. GNR-T-97-5). There has been a considerable amount of data exchanged and a number of conversations between myself and each of the parties, but as most of this has been informal, I thought it best to summarize my understanding of the current status of the discussions.
In response to the data requests of Staff, MCI, AT&T, U S WEST, GTE and most other utilities provided those parties that had signed the necessary agreements with proprietary information. My analysis of that information indicated the payphone operations of all Idaho LECs were either self supporting, or any deficit that was present was so small that changes to access charges were not appropriate at this time. I informally told MCI and AT&T of my findings and they asked me to look at a model developed by MCI, which they claimed provided a more thorough analysis than I had conducted.
I was provided a copy of the model in August, and based upon the analysis for U S WEST included with the model, again concluded no subsidy existed. In early September, I provided U S WEST, MCI and AT&T a copy of a draft report which included my conclusion that no changes to access charges were appropriate at this time. MCI promptly responded with a revised version of the model, which included significantly greater detail. This model did identify a subsidy for U S WEST.
The basic calculations included in the model did not vary considerably from that of my own analysis, but this model used data from ARMIS reports as inputs, rather than the data provided directly by U S WEST. The ARMIS data differed significantly from the U S WEST data in a number of key elements, which is the primary reason for the different conclusion.
Tim Gates
October 6, 1997
Page 2
With MCI’s permission I provided U S WEST with a copy of the analysis, including the ARMIS input data, and requested a response as to why the data was different between the two sources and whether the conclusion was accurate. One of the more significant discrepancies was the number of company-owned payphones. U S WEST informally indicated a possible explanation may be the ARMIS data included semi-public pay phones, while the data provided by U S WEST did not. U S WEST requested an opportunity to look into it more thoroughly and indicated they would get back to me.
A few days later, U S WEST indicated discussions/negotiations were being conducted between AT&T/MCI and U S WEST on a corporate-wide level (14 states), and that U S WEST was in the process of preparing forward-looking cost studies for those discussions. They preferred to wait until those numbers were available before responding to my request so that the numbers provided to Idaho could be consistent with those provided to the 14-state discussions. These numbers were expected to be available by mid-October. U S WEST indicated these discussions might result in a corporate-wide settlement of this issue.
In light of these discussions, I indicated a willingness to wait for the corporate-wide numbers. I also indicated that if the parties were trying to resolve this dispute among themselves, I wanted to give those discussions an opportunity to succeed. I suggested it may be appropriate to put the Idaho proceedings on the back burner until the corporate-wide discussions are concluded, one way or the other.
As the Commission’s orders approving the April 15 payphone deregulation tariffs left open the possibility of a refund of any overpayments since April 15, should the Commission ultimately find that further rate adjustments were appropriate, I believe the risk of jeopardizing the corporate-wide negotiations exceeds the risk of a delay in this matter. Therefore, unless I am presented with reasons for proceeding otherwise, I intend to defer any further action on this matter for 45 to 60 days, or until I hear the negotiations have concluded.
I hope this update is useful. Please let me know if my understanding of any of the actions in this case needs to be revised.
Sincerely,
Wayne Hart
Telecommunications Analyst
WH:gdk:i:wpfiles/utelcomm/payslow.ltr
October 6, 1997
John Souba
U S WEST Communications, Inc.
P.O. Box 7888
Boise, ID 83723
Dear John:
I thought I would provide an update of the status of the discussions in the Commission’s review of the emergency petition filed by MCI and AT&T regarding payphone subsidies (Case No. GNR-T-97-5). There has been a considerable amount of data exchanged and a number of conversations between myself and each of the parties, but as most of this has been informal, I thought it best to summarize my understanding of the current status of the discussions.
In response to the data requests of Staff, MCI, AT&T, U S WEST, GTE and most other utilities provided those parties that had signed the necessary agreements with proprietary information. My analysis of that information indicated the payphone operations of all Idaho LECs were either self supporting, or any deficit that was present was so small that changes to access charges were not appropriate at this time. I informally told MCI and AT&T of my findings and they asked me to look at a model developed by MCI, which they claimed provided a more thorough analysis than I had conducted.
I was provided a copy of the model in August, and based upon the analysis for U S WEST included with the model, again concluded no subsidy existed. In early September, I provided U S WEST, MCI and AT&T a copy of a draft report which included my conclusion that no changes to access charges were appropriate at this time. MCI promptly responded with a revised version of the model, which included significantly greater detail. This model did identify a subsidy for U S WEST.
The basic calculations included in the model did not vary considerably from that of my own analysis, but this model used data from ARMIS reports as inputs, rather than the data provided directly by U S WEST. The ARMIS data differed significantly from the U S WEST data in a number of key elements, which is the primary reason for the different conclusion.
John Souba
October 6, 1997
Page 2
With MCI’s permission I provided U S WEST with a copy of the analysis, including the ARMIS input data, and requested a response as to why the data was different between the two sources and whether the conclusion was accurate. One of the more significant discrepancies was the number of company-owned payphones. U S WEST informally indicated a possible explanation may be the ARMIS data included semi-public pay phones, while the data provided by U S WEST did not. U S WEST requested an opportunity to look into it more thoroughly and indicated they would get back to me.
A few days later, U S WEST indicated discussions/negotiations were being conducted between AT&T/MCI and U S WEST on a corporate-wide level (14 states), and that U S WEST was in the process of preparing forward-looking cost studies for those discussions. They preferred to wait until those numbers were available before responding to my request so that the numbers provided to Idaho could be consistent with those provided to the 14-state discussions. These numbers were expected to be available by mid-October. U S WEST indicated these discussions might result in a corporate-wide settlement of this issue.
In light of these discussions, I indicated a willingness to wait for the corporate-wide numbers. I also indicated that if the parties were trying to resolve this dispute among themselves, I wanted to give those discussions an opportunity to succeed. I suggested it may be appropriate to put the Idaho proceedings on the back burner until the corporate-wide discussions are concluded, one way or the other.
As the Commission’s orders approving the April 15 payphone deregulation tariffs left open the possibility of a refund of any overpayments since April 15, should the Commission ultimately find that further rate adjustments were appropriate, I believe the risk of jeopardizing the corporate-wide negotiations exceeds the risk of a delay in this matter. Therefore, unless I am presented with reasons for proceeding otherwise, I intend to defer any further action on this matter for 45 to 60 days, or until I hear the negotiations have concluded.
I hope this update is useful. Please let me know if my understanding of any of the actions in this case needs to be revised.
Sincerely,
Wayne Hart
Telecommunications Analyst
WH:gdk:i:wpfiles/utelcomm/payslow.ltr
October 6, 1997
Mary S. Hobson
Stoel, Rives LLP
Suite 1900
101 S. Capitol Blvd.
Boise, ID 83702-5958
Dear Mary:
I thought I would provide an update of the status of the discussions in the Commission’s review of the emergency petition filed by MCI and AT&T regarding payphone subsidies (Case No. GNR-T-97-5). There has been a considerable amount of data exchanged and a number of conversations between myself and each of the parties, but as most of this has been informal, I thought it best to summarize my understanding of the current status of the discussions.
In response to the data requests of Staff, MCI, AT&T, U S WEST, GTE and most other utilities provided those parties that had signed the necessary agreements with proprietary information. My analysis of that information indicated the payphone operations of all Idaho LECs were either self supporting, or any deficit that was present was so small that changes to access charges were not appropriate at this time. I informally told MCI and AT&T of my findings and they asked me to look at a model developed by MCI, which they claimed provided a more thorough analysis than I had conducted.
I was provided a copy of the model in August, and based upon the analysis for U S WEST included with the model, again concluded no subsidy existed. In early September, I provided U S WEST, MCI and AT&T a copy of a draft report which included my conclusion that no changes to access charges were appropriate at this time. MCI promptly responded with a revised version of the model, which included significantly greater detail. This model did identify a subsidy for U S WEST.
The basic calculations included in the model did not vary considerably from that of my own analysis, but this model used data from ARMIS reports as inputs, rather than the data provided directly by U S WEST. The ARMIS data differed significantly from the U S WEST data in a number of key elements, which is the primary reason for the different conclusion.
Mary S. Hobson
October 6, 1997
Page 2
With MCI’s permission I provided U S WEST with a copy of the analysis, including the ARMIS input data, and requested a response as to why the data was different between the two sources and whether the conclusion was accurate. One of the more significant discrepancies was the number of company-owned payphones. U S WEST informally indicated a possible explanation may be the ARMIS data included semi-public pay phones, while the data provided by U S WEST did not. U S WEST requested an opportunity to look into it more thoroughly and indicated they would get back to me.
A few days later, U S WEST indicated discussions/negotiations were being conducted between AT&T/MCI and U S WEST on a corporate-wide level (14 states), and that U S WEST was in the process of preparing forward-looking cost studies for those discussions. They preferred to wait until those numbers were available before responding to my request so that the numbers provided to Idaho could be consistent with those provided to the 14-state discussions. These numbers were expected to be available by mid-October. U S WEST indicated these discussions might result in a corporate-wide settlement of this issue.
In light of these discussions, I indicated a willingness to wait for the corporate-wide numbers. I also indicated that if the parties were trying to resolve this dispute among themselves, I wanted to give those discussions an opportunity to succeed. I suggested it may be appropriate to put the Idaho proceedings on the back burner until the corporate-wide discussions are concluded, one way or the other.
As the Commission’s orders approving the April 15 payphone deregulation tariffs left open the possibility of a refund of any overpayments since April 15, should the Commission ultimately find that further rate adjustments were appropriate, I believe the risk of jeopardizing the corporate-wide negotiations exceeds the risk of a delay in this matter. Therefore, unless I am presented with reasons for proceeding otherwise, I intend to defer any further action on this matter for 45 to 60 days, or until I hear the negotiations have concluded.
I hope this update is useful. Please let me know if my understanding of any of the actions in this case needs to be revised.
Sincerely,
Wayne Hart
Telecommunications Analyst
WH:gdk:i:wpfiles/utelcomm/payslow.ltr
October 6, 1997
Fred Logan
State Mgr-Regulatory/Govt. Affairs
GTE Northwest, Inc.
P.O. Box 1100
Beaverton, OR 97006
Dear Fred:
I thought I would provide an update of the status of the discussions in the Commission’s review of the emergency petition filed by MCI and AT&T regarding payphone subsidies (Case No. GNR-T-97-5). There has been a considerable amount of data exchanged and a number of conversations between myself and each of the parties, but as most of this has been informal, I thought it best to summarize my understanding of the current status of the discussions.
In response to the data requests of Staff, MCI, AT&T, U S WEST, GTE and most other utilities provided those parties that had signed the necessary agreements with proprietary information. My analysis of that information indicated the payphone operations of all Idaho LECs were either self supporting, or any deficit that was present was so small that changes to access charges were not appropriate at this time. I informally told MCI and AT&T of my findings and they asked me to look at a model developed by MCI, which they claimed provided a more thorough analysis than I had conducted.
I was provided a copy of the model in August, and based upon the analysis for U S WEST included with the model, again concluded no subsidy existed. In early September, I provided U S WEST, MCI and AT&T a copy of a draft report which included my conclusion that no changes to access charges were appropriate at this time. MCI promptly responded with a revised version of the model, which included significantly greater detail. This model did identify a subsidy for U S WEST.
The basic calculations included in the model did not vary considerably from that of my own analysis, but this model used data from ARMIS reports as inputs, rather than the data provided directly by U S WEST. The ARMIS data differed significantly from the U S WEST data in a number of key elements, which is the primary reason for the different conclusion.
Fred Logan
October 6, 1997
Page 2
With MCI’s permission I provided U S WEST with a copy of the analysis, including the ARMIS input data, and requested a response as to why the data was different between the two sources and whether the conclusion was accurate. One of the more significant discrepancies was the number of company-owned payphones. U S WEST informally indicated a possible explanation may be the ARMIS data included semi-public pay phones, while the data provided by U S WEST did not. U S WEST requested an opportunity to look into it more thoroughly and indicated they would get back to me.
A few days later, U S WEST indicated discussions/negotiations were being conducted between AT&T/MCI and U S WEST on a corporate-wide level (14 states), and that U S WEST was in the process of preparing forward-looking cost studies for those discussions. They preferred to wait until those numbers were available before responding to my request so that the numbers provided to Idaho could be consistent with those provided to the 14-state discussions. These numbers were expected to be available by mid-October. U S WEST indicated these discussions might result in a corporate-wide settlement of this issue.
In light of these discussions, I indicated a willingness to wait for the corporate-wide numbers. I also indicated that if the parties were trying to resolve this dispute among themselves, I wanted to give those discussions an opportunity to succeed. I suggested it may be appropriate to put the Idaho proceedings on the back burner until the corporate-wide discussions are concluded, one way or the other.
As the Commission’s orders approving the April 15 payphone deregulation tariffs left open the possibility of a refund of any overpayments since April 15, should the Commission ultimately find that further rate adjustments were appropriate, I believe the risk of jeopardizing the corporate-wide negotiations exceeds the risk of a delay in this matter. Therefore, unless I am presented with reasons for proceeding otherwise, I intend to defer any further action on this matter for 45 to 60 days, or until I hear the negotiations have concluded.
I hope this update is useful. Please let me know if my understanding of any of the actions in this case needs to be revised.
Sincerely,
Wayne Hart
Telecommunications Analyst
WH:gdk:i:wpfiles/utelcomm/payslow.ltr
October 6, 1997
David Hackett
NW Payphone Assn.
Miller/Nash
4400 Two Union Square
601 Union St.
Seattle, WA 98101-2352
Dear Mr. Hackett:
I thought I would provide an update of the status of the discussions in the Commission’s review of the emergency petition filed by MCI and AT&T regarding payphone subsidies (Case No. GNR-T-97-5). There has been a considerable amount of data exchanged and a number of conversations between myself and each of the parties, but as most of this has been informal, I thought it best to summarize my understanding of the current status of the discussions.
In response to the data requests of Staff, MCI, AT&T, U S WEST, GTE and most other utilities provided those parties that had signed the necessary agreements with proprietary information. My analysis of that information indicated the payphone operations of all Idaho LECs were either self supporting, or any deficit that was present was so small that changes to access charges were not appropriate at this time. I informally told MCI and AT&T of my findings and they asked me to look at a model developed by MCI, which they claimed provided a more thorough analysis than I had conducted.
I was provided a copy of the model in August, and based upon the analysis for U S WEST included with the model, again concluded no subsidy existed. In early September, I provided U S WEST, MCI and AT&T a copy of a draft report which included my conclusion that no changes to access charges were appropriate at this time. MCI promptly responded with a revised version of the model, which included significantly greater detail. This model did identify a subsidy for U S WEST.
The basic calculations included in the model did not vary considerably from that of my own analysis, but this model used data from ARMIS reports as inputs, rather than the data provided directly by U S WEST. The ARMIS data differed significantly from the U S WEST data in a number of key elements, which is the primary reason for the different conclusion.
David Hackett
October 6, 1997
Page 2
With MCI’s permission I provided U S WEST with a copy of the analysis, including the ARMIS input data, and requested a response as to why the data was different between the two sources and whether the conclusion was accurate. One of the more significant discrepancies was the number of company-owned payphones. U S WEST informally indicated a possible explanation may be the ARMIS data included semi-public pay phones, while the data provided by U S WEST did not. U S WEST requested an opportunity to look into it more thoroughly and indicated they would get back to me.
A few days later, U S WEST indicated discussions/negotiations were being conducted between AT&T/MCI and U S WEST on a corporate-wide level (14 states), and that U S WEST was in the process of preparing forward-looking cost studies for those discussions. They preferred to wait until those numbers were available before responding to my request so that the numbers provided to Idaho could be consistent with those provided to the 14-state discussions. These numbers were expected to be available by mid-October. U S WEST indicated these discussions might result in a corporate-wide settlement of this issue.
In light of these discussions, I indicated a willingness to wait for the corporate-wide numbers. I also indicated that if the parties were trying to resolve this dispute among themselves, I wanted to give those discussions an opportunity to succeed. I suggested it may be appropriate to put the Idaho proceedings on the back burner until the corporate-wide discussions are concluded, one way or the other.
As the Commission’s orders approving the April 15 payphone deregulation tariffs left open the possibility of a refund of any overpayments since April 15, should the Commission ultimately find that further rate adjustments were appropriate, I believe the risk of jeopardizing the corporate-wide negotiations exceeds the risk of a delay in this matter. Therefore, unless I am presented with reasons for proceeding otherwise, I intend to defer any further action on this matter for 45 to 60 days, or until I hear the negotiations have concluded.
I hope this update is useful. Please let me know if my understanding of any of the actions in this case needs to be revised.
Sincerely,
Wayne Hart
Telecommunications Analyst
WH:gdk:i:wpfiles/utelcomm/payslow.ltr
October 6, 1997
Conley Ward
Givens, Pursley & Huntley
P.O. Box 2720
Boise, ID 83701-2720
Dear Conley:
I thought I would provide an update of the status of the discussions in the Commission’s review of the emergency petition filed by MCI and AT&T regarding payphone subsidies (Case No. GNR-T-97-5). There has been a considerable amount of data exchanged and a number of conversations between myself and each of the parties, but as most of this has been informal, I thought it best to summarize my understanding of the current status of the discussions.
In response to the data requests of Staff, MCI, AT&T, U S WEST, GTE and most other utilities provided those parties that had signed the necessary agreements with proprietary information. My analysis of that information indicated the payphone operations of all Idaho LECs were either self supporting, or any deficit that was present was so small that changes to access charges were not appropriate at this time. I informally told MCI and AT&T of my findings and they asked me to look at a model developed by MCI, which they claimed provided a more thorough analysis than I had conducted.
I was provided a copy of the model in August, and based upon the analysis for U S WEST included with the model, again concluded no subsidy existed. In early September, I provided U S WEST, MCI and AT&T a copy of a draft report which included my conclusion that no changes to access charges were appropriate at this time. MCI promptly responded with a revised version of the model, which included significantly greater detail. This model did identify a subsidy for U S WEST.
The basic calculations included in the model did not vary considerably from that of my own analysis, but this model used data from ARMIS reports as inputs, rather than the data provided directly by U S WEST. The ARMIS data differed significantly from the U S WEST data in a number of key elements, which is the primary reason for the different conclusion.
Conley Ward
October 6, 1997
Page 2
With MCI’s permission I provided U S WEST with a copy of the analysis, including the ARMIS input data, and requested a response as to why the data was different between the two sources and whether the conclusion was accurate. One of the more significant discrepancies was the number of company-owned payphones. U S WEST informally indicated a possible explanation may be the ARMIS data included semi-public pay phones, while the data provided by U S WEST did not. U S WEST requested an opportunity to look into it more thoroughly and indicated they would get back to me.
A few days later, U S WEST indicated discussions/negotiations were being conducted between AT&T/MCI and U S WEST on a corporate-wide level (14 states), and that U S WEST was in the process of preparing forward-looking cost studies for those discussions. They preferred to wait until those numbers were available before responding to my request so that the numbers provided to Idaho could be consistent with those provided to the 14-state discussions. These numbers were expected to be available by mid-October. U S WEST indicated these discussions might result in a corporate-wide settlement of this issue.
In light of these discussions, I indicated a willingness to wait for the corporate-wide numbers. I also indicated that if the parties were trying to resolve this dispute among themselves, I wanted to give those discussions an opportunity to succeed. I suggested it may be appropriate to put the Idaho proceedings on the back burner until the corporate-wide discussions are concluded, one way or the other.
As the Commission’s orders approving the April 15 payphone deregulation tariffs left open the possibility of a refund of any overpayments since April 15, should the Commission ultimately find that further rate adjustments were appropriate, I believe the risk of jeopardizing the corporate-wide negotiations exceeds the risk of a delay in this matter. Therefore, unless I am presented with reasons for proceeding otherwise, I intend to defer any further action on this matter for 45 to 60 days, or until I hear the negotiations have concluded.
I hope this update is useful. Please let me know if my understanding of any of the actions in this case needs to be revised.
Sincerely,
Wayne Hart
Telecommunications Analyst
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