20010530Application.pdf

RECEivED E
ConleyWard,ISB #1683 FILEDGIVENSPURSLEYLLP
277 North 6th Street,Suite 200 2001 MAY 30 PM W 26
P.O.Box 2720 UBLICBoise,ID 83701
L OMMISSION(208)388-1200
[phone] (fax)NEW CAM
Attorneys for Rural Telephone Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE pg p.pggyPETITIONSOFCUSTOMERSOFI
ITHERURALTELEPHONEi CASE NO.-GNPA'-99-9--COMPANY TO JOIN THE TREASUREVALLEYEXTENDEDSERVICE
ICALLINGAREA.
IN THE MATTER OF THE PETITION GASE--NOWNR=T=98-18
OF CUSTOMERS OF THE RURALTELEPHONECOMPANYBOISE RURAL TELEPHONE COMPANY'SRIVEREXCHANGETOJOINTHEMOTIONFORINCREASEDIDAHOUSWESTMOUNTAINHOMEUSFFUNDINGEXCHANGEAND/OR THE
TREASURE VALLEY EXTENDEDSERVICECALLINGAREA.
Rural TelephoneCompany("Rural Telephone"or "Applicant"),by and
through its attorneys Givens Pursley LLP,makes this Motion pursuant to this
Commission's Order No.28114 in the above entitled proceeding.In support of its
Motion,Rural Telephonestates as follows:
1.This case was initiated by two petitions from Rural Telephone'sTipanuk
and Boise River customers seekingextended area service ("EAS")between their
exchanges and Qwest'sBoise calling area.On August 20,1999,the Commission
issued Order No.28114 granting the petitions.
2.Order No.28114 provided that Rural Telephoneshould recover the
Rural Telephone's Motion-1
increased costs attributable to EAS partly through an increase in local rates to
$24.10 per month for residential customers and $42.00 per month for business
customers.The Order further provided that,given the strong community of interest
and the necessityof upgrading facilities even in the absence of EAS,"it is in the
public interest to support EAS for these exchanges in part by increased
distributions from [the Idaho Universal Service Fund ("USF")]."Order No.28114 at
11.
3.On February 14,2001,Rural Telephoneand QwestimplementedEAS and
Rural Telephoneraised its local rates to the levels specified in Order No.28114.
After giving effect to the increase in rates,Rural Telephone,calculates that it will
fall $125,562 short in recoveringthe annual revenue deficiency attributable to the
implementation of EAS.The attached testimony and exhibits of Ray Hendershot
provide further details regarding the determination of this amount.
4.For the calendar year 2001 only,Rural Telephonerespectfully requests
that the increase in the Company'sannual USF distributions be paid in a simple
lump sum payment of $125,562 on July 1,2001.This lump sum paymentwill
partially compensate Rural Telephonefor the lag in recovery of the substantial
expenditures it has made in response to the Commission's Order.Beginningon
January 1,2002,distributions would be paid monthly in the normal manner.
5.Rural Telephonedoes not request oral argument or a hearing on this
Motion.In the event the Commission determines that further proceedings on this
Motion are necessary,Applicant stands ready for immediate hearing.
WHEREFORE,Rural Telephonerespectfully moves this Commission for an
Order:
Rural Telephone's Motion-2
1.Authorizing Rural Telephoneto recover the additional sum of $125,652
per year from the Idaho Universal Service Fund,beginning with a lump sum
payment on July 1,2001 for the calendar year 2001.
2.Granting such other relief as the Commission deems just and reasonable
in this matter.
DATED this 30th day of May,200
Con ey War
GIV NS P LEY LLPAttorneysforApplicant
Rural Telephone's Motion-3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 30th day of May,2001,I caused a true andcorrectcopyoftheforegoingtobeservedupon:
Jean Jewell,SecretaryIdahoPublicUtilitiesCommission
472 W.Washington Street
Boise,ID 83702
by hand delivering the same to the above-named at the last known address(s)as setforthabove.
Rural Telephone's Motion-4
RECElVED
ConleyWard,ISB #1683 FILED
GIVENS PURSLEY LLP :26277North6thStreet,Suite 200P.O.Box 2720 PUBLilBoise,ID 83701 UTiLÙ S COffilSSION
[phone]
[phone] (fax)
Attorneys for Rural Telephone Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THEPETITIONSOFCUSTOMERS OF I
THE RURAL TELEPHONE i CASE NO.GNR-T-97-9COMPANYTOJOINTHETREASURE,'VALLEY EXTENDED SERVICE I
ICALLINGAREA.
IINTHEMATTEROFTHEPETITION CASE NO.GNR-T-98-18OFCUSTOMERSOFTHERURALTELEPHONECOMPANYBOISERIVEREXCHANGETOJOINTHEUSWESTMOUNTAINHOMEEXCHANGEAND/OR THETREASUREVALLEYEXTENDEDSERVICECALLINGAREA.
TESTIMONY
OF
RAYMOND A.HENDERSHOT
FOR
RURAL TELEPHONE COMPANY
1 Q:PLEASE STATE YOUR NAME AND BUSINESS ADDRESS.
2 A:My name is RaymondA.Hendershot.My business address is 2270
3 LaMontana Way,P.O.Box 25969,Colorado Springs,Colorado 80936.
4 Q:BY WHOM ARE YOU EMPLOYED AND IN WHAT CAPACITY?
5 A:I am a Vice President for GVNW Inc./Management("GVNW").
6 Q:FOR WHOM ARE YOU APPEARING IN THIS PROCEEDING?
7 A:I am appearingon behalf of Rural TelephoneCompany("Rural"or
8 "Company")in this case.
9 Q:HAVE YOU PREVIOUSLY FILED DIRECT TESTIMONY IN THIS CASE?
1 0 A:Yes.
1 1 Q:WHAT IS THE PURPOSE OF THIS TESTIMONY?
1 2 A:My testimony calculates the cost of providing EAS and the financial impact
1 3 on the Companyof providing this service.I also calculate the revenue
1 4 deficiency that the Companyis entitled to recover from the Idaho Universal
1 5 Service Fund.("USF").
1 6 Q.HAVE YOU PREPARED AN EXHIBIT THAT SUMMARIZES THESE
1 7 CALCULATIONS?
1 8 A.Yes.Exhibit No.1 lists the actual cost of EAS by capital and expense
1 9 categories.The workpapers supporting these calculations have been
2 0 reviewed by the Commission Staff.
2 1 Q WOULD YOU PLEASE DESCRIBE EXHIBIT NO.1?
2 2 A.The exhibit is quite straightforward.The total capital cost of the
2 3 necessary improvementsappear on Line 6 and total $511,467.After
R.Hendershot--Page 1
Rural Telephone Company
Case No.GNR-T-97-9
1 appropriate subtractions,the net capital cost is $461,676 (Line 11).
2 The net increase in return is $45,124 (Line 12),and annual
3 depreciation charges add an additional $32,317 (Line 17)to the total
4 costs.The annual costs for lost access revenues,lost federal support,
5 and litigation costs appear on Lines 18-20.The total annual cost
6 increase of $196,507 is listed on Line 22.Subtracting the annual
7 revenue gain from the increase in rates required by Order No.28114
8 (Line 23),produces a net annual revenue deficiency of $125,652 (Line
9 24).
1 0 Q.HOW SHOULD THIS REVENUE DEFICIENCY BE RECOVERED?
1 1 A.Order No.28114 states that the Companyis entitled to recover this
1 2 deficiency by increasing its annual USF draw.In fairness,the
1 3 Companyshould be allowed to recover the 2001 deficiency in an
1 4 immediate payment as partial compensationfor the substantial time
1 5 lag between the Company'scapital expendituresand its recovery of its
1 6 costs.We suggestthat a single payment on July 1,2001 for the
1 7 calendar year 2001 is reasonable and appropriate.
1 8 Q DOES THIS CONCLUDE YOUR TESTIMONY?
1 9 A.Yes,it does.
R.Hendershot-Page 2
Rural Telephone Company
Case No.GNR-T-97-9