GNRT937Cv1.docx

Q.Please state your name and address.
A.My name is Wayne Hart.  My business address is 472 West Washington, Boise, Idaho.
Q.By whom are you employed, and in what capacity?
A.I am employed by the Idaho Public Utilities Commission (IPUC; Commission) as a Telecommunications Analyst in the Telecommunications Section.
Q.Are you the same Wayne Hart who previously filed direct testimony in this proceeding?
A.Yes, I am.
Q.U S WEST’s witness Lightfoot indicated in his direct testimony that U S WEST would prefer that any expansion of the toll free calling area that includes part of U S WEST’s Treasure Valley Expanded Area Service (EAS) include all of the Treasure Valley EAS.  Does the calling data support such an expansion?
A.Calling data for the entire region was not available, but I was able to analyze calling data from the three Citizens’ exchanges (Homedale, Wilder, Parma) to and from Boise.  As one would expect with the greater distances involved and the higher toll costs, there are fewer calls per line to and from Boise than to Caldwell, and the number of calls per line to Boise is about the same as the number per line to Nampa.  The number of lines that do not make any calls to Boise in a month is significantly higher.  Approximately nine out of ten lines in the three Citizens’ exchanges did not make a single call to Boise in each of the three months for which data was analyzed.  Less than two percent of the lines made four or more calls to Boise during any of the three months, and that two percent of the lines accounted for over half of the calls made to Boise numbers.
Q.Does this calling data indicate that these exchanges should not be included in the Treasure Valley EAS?
A.Not necessarily.  When the impact of rates are taken into account, the calling data from these exchanges is probably very similar to the data from a number of other communities that were included in the Treasure Valley EAS.  Whether viewed from a geographical, sociological or economic perspective, it is logical to include these three communities in the Treasure Valley.  If these communities were served by U S WEST instead of Citizens, they would probably have been included in the Treasure Valley EAS.
Q.What would be the revenue impacts of including these three exchanges in the Treasure Valley EAS?
A.Although I did not have data for calls from these exchanges to the entire Treasure Valley EAS, I was able to estimate the impact based upon data U S WEST provided for calls from all the exchanges in the EAS to the Citizens exchanges.  In order to provide Citizens with full recovery of the revenues they reported for all of the routes in the entire Treasure Valley EAS, the cost would exceed $20 per month for each customer.  This amount includes the $14 that was identified in my direct testimony for the Caldwell and Nampa exchanges.  
Q.Do you believe that the customers of these three exchanges would support such an increase in their monthly charges?
A.No.  As I stated in my direct testimony, a majority of the customers in these exchanges do not make a significant number of calls each month to the exchanges in the Treasure Valley EAS, and I do not believe they would support an increase in their rates of this magnitude.
Q.Does this information change your original recommendation not to provide an EAS for these routes?
A.While I still believe a traditional EAS with full cost recovery would be too expensive with Citizens’ current rate structure, I do believe that the customers in these exchanges deserve an alternative to the current rates.  As I indicated in my direct testimony, there are changes to Citizen’s access charges and rate structure that are expected in the near future and it would be appropriate to reconsider this issue after the impacts of those changes are more fully understood.  As
U S WEST witness Lightfoot indicated, there are significant reasons for considering EAS questions on a Company-wide basis, and I think that is certainly appropriate for Citizens.  However, I don’t think it is appropriate to make these customers wait any longer.  I believe that optional calling plans should be developed as soon as possible that provide alternatives to those customers who choose to participate.
Q.Citizen’s witness Parries indicated that the Company did not think that such a plan could be provided at a price that customers would find acceptable.  Do you agree?
A.No.  I believe that Citizens needs to respond to the needs of these customers, even though at least for the short term it may not be revenue neutral.  Citizens has indicated that it expects to be able to address the EAS issues more fully within a year, so the optional plans developed now would not necessarily be in place for very long.  Citizens could limit its exposure by accelerating its analysis and developing statewide solutions at a sooner date.
Q.Does that conclude your testimony?
A.Yes.