200511042nd staff request to Frontier.pdf

CECELIA A. GASSNER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 6977
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
ECEIVED
, n.ED
I. P'A
" : ,' ,-"
~I I
-1 FU8UC
I ';. i"~!ilAr/'O~1i ; !~- i i ,.J -"-,I,, I
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE INVESTIGATION
TO DETERMINE WHETHER IT IS
REASONABLE FOR FRONTIER
COMMUNICATIONS OF IDAHO TO
PROVIDE TELECOMMUNICATIONS
SERVICE TO CUSTOMERS LOCATED IN
THE TAMARACK RESORT.
CASE NO. CTC-05-
SECOND PRODUCTION
REQUEST OF THE COMMISSION
STAFF TO FRONTIER
COMMUNICATIONS OF IDAHO
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record
Cecelia A. Gassner, Deputy Attorney General, requests that Citizens Telecommunications
Company of Idaho dba Frontier Communications of Idaho ("Frontier;) provide the following
documents and information on or before FRIDAY, DECEMBER 2,2005.
Please provide answers to each question; supporting workpapers that provide detail or are
the source of information used in calculations; the name and telephone number of the person
preparing the documents relied upon in answering the questions; and the name, location and
telephone number of the record holder.
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person( s) and the witness who can sponsor the answer at hearing if need
be. See IDAP A 31.01.01.228.
SECOND PRODUCTION REQUEST TO
FRONTIER COMMUNICA nONS NOVEMBER 4, 2005
This Production Request is to be considered as continuing, and Frontier is requested to
provide, by way of supplementary responses, additional documents that it or any person acting
on its behalf may later obtain that will augment the documents produced.
Request No.5: Has Frontier made a request for interconnection with Tamarack? If so
have Frontier and Tamarack entered into negotiations for an interconnection agreement? If they
have not yet entered into such negotiations, why not?
Request No.6: If Frontier has not yet made a request for interconnection with
Tamarack, does the Company intend to do so? If not, why not?
Request No.7: Is it technically feasible for Frontier s network to interconnect or
translate with Tamarack's network?
Request No.8: If the response to Request No.7 is positive, please provide an estimate
with appropriate documentation, of the overall cost of investment that would be necessary to
accomplish such interconnection.
Request No.9: How does Frontier anticipate recovering its investment costs if it
interconnects with the Tamarack network?
Request No. 10: Please provide an estimate, with appropriate documentation, of any rate
increase to Frontier s customers outside of the Tamarack service area that may be needed to
recover its investment costs of providing services to customers in the Tamarack service area.
Dated at Boise, Idaho, this day of November 2005.
ceceli
Deputy Attorney General
Technical Staff: Carolee Hall
i:umisc/ctctO5.2cgch 2
SECOND PRODUCTION REQUEST TO
FRONTIER COMMUNICATIONS NOVEMBER 4, 2005
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 4TH DAY OF NOVEMBER 2005
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO FRONTIER COMMUNICATIONS OF IDAHO, IN
CASE NO. CTC-05-, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
INGO HENNINGSEN MANAGER MARY S HOBSON
STATE GOVERNMENT AFFAIRS STOEL RIVES LLP
CITIZENS COMMUNICATIONS OF IDAHO 101 S CAPITOL BLVD, SUITE 1900
3 TRIAD CENTER SUITE 160 BOISE, ID 83702-5958
SALT LAKE CITY UT 84180
SHELBY WEIMER
TAMARACK VIDEO & TELECOM
960 BROADWAY AVE
SUITE 100
BOISE ID 83706
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
\.
~Jt:b. kodL
SECRETARY
CERTIFICATE OF SERVICE