200508261st staff request to Frontier.pdf

KIRA DALE PFISTERER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 6571
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
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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-
FIRST 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
Kira Dale Pfisterer, 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, SEPTEMBER 16, 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.
FIRST PRODUCTION REQUEST
TO FRONTIER
AUGUST 26, 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.1: Please provide all engineering diagrams and other descriptions
indicating the specific plant facilities (conduit, fiber, copper, manhole covers, etc.) that Frontier
installed at Tamarack Resort.
Request No.2: Please provide a detailed cost analysis indicating how much it would
cost to serve the customers within the Tamarack resort as a facilities-based provider.
Request No.3: Please provide a detailed cost analysis indicating how much it would
cost to serve the customers within the Tamarack Resort should Frontier extend facilities to
Tamarack's PBX and interconnect at that point. Include all costs relating to interfacing with the
Tamarack facilities, interconnection expenses and any other incidental costs that Frontier
believes it will incur as a result providing service within the Tamarack Resort through
interconnection. Please specifically identify the equipment and costs Frontier will need to install
in order to interconnect with Tamarack's fiber network.
Request No.4: If conduit is present within the Tamarack Resort, please explain why
Frontier believes it will have to plow in new facilities in order to serve Tamarack Resort
customers.
Dated at Boise, Idaho, this 2/r;
'"
day of August 2005.
tJ.
Kira D. Pfiste r
Deputy Attorney General
Technical Staff: Carolee Hall
i:umisc/ctctO5.2kdpch 1
FIRST PRODUCTION REQUEST
TO FRONTIER
AUGUST 26, 2005
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS
TH DAY OF AUGUST 2005
SERVED THE FOREGOING FIRST 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
TATE GOVERNMENT AFF AIRS
CITIZENS COMMUNICATIONS OF IDAHO
3 TRIAD CENTER SUITE 160
SALT LAKE CITY UT 84180
SECRETARY
CERTIFICATE OF SERVICE