HomeMy WebLinkAbout19970708First Request to Filer Mutual.docBRAD PURDY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-0357
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF FILER MUTUAL TELEPHONE COMPANY ) CASE NO. FIL-T-97-1
FOR DISBURSEMENTS FROM THE IDAHO )
UNIVERSAL SERVICE FUND ) FIRST PRODUCTION
) REQUEST OF THE
) COMMISSION STAFF
) TO FILER MUTUAL
) TELEPHONE COMPANY
_____________________________________________ )
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Brad Purdy, Deputy Attorney General, requests that Filer Mutual Telephone Company provide the following documents and information on or before TUESDAY, JULY 22, 1997.
This Production Request is to be considered as continuing, and Filer Mutual Telephone Company 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.
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; and the name, location and telephone number of the record holder.
Request No. 1: Please provide all supporting workpapers for Exhibits 1 through 7 filed in FIL-T-97-1 as part of Raymond Hendershots testimony.
Request No. 2: Please provide all information and workpapers used to separate Interstate and Intrastate operations in FIL-T-97-1.
Request No. 3: Please provide the 1996 year-end trial balance for Filer Mutual Telephone Company.
Request No. 4: Please provide the most recent chart of accounts with definitions of accounts and use.
Request No. 5: Please provide the cost allocation manual(s).
Request No. 6: Please provide the name, phone number and address of person(s) to contact to arrange the audit dates. Is this the same person to contact regarding questions on audit requests? If not, please provide the name, phone number and address of the person(s).
Request No. 7: Please provide a list of addresses where accounting functions are preformed for the Company and for Idaho. List the name of each accounting function that is performed at each location.
Request No. 8: Please provide all traffic studies for 1994, 1995, and 1996.
Request No. 9: Please provide a detailed list of continuing property records by wire center by account.
Request No. 10: Please provide detailed plant reserve records.
Request No. 11: Please provide a copy of the construction budget for 1997 and a five year construction plan.
Request No. 12: Please supply the direct-dialed calling data for the months from April through June, 1997 on a month-by-month basis using the format below for calls on each of the following routes:
Originating Point Terminating Point
Filer Bliss
Filer Buhl
Filer Castleford
Filer Dietrich
Filer Eden
Filer Gooding
Filer Hagerman
Filer Hazelton
Filer Jerome
Filer Kimberly
Filer Murtaugh
Filer Shoshone
Filer Twin Falls
Filer Wendell
Please identify the above data for each month, originating location and terminating location in the following format:
Monthly
# of # of Lines Percent of Toll
Messages Making Calls Access Lines Charges
0
1
2
3
4
5
6
7
8
9
10-15
16-30
31-45
46-60
61-100
101 & Over
Originating Point Terminating Point
Hollister Bliss
Hollister Buhl
Hollister Castleford
Hollister Dietrich
Hollister Eden
Hollister Gooding
Hollister Hagerman
Hollister Hazelton
Hollister Jerome
Hollister Kimberly
Hollister Murtaugh
Hollister Shoshone
Hollister Twin Falls
Hollister Wendell
Please identify the above data for each month, originating location and terminating location in the following format:
Monthly
# of # of Lines Percent of Toll
Messages Making Calls Access Lines Charges
0
1
2
3
4
5
6
7
8
9
10-15
16-30
31-45
46-60
61-100
101 & Over
Request No. 13: Please provide the following information for calls (excluding calling card, credit card, and operator-assisted) originating from Filer to the U S WEST exchanges and Hollister to the U S WEST exchanges listed above for each month reported:
A. Residence Accounts
1) total number of toll calls;
2) total toll minutes;
3) total toll revenue;
4) total number of access lines; and
5) number of customers.
B. Business Accounts
1) total number of toll calls;
2) total toll minutes;
3) total toll revenue;
4) total number of access lines; and
5) number of customers.
Additionally, please itemize the total number of calling card, credit card, collect and other operator-assisted calls for the same routes.
Request No. 14: How many Filer and Hollister customers have Foreign Exchange (FX) lines with the open end (dial tone) in each of the above listed U S WEST exchanges (in Request No. 12)? Please specify by originating exchange.
Request No. 15: How many 800/888 lines originate in the exchanges listed above for business customers and how many for residential customers?
Request No. 16: Please provide the number of business, residence, 800/888, FX lines and total message minutes for toll usage from January through June, 1997, in the above mentioned exchanges.
Request No. 17: How are calls currently transported from the Filer and Hollister exchanges to the U S WEST exchanges listed above? Where are the problem areas (if any) in these routes?
A. Please describe the interexchange facilities used to carry traffic between these exchanges.
B. Please include diagram(s) showing these call routes.
C. Does Filer Mutual plan to change or upgrade any of these facilities within the next five years?
Request No. 18: Please describe any facility upgrades or new equipment (including switch software) that would be required to implement EAS on the routes listed in Request
No. 12. Itemize the type of equipment/facilities, labor required and the estimated cost, and please provide working papers for such calculations.
Request No. 19: What is the design blocking probability for the interoffice trunking/switching alternatives itemized above? Will Filer or Hollister have any abandoned plant? Which facility alternatives does Filer or Hollister consider to be the most cost effective?
Request No. 20: Please list all access revenue generated from calls between the routes listed in Request No. 12. Itemize access revenue according to originating and terminating common carrier line charges, switching, transport minutes, billing and collection, and any additional access charges Filer Mutual assesses.
Request No. 21: Does Filer Mutual foresee any significant problems in providing the described EAS? Does Filer Mutual suggest any alternatives to EAS to provide toll relief to customers calling among the exchanges listed in Request No. 12?
Request No. 22: What optional calling plans does Filer Mutual offer on the routes listed above. Please include the rates and any discounts that apply.
Request No. 23: For each of the services listed in the previous question:
a. indicate the date that the service was first introduced.
b. provide the projections prepared by the marketing (or other appropriate Filer Mutual department or unit) of the anticipated demand for the service at the time it was introduced.
Request No. 24: Provide the following data:
a. The total number of residential (i) accounts and (ii) lines for each of the years 1994 through 1996.
b. The total number of residential accounts that subscribe to more than one line for each of the years 1994 through 1996.
c. The total number of residential accounts that Filer Mutual estimates to be eligible for Telephone Assistance Program.
d. The total number of residential accounts that are presently participating in the Telephone Assistance Program, separately by exchange.
e. Provide penetration rates (percentage of households subscribing to local exchange service) separately, again at the most disaggregated level for which data is available, for ten most densely populated areas.
f. The total number of basic (for this and all other references, basic business local exchange service refers to small business customers with five access lines or less as defined in Idaho Code 62-603(8)) business local exchange service (i) accounts and (ii) lines for each of the years 1994 through 1996.
Request No. 25: Provide penetration rates separately for residence and business customers for each of the years 1994 through 1996 for each of the following services:
a. three-way calling
b. call waiting
c. caller identification
d. repeat dial
e. voice messaging service
f. ring identification
g. speed calling
h. any other services identified in response to subpart (b) of previous question. (Request No. 24)
Request No. 26: Please provide any and all workpapers explaining how the stimulation factor of 3 was derived (R. Hendershot (Di) page 10, line 3).
Request No. 27: Please provide the total number of access lines and revenue from those lines, that serve Nevada along with all supporting documentation and working papers.
Request No. 28: Please provide all working papers associated with Filer Mutuals application for EAS, including but not limited to Board of Director Minutes pertaining to the final vote for such.
Request No. 29: Please provide working papers that show the actual additional capital requirements of $8,000 or less for reconfiguring Filer Mutual for the implementation of EAS. (R. Hendershot (Di) page 8, line 6)
DATED at Boise, Idaho, this day of July 1997.
______________________________________
Brad Purdy
Deputy Attorney General
Technical Staff: Madonna Faunce
Carolee Hall
BP:MF/CH/jo/umisc\prodeq\filt971.lst
FIRST PRODUCTION REQUEST
TO FILER MUTUAL 1 JULY 8, 1997