HomeMy WebLinkAbout200402051st Request of Staff to Rural Telephone.pdfLISA NORDSTROM
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-0314
IDAHO BAR NO. 5733
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Street Address for Express Mail:
472 W WASHINGTON
BOISE ID 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION FROM
THE RESIDENTS OF THE THREE CREEK
AREA FOR EXTENDED AREA SERVICE
INTO THE MAGIC V ALLEY REGIONAL
CALLING AREA.
CASE NO. GNR-00-
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO RURAL TELEPHONE
COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record
Lisa Nordstrom, Deputy Attorney General, requests that Rural Telephone Company (Rural)
provide the following documents and information on or before FRIDAY, MARCH 12, 2004.
The Company is reminded that responses pursuant to Commission Rules of Procedure
must include the name and phone number of the person preparing the document, and the name
location and phone number of the record holder. Reference IDAP A 31.01.01.228.
This Production Request is to be considered as continuing, and Rural 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
FIRST PRODUCTION REQUEST
TO RURAL TELEPHONE COMPANY FEBRUARY 5 , 2004
preparing the documents; 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. For all
responses to the following requests, please provide all appropriate workpapers, electronic
files and underlying formulas in Excel format.
Request No.1: Please supply the direct-dialed calling data for the months of November
2003 through January 2004 on a month-by-month basis using the format below for each of the
following:
Originating Exchange
Three Creek
Three Creek
Three Creek
Three Creek
Three Creek
Three Creek
Three Creek
Three Creek
Three Creek
Three Creek
Three Creek
Three Creek
Three Creek
Three Creek
Three Creek
Three Creek
Three Creek
Terminating Exchange
Twin Falls
Jerome
Richfield
Bliss
Buhl
Castleford
Hollister
Dietrich
Eden
Gooding
Hagerman
Hazelton
Kimberly
Murtaugh
Shoshone
Wendell
Filer
If the direct-dialed calling data for the listed exchanges is not available for this time period
please provide the most recent data available.
FIRST PRODUCTION REQUEST
TO RURAL TELEPHONE COMPANY F~BRUARY 5, 2004
Please identify the above data for each month, originating location and terminating
location in the following format:
Monthly
#of
Messages
10-
16-
31 & over
# of Lines
Making Calls
Percent of
Access Lines
Toll
Charges
Request No.2: Please provide the following information for calls (excluding calling
card, credit card and operator-assisted) originating from the exchanges described in Request
No. I for each month reported:
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.
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 for the same months.
FIRST PRODUCTION REQUEST
TO RURAL TELEPHONE COMPANY FEBRUARY 5, 2004
Request No.3: As of January 1 , 2004, how many Three Creek customers had Foreign
Exchange (FX) lines between the exchanges listed in Request No.1? Please specify by
originating exchange and terminating exchange. If the data is not available as of January 1 , 2004
please provide the most recent count.
Request No.4: As of January 1 , 2004, how many toll-free "800" lines originate in the
Three Creek exchange for Three Creek business and residential customers respectively? If the
data is not available as of January 1, 2004, please provide the most recent count.
Request No.5: How are calls currently transported from the Three Creek exchange to
the exchanges of the Magic Valley Calling Area listed in Request No.1? Are there any plant or
facility problems or limitations in these routes? Does Rural Telephone plan to change or upgrade
any of these facilities within the next five years?
Request No.6: Please describe any facility upgrades or new equipment that would be
required to implement EAS on the routes listed in Request No.1. Itemize the type of
equipment/facilities, labor required and the estimated cost.
Request No.7: Please list all access revenue generated from calls between the routes
described in Request No.1. Itemize access revenue according to originating and terminating
common carrier line charges, switching, transport minutes, billing and collection, and any
additional access charges Rural Telephone assesses.
Request No.8: Did Rural Telephone use a stimulation factor in its estimates for
facilities upgrades? If so, what factor was used? Describe how this stimulation factor was
derived.
FIRST PRODUCTION REQUEST
TO RURAL TELEPHONE COMPANY FEBRUARY 5 , 2004
Request No.9: Does Rural Telephone foresee any significant problems in providing the
EAS described in Request No.1? Does Rural Telephone suggest any alternatives to EAS among
the exchanges described in Request No.
Request No. 10: Does Rural Telephone support the provision ofEAS for the routes
described in Request No.1? Why or why not?
./ -ij
DATED at Boise, Idaho, this day of February 2004.
/ ~
Technical Staff:Doug Cooley
i:umisc:prodreq/gnrtOOAl.lcdc
FIRST PRODUCTION REQUEST
TO RURAL TELEPHONE COMPANY FEBRUARY 5, 2004
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 5TH DAY OF FEBRUARY 2004
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO RURAL TELEPHONE IN CASE NO. GNR-00-, BY
MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
MARY S HOBSON
STOEL RIVES
101 S CAPITOL BLVD STE 1900
BOISE ID 83702-5958
WENDY MOSER
QWEST CORPORATION
1801 CALIFORNIA ST STE 5100
DENVER CO 80202
CLAVIN K SIMSHA W
CENTURYTEL OF THE GEM STATE INC
PO BOX 9901
VANCOUVER W A 98668
KATHY TAYLOR
CENTURYTEL OF THE GEM STATE INC
290 N MAIN
KALISPELL MT 59901
JAMES R MARTELL
RURAL TELEPHONE CO
704 W MADISON AVE
GLENNS FERRY ID 83623
DA VID A CARPENTER
RURAL TELEPHONE CO
41241 MANITAU RD SE
STAYTON OR 97383-9709
FILER MUTUAL TELEPHONE
405 MAIN ST
PO BOX 89
FILER ID 83328-0089
HARLAN MINK
HOUSE CREEK RANCH
ROGERSON ID 83302
CERTIFICATE OF SERVICE