200406251st Request of Staff to CenturyTel.pdf

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LISA NORDSTROM
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5733
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UTILJTIES COr1MJSSION
Street Address for Express Mail:
472 W WASHINGTON
BOISE ill 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION FROM
THE RESIDENTS OF THE SHOUP AREA
REQUESTING EXTENDED AREA SERVICE
INTO SALMON, IDAHO.FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO CENTURYTEL OF IDAHO
CASE NO. GNR-01-
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record
Lisa Nordstrom, Deputy Attorney General, requests that CenturyTel of Idaho (CenturyTel;
Company) provide the following documents and information on or before FRIDAY, JULY 23
2004.
This Production Request is to be considered as continuing, and CenturyTel 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.
For each item, please indicate the name of the person(s) preparing the answers, along with
FIRST PRODUCTION REQUEST
TO RURAL TELEPHONE COMPANY JUNE 24, 2004
the job title of such person(s) and the witness who can sponsor the answer at hearing. Reference
IDAPA 31.01.01.228. For documents provided please include the name and phone number of
the person preparing the document, and the name, location and phone number of the record
holder.
For all responses to the following requests, please provide all workpapers, diskettes
(3.5 in.) and all underlying formulas in Excel (version 5) language.
Request No.1: The Commission is considering the EAS requested by the approximately
50 residents of Rural Telephone s Shoup exchange (prefix 394) into the CenturyTel exchanges of
North Fork and Salmon. Please describe any facility upgrades or new equipment that would be
required by CenturyTel to implement this EAS. Itemize the type of equipment/facilities, labor
required and the estimated cost. Additionally, please describe and document any other costs or
lost revenues that CenturyT el would seek to recover if this EAS were granted.
Request No.2: Does CenturyTel foresee any significant problems in providing the
described EAS? Does CenturyTel suggest any alternatives to this EAS?
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DATED at Boise, Idaho, this eX'! day of June 2004.
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Lisa N ordstro
Deputy Attorn
Technical Staff:Doug Cooley
umisc/prodreq/gnrtO3.llndc prd reg 1 century
FIRST PRODUCTION REQUEST
TO RURAL TELEPHONE COMPANY JUNE 24, 2004
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 24TH DAY OF JUNE 2004
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO CENTURYTEL OF IDAHO IN CASE NO. GNR-01-
BY MAILING A COpy THEREOF POSTAGE PREPAID TO THE FOLLOWING:
MIKE FOX
CENTURYTEL OF IDAHO INC
PO BOX 4065
MONROE LA 71211
MORGAN W RICHARDS JR
MOFF ATT THOMAS ET AL
PO BOX 829
BOISE ill 83701-0829
JAMES R MARTELL
RURAL TELEPHONE COMPANY
704 W MADISON AVE
GLENNS FERRY ID 83623
CERTIFICATE OF SERVICE