200406251st Request of Staff to Rural Telephone.pdf

LISA NORDSTROM
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5733
ECEfVED 0fLED
ZUU4 JUt~ 24 Pi'iJ2: 11
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UTILITIES COMt1fSSlON
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 SHOUP AREA
REQUESTING EXTENDED AREA SERVICE
INTO SALMON, IDAHO.FIRST PRODUCTION
REQUEST OF THE
COMMISSION- STAFF
TO RURAL TELEPHONE
COMPANY
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 Rural Telephone Company (Rural)
provide the following documents and information on or before FRIDAY, JULY 23, 2004.
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
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. Reference
FIRST PRODUCTION REQUEST
TO RURAL TELEPHONE COMPANY JUNE 24, 2004
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: How are calls currently transported from the Shoup exchange to the
CenturyTel exchanges of North Fork and Salmon? Are there any plant/facility problems or
limitations in this route? Does Rural Telephone plan to change or upgrade any of these facilities
within the next five years?
Request No.2: 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.3: 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.4: 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.
Request No.5: 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.6: Does Rural Telephone support the provision ofEAS for the routes
described in Request No.1? Why or why not?
FIRST PRODUCTION REQUEST
TO RURAL TELEPHONE COMPANY JUNE 24 2004
Request No.7: Staffhas calling data from Shoup to the North Fork and Salmon
exchanges during May 2001. Staff believes this calling data continues to reflect the number of
customers and calling traffic for this case. Does Rural Telephone agree or should new calling
data be gathered?
Request No.8: To your knowledge, do customers in the Shoup exchange have access to
local internet service?
DATED at Boise, Idaho, this
~y
of June 2004.
isa N ordstro
Deputy Atto
Technical Staff:Doug Cooley
umisc/prod req/gnrtO3.1lndc prod reg 1 rural
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 RURAL TELEPHONE COMPANY, IN CASE NO.
GNR-01-, BY MAILING A COpy THEREOF POSTAGE PREPAID, TO THE
FOLLOWING:
MIKE FOX
CENTUR YTEL OF IDAHO INC
PO BOX 4065
MONROE LA 71211
MORGAN W RICHARDS JR
MOFFATT THOMAS ET AL
PO BOX 829
BOISE ID 83701-0829
JAMES R MARTELL
RURAL TELEPHONE COMPANY
704 W MADISON AVE
GLENNS FERRY ID 83623
SEC
CERTIFICATE OF SERVICE