970925US.docx

BRAD PURDY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO  83720-0074
[phone]
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 PETITIONS)
REQUESTING EXTENDED AREA SERVICE)CASE  NO.  GNR-T-96-5
(EAS) BETWEEN ARBON AND AMERICAN)
FALLS, ARBON AND POCATELLO, AND  )SECOND PRODUCTION
BETWEEN ROCKLAND AND AMERICAN )REQUEST OF THE
FALLS. )COMMISSION STAFF
)TO U S WEST
)COMMUNICATIONS, INC.
___________________________________________)
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Brad Purdy, Deputy Attorney General, requests that U S WEST Communications, Inc. provide the following documents and information, pursuant to Rule 225 of the Idaho Public Utilities Commission’s Rules of Procedure, IDAPA 31.01.01, on or before WEDNESDAY,
OCTOBER 8, 1997.
This Production Request is to be considered as continuing, and U S WEST Communications, Inc. 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.
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 questions below that are the results of calculations or are the result of supporting data, please provide the information with underlying formulas on hard copy and on a 3 1/2" diskette in WordPerfect 6.0 or Lotus 1-2-3 release 4.0 or Excel release 5.0.
Request No. 17:In your responses to Staff’s First Production Request, Request Nos. 007 (routing), 008 (upgrades), 009 (blocking), and 013 (stimulation), you indicated that you could provide a network analysis for proposed EAS routes in Idaho in approximately 8 to 10 weeks.  Is this report now available?  Please provide a copy of U S WEST’s network analysis.  Also provide a worksheet showing an itemization of the costs of implementing the requested EAS regions and lost revenue U S WEST will incur in providing the proposed EAS.  Provide supporting calculations on a spreadsheet and on a diskette.
Request No. 18:The following three questions request cost data for three different scenarios.  Please itemize the material requested, and also provide spreadsheet and diskette supporting data for each scenario:
(a)  Please provide facilities/equipment/software costs if the Commission orders an EAS for calls from American Falls and Pocatello to Arbon and Rockland.
(b)  Please provide facilities/equipment/software costs if the Commission orders an EAS for calls from American Falls, Pocatello, Blackfoot and Idaho Falls to Arbon and Rockland.  Please itemize the type of equipment/facilities, the labor required and the estimated cost.
(c)  Please provide facilities/equipment/software costs if the Commission orders an EAS for calls from the entire U S WEST southern Idaho EAS region to Arbon and Rockland.  Please itemize the type of equipment/facilities, the labor required and the estimated cost.
Request No. 19:Staff’s Request No. 10 requested a list of access revenue generated from calls between these routes.  U S WEST replied that it cannot provide access revenues on a route specific basis.
(a)  Please provide the “average” distance sensitive transport costs which Staff should take from the tariff to use in an access minute calculation in order to arrive at a reasonable access (except billing and collection) and the revenue for these calls.
(b)  What is U S WEST’s billing and collection rate per call?
(c)  What is U S WEST’s overall average length of call on these routes?
(d)  Can U S WEST provide detail regarding access revenue generated for calls on a company-specific basis. . . That is, can U S WEST provide data regarding originating and terminating access revenue paid to Rockland Telephone Company.  If it is available, please provide the requested data and also showing billing and collection revenue/expense.  Also please provide supporting calculations on a spreadsheet and on a diskette.
(e)  Please provide a conversion factor that Staff can apply to billed toll minutes in order to achieve a reasonable number of access minutes.
DATED  at Boise, Idaho, this            day of September 1997.
______________________________________
Brad Purdy
Deputy Attorney General
Technical Staff:B. Brown
BP:BB:jo\umisc\prdreq\gnrt965u.sw2