HomeMy WebLinkAbout970926RK.docxBRAD PURDY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-0300
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 ROCKLAND
___________________________________________) TELEPHONE COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Brad Purdy, Deputy Attorney General, requests that Rockland Telephone Company 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 Rockland 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.
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.
For all of the traffic data requested below, please use the same format that was requested in Request No. 1.
Request No. 17:Request No. 1 requested specified traffic data to be provided by exchange. In come instances, this data was provided in multiple sections, by different CLLI codes, making it impossible to determine the distribution of calls to exchanges with multiple CLLI codes.
(a) Please provide the same data that was provided in response to Staff’s First Production Request for the combined data for each of the following exchanges:
American Falls(AMERICNGID, AMERICNFID, AMERIFLLID)
Blackfoot/Riverside(BLACKFOTID, BLACKFOOID, RIVERSIDID)
Preston(DAYTON ID, PRESTON ID, and whatever you use for Franklin)
Shelley/Firth(FIRTH ID, SHELLEY ID)
Grace/Thatcher(GRACE ID, THATCHERID)
Idaho Falls(IDAHOFALID, IDAHOFLSID)
Pocatello/Inkom(INKOM ID, POCATELLID)
Rigby(RIGBY ID, LEWISVILID, and whatever you use for Menan)
(b) Why do these exchanges have different CLLI codes?
Request No. 18:Call data received from Rockland reports traffic to Arbon from Rockland and traffic to Rockland from Arbon as follows:
CallsBilled RevAccess MinsAccess Rev
Arbon to Rockland
August31$16.41130.1$ 8.39
September29$16.01118.2$ 7.62
October47$26.48209.2$13.51
Rockland to Arbon
August39$24.46163.2$10.53
September31$24.92177.9$11.48
October33$23.23182.4$11.77
(a) Are calls between Arbon and Rockland toll calls?
(b) What is the charge for a call between Arbon and Rockland? Please specify charges for each time-of-day discount zone.
(c) Does U S WEST carry these calls?
(d) Does Arbon or Rockland impute any access charges or other cost of providing these calls to itself? Please provide workpapers and diskette.
(e) Please provide itemized worksheets showing calculations that lead to the net revenue (e.g. actual and imputed revenue minus actual and imputed costs, including costs for billing and collection) for this traffic.
Request No. 19:The traffic data submitted for Rockland’s show calls from Rockland to Rockland as follows:
August74$22.92102.5$ 6.61
September62$19.91 92.6$ 5.97
October70$12.92 49.7$ 3.21
(a) What kind of billable calls are made from Rockland to Rockland?
(b) Does U S WEST carry these calls?
(c) Does Rockland impute any access charges or other cost of providing these calls to itself? Please provide workpapers.
(d) Please provide itemized worksheets showing calculations that lead to the net revenue (e.g. actual and imputed revenue minus actual and imputed costs, including costs for billing and collection) for this traffic.
Request No. 20:Staff’s First Production Request asked for traffic from Rockland and Arbon to Bancroft and Roberts. No data was provided. Please provide data for these routes in the same format as shown in Request No. 1. If there was no traffic, please so state.
Request No. 21:Staff appreciates that Rockland provided traffic data from Rockland and Arbon to Montpelier and Preston, even though they were not included in Staff’s request. There was no data provided for calls from Arbon to Montpelier. Please provide this data; if there were no calls, please so state.
Request No. 22:Rockland provided Billed Revenue and Access Revenue in response to Staff’s Request Nos. 1 and 2.
(a) Does Billed Revenue include rounded minutes? Night/evening discounts? Bad debt writeoffs? What percentage of toll revenue is bad debt?
(b) Did Rockland report total access minutes, including busy/no answer calls, test calls, etc.
(c) Did Rockland receive access revenue for all of these minutes?
(d) How many calls/minutes were made during peak periods? How many calls/minutes were made during off-peak periods?
(e) Does Rockland bill for and collect for toll minutes? Does Rockland keep the collections for toll minutes?
(f) Please provide, for each line item you have provided in response to Staff’s Request No. 1:
(1)the actual toll revenue (including evening and night discounts) for which you billed if different from what was reported;
(2)actual originating access revenue (including billing and collection revenue) you receive from U S WEST and all other interexchange carriers;
(3)peak and off-peak access revenue for each distribution shown in your Response No. 1, and
(4)terminating access revenue you receive from interexchange carriers other than U S WEST.
Request No. 23:For calls from the U S WEST exchanges listed in Request No. 1 into Rockland and Arbon, please list the amount of terminating access revenue you booked from
U S WEST for the months you are reporting.
Request No. 24:Staff’s Request No. 2, requested, among other things, the total number of lines and the total number of customers for business and residential classes. Rockland referred to its Exhibit A, which provided the total number of lines. Please provide the total number of business customers and the total number of residential customers that use the access lines you reported.
Request No. 25:Staff’s Request No. 3 asked for the total number of messages and minutes for each of the three reporting months by exchange. The response to this question was expected to permit Staff to calculate the amount of calls, average access minutes per call and revenue that would be removed from Rockland exchanges by the proposed EAS as a percent of the company’s total toll revenue. Staff does not understand the response.
(a) The number of lines (in the October 1 report for example) was 263 and 73 for Rockland and Arbon respectively in the traffic data report. The “total” report that responds to Request No. 3 shows the number of lines to be 667 and 234 lines, respectively. Why are these numbers different?
(b) The other data is equally inconsistent. Please explain and provide worksheets and data to support the calculations.
Request No. 26:Staff’s Request No. 4 asks that Rockland specify by originating exchange and terminating exchange the number of FX lines. Rockland reported one Rockland customer has an FX line, but does not specify the terminating exchange. In what exchange does this Rockland customer’s FX terminate?
Request No. 27:Staff’s Request No. 8 requested that an itemization of the type of equipment/facilities, labor required and estimated costs that would be required to provide the proposed EAS. Rockland responded that there would only be software and programming costs. Please itemize the software and programming costs you would incur, along with any other costs Rockland may have forgotten to mention, such as federal Universal Service Fund support. Please provide worksheets and calculations.
Request No. 28:Staff’s Request No. 10 requested a list of all access revenue generated from calls listed in Request No. 1 according to originating and terminating CCL, switching, transport, B&C and any additional charges. Rockland’s response referred Staff to the response to Request No. 1 where the access revenue was apparently calculated by multiplying access minutes by .0645 rates.
(a) Please itemize the individual rates for CCL, switching, transport and B&C that you used to arrive at the .0645 multiplier.
(b) Also please show how many peak and how many off-peak minutes were provided in each of the specified months.
(c) Please provide spreadsheets and supporting diskettes showing the calculations you used to report the access revenue earned by the CCL, switching, transport and B&C minutes, for peak and off-peak minutes, for each of the three months for which you are reporting. (Do not include the terminating revenue requested in Request No. 23 above.
Request No. 29:Staff’s Request No. 12 asks how Rockland is compensated for the calls between the specified routes, and Rockland responded simply that it was compensated through Carrier Access Billing. Please confirm whether the following information is correct:
Originating calls
Rockland originates a call and sends it to USW.
USW transports and terminates or passes on the call.
USW pays Rockland for originating access and billing and collection.
Rockland bills the end-user customer for the call (incurring billing and collection
expenses).
Rockland collects the toll revenue and gives it to USW.
If this scenario is correct, then Rockland’s net revenue for originating a call is a result of:
Originating access fees (including B&C revenue) paid by toll carriers
less
B&C expenses.
Is this correct? If it is not correct, please explain the proper scenario.
Terminating Calls
USW originates a call and terminates it in the Rockland exchange.
USW advises Rockland (monthly) of the amount it owes for terminating access charges.
USW pays Rockland for terminating access.
If this scenario is correct, then Rockland’s net revenue for terminating a call is:
Terminating access fees paid by toll carriers.
Is this correct? If it is not correct, please explain the proper scenario.
Request No. 30:In Rockland’s Response No. 14, Rockland mentioned it cannot accurately calculate the interstate revenue until the FCC finishes its proceedings on the USF and access charge reform. Now that the first report and order has been issued, please provide, in detail, how the interstate revenue is to be calculated, how much it will be and when any modifications to the plan go into effect. Once again, Staff would remind Rockland that we are looking for the costs that will need to be reimbursed to Rockland to make it whole. Anything that you omit in your responses to Staff will result in erroneous estimates and possible shortfalls in the calculations the Commission makes to reimburse Rockland. Please provide the information on spreadsheets and on diskette.
Request No. 31:Please indicate whether the data you have supplied includes toll carriers other than U S WEST. If not, please estimate how much additional traffic is carried by other toll carriers. Is the billing and access fee arrangement for other carriers the same as the arrangement with U S WEST? If not, please describe the differences.
Request No. 32:Please send a Rockland/Arbon telephone directory.
Request No. 33:What is Rockland’s total billing and collection revenue? What is Rockland’s billing and collection revenue net of U S WEST?
DATED at Boise, Idaho, this day of September 1997.
______________________________________
Brad Purdy
Deputy Attorney General
Technical Staff:B. Brown
BP:BB:jo\umisc\prdreq\gnrt965r.ok2