970923.docx

DONALD L. HOWELL, II
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 PETITION FROM)
RESIDENTS OF SWAN VALLEY, IRWIN)CASE  NO.  GNR-T-96-6
AND PALISADES REQUESTING EXTENDED)
AREA SERVICE (EAS) TO IDAHO FALLS)FIRST PRODUCTION
AND SURROUNDING COMMUNITIES, AND)REQUEST OF THE
THE TOWNS OF RIRIE, VICTOR AND)COMMISSION STAFF
DRIGGS.)TO U S WEST
)COMMUNICATIONS, INC.
___________________________________________)
The Staff of the Idaho Public Utilities Commission, by and through its attorney of  record, Donald L. Howell, II, 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          OCTOBER 21, 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 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 working papers, diskettes (3.5) and allunderlying formulas in Lotus 123 4.0 language.
Request No. 1:  Please supply the direct-dialed calling data for the months from April through July 1997 on a month-by-month basis using the format below for calls on each of the following routes.  Please accumulate all data by exchanges.
Originating ExchangesTerminating Exchanges
WayanAmerican Falls
WayanBancroft
WayanBlackfoot/Riverside
WayanDowney
WayanGrace/Thatcher
WayanIdaho Falls
WayanLava Hot Springs
WayanMcCammon
WayanMontpelier
WayanPocatello/Inkom
WayanPreston
WayanRexburg
WayanRigby/Lewisville-Menan
WayanRirie
WayanRoberts
WayanShelley/Firth
WayanSoda Springs
Please identify the above data for each month, originating location and terminating location in the following format:
Monthly
#   of# of LinesPercent of Toll
MessagesMaking CallsAccess LinesCharges
0
1
2
3
4
5
6
7
8
9
10-15
16-30
31-45
46-60
61-100
101 & Over
Request No. 2:  Please supply the direct-dialed calling data for the months from April through July 1997 on a month-by-month basis using the format below for calls on each of the following routes.  Please accumulate all data by exchanges.
Originating ExchangesTerminating Exchanges
IrwinAmerican Falls
IrwinBancroft
IrwinBlackfoot/Riverside
IrwinDowney
IrwinGrace/Thatcher
IrwinIdaho Falls
IrwinLava Hot Springs
IrwinMcCammon
IrwinMontpelier
IrwinPocatello/Inkom
IrwinPreston
IrwinRexburg
IrwinRigby/Lewisville-Menan
IrwinRirie
IrwinRoberts
IrwinShelley/Firth
IrwinSoda Springs
Please identify the above data for each month, originating location and terminating location in the following format:
Monthly
#   of# of LinesPercent of Toll
MessagesMaking CallsAccess LinesCharges
0
1
2
3
4
5
6
7
8
9
10-15
16-30
31-45
46-60
61-100
101 & Over
Request No. 3:  Please provide the following information for calls (excluding calling card, credit card, and operator-assisted) originating from Irwin terminating into the U S WEST exchanges also include Wayan to the U S WEST exchanges listed above for each month reported:
A.  Residence Accounts
1)total number of toll calls;
2)total toll minutes;
3)total toll revenue;
B.  Business Accounts
1)total number of toll calls;
2)total toll minutes;
3)total toll revenue;
Additionally, please itemize the total number of calling card, credit card, collect and other operator-assisted calls for the same routes.
Request No. 4:  How many Irwin and Wayan customers have Foreign Exchange (FX) lines with the open end (dial tone) in each of the above listed U S WEST exchanges (in Request Nos. 1 and 2)?  Please specify by terminating exchange.
Request No. 5:  Please provide the total number of access minutes, total message and toll minutes for toll usage from January through July 1997, from the U S WEST exchanges into the proposed EAS  (originating) exchanges in Request Nos. 1 and 2.
Request No. 6:  How are calls currently transported between the Irwin andWayan exchanges to the U S WEST exchanges listed above?  Where are the problem areas (if any) in these routes?
A.Please describe the interexchange facilities used to carry traffic between these exchanges.
B.Please explain any capital expenditures required for providing EAS to the Irwin and Wayan exchanges.
Request No. 7:  Please describe any facility upgrades or new equipment (including switch software) that would be required to implement EAS on the routes listed in Request Nos. 1 and 2.  Itemize the type of equipment/facilities, labor required and the estimated cost, and please provide working papers for such calculations.
Request No. 8:  Please list all access revenues generated by U S WEST for calls between the routes listed in Request Nos. 1 and 2.  Itemize access revenues according to originating and terminating access minutes, common carrier line charges, switching, transport minutes, billing and collection arrangements, and any additional charges U S WEST assesses to Silver Star.
Request No. 9:  Please provide any lost revenues U S WEST anticipates in facilitating the requested EAS routes in Request Nos. 1 and 2.  Itemize these lost revenues according to originating and terminating access minutes, common carrier line charges ( if any), switching, transport minutes, billing and collection arrangements, and any additional projected lost revenue that U S WEST anticipates.
Request 10: Please provide a diagram explaining how U S WEST anticipates routing the traffic between Irwin and Wayan into the Eastern Idaho EAS region.
Request No. 11:  Does U S WEST foresee any significant problems in facilitating the described EAS?  If so please itemize and provide all working papers to support such data.
DATED  at Boise, Idaho, this            day of September 1997.
______________________________
Donald L. Howell, II
Deputy Attorney General
Technical Staff:Carolee Hall
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