980331.docx

Donald L. Howell, II
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington
PO Box 83720
Boise, ID 83720-0074
Telephone:  [phone]
FAX:  [phone]
Attorney for Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION FROM RESIDENTS OF SWAN VALLEY, IRWIN AND PALISADES REQUEST­ING EXTENDED AREA SERVICE (EAS) TO ALL OF BONNEVILLE COUNTY, AND THE TOWNS OF RIRIE, VICTOR AND DRIGGS.
)
)
)
)
)
)
CASE NOS.  GNR-T-96-6
                      GNR-T-97-3
                      GNR-T-97-8

)
IN THE MATTER OF THE PETITION FROM RESIDENTS OF GRAY’S LAKE, WAYAN AND FREEDOM REQUESTING INCLUSION IN THE U S WEST COMMUNICATIONS EASTERN IDAHO CALLING REGION.

IN THE MATTER OF THE PETITION FROM RESIDENTS OF TETON COUNTY REQUEST­ING EXTENDED AREA SERVICE (EAS) TO THE GREATER IDAHO FALLS AREA.

)
)
)
)
)
)
)
)
)
)
)
)
STIPULATION OF U S WEST COMMUNICATIONS, INC. AND
IDAHO PUBLIC UTILITIES COMMISSION STAFF
COMES NOW U S WEST Communications, Inc. (U S WEST) and the Idaho Public Utilities Commission Staff (Staff) by and through their respective attorneys of record, and submit this Stipulation.
1.U S WEST and Staff stipulate that a hearing should be held to determine U S WEST’s cost of EAS in Case Nos. GNR-T-96-6, GNR-T-97-3, and GNR-T-97-8; as well as to develop a methodology to determine U S WEST’s cost of EAS in these and future EAS cases.
2.U S WEST further stipulates to withdraw its objections to the Stipulated Local Exchange Rates set forth in the Commission’s Proposed Order in the above referenced cases; withdraw the Affidavit of Mary S. Hobson filed in support of U S WEST’s Motion for Hearing and Memorandum in Opposition to Proposed Order and in Support of Motion for Hearing in Case Nos. GNR-T-96-6, GNR-T-97-3, and GNR-T-97-8; and to withdraw certain references in U S WEST’s Memorandum on pages 4, 5, and 16.(footnote: 1)
3.If the event that the Commission does not adopt this stipulation, the Staff and U S WEST each reserve their rights to fully litigate the issues encompassed in this Stipulation including U S WEST’s right to refile withdrawn materials and the Staff’s right to file a Motion to Strike the Affidavit, exhibits, and certain references contained the Company’s Supporting Memorandum, if necessary.
DISCUSSION
On file with the Commission is Staff’s Response to U S WEST’s Opposition to Proposed Order and Motion for Hearing filed March 27, 1998 which sets forth Staff’s recommendation that U S WEST be granted a hearing to consider U S WEST’s costs for implementing EAS in these cases and to establish a method for determining such costs in these and future EAS cases.  Staff’s Response at 2.
Insomuch as there is no disagreement between the Company and Staff that U S WEST should receive compensation, determined by an appropriate methodology, for its cost of implementing EAS, the Company and the Staff agree that a hearing should be scheduled to determine U S WEST’s compensation in the above referenced cases and to determine a methodology for compensation in pending and future EAS cases.  Staff and the Company have further agreed to submit, on or before April 10, 1998, to the Commission for its approval a proposed time line for scheduling such a hearing and related proceedings.  U S WEST and Staff respectfully petition the Commission for an order granting a hearing to determine methodology and compensation to U S WEST for its costs of implementing EAS.  
PRAYER
Based upon the Stipulation set out above, U S WEST and Staff respectfully request that the Commission grant a hearing and allow for the parties, on or before April 10, 1998, to submit a time line for conducting that hearing and relevant proceedings.
U S WEST withdraws its objection to the stipulated local exchange rates set forth in the Proposed Order; the Affidavit of Mary S. Hobson filed in Support of U S WEST’s Motion for Hearing and Opposition to Proposed Order in Case No. GNR-T-96-6, GNR-T-97-3, and GNR-T-97-8; and withdraws the aforementioned references in the Memorandum as described above.
Respectfully submitted this   31st    day of March 1998.
Peter Butler
U S WEST, Inc.
1600 7th Avenue, Suite 3206
Seattle, WA 98191
and

Robin L. Denison
Mary S. Hobson
Stoel Rives LLP
Attorneys Representing
U S WEST Communications, Inc.
and

Donald L. Howell, II
Deputy Attorney General
Attorney for
Idaho Public Utilities Commission
bls/N-gnrt966.dh5
FOOTNOTES
1:
U S WEST agrees to withdraw the following text in its Memorandum: (1) page 4,  line 5 of the full paragraph (beginning “Specifically, U S WEST . . .”) through the end of the paragraph; (2) page 4, the fifth line from the bottom of the page (beginning with “At the settlement conference, . . .”) and continuing through the Affidavit citation on page 5 and inserting the following text “U S WEST has raised the question of its own compensation in connection with the conversion of toll to local service with Staff and believes now is the time to address that issue.”; and (3) page 16, the text in the last full paragraph (beginning with “the possibility”  through the word “herewith” in that sentence).