HomeMy WebLinkAbout970207.docxWELDON B. STUTZMAN
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 FROM)
CITIZENS IN ABERDEEN, IDAHO)CASE NO. GNR-T-96-7
REQUESTING EXTENDED AREA SERVICE )
(EAS) BETWEEN ABERDEEN AND AMERI-)FIRST PRODUCTION
CAN FALLS, AND ABERDEEN AND )REQUEST OF THE
BLACKFOOT.)COMMISSION STAFF TO
)CITIZENS TELECOMMU-
___________________________________________)NICATIONS COMPANY
OF IDAHO
The Staff of the Idaho Public Utilities Commission, by and through its attorney of
record, Weldon B. Stutzman, Deputy Attorney General, requests that Citizens Telecommunications Company of Idaho 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 FEBRUARY 28, 1997.
This Production Request is to be considered as continuing, and Citizens Telecommunications Company of Idaho 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 show 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.
In answering the following questions, please include in your data for exchanges all wire centers and communities within the exchange. For example, traffic data for the Pocatello exchange should include traffic data to and/or from Chubbuck and Fort Hall.
Request No. 1:Please supply the direct-dialed calling data for the months of July, August and September 1996 on a month-by-month basis using the format below for calls from Aberdeen to each of the following exchanges:
Idaho Falls
Rigby
Ririe
Roberts
Blackfoot/Riverside
Shelley/Firth
Rexburg
Pocatello/Inkom
American Falls
Lava Hot Springs
McCammon
Downey
Grace/Thatcher
Bancroft
Soda Springs
Please list the above data for each month, originating location and terminating location in the following format:
Monthly
# of # of Lines Percent 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 provide the following information for calls (excluding calling card, credit card and operator-assisted) from Aberdeen to the exchanges listed in Request No. 1 for each month reported:
A.Residence Accounts
1) total number of toll calls;
2) total toll minutes;
3) total toll revenue;
4) total number of access lines; and
5) number of customers.
B.Business Accounts
1) total number of toll calls;
2) total toll minutes;
3) total toll revenue;
4) total number of access lines; and
5) number of customers.
Additionally, please itemize the total number of calling card, credit card, collect and other operator-assisted calls for the same routes.
Request No. 3:Please provide the total number of messages and minutes by month for each exchange for each of the months.
Request No. 4:How many Foreign Exchange (FX) lines does the Aberdeen exchange provide with the open end (dial tone) in the U S WEST exchanges listed in Request No. 1? Please specify by terminating exchange.
Request No. 5:How many 800 lines does the Aberdeen Exchange provide? Please provide the number of business 800 lines and the number of residential 800 lines.
Request No. 6:Please provide the number of business, residence, 800, FX lines and toll usage by year for the years 1991 through 1995 inclusive in theses exchanges.
Request No. 7:How are calls currently transported from the Aberdeen exchange to the exchanges listed in Request No. 1? 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 include diagram(s) showing these call routes.
C.Does Citizens plan to change or upgrade any of these facilities within the next five years?
Request No. 8:Please describe any facility upgrades or new equipment (including switch software) 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. 9:What is the design blocking probability for the interoffice trunking/switching alternatives itemized above? Will Citizens have any abandoned plant? Which facility alternatives does Citizens consider most cost effective?
Request No. 10:Please list the access revenue generated from calls between the routes listed 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 Citizens assesses.
Request No. 11:Please itemize the toll revenue generated from calls between the routes listed in Request No. 1.
Request No. 12:How is Citizens compensated for calls it carries between the routes listed in Request No. 1?
Request No. 13:Did Citizens use a stimulation factor in its estimates for upgrading facilities? If so, what factor was used? Describe how this stimulation factor was derived.
Request No. 14:Does Citizens foresee any significant problems in providing the described EAS? Does Citizens suggest any alternatives to EAS to provide toll relief to customers calling among the exchanges listed in Request No. 1?
Request No. 15:Does Citizens support the provision of EAS for the routes listed in Request No. 1? Why or why not?
Request No. 16:What optional calling plans does Citizens offer on the routes listed in Request No. 1? Please provide the rates and any discounts that apply.
DATED at Boise, Idaho, this day of February 1997
______________________________________
Weldon B. Stutzman
Deputy Attorney General
Technical Staff:B. Brown
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