970926.docx

DONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
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 OF CUSTOMERS OF THE FREMONT TELCOM TELEPHONE COMPANY TO JOIN THE EASTERN IDAHO EXTENDED SERVICE CALLING AREA.
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CASE NO. GNR-T-97-14
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO FREMONT TELCOM
TELEPHONE COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Donald L. Howell, II, Deputy Attorney General, requests that Fremont Telcom Telephone Company provide the following documents and information on or before OCTOBER 20, 1997.
This Production Request is to be considered as continuing, and Fremont Telcom 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.
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 consolidate traffic data to and/or from Chubbuck and Inkom. All responses to the following request must be accompanied with all working papers and spreadsheets (with formulas on computer media).  All computer media used must be on diskettes (3.5") using Lotus 123 (4.0) or Excel 5.0 language.
Request No. 1:  Please supply the direct-dialed calling data for the months from April through June, 1997 on a month-by-month basis using the format below for calls on each of the following routes:
Originating ExchangeTerminating Exchange
St. AnthonyAmerican Falls
St. AnthonyBancroft
St. AnthonyBlackfoot/Riverside
St. AnthonyDowney
St. AnthonyGrace/Thatcher
St. AnthonyIdaho Falls
St. AnthonyLava Hot Springs
St. AnthonyMcCammon
St. AnthonyMontpelier
St. Anthony Paris
St. AnthonyPocatello/Inkom/ChubbuckSt. AnthonyPreston/Dayton/FranklinSt. AnthonyRexburg
St. AnthonyRigby/Lewisville/MenanSt. AnthonyRirie
St. AnthonyRoberts
St. AnthonyShelley/Firth
St. AnthonySoda 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 provide the following information for calls (excluding calling card, credit card, and operator-assisted) originating from St. Anthony 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;
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 supply the direct-dialed calling data for the months from April through June 1997 on a month-by-month basis using the format below for calls on each of the following routes:
Originating ExchangeTerminating Exchange
AshtonAmerican Falls
AshtonBancroft
AshtonBlackfoot/Riverside
AshtonDowney
AshtonGrace/Thatcher
AshtonIdaho Falls
AshtonLava Hot Springs
AshtonMcCammon
AshtonMontpelier
Ashton Paris
AshtonPocatello/Inkom/ChubbuckAshtonPreston/Dayton/FranklinAshtonRexburg
AshtonRigby/Lewisville/MenanAshtonRirie
AshtonRoberts
AshtonShelley/Firth
AshtonSoda 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. 4:  Please provide the following information for calls (excluding calling card, credit card, and operator-assisted) originating from Ashton 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;
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. 5: Please supply the direct-dialed calling data for the months from April through June 1997 on a month-by-month basis using the format below for calls on each of the following routes:
Originating ExchangeTerminating Exchange
Island Park American Falls
Island ParkBancroft
Island ParkBlackfoot/Riverside
Island ParkDowney
Island ParkGrace/Thatcher
Island ParkIdaho Falls
Island ParkLava Hot Springs
Island ParkMcCammon
Island ParkMontpelier
Island Park Paris
Island ParkPocatello/Inkom/ChubbuckIsland ParkPreston/Dayton/FranklinIsland ParkRexburg
Island ParkRigby/Lewisville/MenanIsland ParkRirie
Island ParkRoberts
Island ParkShelley/Firth
Island ParkSoda 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. 6:  Please provide the following information for calls (excluding calling card, credit card, and operator-assisted) originating from Island Park 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;
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. 7:  How many customers have Foreign Exchange (FX) lines with the open end (dial tone) in each of the originating Fremont exchanges (Ashton, Island Park, St. Anthony).
Request No. 8:  How many 800/888 lines terminate in the Fremont exchanges listed above for business customers and how many for residential customers?
Request No. 9:  Please provide the number of business, residence, 800/888, FX lines and total message minutes for toll usage from April through June 1997, in the above mentioned Fremont exchanges.
Request No. 10:  How are calls currently transported from the Fremont 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 include diagram(s) showing these call routes.
C.Does Fremont Telcom plan to change or upgrade any of these facilities within the next five years?
Request No. 11:  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, 3, and 5. Itemize the type of equipment/facilities, labor required and the estimated cost, and please provide working papers for such calculations.
Request No. 12:  What is the design blocking probability for the interoffice trunking/switching alternatives itemized above?  Will Fremont Telcom have any abandoned plant?  Which facility alternatives does Fremont Telcom consider to be the most cost effective?
Request No. 13:  Please list all access revenue generated from calls between the routes listed in Request Nos. 1, 3, and 5.  Itemize access revenue according to originating and terminating common carrier line charges, switching, transport minutes, billing and collection, and any additional access charges Fremont Telcom assesses.
Request No. 14:  Does Fremont Telcom foresee any significant problems in providing the described EAS?  Does Fremont Telcom suggest any alternatives to EAS to provide toll relief to customers calling among the exchanges listed in Request Nos. 1, 3, and 5?
Request No. 15:  What optional calling plans does Fremont Telcom offer on the routes listed above?  Please include the rates and any discounts that apply.
Request No. 16:  Does Fremont Telcom support provision of EAS on these routes?  Under what conditions?
DATED  at Boise, Idaho, this            day of September 1997
______________________________
Donald L. Howell, II
Deputy Attorney General
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