971222v1.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 COMPANY TO JOIN THE U S WEST
COMMUNICATIONS, INC. EASTERN IDAHO REGIONAL CALLING AREA.
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CASE NO. GNR-T-97-14
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO SILVER STAR
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 Silver Star Telephone Company provide the following documents and information on or before JANUARY 20, 1998.
This Production Request is to be considered as continuing, and Silver Star 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.  All responses to the following request must be accompanied with all workpapers 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 Exchange/Wire CenterTerminating Exchange
IrwinAshton
WayanIsland Park
St. Anthony including
    (Teton/Newdale wire centers)
Please identify 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) originating from Silver Star exchanges into the Fremont exchanges listed above for each month reported:
A.Resident 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 operated-assisted calls for the same routes.
Request No. 3:   How many customers have Foreign Exchange (FX) lines with the open end (dial tone) in each of the above listed Silver Star exchanges/wire centers in Request No.1?
Request No. 4:   How many 800/888 lines from Fremont terminate in the Silver Star exchanges listed above for business customers and how many for residential customers?
Request No. 5:   How are calls currently transported between the Fremont exchanges into the Silver Star 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 Silver Star plan to change or upgrade any of these facilities within the next five years?
Request No. 6:   Please list all access revenues generated from calls between the routes listed in Request No.1.  Itemize access revenue according to originating and terminating access minutes, common carrier line charges, switching, transport minutes, billing and collection arrangements, and any additional charges Silver Star assesses to Fremont.
DATED  at Boise, Idaho, this            day of December 1997
______________________________
Donald L. Howell, II
Deputy Attorney General
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