971222v3.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 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 on or before JANUARY 20, 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.
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 terminating routes individually:
Originating Exchange/Wire CenterTerminating Exchange
American FallsAshton, Island Park, St. Anthony/Teton wire center
BancroftAshton, Island Park, St. Anthony/Teton wire center
Blackfoot/RiversideAshton, Island Park, St. Anthony/Teton wire centerDowneyAshton, Island Park, St. Anthony/Teton wire center
Grace/ThatcherAshton, Island Park, St. Anthony/Teton wire center
Idaho FallsAshton, Island Park, St. Anthony/Teton wire center
Lava Hot SpringsAshton, Island Park, St. Anthony/Teton wire center
McCammonAshton, Island Park, St. Anthony/Teton wire center
MontpelierAshton, Island Park, St. Anthony/Teton wire center
Pocatello/InkomAshton, Island Park, St. Anthony/Teton wire center
PrestonAshton, Island Park, St. Anthony/Teton wire center
RexburgAshton, Island Park, St. Anthony/Teton wire center
Rigby/Lewisville-MenanAshton, Island Park, St. Anthony/Teton wire center
RirieAshton, Island Park, St. Anthony/Teton wire center
RobertsAshton, Island Park, St. Anthony/Teton wire center
Shelley/FirthAshton, Island Park, St. Anthony/Teton wire center
Soda SpringsAshton, Island Park, St. Anthony/Teton wire center
Request No. 2:   Please provide the following information for calls (excluding calling card, credit card, and operator-assisted) originating from U S WEST 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 Fremont customers have Foreign Exchange (FX) lines with the open end (dial tone) in each of the above listed U S WEST eastern Idaho EAS area exchanges in Request No. 1?
Request No. 4:   How many 800/888 lines from Fremont terminate in the U S WEST 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 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.
Request No. 6:   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, and please provide work papers for such calculations.
Request No. 7:   Please provide any and all access revenues, billing and collections charges and any other charges that Fremont assesses U S WEST for the period from April through June 1997.
Request No. 8:   Does U S WEST foresee any significant problems in facilitating the described EAS?  Please provide a diagram explaining how U S WEST anticipates routing the traffic between the Fremont exchanges into the U S WEST eastern Idaho EAS region.
Request No. 9: Does or will U S WEST have any shared facilities with Fremont?
DATED  at Boise, Idaho, this            day of December 1997
______________________________
Donald L. Howell, II
Deputy Attorney General
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