19950818First Request to GTE.doc

WELDON B. STUTZMAN
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 APPLICATION OF GTE NORTHWEST, INCORPORATED TO EXTEND ITS LOCAL CALLING PLAN (LCP) FOR THE PROVISION OF TOLL-FREE EXTENDED AREA SERVICE (EAS) TO ITS EXCHANGES IN IDAHO. )
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) CASE NO. GTE-T-95-2

FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO GTE NORTHWEST,
INCORPORATED

The Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Weldon B. Stutzman, Deputy Attorney General, requests that GTE Northwest, Incorporated provide the following documents and information on or before FRIDAY, SEPTEMBER 1, 1995.

This Production Request is to be considered as continuing, and GTE Northwest, Incorporated 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.

Request No. 1: Number of lines by exchange and by current local rate classification. Also show the current rate and associated monthly revenue.

Request No. 2: For those lines in No. 1 above that are measured service lines, show the current number of measured local calls, minutes and revenue by intraexchange and interexchange.

Request No. 3: The number of toll calls, minutes and revenue by exchange and by route for those toll routes that are proposed to become local. Include calls, minutes and revenue from optional calling plans and payphones.

Request No. 4: Number of lines by exchange and assumed LCP rate classification. Also show the proposed flat rate and associated monthly revenue and the number of assumed measured calls, minutes and revenue by mileage band.

Request No. 5: If assumed number of lines for each LCP rate classification is based on general assumed percentages, please provide those percentages and their justifications. If the assumed number of lines is based on individual exchange considerations, please provide the considerations used for each exchange or otherwise explain how the estimates were made.

Request No. 6: Provide any assumptions used by GTE in estimating the number of measured calls under the LCP proposal.

DATED at Boise, Idaho, this day of August 1995.

______________________________________
Weldon B. Stutzman
Deputy Attorney General
la/gdk/umisc\prdreq\gtet952.ws

FIRST PRODUCTION REQUEST
TO GTE 1 AUGUST 18, 1995