GTET961.docx

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
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 TARIFF ADVICE NO. 96-09 TO ADD RATES, TERMS AND CONDITIONS FOR INTRALATA EQUAL ACCESS  
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CASE NO. GTE-T-96-1
FIRST WRITTEN INTERROGATORIES AND 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, JULY 12, 1996.
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.
If any of the information requested cannot be provided at the Commission offices in Boise, Idaho please notify the Commission Staff immediately so other arrangements can be made.
REQUEST NO. 1:Please provide invoices and/or bids/cost estimates for required changes in GTE billing systems.  Identify who will complete the changes (i.e., in-house personnel, affiliate personnel or unrelated third party).
REQUEST NO. 2:Please provide a copy of the intraLATA equal access impact study on the GTE administrative systems.
REQUEST NO. 3:Please provide a complete list of the administrative systems identified in the impact study and explain how costs to implement needed changes were determined.  Provide documents showing the costs to update for each system and provide information used to develop these costs.
REQUEST NO. 4:Identify the cost pools where the billing system costs and the administrative costs will be assigned.
REQUEST NO. 5:Please provide the allocation factors for all states used for each cost pool affected.
REQUEST NO. 6:For the software purchase expenses for the Northern Telecom DMS10 &DMS100, AGCS GTD5, AT&T #2EAX & 5ESS were there any RTU costs associated with these switches in 1995?  If so please provide the total costs, the cost pool assignments, and the allocations to each state.  Please provide copies of the contracts showing the RTU and work papers showing how the buy out costs were determined.
REQUEST NO. 7:Is it correct that there have been no direct costs for the right-to-use expenses for any SCDCO, 1AESS, EWSD or NX2A switches in the state of Idaho?  Have any of these costs been assigned to any other customer class in the State of Idaho?  If yes, please identify the customer class and the costs.  Have any of these costs been assigned to any other state?  If yes, please identify the state and the costs.  Explain why there are no costs in the State of Idaho.  Be detailed in your answer.
REQUEST NO. 8:Please provide budgets, workpapers, work orders, etc., showing engineering and installation costs for the 15 host switches, including engineering, installation and translation costs.  Are these costs directly assigned for installation of software in Idaho or are they costs assigned through an allocation process?  If the costs are allocated provide the pool and allocation factor.
REQUEST NO. 9: Please provide worksheets showing the calculation of the expected expenses for customer notification.
REQUEST NO. 10:Please explain how GTE will monitor the actual expenses incurred to implement intraLATA equal access, and how GTE will reconcile this expense to the revenue recovered.  Is GTE willing to provide the Commission with this information on a yearly basis?  If the recovery rate for the last year is significantly higher to fully recover the costs, would GTE  expect to extend the time of recovery?
REQUEST NO. 11:Please provide supporting data for the Originating Intrastate Toll & Access MOU of 68,031,157.
REQUEST NO. 12:Please provide any additional costs and information that have been identified or refined since May 22, 1996.
DATED  at Boise, Idaho, this            day of June, 1996.
______________________________________
Weldon B. Stutzman
Deputy Attorney General
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