970418.docx

SUSAN HAMLIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, ID  83720-0074
[phone]
Street Address for Express Mail:
472 W. WASHINGTON STREET
BOISE, ID  83702-5983
Attorney for Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF GTE NORTHWEST, INCORPORATED TO DETERMINE AND FIX PROPER AND ADE­QUATE RATES OF DEPRECIATION FOR SEVERAL CLASSES OF ITS DEPRECIABLE PROPERTY.
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CASE NO. GTE-T-97-5
SUPPLEMENT TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO
GTE NORTHWEST
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Susan Hamlin, Deputy Attorney General, requests that GTE Northwest, Incorporated provide the following documents and information on or before THURSDAY, MAY 8, 1997.
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.
The following production requests had incorrect reference numbers contained in the text of the production request filed on April 17, 1997.  The following is the corrected text and should be answered in place of the previous requests:
Supplemental Request No. 2:For each person identified in response to Request No. 1, please provide a curriculum vitae and copies of all testimony filed by the person in any regulatory jurisdiction for the last three years.
Supplemental Request No. 8:Provide a copy of the following:
a.All studies prepared by Technology Futures, Inc. (TFI) relied upon by GTE in determining the depreciation rates requested in this case.
b.All work papers and analyses developed by, or on behalf of, TFI that support the findings made in each TFI study supplied in response to Request No. 8a.
c.All comparisons of prior forecasts to actual depreciation lives that TFI has prepared, or GTE has prepared to validate the accuracy of the TFI forecasts.
Supplemental Request No. 9:For each of the studies related to Request Nos. 7 and 8, provide the following information:
a.The cost of capital;
b.Revenues from new services made possible by deployment of the new technologies substituting for GTE embedded investments;
c.Forecasts of GTE market share for those services furnished via the new technologies being deployed;
d.The rate of price inflation/deflation, either for the national economy or the specific types of new technologies being acquired;
e.Asset lives of new technology investments being undertaken;
f.Vintages of customer premises equipment used in conjunction with GTE services (e.g., telephone sets, modems, etc.).
g.Historical life indications for each account in Plant in Service.
h.Life projections for each account in Plant in Service.
i.Future net salvage for each account in Plant in Service.
j.The calculation of remaining life for each account in Plant in Service.
Supplemental Request No. 16:For each switch in Request No. 15 provide a schedule showing the capacity of the switch and the number of access lines in use at December 31, 1996.
DATED  at Boise, Idaho, this            day of April, 1997.
______________________________________
Susan Hamlin
Deputy Attorney General
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