20001025First Request to Qwest.doc

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3283

Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983

Attorney for the Commission Staff

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF QWEST'S TARIFF ADVICE NO. 00-02-N AND TRANSMITTAL NO. 00-07-PL ADJUSTING THE EQUAL ACCESS RECOVERY CHARGE FOR NORTHERN AND SOUTHERN IDAHO. )
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) CASE NO. QWE-T-00-4

FIRST PRODUCTION REQUESTS OF THE COMMISSION STAFF TO QWEST CORPORATION

The Staff of the Idaho Public Utilities Commission by and through its attorney of record, Weldon B. Stutzman, Deputy Attorney General, requests Qwest Corporation (Qwest) provide the following documents and information, pursuant to Commission Rule of Procedure 225, IDAPA 31.01.01.225, on or before WEDNESDAY, NOVEMBER 15, 2000.
This Production Requests is to be considered as continuing, and Qwest 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: Please describe and document the total Company costs associated with implementing intraLATA equal access in each of the states where Qwest provides service.

Request No. 2: Please separate and identify Qwest’s costs that are specifically associated with implementing equal access in its northern Idaho service area.

Request No. 3: Please separate and identify Qwest’s costs that are specifically associated with implementing equal access in its southern Idaho service area.

Request No. 4: Please describe and document the total originating intraLATA minutes that Qwest has recorded over the past year that are subject to the EANRC in southern Idaho.

Request No. 5: What does Qwest project as the amount of originating intraLATA minutes that will be subject to the EANRC in southern Idaho for each of the next two years?

Request No. 6: Please describe and document the total originating intraLATA minutes that Qwest has recorded over the past year that are subject to the EANRC in northern Idaho.

Request No. 7: What does Qwest project as the amount of originating intraLATA minutes that will be subject to the EANRC in northern Idaho for each of the next two years?

Request No. 8: Please provide and explain the calculations for arriving at the proposed increase to the EANRC in southern Idaho.

Request No. 9: To date, how much revenue has Qwest collected from the EANRC in southern Idaho and in Northern Idaho?

Request No. 10: How many interexchange carriers are currently participating in paying the EANRC in southern Idaho and in northern Idaho?

Request No. 11: What percentage of customers in southern Idaho and in northern Idaho are presubscribed to Qwest as their intraLATA toll carrier?

Request No. 12: Please identify all EANRC rates charged by Qwest in each state where Qwest has implemented intraLATA equal access.

Request No. 13: When does Qwest anticipate closing the sale transaction of its northern Idaho exchanges? How does Qwest anticipate the collection of the EANRC will be handled in northern Idaho after the sale?

DATED at Boise, Idaho, this day of October 2000.

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Weldon B. Stutzman
Deputy Attorney General

Technical Staff: Doug Cooley

WS:DC:gdk:umisc/prdreg/qwet004.wsdc
FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO QWEST 1 OCTOBER 25, 2000