20011228First Request to Qwest.doc

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB 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 DETERMINING PRICES FOR UNBUNDLED NETWORK ELEMENTS (UNE) IN QWEST CORPORATION’S STATEMENT OF GENERALLY AVAILABLE TERMS (SGAT). )
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) CASE NO. QWE-T-01-11

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 FRIDAY, JANUARY 11, 2002.
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 provide inputs for the Integrated Cost Model (ICM) used in calculating wholesale rates that have either been approved or adopted in the following states:
Arizona
Colorado
New Mexico
Utah
Iowa
Washington

Request No. 2: Please indicate if the model inputs for the above-mentioned states are adopted or Commission approved. If the rates are Commission-approved, please provide State Commission Order numbers.

Request No. 3: For each of the states listed in Request No. 1, please provide the statewide averaged wholesale and deaveraged loop rates by zone (if applicable) for each of the following elements:
2 Wire Unbundled Loop
4 Wire Unbundled Loop
Unbundled Loop Grooming (2 and 4 Wire)

Request No. 4: For each state in Request No. 1, please provide Attachment A (SGAT Rate Elements) that have been approved and/or accepted by each Commission.

DATED at Boise, Idaho, this day of December 2001.

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Weldon B. Stutzman
Deputy Attorney General

Technical Staff: Carolee Hall

WS:CH::umisc/prdreg/qwet01.11wsch1
FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO QWEST 1 DECEMBER 28, 2001