20010706First Request to Qwest.doc

DONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3366

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 THE TARIFF ADVICE SUBMITTED BY QWEST CORPORATION TO REVISE ITS PERCENT INTRASTATE USAGE (PIU) REPORTING PROCEDURES FOR ACCESS SERVICES IN ITS NORTHERN IDAHO SERVICE AREA. )
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) CASE NO. QWE-T-01-16

FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO QWEST CORPORATION

The Staff of the Idaho Public Utilities Commission by and through its attorney of record, Donald L. Howell, II, 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 TUESDAY, JULY 31, 2001.
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.

Please answer the following questions for each of three calendar years: 1998, 1999, and 2000.

Request No. 1: Have there been occasions over the past three years when subscribing interexchange carriers have not filed projected percent of interstate usage with the Company? If so, please describe the circumstances and explain how the Company handled this noncompliance.

Request No. 2: Has the Company ever in the past three years needed to use the default 50% PIU provided in the tariff because of failure of any subscriber to report? If so, please describe the circumstances of the investigations and the results of the Company's investigations.

Request No. 3: Has the Company ever in the past three years needed to request call detail records or other supporting documents to verify any subscriber's reported PIU? If so, please describe the circumstances of the investigations and the results of the Company's investigations. Please list for each case the PIU before investigation and the PIU after investigation.

Request No. 4: Has the Company ever in the past three years needed to request an audit in order to verify the PIU reported by any subscriber? If so, please describe the circumstances of the investigations and the results of the Company's investigations. Please list for each case the PIU before audit and the PIU after audit.

Request No. 5: Regarding Feature Group D terminating minutes, please describe the potential circumstances where terminating location cannot be determined from the Company's call detail records. Please make your response comprehensive.

Request No. 6: Regarding Feature Group A and B jurisdiction, has the Company ever investigated the calling records and detail of subscribers that claim to provide only interstate services? If so, please describe the circumstances of the investigations and the results of the Company's investigations. Please list for each case the PIU before audit and the PIU after audit.
Request No. 7: In the seven years since the Company adopted the current policies (April, 1994) regarding PIU reporting, how has technology changed and/or improved the Company's ability to determine the PIU factors of its customers?

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

________________________________
Donald L. Howell, II
Deputy Attorney General

Technical Staff: Birdelle Brown

DH:BB:i::umisc/prdreg/qwet01.16dhbb
FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO QWEST 1 JULY 6, 2001