20030506Supplemental 1st Request of Staff.pdf

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DONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3366
RECEIVED FilED
2003 MAY -5 PH 2: 16
iDt'J PUGUC
UTILITIES CDr1HISSION
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
QWEST CORPORATION TO PHASE OUT AND )
CLOSE THE BOISE AND POCATELLO
CUSTOMER PAYMENT CENTERS.
CASE NO. QWE-03-
SUPPLEMENTAL 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 , IDAP A
31.01.01.225, on or before FRIDAY, MAY 9, 2003.
The Company is reminded that responses pursuant to Commission Rules of Procedure
must include the name and phone number of the person preparing the document, and the name
location and phone number of the record holder. Reference IDAP A 31.01.01.228.
This Production Request 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.
SUPPLEMENTAL FIRST PRODUCTIONREQUEST TO QWEST MAY 5, 2003
Please provide answers to each question; supporting workpapers that provide detail or are
the source of information used in calculations; the name and telephone number of the person
preparing the documents; and the name, location and telephone number of the record holder.
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.
Supplemental Request No.4: Supplemental Staff Request in regard to Qwest's
Response to Staff Request No.4. What is the fixed unit rate paid by Qwest for each walk-
payment processed? Please provide a copy of the contract with First Data Corporation.
Supplemental Request No. 14: Supplemental Staff Requests in regard to Qwest's
Response to Staff Request No. 14.
1. Please explain what is meant by the term "processed" in regard to the 37 567
payments processed by the tellers at the Pocatello Cpc.
2. Please explain what happens with the payments received in the drop box (6,495
for 2002). Do the tellers at the CPC open these envelopes and make notes on
customer accounts? Are the payments received in the drop box treated differently
than those taken personally by the tellers? How long does it take for a payment to
post that was placed in the drop box at the Pocatello CPC?
3. Of the 37 567 payments processed by the tellers in the Pocatello CPC, are the
495 payments received in the drop box or the 699 payments handed to tellers
included in that number?
4. Please explain the 699 payments that were handed to the tellers to be dropped in
the mail. Did these payments come through the mail? Were the payments made
in person? Were they addressed to the Pocatello address of the CPC? What
happens to those payments? Were any of the 699 payments processed at the
CPC? Were the 699 payments mailed somewhere else for processing? If so
SUPPLEMENTAL FIRST PRODUCTIONREQUEST TO QWEST MAY 5 , 2003
where were they mailed and how long would it take for a payment received in that
manner to post to a customer s account?
Supplemental Request No. 15: Supplemental Staff Requests in regard to Qwest's
Response to Staff Request No. 15.
I. Please explain what is meant by the term "processed" in regard to the 25 644
payments processed by the tellers at the Boise Cpc.
2. Please explain what happens with the payments received in the drop box (6 682
for 2002). Do the tellers at the CPC open these envelopes and make notes on
customer accounts? Are the payments received in the drop box treated differently
than those taken personally by the tellers? How long does it take for a payment to
post that was placed in the drop box at the Boise CPC?
3. Ofthe 25 644 payments processed by the tellers in the Boise CPC, are the 6 682
payments received in the drop box or the 234 payments handed to tellers included
in that number?
4. Please explain the 234 payments that were handed to the tellers to be dropped in
the mail. Did these payments come through the mail? Were the payments made
in person? Were they addressed to the Boise address of the CPC? What happens
to those payments? Were any of the 234 payments processed at the Boise CPC?
Were the 234 payments mailed somewhere else for processing? If so, where were
they mailed and how long would it take for a payment received in that manner to
post to a customer s account?
Supplemental Request No. 16: Supplemental Staff Requests in regard to Qwest'
Response to Staff Request No. 16. Please explain what it means when "payments are recorded
daily . How does that differ from "noted on the account"? If payments are placed in a drop box
are the payments opened at the CPCs and the customer s account updated to reflect that payment
SUPPLEMENTAL FIRST PRODUCTIONREQUEST TO QWEST MAY 5 , 2003
was made? Does that update consist of a written note on the customer s account or is the
payment actually recorded in the Company s billing records for the customer?
DATED at Boise, Idaho, this day of May 2003.
Donald L. How , II
Deputy Attorney General
Technical Staff: Carol Cooper
Joe Cusick
i:umisc/prdreg/qwetO3.1Odhcjjwc2
SUPPLEMENTAL FIRST PRODUCTIONREQUEST TO QWEST MAY 5 , 2003
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 5TH DAY OF MAY 2003
SERVED THE FOREGOING SUPPLEMENTAL FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF TO QWEST CORPORATION, IN CASE NO. QWE-03-
, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
MARY S HOBSON
STOEL RIVES LLP
SUITE 1900
101 S CAPITOL BLVD
BOISE ID 83702-5958
ADAM L SHERR
QWEST
1600 7TH AVE ROOM 3206
SEATTLE WA 98191
CERTIFICATE OF SERVICE