960123.docx

DONALD HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE,  IDAHO  83720-0074
[phone]
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 IMPROVING OR REPLACING U S WEST COMMUNICATIONS’ REVENUE SHARING PLAN FOR SOUTHERN IDAHO.
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CASE NO. USW-S-95-4
COMMISSION STAFF’S ANSWER TO MCI’S INTERROGATORY TO COMMISSION STAFF
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Donald Howell, II, Deputy Attorney General, provides the following documents and information in response to the MCI’s Interrogatory to Commission Staff.
Request No. 1At page 15 of her testimony, Ms. Miller identifies the goals established by the Commission in Case USW-S-94-3, one of which is “enhancing effective competition.”  Please state, in detail, how the joint proposal of staff and US West meets the goal of enhancing effective competition with respect to:
A.The intralata toll market for Southern Idaho;
B.The interlata, intrastate toll market for the State of Idaho;
C.The transport and access market within the US West service territory;
D.The local exchange market for business customers subscribed to five or more lines;
E.The local exchange market for business customers subscribed to fewer than five lines;
F.The residential local exchange market;
G.Any other telecommunication market in the state of Idaho which you consider relevant to this proceeding.
Answer No. 1The joint proposal is designed to address concerns with the existing U S WEST revenue sharing plan.  Of specific concern to the Commission was the “anti-competitive appearance” of using  revenue sharing funds to compensate U S WEST for lost toll revenue when a toll route was converted to EAS in the intraLATA toll market for southern Idaho.  The joint proposal addresses this concern.  It does not purport to remove barriers to competition in the other communications markets identified in MCI’s interrogatory (B-G).  Lines 5-10, page 16, of Ms. Miller’s direct testimony qualify the limited extent to which the Staff believes the joint proposal enhances competition:
Dropping the automatic compensation to U S West for toll revenue
lost because of future extensions of local service through EAS will put
U S West on a more even footing with other toll providers in the state
and should, therefore, eliminate at least some competitive concerns.
DATED  at Boise, Idaho, this            day of January 1996.

Donald Howell, II
Deputy Attorney General
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