USWS965v1.docx

DONALD L. 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 APPLICATION OF U S WEST COMMUNICATIONS, INC., FOR AUTHORITY TO INCREASE ITS RATES AND CHARGES FOR REGULATED TITLE 61 SERVICES.
)
)
)
)
)
)
)
)
)
)
CASE NO. USW-S-96-5
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO U S WEST
COMMUNICATIONS, INC.
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Donald L. Howell, II, Deputy Attorney General, requests that U S WEST Communications, Inc. (U S WEST; USW; Company) provide the following documents and information on or before September 24, 1996.
This Production Request is to be considered as continuing, and U S WEST Communications, Inc. 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.
Provide responses in electronic form where possible, e.g., spreadsheets used to derive responses.  Any spreadsheets provided should include formulas rather than just values.
Request No. 1:  From January 1, 1991 through December 31, 1995, please list by month how many southern Idaho residential customer lines had non-published telephone service, the revenue collected from the service and equipment charges, and the revenue collected from the monthly charges.
Request No. 2:  From January 1, 1991 through December 31, 1995, please list by month how many southern Idaho business customer lines had non-published telephone service, the revenue collected from the service and equipment charges, and the revenue collected from the monthly charges.
Request No. 3:  From January 1, 1991 through December 31, 1995, please list by month how many southern Idaho residential customer lines had non-listed telephone service, the revenue collected from the service and equipment charges, and the revenue collected from the monthly charges.
Request No. 4:  From January 1, 1991 through December 31, 1995, please list by month how many southern Idaho business customer lines had non-listed telephone service, the revenue collected from the service and equipment charges, and the revenue collected from the monthly charges.
Request No. 5:  Please provide non-published and non-listed recurring and non-recurring charges on a state-by-state basis by year from 1991 through 1995 for each state served by           U S WEST.
Request No. 6:  When customers request either a non-published or non-listed phone number, please explain how customers are informed of conditions under which their number might be revealed.  Please provide copies of written information provided to customers.       
Please provide documentation/service representative handbook pages and on-screen prompts used by service representatives to explain non-published and non-listed numbers to customers.
Request No. 7:  Are outside marketing companies provided information regarding non-published/non-listed customers?  Are non-published customers treated differently from non-listed customers in this regard?  Please explain.
Request No. 8:  Please explain U S WEST’s policy regarding marketing of U S WEST products and services to customers with non-published/non-listed status.  If outside marketing companies are not provided with non-published/non-listed numbers but U S WEST marketing representatives, including outside marketing companies acting as agents for U S WEST are provided with those numbers, please cite any laws, tariffs, rules or orders which allow such a distribution to be made.
Request No. 9:  Please provide the following distribution for U S WEST directory assistance calls by month for January through December 1995.  The number of customers who made:
0calls
1call
2calls
3calls
4calls
5calls
More than 5 calls to directory assistance
Request No. 10:  What is the total number of U S WEST directory assistance calls by month for January through December 1995?  What was the monthly revenue collected during this same time period?
Request No. 11:  Please provide by year for the years 1991 through 1995 the average time interval between when a telephone number is disconnected and the account closed, and when the number is available for reassignment?  What is the minimum interval?  Does this vary by wire center?  Is the timing different for business than residential numbers?  If so, please explain.
Request No. 12:  On billing and collection contracts with interexchange carriers, what is the maximum interval allowed between a customer placing a call and the IXC submitting a tape to USW for billing?
Question Nos. 13 through 16 pertain to temporary suspension of service-customer initiated, as found in U S WEST Basic Local Exchange Tariff, Section 2.2.10 A, B and C.
Request No. 13:  Please list the recurring and non-recurring rates charged by USW in each state it serves for temporary suspension of service (vacation service) and restoral to regular status.  Please give both business and residential rates on a state-by-state basis by year for the years 1991 through 1995.
Request No. 14:  How many southern Idaho customers subscribed to Section B (suspension of all service) in 1995?  How many southern Idaho customers subscribed to    Section C (suspension of a portion of service) in 1995?
Request No. 15:  Please provide documentation/service representative handbook pages and on-screen prompts used by service representatives to explain these vacation services to customers.
Request No. 16:  Please explain the benefits/protections of subscribing to vacation services.  Is a customer’s phone number and physical phone line reserved during suspension?
Request No. 17:  Please provide the number of U S WEST’s customer complaints filed directly with U S WEST and not involving PUC intervention by year for the years 1991 through
1995 for southern Idaho.  Please characterize the nature of the complaints, such as repair, held orders, disconnection, etc.
Request No. 18:  Pertaining to call screening and restoral services as described in           U S WEST Exchange and Network Services Catalog Section 10, please provide on a state-by-state basis for each state served by U S WEST the rates charged per line for:
Toll Restriction -- Page 6, Item 10.4.4
Blocking -- Page 7, Item 10.4.7
MTS Restoration Charge -- Page 19, Item 2.2.9 B.3
Request No. 19:  What is U S WEST’s policy with regard to requests from customers to freeze their “preferred interexchange carrier” (PIC)?  Is it the Company's policy that customers must first be “slammed” before a PIC freeze request will be honored?  Please provide copies of any tariffs, rules or regulations that support the Company’s policy as well as all documentation (handbook pages, on-screen prompts) used by service representatives in explaining the Company’s policy to customers.
Request No. 20:  Please provide the number of customers who were “toll restricted” during calendar year 1995.  How many of these toll restricted customers subscribed to optional non-regulated services (such as call waiting, caller identification, etc.)?  How many were disconnected?   Please provide the number of customers who were “full toll denied” during calendar year 1995.  How many of these customers had optional non-regulated services?  How many were disconnected?
Request No. 21:  Please provide the number of ITAP customers for the calendar year 1995.  How many of these ITAP customers subscribed to optional non-regulated services?  Please provide documentation/handbook pages and on-screen prompts used by service representatives when customers inquire or apply for ITAP service.
Request No. 22:  Please provide documentation/service representative handbook pages and on-screen prompts used by service representatives to explain the optional service “linebacker.”
Request No. 23:  Provide numbers of Title 61 customers, as of December 31, 1995, by class of service (e.g. LMR, IFR, IFB, etc.), by exchange and also aggregated into rate groups.
Request No. 24:  Provide numbers of Title 62 customers, as of December 31, 1995, by class of service (e.g. LMR, IFR, IFB, etc.), by exchange and also aggregated into rate groups.
Request No. 25:  Please provide for year-end 1995, southern Idaho:  Idaho State financial data (results of operations) on a total state basis (unseparated), separated results (Idaho intrastate), and Title 61 and Title 62 basis.  Show results prior to adjustments made for this case.
Request No. 26:  Provide workpapers showing the derivation of the $6 million decrease in revenue requirement if the EAS calling areas are approved.  Please show the revenue derived from rates based on no regional EAS compared to the revenue derived from rates with regional EAS.  Ref. Wright p.37
Request No. 27:  Provide average monthly local minutes of use, for business and for residential customers, by time of day, as well as workpapers showing derivation of revenue impact of changing local usage charge and offering free three hours of local calling for measured local service (+$50,000 for business, -$108,632 for residence).  Ref. Owen p.5
Request No. 28:  Provide information on the sample sizes and the dates at which information was gathered on minutes of use to derive the SLUs or SLUSs used in the allocation process.
Request No. 29:  Provide workpapers and data in support of $38.2 million revenue increase for residential and business customers, showing the breakdown between the usage charge and the basic monthly charge, for business and for residence customers by rate group and classes or types of service.  Ref. Owen p.9
Request No. 30:  Provide workpapers showing derivation of the difference in investment per access line between business and residential service, including cost of provisioning, average loop length, and support service.  Provide cost models, including documentation, used to produce investment calculations.  Ref. Elder p.18 or Owen p.11
Request No. 31:  Provide workpapers showing the dollar magnitude and derivation of the “remaining gap,” the amount of ITAP discount not financed by the existing surcharge and how spreading the undercollection affects other rates.  Ref. Owen p.17
Request No. 32:  Provide workpapers showing derivation of the negative revenue impacts associated with changes to residential non-recurring charge for access line (-$140,822) and to vacation rates (-$19,301 and -$4,239).  Ref. Owen p.23

Request No. 33:  Identify the specific percentage of access lines and “secondary allocation procedures” used to separate Title 61 and 62 revenues and expenses.  Ref. Elder p.11
Request No. 34:  What models or data or other evidence have been used to define and quantify harm and disadvantage to U S WEST from current depreciation policy?  (“use of unrealistic depreciation lives ... are no longer sustainable,” “depreciation lives are not competitive”).  Ref. Wozniak p.14, Wilson p.2, or Easton p.6
Request No. 35:  Quantify and provide evidence on the “new costs which will be incurred to implement the Federal Act's mandates” and specify how they relate in size to the “continuing demands to meet service obligations.”  Ref. Wilson p.31
Request No. 36:  Provide copies of any specific cost allocation studies done in support of this rate case.
Request No. 37:  Provide copies of any forward-looking cost studies (e.g. TSLRIC or TELRIC) performed for USW southern Idaho operations.
Request No. 38:  Please provide copies of the following reports issued between    January 1, 1995 and June 30, 1996:
A.  MTAS - Mechanized Trouble Analysis 67 Report.  Data for all residential and business customers within the total southern Idaho operations level reporting any trouble for any (Title 61 and Title 62) service.
B.  MIHR - Mechanized Installation History Report.  Data for all residential and business installations within the total southern Idaho operations level for all Title 61 or Title 62 products.
C.  RED HOTS - Weekly Held Order Report from Capacity Provisioning for all residential or business customers within the total southern Idaho operations level for all Title 61 or Title 62 products.
D.  Access Monthly Report from the Demand Forecast Center for U S WEST as a whole and for the Idaho response team.  It is preferred that this data be provided as either a Lotus 123 or Excel spreadsheet file.
Request No. 39:  Please provide information about all firms or vendors responding to calls from consumers concerning any matter on a contract basis for any portion of the period from January 1, 1995 through June 30, 1996.  For each firm provide the name of the firm, their location and nature of calls handled, as well as information by month on the:  1) number of calls received, 2) number of calls abandoned, 3) the number of customers receiving a busy signal, 4) the number of customers placed on hold, 5) the number of calls answered with 20 seconds, and 6) the number answered within 1 minute.  The information provided should be at least as detailed as that provided for U S WEST's own phone centers in the Access Monthly Report.
Request No. 40:  Please provide a copy of the training manuals and/or other materials used in training the individuals who respond to customer inquiries regarding the establishment of new service, for both business and residential customers.  This material should include the text from any computer-based training that is provided such persons.  If “scripts,” outlines, or any other marketing or customer assistance aids are prepared or recommended for use by such persons in responding to such inquiries, copies of these items should also be provided.
Request No. 41:  Please provide a copy of the training manuals and/or other materials used in training the individuals who respond to customer reports of service outages or problems, for both business and residential customers.  This material should include the text from any computer-based training that is provided such persons.  If “scripts,” outlines, or any other marketing or customer assistance aids are prepared or recommended for use by such persons in responding to such inquiries, copies of these items should also be provided.
Request No. 42:  Please provide a copy of the training manuals and/or other materials used in training the individuals who respond to customer inquiries regarding billing or payment problems, for both business and residential customers.  This material should include the text from any computer-based training that is provided such persons.  If “scripts,” outlines, or any other marketing or customer assistance aids are prepared or recommended for use by such persons in responding to such inquiries, copies of these items should also be provided.
Request No. 43:  Please provide a copy of the training manuals and/or other materials used in training the individuals who contact customers in order to obtain payments of any amounts owed the Company that are past due, for both business and residential customers.  This material should include the text from any computer-based training that is provided such persons.  If “script,” outlines, or any other marketing or customer assistance aids are prepared or recommended for use by such persons in responding to such inquiries, copies of all these items should also be provided.
Request No. 44:  Please provide a description of the current training regimen for service representatives in the business offices and repair centers, (i.e. xx hours of classroom training;    xx hours of training on a simulator; xx hours of on-the-job training with continuous oversight by a trainer; xx hours of on-the-job training with access to a mentor/supervisor/trainer; etc.).  How does this differ from the training used in 1990 and in 1983.
Please No. 45:  Please provide information on the number of personnel employed by           U S WEST in the following categories on December 31 for 1983, 1990, and 1995 that were dedicated entirely to providing service to southern Idaho customers, those who's time was split between providing service to southern Idaho and other areas and for U S WEST as a whole:
A.  Field/central office service technicians
B.  Customer service representative/account representative
C.  Field engineers
D.  Central office engineers
E.  Operators
F. Billing service representatives
DATED  at Boise, Idaho, this            day of September 1996.
______________________________________
Donald L. Howell, II
Deputy Attorney General
Technical Staff:
Carol J. Cooper
Bill Eastlake
Wayne Hart
umisc\prdreq\usws965.dh1
cj 1-22\be 23-37\wh 38-45