USWS965v14.docx

SUSAN HAMLIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE,  IDAHO  83720-0074
[phone]
Attorney for the Commission Staff
BEFORE  THE  IDAHO  PUBLIC  UTILITIES  COMMISSION

IN THE MATTER OF THE APPLICATION)
OF U S WEST COMMUNICATIONS, INC.)CASE  NO.  USW-S-96-5
FOR AUTHORITY TO INCREASE ITS)
RATES AND CHARGES FOR)STAFF'S RESPONSE   
REGULATED TITLE 61 SERVICES.)TO THE FIRST PRODUCTION
)REQUEST OF U S WEST
________________________________)COMMUNICATIONS, INC.
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Susan Hamlin, Deputy Attorney General, hereby responds to U S WEST Communications, Inc.’s First Request for Production to the Idaho Public Utilities Commission Staff dated November 12, 1996.
Request No. 1:  For each item please list 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.
Response No. 1: Staff members with relevant information pertaining to U S WEST’s request have been  identified under each response listed below.
Request No. 2:  Please identify each person that you intend to call as a witness either on direct (reply) or rebuttal (surrebuttal) by name, employer, job title and business.
Response No. 2:  Witnesses on direct will be:  Terri Carlock, IPUC, Audit Section Supervisor, P.O. Box 83720, Boise, ID, 83720-0074; Sydney Lansing, IPUC, Senior Auditor, P.O. Box 83720, Boise, ID, 83720-0074; Madonna Faunce, IPUC, Senior Auditor, P.O. Box 83720, Boise, ID, 83720-0074; Kathleen L. Stockton, IPUC, Auditor, P.O. Box 83720, Boise, ID, 83720-0074; Kent Schneider, IPUC, Auditor, P.O. Box 83720, Boise, ID, 83720-0074; Bill Eastlake, IPUC, Telecommunications Analyst, P.O. Box 83720, Boise, ID, 83720-0074; Carol J. Cooper, IPUC, Utilities Compliance Investigator, P.O. Box 83720, Boise, ID, 83720-0074; Wayne Hart, IPUC, Utilities Compliance Investigator, P.O. Box 83720, Boise, ID, 83720-0074; Dr. Lee Selwyn, Economics & Technology, Inc., President; One Washington Mall, Boston, MA, 02108; Susan M. Baldwin, Economics & Technology, Inc., Vice President, One Washington Mall, Boston, MA, 02108.
Staff does not know who it will call as witnesses for rebuttal at this time.  Staff will provide copies of its rebuttal testimony when it is filed with the Commission.

Request No. 3:  For each person identified in response to Request No. 2, please provide a curriculum vitae and copies of all testimony filed by the person in any regulatory jurisdiction for the last three years.
Response No. 3:  Enclosed are copies of testimony for each IPUC Staff witness in a regulatory jurisdiction in the past three years.  Included as part of Staff's testimony filed in this case, Case No. USW-S-96-5, is a curriculum vitae of the relevant background for each individual witness.  The following testimony is enclosed which was prepared by each individual witness:  Kathleen L. Stockton, Case No. CAP-W-95-1 (Interim and Direct), Terri Carlock, Case No. CAP-W-95-1 (Interim and Direct), IPC-E-94-5, IPC-E-95-11, Sou-W-94-1, WWP-E-94-7/WWP-G-94-4; Madonna Faunce, Case No. EUW-W-94-1, Case No. PPL-E-94-1, Case No. UWI-W-95-2 (Direct and Rebuttal), Case No. UWI-W-96-1/WSM-W-96-1, Case No. WWP-E-94-7/WWP-G-94-4; Bill Eastlake, Case No. GTE-T-95-3, Case No. USW-S-95-1 (Direct and Rebuttal); Wayne Hart, Case No. IPC-E-94-5, Carol J. Cooper, Case No. SOU-W-94-1, Case No. USW-S-94-4; Sydney Lansing, Case No. USW-S-94-4,  (Direct and Direct Reconsideration),        Case No. USW-S-95-4, Case No. USW-S-96-4.  
Also included is the curriculum vitae for Staff witnesses Dr. Lee Selwyn and Susan M. Baldwin.  Staff has identified  78 testimonies, reports or other documents that have been filed with a U.S. regulatory jurisdiction in the past three years.  A list of their documents were provided to U S WEST’s counsel on November 20, 1996. Staff objects to the entire production of these documents because it is burdensome and voluminous.  On November 25, 1996, U S WEST requested copies of 35 documents.  Staff anticipates copies of these documents will be available November 27, 1996.
Request No. 4:  Please provide all workpapers supporting the testimony in the present docket of each person that you identify as a witness.  This is a continuing request and pertains to the rebuttal or surrebuttal of each witness as well as to their direct or reply testimony.
Response No. 4: Staff referred to all production requests and audit requests served in this case in preparation and support of testimony, as well as annual reports of U S WEST.  Staff has enclosed workpapers in support of its testimony.  Those workpapers which have been identified as containing allegedly confidential or proprietary information has been copied on yellow paper, marked as confidential and delivered under separate cover.

Request No. 5:  Please identify by name and job description all persons employed on the Staff of the Idaho Public Utilities Commission who have been engaged in the gathering, review or analysis of information, documents or other date belonging to or pertaining to    U S WEST Communications, Inc. or its parent and affiliate companies in connection with this docket or with the field audit performed by Staff in connection with this docket and/or any recent Revenue Sharing docket.
Response No. 5:  Staff objects to this request on the grounds that it is overly broad and seeks information that is protected by attorney/client privilege and is work product.  However, Staff members who have relevant information and who will be testifying for this docket have previously been identified in Staff's response to U S WEST's Production Request No. 2.
Request No. 6:  Please identify by name and job description each person employed by or acting as a consultant or employee of a consultant who has been engaged in the gathering, review or analysis of information, documents or other data belonging to or pertaining to U S WEST Communications, Inc. or its parent or affiliate companies in connection with this docket or with the audit performed in connection with the audit performed by Staff.
Response No. 6:  Staff objects to this request on the grounds that it is overly broad and seeks information that is protected by attorney/client privilege and is work product. The persons employed as a consultant for Staff with relevant information and who will be testifying for this docket have previously been identified in Staff’s response to U S WEST Product Request No. 2.
Request No. 7:  For each person identified in response to Request No. 5, please provide an accounting of the number of hours devoted to performance of the gathering, review or analysis including any associated travel time.  If records of employee time are not available, please provide estimates.
Response No. 7:  Staff objects to this request on the grounds that it asks for information that is not relevant and is not likely to lead to discovery of admissible evidence in this proceeding.  Further, Staff objects on the basis that it seeks information that is protected by attorney/client privilege and is work product.
Request No. 8:  For each person identified in response to Request No 6, please provide an accounting of all hours billed or recorded for purposes of future billing for the work performed.
Response to No. 8: Staff objects to this request on the grounds that it asks for information that is not relevant and is not likely to lead to discovery of admissible evidence in this proceeding.  Further, Staff objects on the basis that it seeks information that is protected by attorney/client privilege and is work product.
Request No. 9:  Does the Commission Staff intend to call a witness pertaining to the level of service quality that is provided by U S WEST?  If the answer is affirmative, please provide the following:
a.The name, job title and business address of each of each person whose testimony in whole or in part will describe U S WEST's quality of service; and
b.Each and every document, report or other data source upon which the witness(s) rely in preparing or presenting their testimony.
Request No. 9:  Staff witness Hart will be addressing the level of service quality.  The information request in Part a. is included in his Direct Testimony in this case.  The information request in Part b. is included as part of Staff witness Hart’s workpapers.  Most of the information used by the witness is contained in the complaint data maintained by the Consumer Assistance Section of the Commission.  Although the names and other personal information in the database is confidential, a disk containing the relevant information in a non-confidential form is provided with this response.  The disk contains a relatively large text file in a compressed format and the software necessary to decompress the file.
Most of the data presented in Staff testimony was obtained from the non-confidential information provide on this disk.  However, some of the information can only be obtained from the narrative portion of the complaint records dealing with U S WEST, which is not on the disk.  This data is voluminous and because the narrative includes names, addresses and phone numbers in a random manner, it would be extremely time consuming and difficult to remove the confidential information and make a non-confidential or public version of this data.  Staff will make the narrative information available at the offices of the Idaho Public Utilities Commission to U S WEST and other parties in this case who have executed the confidential information agreements in this proceeding.
Answer prepared by Wayne Hart.
Request No. 10:  Did the Staff make any effort to compare the level of service quality provided by U S WEST in southern Idaho as compared to other states in which      U S WEST operates?  If so, please provide the following:
a.copies of all documents or other data used by Staff in making any such comparison;
b.a description of all service quality measurements or other indicia used by the Staff in making any such comparisons;
c.the time frame (month and year) of any data pertaining to U S WEST service quality used in making such a comparison;
d.the jurisdictional location of any data pertaining to U S WEST service quality used in making such a comparison; and,
e.the results of any such comparison.
Response No. 10:  Staff did not compare the level of service quality provided by U S WEST in Idaho to that provided by U S WEST outside of Idaho.  Answer prepared by Wayne Hart.
Request No. 11:  Did Staff make any effort to analyze the relationship between spare capacity in the network, i.e., in feeder and distribution plant and central office capacity, on such service quality measures as held orders?  If so, please provide the following:
a.copies of all documents, studies or other data upon which Staff relied in making an such analysis; and,
b.the results of any such analysis.
Response No. 11:  No.  Answer prepared by Wayne Hart.
Request No. 12:  Does Staff recommend that the Commission consider or adopt any financial incentives or penalties in connection with U S WEST's service quality in connection with this rate ?  If so, please provide the following:
a.a complete description of any such recommendation;
b.each and every fact upon which Staff relies in support of its recommendation; and,
c.each and every document, study or other information source relied upon by Staff in reaching the decision to make its recommendation.
Response No. 12:  Yes.  This information is provided in response to U S WEST Production Request No. 9.  Answer prepared by Wayne Hart.
Request No. 13:  Does the Staff rely on a tally of “customer complaints” or “customer contacts” to draw conclusions about U S WEST service quality in connection with this case?  If your response is affirmative, please provide the following:
1.A  total tally of customer complaints for the years 1991-1995 and for partial 1996 made in connection with U S WEST's southern Idaho operations.
2.A total tally of customer contacts for the years 1991-1995 and for partial 1996 recorded as being associated with U S WEST's southern Idaho operations.
3.An explanation of how the Staff distinguishes between complaints and customer contacts.
4.An analysis of the number of investigated complaints in each year which were determined by Staff to represent cases in which U S WEST was “at fault” i.e., instances in which U S WEST's actions or failures to act caused or substantially contributed to the customer's problem.
5.An analysis of the number of investigated complaints in each year which were made in connection with a service which is exclusively Title 61.
6.An analysis of the number of the number of investigated complaints in each year which were made in connection with a service which is exclusively Title 62.
7.An analysis of the number of investigated complaints in each year which were made in connection with a combination of Title 61 and Title 62 services.
8.An analysis of the number of investigated complaints in each year which were made in connection with billing or collection activities of U S WEST.
Response No. 13:  Yes.  The information requested for Parts 1 and 2 above is included in the data provided on the disk in response to U S WEST Production Request No. 9.  The information requested for Part 3 above is explained in Staff witness Wayne Hart's prefiled direct testimony in this proceeding.  Part 4:  Staff has not made a determination as to fault for the investigated complaints referenced in this case.  Staff began an experiment of recording a determination of fault with the other information recorded in the Consumer database early in 1996; however, the experiment has not yet been concluded or evaluated, and this information was not used in preparation for this proceeding.  Parts 5, 6, 7:  Staff’s analysis and discussion of consumer complaints does not differentiate between Title 61 and Title 62 services.  Part 8:  This information was provided in Staff witness Wayne Hart's direct testimony in this case as well as included on the disk provided in response to U S WEST Request No. 9.
Answer prepared by Wayne Hart.
Request No. 14:  Please provide all documents, workpapers, and analyses that the Staff relied upon to answer the proceeding response to Request No. 13.
Response No. 14:  This information is provided in the response to U S WEST Request No. 9.  Answer prepared by Wayne Hart.
DATED at Boise, Idaho, this               day of November 1996.
______________________________________
Susan Hamlin
Deputy Attorney General
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