USWS965v17.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 TO THE   
REGULATED TITLE 61 SERVICES.)SECOND 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 Second Request for Production to the Idaho Public Utilities Commission Staff dated December 11, 1996.  Staff has provided the partial responses to U S WEST’s Second Production Request on December 24, 1996 and December 26. 1996.
Request No. 1:Hart p. 4
Please provide more detail as to how Staff determines a "trend."  What minimum period of time is required before Staff concludes a "trend" is established?  What minimum number of complaints/inquiries is required to establish a trend?
Response No. 1:A trend would be any pattern that is sustained or repeated.  Staff has not established a minimum period of time or a specific number of complaints that constitutes a trend.
Request No. 2:Hart p. 4
This request and all that follow which are of similar format request actual numeric counts.  Reference to Staff testimony or exhibits depicting certain information in graphic form will not be responsive to this request.
By year, from 1989 to present, breakdown the total number of Staff recorded "complaints" and "inquiries and comments" by category.  Provide the same information for each utility with which you compare U S WEST in this docket.
Response No. 2:Information describing customer complaints for the years 1990 through September of 1996 was included in the workpapers for Staff witness Hart in Staff’s response to U S WEST’s First Production Request Nos. 4 and 9.  Detailed information is no longer available for 1988 and 1989, but gross totals were taken from the 1988 and 1989 Annual Reports, excerpts of which were provided with Mr. Hart’s workpapers.
Request No. 3:Hart p. 5
By year, from 1989 to present, breakdown the total number of complaints/inquiries which fall into each of the two groups described on lines 6-17.  Provide the same information broken down in the same way for each utility with which U S WEST is compared in this docket.
Response No. 3:See Staff’s response to U S WEST’s Second Production Request No. 2.
Request No. 4:Hart p. 7
Please provide the calculation and data which supports the statement on page 7, line 20 of your testimony that "almost 12,000 customers in southern Idaho experienced a delay in the installation of their phone lines in the first eight months of 1996."
Response No. 4:The information provided to the Commission in a briefing by
U S WEST on October 9, 1996, indicated that U S WEST had a total of 35,289 “Fielded Installs” from January, 1996 through August of 1996.  I apportioned 25% of those to business and 75% to residential, which is approximately the same percentages of lines in each category as identified in the Company’s 1995 Annual Report to the Commission.  This results in a total of 8,822 business installations and 26,467 residential installations.  I multiplied these numbers by the inverse of the number reported by U S WEST for “Appointments Offered” which would represent the appointments not offered, as reported in the Company’s Basic Service Measurements report for September of 1996.  For businesses, the calculation was 8822 lines times 46.2% for a total of 4076 lines that were not installed within the two day interval.  For residential, the calculation is 26,467 lines times 29.1% for a result of 7702 lines that were not installed within the standard two day interval.  Adding the two results together give a total of 11,778 lines that were not installed within the standard 2 day interval.
Request No. 5:Hart p. 10
By year, from 1989 to present, provide the total number of "instances where there is a change in the utility's position or approach to a customer's concern after the consumer has contacted the Commission."  Provide the same information and breakdown for each other utility with which U S WEST is compared in this case.
Response No. 5:See Staff’s response to U S WEST’s Second Production Request No. 2.
Request No. 6:Hart
For each year, from 1989 to present, break down the total number of "complaints" and "inquiries and comments" recorded by Staff into the following categories:
Held Orders
Miscellaneous Installation Issues
Out of Service
Miscellaneous Service Quality Issues
Credit Issues
Disconnection
Pay Per Call
Disputed Toll
Delayed Billing
Miscellaneous Billing
Rates & Policies
Carrier Selection
Toll Plans / EAS
Caller ID
All other
Response No. 6:See Staff’s response to U S WEST’s Second Production Request No. 2.  To assist U S WEST in interpreting the data, Staff identifies the primary subject matter of
each consumer contact via a “reason” code.  Staff grouped the following “reason” codes into the categories identified in the question.
       CategoryApplicable type codes
Held Orders205
Misc. Installation Issuesall 200's except 205
Out of Service301
Misc. Service Quality issuesall 300's except 301
Credit Issuesall 400's and 100's
Disconnectionsall 500's
Pay per call606
Disputed Toll607
Delayed billing604
Miscellaneous billingall 600's except 604, 606 and 607
Rates and Policiesall 700's
Carrier Selections801
Toll Plan/EAS803
Caller ID804
All OtherAll 800's except 801, 803 & 804, all 900's.
Request No. 7:Hart
Provide the same information and breakdown for all other utilities with which
U S WEST is compared in this docket.  For utilities that do not provide telephone service and hence do not face certain issues, please group complaints and inquiries as you find them mostly logically categorized, but at a minimum, provide categories for:
Delayed Installation
Miscellaneous Installation Issues
Out of Service
Miscellaneous Service Quality Issues
Credit
Disconnection
Miscellaneous Billing Issues
Rates and Policies
Response No. 7:See Staff’s response to U S WEST’s Second Production Request No. 6.
Request No. 8:Hart
Provide the same information and breakdowns as in the two previous requests for Staff investigations only.
Response No. 8:See Staff’s response to U S WEST’s Second Production Request No. 6.  Records marked as “N” in the field identified as “comment/info only” are investigated complaints.
Request No. 9:Hart
Break down the information provided in the immediately proceeding request in each category by whether or not there was a change in the utility's position or approach to a customer's concern after the consumer contacted the Commission.  Provide the same breakdown for all other utilities with which U S WEST is compared in this docket.
Response No. 9:See Staff’s response to U S WEST’s Second Production Request No. 6.  Records marked as “Y” in the field identified as “Action Mod/Rev” are those in which there was a change in the utility’s position or approach.
Request No. 10:Hart p. 18
Provide work papers for and calculations of the growth percentages for U S WEST and all other utilities with which it is compared for years in your testimony.  Provide the base data (number of lines/meters per year, number of net installations) for each utility for the years 1989 to the present.
Response No. 10:The following table includes the data for the number of lines or meters for each year from 1990 through 1995 for each of the utilities included in Staff’s testimony.  Because 1996 numbers are not yet available, Staff used the 1995 numbers in calculations for 1996.  The data for this table was obtained from the annual reports submitted by each utility to the PUC.  Information on the number of “gas only” customers for Washington Water Power was provided by the staff from that utility for 1993 and 1995, and extrapolated to obtain a number for the other years.
     Utility  1990   1991   1992   1993   1994   1995
Intermountain Gas113,830119,854127,013136,015148,630152,271
Washington Water Power  73,230  74,739  76,893  81,151  85,763  97,928
Idaho Power Company271,794278,166285,871295,557306,965317,772
Utah Power Company  42,655  44,010  45,255  46,130  47,310  47,992
GTE Northwest  85,549  79,690  78,070  94,322107,128113,200
U S WEST (SOID)332,913334,023349,297367,049388,980      *
* U S WEST claims this number is confidential.
Calculations for percentages of growth were made using the following formula:
(current year-previous year)/previous year
Request No. 11:Hart p. 20
Provide all data upon which you rely for the statement "typically telephone companies do not need to visit the customer's premises on each charge or new connection order, unlike other utilities . . ."  Explain why this alleged difference indicates telephone service should be less susceptible to service quality complaints.  Explain why meter reading visits of metered utilities have impact on service quality.
Response No. 11:Staff relied upon U S WEST’s explanation to the PUC service quality audit team in Case No. USW-S-95-4, as well as numerous explanations on the advantages of soft dial tone that the Company has provided the Staff over the past several years.  The Company has repeatedly informed Staff that soft dial tone service, in most cases, eliminated the need for the installation technician to visit the premises if telephone service had previously been provided to the premise, and that in most cases, moves and changes can be made by actions taken solely in the central office.  The Company provided this information to bolster the Company’s claims that it had it’s held order problems under control and that the number of held orders would be declining soon.  As explained in Staff witness Hart’s testimony, on page 20, lines 6 through 20, electric and gas utilities must visit each premise to read the meter whenever there is a change of customers.  This is a manpower requirement that telephone utilities, especially those using soft dial tone technology, do not necessarily incur.
Request No. 12:Hart
Provide the date of adoption of the ROC service quality standards for each state within U S WEST region.  If any portion of the ROC service quality standards were deleted or modified by any commission in a U S WEST state please detail each such modification or deletion.
Response No. 12:Staff did not indicate in its testimony that the ROC standards had been formally adopted by any Commission.  Staff does not possess information to provide a more definitive answer.
Request No. 13:Hart p. 44
List and describe all "Staff recommendations for the state-specific variables" to the ROC service quality standards presented in this case.
Response No. 13:The only Staff specific variables recommended by the Staff was in the area of Provisioning.  Staff recommended that the average number of held orders not exceed eighty (80) on average per month, or 0.02% percent of working access lines on average per month.
Request No. 14:Hart p. 45
Describe in detail all input provided by any member of the IPUC Staff or any Commissioner in the "consensus process" which you state "involved input from Commissions and Staff from all the states in which U S WEST provides service."  Provide all memos, reports, notes, outlines, transcripts, E-Mail messages or other documents which embody, reflect or relate to any input to this process provided any IPUC Staff member (past or present) and any Idaho Commissioner.
Response No. 14:Staff objects to this request on the grounds that it is voluminous and burdensome and/or is work product.  However, Staff witness Hart relied upon the cover letter that accompanied the ROC Service Quality Standard recommendations, which was included as part of Staff Exhibit No. 124, as well as his general understanding of the process involved in such deliberations, in making this statement.  He also reviewed U S WEST’s response to an earlier draft of the ROC recommendation.  This document is attached.  No other ROC related “memos, reports...or other documents” were consulted in developing this testimony.
Request No. 15:Hart p. 31
A.Please provide the number of months U S WEST was fined for failure to comply with 24 hour restoration of service standard.
B.Please provide all information upon which Staff relies to demonstrate U S WEST has NOT met the out-of-service restoration standard for the months of February, 1996 to present.
Response No. 15:
A.Four months (southern Idaho).
B.Staff made no such assertion on page 31.  On page 34 of Mr. Hart’s testimony, he stated that based upon the monthly BSM reports submitted to the Commission by the Company, the Company had met the 24 hour service restoration standard in the months of February through May, missed it in June, and met it in July, August and September.  He also indicated that if compliance with this rule were determined using the method preferred by Staff, which does not exclude “extenuating circumstances,” the Company has not met the standard for any of the months in 1995 or 1996.
Request No. 16:Hart p. 32.
A.For the years 1989 to present, provide by month the absolute number of investigations of service restoration problems which your records reveal involved repeat trips to resolve the same problem.  To the extent possible from your records, further break down these instances between instances involving "intermittent" problems and "simple problems that didn't get fixed the first time."
B.Please provide the same data for each other utility which with you compare U S WEST in this docket.
Response No. 16:
A. & B.Staff objects to this request on the grounds that the term “absolute number” is vague and ambiguous.  Further, Staff objects to this request on the grounds that to fully answer this question would require a special study that would be extremely time  consuming and burdensome.  Testimony was based upon comments made by customers during conversations with investigators and documented in investigation narratives.  Information describing customer complaints for the years 1990 through September of 1996 was included in the workpapers for Staff witness Hart in Staff’s response to U S WEST’s First Production Request Nos. 4 and 9.  The underlying narrative of the investigatory record is not subject to disclosure.  Reference Commission Rules of Procedure, Rule 26; Idaho Code Section 9-337(5); Idaho Code Section 9-335; Idaho Code Section 9-340(22).  All identified inquiries and complaints were considered, investigated and handled informally by Staff.  Reference Commission Rules of Procedures, Rule 21.
However, Staff has agreed to provide all parties to this case who have executed a protective agreement access to the narrative records for these investigations and has made those records available during normal business hours at the office of the PUC.  See Staff’s response to U S WEST’s First Production Request No. 9 Detailed information is no longer available for 1988 and 1989, but gross totals were taken from the 1988 and 1989 Annual Reports, excerpts of which were provided with Mr. Hart’s workpapers.  Staff investigation records do not include a mechanism to readily identify whether an investigation of a repair problem involved repeat visits for the same problem.  However, while preparing his testimony, Staff witness Hart reviewed the narrative portion of the investigation records and kept a simple tally of the number of such investigations that included any information that indicated repeat visits were necessary to complete the repair.  The tally was not kept on a monthly basis, so this information is not available on a monthly basis.  Staff’s review of the investigation conducted between January 1 and September 30 of 1995, showed 57 repair investigation records containing information about repeat repairs.  For October 1, 1995 through September 30, 1997 Staff found 87 repair investigations containing information about repeat repairs.
Staff had not conducted such an analysis of the repair records for the other utilities.  However, because the number of such investigations is relatively small, Staff has reviewed the repair investigation records from January 1, 1995 through September 30, 1996, and tallied the number of repair investigation records that contain information indicating a repeat visit was required to resolve the problem.  The results of this review is:
    Utility1/1/95-9/30/9510/1/95-9/30/96
Idaho Power1314
Utah Power1215
Washington Water Power02
Intermountain Gas00
GTE Northwest108
Request No. 17:Hart p. 36
For the years 1989 to present, provide by month the absolute numbers of service quality and held order investigations which revealed a "discrepancy" between information provided by the complainant and that reported by U S WEST.  Please provide the same information for all other utilities with which you compare U S WEST in this docket.
Response No. 17:Staff objects to this request on the grounds that the term “absolute number” is vague and ambiguous.  Further, Staff objects on the grounds that to fully answer this question would require a special study that would be extremely time consuming and burdensome.  See Staff’s response to U S WEST’s Second Production Request No. 16.  As in the response to Request No. 16, Staff investigation records do not include a mechanism to readily identify whether an investigation identifies a discrepancy between the information provided by the customer and that of the Company.  However, while preparing his testimony, Staff witness Hart reviewed the narrative portion of the investigation records for repair and delayed service installations and kept a simple tally of the number of such investigations that included any information that indicated such a discrepancy.  The tally was not kept on a monthly basis, so this information is not available on a monthly basis.
For investigations conducted between January 1 and September 30 of 1995, a total of 19 repair investigation records contained information that led Staff witness Hart to conclude that there was a discrepancy between the information provided by the customer and that provided by the Company.  The number of repair and held order investigations tallied as including a discrepancy for the period October 1, 1995 through September 30, 1996 was 112.
Staff had not conducted such an analysis of the repair and delayed installation records for the other utilities.  However, because the number of such investigations is numerically small, Staff has reviewed the repair and delayed service installation investigation records from January 1, 1995 through September 30, 1996, and tallied the number of such investigation records that contain information indicating a discrepancy between the information provided by the Company and the customer.  The results of this review are:
    Utility1/1/95-9/30/9510/1/95-9/30/96
Idaho Power10
Utah Power01
Washington Water Power00
Intermountain Gas01
GTE Northwest21
Request No. 18:Hart p. 39
A.Provide by month the absolute numbers of held order and service quality investigations which included "references to some form of difficulty in reaching a person who could address their concerns."
B.Provide the same information for each of the other utilities with which you compare U S WEST in this docket.
Response No. 18:
A. & B.Staff objects to this request on the grounds that the term “absolute number” is vague and ambiguous.  Further, Staff objects on the grounds that to fully answer this question would require a special study that would be extremely time consuming and burdensome.  See Staff’s response to U S WEST’s Second Production Request No. 16. This information is only available through a review of the narrative portion of the investigation records.  For the period of January 1 to September 30, 1995, there were 43 investigations that included a specific reference to a difficulty in reaching the Company.  For the period of October 1, 1995 through September 30, 1996, the number was 55.
Staff had not conducted such an analysis of the repair and delayed installation records for the other utilities.  However, because the number of such investigations is numerically small, Staff has reviewed the repair and delayed service installation investigation records from January 1, 1995 through September 30, 1996, and tallied the number of such investigation records that contain information indicating a difficulty in reaching the Company.  The results of this review are:
    Utility1/1/95-9/30/9510/1/95-9/30/96
Idaho Power73
Utah Power43
Washington Water Power01
Intermountain Gas00
GTE Northwest03
Request No. 19:Hart p. 41
Provide by month for the period over which you have tracked this indicator the absolute number of "customers contacting the IPUC about delayed service" who reported problems with receiving a return call from the U S WEST Held Order Group.
Response No. 19:Staff objects to this request on the grounds that the term “absolute number” is vague and ambiguous.  Further, Staff objects on the grounds that to fully answer this question would require a special study that would be extremely time consuming and burdensome.  See Staff’s response to U S WEST’s Second Production Request No. 16.  Staff does not routinely “track this indicator.”  However, a review of the investigation records for the period of October 1, 1995, through September 30, 1996, revealed a total of 25 investigations involving customers who indicated that they had not received a return call in response to messages they had left with the contact number they had been given for information about their held order.
Request No. 20:Hart p. 41
Provide by month the absolute number of held order investigations that included "other access issues."  Please divide this number between those who complained that they did not receive sufficient information and those that had some other access-related complaint.  Does the 5% number stated here relate to calls to the Held Order Group or to all U S WEST customer contact numbers?
Response No. 20:Staff objects to this request on the grounds that the term “absolute number” is vague and ambiguous.  Further, Staff objects on the grounds that to fully answer this question would require a special study that would be extremely time consuming and burdensome.  See Staff’s response to U S WEST’s Second Production Request No. 16.  Further, Staff does not have this information available on a monthly basis.  The Staff’s analysis did not include a separate tally of the number of customers complaining about the lack of information provided after reaching a live body at U S WEST.  In preparing his testimony, Staff witness Hart tallied records under a general category, “other access issues.”  The 5% number refers to the percentage of all of the investigations concerning delayed services that included a reference to an access problem that was not a failure to return calls or difficulty in reaching the Company when dialing the general repair number.
Request No. 21:Hart p. 43
Provide by month for the year 1990 for U S WEST the service measurement of average held orders, restoration of out of service conditions, and installation intervals for business and residence service.
Response No. 21:Staff does not have this information for the year 1990.
Request No. 22:Hart p. 44
Please describe all efforts Staff undertook to get input from U S WEST regarding the appropriateness and/or achievability of the "Staff recommendations for the state-specific variables" referenced in your testimony.
Response No. 22:Staff reviewed a copy of the Company’s response to the ROC of the draft standards proposed by the ROC.  A copy of that response is attached.
Request No. 23:Hart p. 48
A.Please provide all data gathered from Idaho customers or relating to Idaho customers that support the claim the amount of the voluntary cellular voucher "does not cover the typical cellular customer's costs."
B.Provide the total number of customer complaints/inquiries which reflect customer's views that U S WEST's cellular program does not cover the customer's costs.
Response No. 23:
A.Staff’s testimony that the amount of the voluntary cellular voucher “does not cover the typical cellular customer’s costs” was based upon oral comments made by consumers to Staff utility compliance investigators.
B.Because such comments are not necessarily recorded in the investigation narratives, it is not possible to quantify the number of customer contacts in which such comments were made.  Staff has made these narratives available for review.  See Staff’s response to U S WEST’s First Production Request No. 9 and Second Production Request No. 16.
Request No. 24:Hart p. 49
A.Please list all of the areas (exchanges) in which customers would be benefitted by the proposed modification of the customer incentive program because cellular service is not available and voice messaging service is available from U S WEST.
B.Please provide all statistical data gathered from Idaho customers or relating to Idaho customers upon which you rely in reaching the conclusion that Idaho customers want and need voice messaging service to be added as an option in Idaho.
C.Provide the total number of customer complaints/inquiries which reflect the customers' view that they want/need voice messaging as an option during the period their order is delayed.
Response No. 24:
A.Staff did not attempt to verify that voice messaging service was available in areas where cellular service is not available.  Staff merely indicated that in the absence of a cellular phone option, voice messaging service is an option that provides the customer with at least minimal telecommunication capability.
B.Staff’s request that voice messaging service would be beneficial was based upon oral comments made by a number of customers with held orders to Staff while performing as a utility compliance investigator.  Because such comments are not necessarily recorded in the investigations narratives, it is not possible to quantify the number of customer contacts in which such comments were made.  Staff has made these narratives available for review.  See Staff’s response to U S WEST’s First Production Request No. 9 and Second Production Request No. 16.
C.Staff’s request that voice messaging service would be beneficial was based upon oral comments made by a number of customers with held orders to Staff compliance investigator.  Because such comments are not necessarily recorded in the investigations narratives, it is not possible to quantify the number of customer contacts in which such comments were made.  Staff has made these narratives available for review.  See Staff’s response to U S WEST’s First Production Request No. 9 and Second Production Request No. 16.
Request No. 25:Hart p. 49
Please provide all data upon which you rely for the claim that the voluntary credit in the amount of the nonrecurring charge is "not sufficient."  Please provide data on all other Idaho utilities with which U S WEST is compared in this docket regarding the level of voluntary incentives that they provide to customers whose service installation is delayed.
Response No. 25:Staff’s indication that the credit in the amount of the non-recurring charge is not sufficient is based upon oral comments made by a number of customers with held orders to Staff witness Hart in the performance of his duties as an investigator, as well as to other investigators receiving similar comments.  Many customers indicated that this credit does not even come close to compensating them for the inconvenience and hassle that is caused by the delay in their service installation.  Because such comments are not necessarily recorded in the investigator’s notes of conversations, it is not possible to quantify the number of customer contacts in which such comments were made.
Request No. 26:Hart p. 51
In response to a prior U S WEST request, Staff indicated that it did not break down complaint and comment information by Title 61 and Title 62.  Since the testimony at lines 5 through 7 suggests Staff has partial information which enables it to distinguish between Title 61 and 62 customers, U S WEST requests that all such information be provided.
Response No. 26:Staff investigatory records are not coded in such a way as to identify Title 61 and Title 62 customers.  However, during the course of investigating complaints, it may become evident that the customer is a Title 62 customer, or that the services that are the subject of the complaint are Title 62 services.  Staff’s comments are based upon the professional experience of Staff witness Hart.  See Staff’s response to U S WEST’s Second Production Request No. 16.  Furthermore, Staff objects to this request on the grounds that it is burdensome and voluminous.  Staff has provided its workpaper in its answer to U S WEST’s First Production Request No. 4.  Staff has also made its narrative available for review at the office of the PUC during regular business hours.  See Staff response to U S WEST’s First Production Request No. 9.
Request No. 27:Hart p. 52
Provide the absolute number by month of cases in which the Staff's investigation record reveals that credits for missed repair commitments were not provided until Staff requested them.
Response No. 27:Staff objects to this request on the grounds that the term “absolute number” is vague and ambiguous.  Further, Staff objects on the grounds that to fully answer this question would require a special study that would be extremely time consuming and burdensome.  Staff’s assertion that credits for missed installation commitments were not provided until Staff requested was based upon Staff witness Hart’s reading of the narrative portion of the investigatory records for all repair investigations for 1995 and through September of 1996.  Staff’s investigatory records do not have a code to capture this information, so it is not able to provide such numbers without an extensive and time-consuming effort.  See Staff’s response to U S WEST’s Second Production Request No. 16.
Request No. 28:Hart p. 52, l. 13
Please provide any estimates made by the Staff which calculate any hardware and/or software costs of providing automatic credits for missed repair commitments.
Response No. 28:Staff has not made an estimate of the costs of providing automatic credits for missed repair commitments, nor has it calculated the costs to consumers who take time off from work to be available for U S WEST repair personnel that do not meet such commitments.
Request No. 29:Hart p. 53
Provide all data and justification upon which you rely for you recommendation that the voluntary credit for missed installation and repair should be doubled.  Please provide data regarding the level of customer credit provided by all other Idaho utilities with which U S WEST is compared in this docket.
Response No. 29:Staff’s testimony that the credit for missed installation and repair should be doubled is based upon oral comments made by a number of customers with delayed installations or repairs to Staff witness Hart in the performance of his duties as an investigator, and to other investigators receiving similar comments.
GTE Northwest has implemented its Service Guarantee Program, a voluntary program that provides residential customers with a credit of $25, and business customers with a credit of $100, if it fails to meet a commitment for either repair or installation.  Staff is not aware of similar programs offered by other regulated Idaho utilities.
Request No. 30:Hart
Please provide any calculations or estimates made by the Staff which quantify the annual cost of its entire service quality package of recommendations.
Response No. 30:Staff did not prepare any estimate of the cost of the service quality package of recommendations.
Request No. 31:Hart p. 55
A.Does Staff believe that there are ramifications of the request that
U S WEST's toll blocking service be re-regulated other than that it would give the Commission the opportunity to change the rate design for the service?  If so, please describe in detail any such ramifications.
B.Please provide all information upon which Staff relies for the conclusion that customers would be financially better off if the Staff's proposed rate design were utilized as opposed to the current
U S WEST design.
Response No. 31:
A.No.
B.Staff’s rate design recommendation was a response to concerns expressed by customers to Staff witness Hart and other investigators in the course of their complaint investigations.  While these comments are frequently not documented in the narrative of the investigation records, and therefore it is not possible to quantify the frequency such concerns are expressed, all of the investigators identified this issue as one of the common concerns expressed by customers who are provided service with a toll restriction.  From the viewpoint of many of these customers, they are force to pay more to receive less.  Many objected to an ongoing charge, when they did not believe the Company experienced ongoing costs.
Staff reviewed the Company’s charges for other services that require an initial programing effort to establish.  Staff identified blocking for 10XXX access, which has a $4 non-recurring charge, and per line blocking for Caller ID, which has an $8 non-recurring charge.  Staff’s recommendation of $6 simply averaged these two charges.
Staff does not have sufficient information to determine the number or percentage of customers that would be better off financially under the Staff’s proposed rate design.
Request No. 32: Hart p. 57
A.Provide all data and information upon which you rely in reaching the conclusion, "collecting zone connection charges based upon out-of-date maps lead to inequalities and discriminatory practices, and is not acceptable."
B.Provide the absolute number, by month of the customer complaints/inquiries the Staff has received on the issue of collection of zone connection charges based on "out-of-data maps."  Further provide the number of such contacts in each month which resulted in U S WEST changing its actions or instigating new actions.
Response No. 32:
A.Zone connection charges are used in lieu of actual costs to simplify the ordering process.  In order to impose such charges as equitably as possible, zones should be designed such that the costs of connecting all of the customers within the zone would be similar.  Factors such as distance from the central office and the density of the development are used in setting zone boundaries.  Over time, as development occurs, parts of a zone that were once rural in character, with relatively few homes per mile, become more dense.  The costs per connection for the more dense areas will decline, and be lower than the areas of the zone that do not experience such growth.  Unless zone boundaries are redrawn, customers from the different areas within the zone will continue to pay the same connection charge, even though the costs of providing their services have changed.  To the extend that some customers are charged a higher percentage of actual costs than others, the charges are no longer equitable and are discriminatory.
B.Staff objects to this request on the grounds that the term “absolute number” is vague and ambiguous.  Further, Staff objects on the grounds that to fully answer this question would require a special study that would be extremely time consuming and burdensome.  See Staff’s response to U S WEST’s Second Production Request No. 16.  Staff investigated at least 7 complaints about zone connection charges in the past year.  At least 4 of these complaints involved customers complaining that they had been charged more than neighbors.
Request No. 33:Hart pp. 57-58
With regard to Staff's concerns relating to special construction charges, please provide by month the absolute number of customer complaints/inquiries the Staff has recorded dealing with this issue.  Please further break down each month's contacts between those relating to Title 61 and Title 62 services to the extent possible.
Response No. 33:Staff objects to this request on the grounds that the term “absolute number” is vague and ambiguous.  Further, Staff objects on the grounds that to fully answer this question would require a special study that would be extremely time consuming and burdensome.  See Staff’s response to U S WEST’s Second Production Request No. 16.  Staff has investigated at least 5 complaints about special construction charges in the past year.  At least 4 of these complaints involved services that were readily determined to be Title 62 services, while the remaining one appeared to be Title 61 services.
Request No. 34:Carol Cooper p. 3
With respect to each  violation referenced in the Carol Cooper testimony, p. 3,  ll. 12-15, please state the name, address, and account number for each alleged violation, and state with specificity each an every fact upon which you base your allegation that Rule 103.01 was violated in each instance.
Response No. 34:Testimony was based on comments made by complainants during conversations with investigators and documented in complaint narratives.  Information describing customer complaints for the years 1990 through September of 1996 was included in the workpapers for Staff witness Hart in Staff's response to U S WEST's First Production Request No. 4.  The underlying narrative of the investigatory record is not subject to disclosure.  Commission Rules of Procedure, Rule 26; Idaho Code § 9-337(5); Idaho Code § 9-335; Idaho Code § 9-340(22).  All identified inquiries and complaints were considered, investigated and handled informally by Staff.  Commission Rules of Procedures, Rule 21.  Staff has agreed to provide all parties to this case who have executed a confidentiality agreement access to narrative records for these investigations and has made those records available at the office of the IPUC during regular business hours.  See Staff's response to U S WEST's First Production Request   No. 9.
Request No. 35:Carol Cooper pp. 4-5
With respect to the testimony, pp. 4-5, regarding alleged violations of Rule 105.02, please identify each and every instance in which "Staff investigations" allegedly "substantiated" that deposits were incorrectly calculated by U S WEST.
Response No. 35:For August 1995, there is at least one complaint that describes problems with calculation of deposits.  In response to that complaint, U S WEST admitted that the deposit amount was based on twice the average of the most recent four bills.  There may be others that have not been discovered because of the volume of records involved.  Staff has made these records available for review.  See Staff's response to U S WEST's Second Production Request No. 34.
Request No. 36:Carol Cooper p. 4
Please provide the total number of complaints/inquiries the Staff has documented regarding calculations of toll deposits by all other toll providers or toll billing agents authorized to do business in Idaho for the years 1994 to present.
Response No. 36:No comparison was made with other toll providers or billing agents.
Request No. 37:Carol Cooper p. 5
With respect to the testimony of Carol Cooper, p. 5, ll. 14-25, please provide the name, address, and account number of the customer for which the Staff allegedly documented four violations of Rule 105.02.
Response No. 37:Testimony was based on comments made by complainants during conversations with investigators and documented in complaint narratives.  Staff has made these narratives available for review.  See Staff's response to U S WEST's Second Production Request No. 34.
Request No. 38:Carol Cooper p. 6
With respect to the testimony of Cooper, at p. 6, please provide each and every fact upon which you base your statement that U S WEST has failed to correctly allocate payments to customers, in violation of Rule 312.03.
Response No. 38:Testimony was based on information gathered during investigations and documented in the complaint narratives.  Staff has made these narratives available for review.  See Staff's response to U S WEST's Second Production Request No. 34.
Request No. 39:Carol Cooper
Please quantify the total number of instances by month for January  1994 to present in which Staff has discovered an alleged violation of Rule 312.03 or 401.02.  Please provide the same information for all other telephone corporations or billing agents of telephone corporations which are authorized to provide service in Idaho.
Response No. 39:There were 13 investigations that outlined problems from January 1, 1996 through September 30, 1996.  Due to voluminous material to examine, there may be more than 13 instances.  Data was not accumulated on a monthly basis.  Results for 1994 or 1995 were not quantified.  No comparison was done to other telephone corporations.
Request No. 40:Carol Cooper
Please quantify the total number of instances by month for January 1991 to the present in which Staff has discovered a situation in which U S WEST has failed to permanently remove disputed charges from a customer's bill.  Provide the same information for all telephone corporations or billing agents of telephone corporations which are authorized to serve Idaho.
Response No. 40:No comparison was made to other telephone corporations or billing agents.  See Staff's response to U S WEST's Second Production Request Nos. 39 and 41.
Request No. 41:Carol Cooper p. 6
With respect to the testimony of Ms. Cooper, p. 6, ll. 24-25 and at p. 7 and 8, please identify each and every instance upon which you base your statement that                U S WEST violated Rule 401.02 by allowing disputed charges to appear on bills, or by removing and then reinstating charges a few months later.
Response No. 41:Testimony was based on comments made by complainants during conversations with investigators and documented in complaint narratives.  Staff has made these records available for review.  See Staff's response to U S WEST's Second Production Request  No. 34.
Request No. 42:Carol Cooper p. 7
Please provide all data and information upon which you rely for the claim that it is unreasonable to require customers to tell U S WEST how they want payments allocated when they are in a dispute with another company.
Response No. 42:No allegation was made in Carol Cooper’s testimony at page 7 “that it is unreasonable to require customers to tell U S WEST how they want payments allocated when they are in a dispute with another company.”  Rather, testimony points out that a customer should not have to repeatedly call the Company to provide directions on how to apply payments.
Request No. 43:Carol Cooper p. 8
A.Please provide all information upon which you rely for the contention that U S WEST has violated Rule 601.03 in connection with its policy not to print apartment and suite number information.
B.Please provide the absolute number of customer complaints/contacts by month for the years 1991 to present which relate to this alleged rule violation.
C.Please provide all data or other information demonstrating that other publishers of telephone directories in the state provide this service without charge.
Response No. 43:
A.See Exhibit No. 116, Schedule C, pages 1 and 2 of Carol J. Cooper’s Direct Testimony.  See also U S WEST’s response to Staff Production Request No. 215.
B.Staff objects to this request on the grounds that it seeks information that is voluminous and burdensome to obtain, further the term  “absolute number” is vague and ambiguous.  However, Staff did research the records for the year 1995 and found that there was one complaint.
C.Staff witness Cooper does not have policies for other publishers in her possession.  Further, Staff witness Cooper did not rely on such data for her testimony.
Request No. 44:Carol Cooper p. 10
With respect to the testimony of Ms. Cooper  at p. 10, regarding U S WEST's new bill format, please identify each and every rule allegedly violated by U S WEST's new bill format.
Response No. 44:U S WEST’s new bill format does not violate PUC rules.
Request No. 45:Carol Cooper
Provide the total number of customer complaints/inquiries Staff has received from customers relating to the new bill format.
Response No. 45:Staff has not identified bill format complaints by a specific reason code.  Customers have made comments about the format while discussing other issues.
Request No. 46:Carol Cooper p. 12
With respect to the testimony of Ms. Cooper at p. 12, ll. 19-24, please identify the number of violations and the number of customers allegedly affected with respect to your statements regarding customers with restricted service who eventually lost their service from U S WEST.
Response No. 46:Staff has not identified by a specific reason code complaints from customers with restricted service who eventually were disconnected.  A review of complaint narratives revealed 38 toll restricted customers who were threatened with disconnection from January 1, 1996 through September 30, 1996.
Request No. 47:Carol Cooper p. 12
With respect to the testimony of Ms. Cooper, p. 12, ll. 19-24, please identify each and every fact upon which you base your statement that there is a pattern demonstrating that "customers who are toll restricted are eventually threatened with disconnection or lose their phone completely because they get further in debt and cannot pay the bill."
Response No. 47:Staff relied on its review of investigatory records.  Staff has made these records available for review.  See Staff's response to U S WEST's Second Production Request No. 34.
Request No. 48:Carol Cooper p. 13
With respect to the testimony of Ms. Cooper, p. 13, ll. 4-7, please provide each and every fact upon which you base your statement that "the added expense of custom calling services and voice messaging service" is a contributing factor for customers who are unable to maintain their monthly payments.
Response No. 48:Staff relied on its review of investigatory records.  Staff has made these records available for review.  See Staff's response to U S WEST's Second Production Request No. 34.
Request No. 49:Carol Cooper pp 13-14
With respect to the testimony of Ms. Cooper, pp. 13-14, please identify the number of customers identified by your research who had prior credit problems who became unable to maintain their monthly payments due to custom calling services and/or voice messaging services.
Response No. 49:Staff has not identified complaints from customers with custom calling services and voice messaging services by a specific reason code.  By reviewing investigatory records for the period from January 1, 1996 through September 30, 1996, Staff identified 99 investigations involving pending or actual disconnection of service for customers with amounts owing for non-regulated services.
Request No. 50:Carol Cooper p. 15
With respect to the testimony of Ms. Cooper at p. 15, ll. 6-12, please identify each and every fact upon which you base your statement that "in the long run, uncollectibles place an upward pressure on rates."
Response No. 50:Uncollectibles decrease the Company’s revenues.  Staff has evidence there has been an increase in uncollectibles, expressed both as actual dollars as well as a percentage of uncollectibles to gross sales.  See line 12 in U S WEST's revenue sharing report for 1995, Case No. USW-S-96-3.
Request No. 51:Carol Cooper p. 16
Please provide the total number of complaints/comments received by Staff from non-listed customers who have been contacted by U S WEST telephone solicitors.
Response No. 51:From January 1, 1996 through September 30, 1996, there were 6 complaints from non-listed customers regarding U S WEST telephone solicitors.
Request No. 52:With respect to the testimony of Ms. Cooper at p. 16, ll. 1-6, please specify the number of customers who were toll restricted or toll denied customers that actually "paid off their toll sooner than agreed to because they wanted their long distance service back."
Response No. 52:Staff objects to this request on the grounds that it seeks information that is voluminous and burdensome to obtain.  However, Staff has made the records available for review.  See Staff's response to U S WEST's Second Production Request No. 34.  
Request No. 53:Carol Cooper pp. 17-19
With respect to the testimony of Ms. Cooper, pp. 17-19, please identify each and every fact upon which you base your statements that U S WEST has discouraged customers from implementing a PIC freeze.
Response No. 53:Staff relied on its review of investigatory records and U S WEST’s responses to Staff’s Production Requests Nos. 19 and 157.  Staff has made these records available for review.  See Staff's response to U S WEST's Second Production Request No. 34.
Request No. 54:Carol Cooper pp. 19-22
With respect to the testimony of Ms. Cooper, at pp. 19-22, please identify the specificity and the number of customers allegedly affected by billing and collection problems.
Response No. 54:From January 1, 1995 through September 30, 1996, there were 892 U S WEST customers who contacted the PUC regarding disconnection or billing problems.
Request No. 55:Carol Cooper pp. 19-22
With respect to the testimony of Ms. Cooper pp. 19-22, please identify each and every fact upon which you base your statements that there have been "a number of problems, including lost and misapplied payments, misplaced proof of payment, delayed return of deposits, and failure to advice [sic] customers of how to allocate payments so that local exchange service could be preserved."  Provide the total number of such investigations the Staff has conducted into such allegations for the years 1994 to present and the total number of such investigations in which U S WEST was found to have been at fault.
Response No. 55:Staff relied on its review of investigatory records.  Staff objects to the request to provide the total number of Staff's investigations and the total number in which    U S WEST was at fault on the grounds that it seeks information that is voluminous and burdensome to obtain.  However, Staff has made the records available for review.  See Staff's response to U S WEST's Second Production Request No. 34.
Request No. 56:Carol Cooper p. 19
With respect to the testimony of Ms. Cooper p. 19, ll. 20-23, please identify each and every fact upon which you base your statement that "there is ample evidence to conclude that the Company is experiencing serious difficulties with its billing and collection operations."
Response No. 56:See Staff's response to U S WEST's Second Production        Request No. 55.
Request No. 57:Eastlake p. 5
Provide a copy of the article by Charles M. Studness referenced on page 5.
Response No. 57:A photocopy of the article is attached.
Request No. 58:Eastlake p. 5
Provide a copy of the Edythe Miller article referenced on page 5.
Response No. 58:A photocopy of the article is attached.
Request No. 59:Eastlake p. 6
Provide all facts and data upon which Mr. Eastlake relies in making the statement that the Company is attempting to recover "all" its costs for the old regulated monopoly world.
Response No. 59:No specific data or facts are relevant to the use of the word in the sentence referenced.  The word “all” is used colloquially with respect to both the old regulated world and the new competitive one.  By implication, the word “all” here refers to the costs normally recoverable under a regulatory regime.  The meaning of the sentence would not be harmed by dropping the term “all” from lines 13 and 15 alike, on page 6.
Request No. 60:Eastlake p. 6
A.Please list the "competitive markets that [U S WEST] has always sought to enter" for which Mr. Eastlake suggests that U S WEST should be willing to "give up some small portion of its return on regulated services".  Please quantify in terms of dollars or percentage of overall return the "small portion" that U S WEST should be expected to "give up."
B.Is it Mr. Eastlake's view that U S WEST should be granted a lower overall rate of return on its Title 61 operations in exchange for exercising its freedoms to provide Title 62 services?  Is Mr. Eastlake suggesting that a lower overall return should be a part of the "price tag" for receiving interLATA freedoms in addition to the federal checklist requirements?  Please explain.
Response No. 60:
A.The markets referred to include both current and future Title 62 services and future interLATA long distance.  The reference to “small portion” is not meant to be formally quantified, but only to imply that it could be a sound business decision for a company to accept lower returns in one phase of its business in order to develop higher returns in a new and expanding phase of its business.
B.No to both questions.
Request No. 61:Eastlake p. 8
Please explain why a customer who states U S WEST is asking "us business customers to subsidize their investments/ expenses" summarizes customers' concerns about U S WEST's proposed residential rate increase.
Response No. 61:This quote was from a business customer who read the USW mail insert and noted that it referred to a “58% increase in revenues from regulated services” and who calculated a 20% increase in business rates from rate groups 1 and 2 being consolidated into rate group 3.  He expresses concern about U S WEST’s proposed revenue increase for its regulated service in the face of new competition.  The complete text of the FAX message is attached.  The discussion in Eastlake testimony leading up to this quote was about general increases in the revenues from Title 61 services and was neither limited nor specific to the proposed residential rate increases.
Request No. 62:Eastlake p. 8, ll. 5-8
A.Provide references including title, author, publisher, publication date and page number for any and all recognized texts or other authoritative publications on economic theory which define the term "subsidy" as "the payment needed to cover losses incurred by a declining cost natural monopoly when it produces out put at the socially optional level of production."
B.Provide photo copies of the relevant pages of any such texts upon which you rely for this statement.
Response No. 62:
A.There is no such reference on page 8.  The sentence on page 9 (referring to the socially “optimal” level) is meant to paraphrase the general context in which the term subsidy is most often used in economics texts.  Attached are title pages plus relevant pages from two economics texts that contain examples of such use of the term.
B.There is no such reference on page 8.  The sentence on page 9 (referring to the socially “optimal” level) is meant to paraphrase the general context in which the term subsidy is most often used in economics texts.  Attached are title pages plus relevant pages from two economics texts that contain examples of such use of the term.
Request No. 63:Eastlake p. 21
A.Does this analysis of the increase in Title 61 revenues resulting from rate group consolidation take into account the number of Rate Group 1 and 2 customers who are being moved to Rate Group 3 as a result of the EAS order?
B.What is Staff's analysis of the revenue increase occasioned by moving remaining Rate Group 1 and 2 customers into the new "out-of-region" rate group proposed by U S WEST?  Provide work papers.
Response No. 63:
A.No.  This analysis behind the rate consolidation portion of Exhibit No.  129 mirrors the methodology for rate spread outlined in USW Response to Staff Production Request STF01-029 and does not consider the EAS order.  The workpapers filed with Eastlake Direct Testimony  and identified as WP2A and WP2B essentially replicate the Company’s Attachments A and C to STF01-029, on which it is clearly noted  that the analysis assumes EAS is not in place.
B.Staff has not performed such analysis for two reasons, one related to methodology and one related to basic data.
First, using methodology similar to that noted in No. 63A Staff attempted to model the EAS proposal from the Company’s original application, but was unable to replicate what the Company asserted was about a $6 million decrease in revenue requirement from $38 to $32 million.  Staff asked for the Company’s original EAS rate spread in a fashion similar to that provided in STF01-029 so that it might use common methodology in its own proposed rate design.  The Company ultimately did not provide that EAS rate spread, arguing that it was reworking the numbers from the original application to reflect the formal EAS order and that it would provide such a rate spread upon filing of its rebuttal testimony.
Second, Staff has never been able to reconcile the three different sets of line counts provided by the Company in response to various production requests.  Staff has asked repeatedly for clarification on this matter.  Absent agreed upon basic residence and business line numbers, disaggregated by exchange and by rate group and by USOC, Staff is unable to make a proper analysis of any EAS proposal.  In addition, Staff and Company agree that the EAS rates in the original application are now incorrect, but no current Company proposal reflecting the terms of the EAS order has been provided.
Request No. 64:Eastlake p. 24; p. 27
A.Provide all facts upon which Staff relies in support of its recommendation that the 2.59 to 1 ratio of business to residential rate should be continued.
B.To the extent Staff has cost data which supports the conclusion that business service is more expensive to provide than residence service, provide all cost studies, formulas, assumptions and calculations used in reaching this conclusion.
Response No. 64:
A.Staff’s testimony outlines several factual reasons for continuation of the current ratio.
B.Staff does not have cost data that provides the information requested.
Request No. 65:Eastlake p. 24, ll. 19-2
Please explain this statement.  Does this testimony imply that U S WEST's costs showing business service is less costly to provide than residence service is polluted with lower Title 62 business services costs?  If Staff has determined that Title 62 business service costs are lower than Title 61 business service costs, provide all facts and data which support this conclusion.
Response No. 65:There is no specific implication intended about the relationship between Title 62 and Title 61 business costs.  The point is that the relationship depends ultimately on the allocation of costs between Title 61 and Title 62.
Request No. 66:Eastlake p. 40
Apart from possible new capital investment, is it Staff's opinion that the only added cost incurred by U S WEST in converting toll to local under the EAS order is in local switching?  If not, please itemize all other additional costs you believe U S WEST will incur in providing expanded local calling.
Response No. 66:No.  Absent any network design and cost figures involved with the implementation of EAS, it is not possible for Staff to estimate costs other than local switching.  Additional transport costs may also be applicable.
Request No. 67:Eastlake
In the recent EAS case, Staff recommended that rates of residential customers be increased to reflect EAS but that business customer's rates should increase only where they were moved to a larger rate group.  Please calculate in the same manner as your calculations in Exhibit 131 the impact on the business to residence ratio occasioned by the EAS rate changes recommended by Staff in the EAS docket.
Response No. 67:Staff Direct Testimony at page 9 in the EAS Case No. USW-S-96-4 and in the transcript at pages 507-508 should not be interpreted as an active recommendation concerning the business to residence ratio.  That testimony passively allows that it is appropriate in that case to make the small change that results from the EAS adder being applied only to residence rates and recommends that the ratios should be decided in the rate case.
As noted in Answer No. 63 above, Staff has not made any specific calculations based on an EAS.
Request No. 68:Eastlake p. 40
What is Staff's understanding of the "joint and common costs" that are included in U S WEST's TELRIC for local switching?
Response No. 68:That both shared and common costs are included and that the part of common costs that varies with provisioning of individual elements is included in the TELRIC itself.  The number Staff used in Exhibit No. 101 for switching cost is labeled a fully allocated cost and is a sum of separate items for TELRIC and for common cost.
Request No. 69:Eastlake p. 40
In calculating U S WEST's revenue requirement in this case what assumption did Staff use regarding U S WEST's rural zone charge recurring revenues?
Response No. 69:Mirroring the rate spread offered by the Company in response to STF01-029, which indicated no consideration of such recurring revenues, Staff has made no attempt to formally model any impacts associated with rural zone charges.  Until revenue sharing funds are exhausted, revenue losses from rural zone charges will be offset by credits.  Going forward such charges will not exist.
Request No. 70:Eastlake p. 41
Provide all reasoning behind Staff's recommendation that remaining Revenue Sharing monies should be returned over a four month period as opposed to a longer or shorter period.
Response No. 70:This was a simple judgment call based on very rough estimation of the size of the possible monthly credit.  Giving it all back in one lump would result in a single large credit.  Giving it back over a period as long as a year would be hardly noticeable on an individual bill.
Request No. 71:Eastlake pp. 41-42
A.List the "set of very important considerations" that should be examined in creating a rate design which involves a large revenue increase from Title 61 services.
B.List the "entirely different set of criteria" Staff believes should be considered in creating a rate design spreading a large Title 61 revenue decrease.
Response No. 71:
A.A variety of considerations important for a large increase can be enumerated.  Some deal with administrative convenience.  Most deal with equity.  Should the increase be phased in or done all at once?  If it is phased, is that for the Company’s public image or to alleviate rate shock?  If it is phased, over how long a period?  Will the increase jeopardize universal service?  If so, are there mitigation strategies, such as offering free conversion to measured service or other lifeline-type programs, that might be appropriate?  Given existing rate ratios, such as the business-residence or the flat-measured ratios, would the increase fall disproportionately on some group of customers?  Would a large increase cause substitution of alternative communication modes for Company offerings and should this elasticity effect be recognized in rate design?  Where the customers are asked to shoulder an increased burden, more  attention must be given to their needs.
B.Please see Eastlake testimony at lines 4-13 of page 42.  Since all customers could be “winners” with a large decrease, questions of equity and relationships among rates diminish in importance.  Increasing in importance in this case may be the need for administrative simplicity, so that the Company is not incurring the cost of making expensive changes in the face of declining revenue requirement.  Where the Company is asked to accommodate a decreased revenue requirement, additional effort should be expended to make that change as simple as possible.
Request No. 72:Eastlake pp. 41-42
A.Assume the Commission determines U S WEST is entitled to a rate increase which will produce an additional $32 million in Title 61 revenues.  Provide your recommendations for the rates for 1FR, 1FB, 1MR, 1MB, and privacy listings.
B.Assume the Commission determines U S WEST's Title 61 revenues should be reduced by $32 million.  Provide your recommendation for the rates for 1FR, 1FB, 1MR, 1MB, and privacy listings.
Response No. 72:
A.Please see Eastlake testimony at page 37 with reference to the business-residence ratio and generically at pages 42 and 43 with reference to principles for rate design.  Staff has recommended only that existing rate ratios be preserved.  Because of both data and methodological uncertainties surrounding the modeling of an EAS proposal, as noted above in Answers No. 63 and 69, Staff has not made calculation of the actual rates that preserve those ratios with any specific revenue requirement.
B.Please see Eastlake testimony at page 37 with reference to the business-residence ratio and generically at pages 42 and 43 with reference to principles for rate design.  Staff has recommended only that existing rate ratios be preserved.  Because of both data and methodological uncertainties surrounding the modeling of an EAS proposal, as noted above in Answers No. 63 and 69, Staff has not made calculation of the actual rates that preserve those ratios with any specific revenue requirement.
Request No. 73:Eastlake p. 42
A.Provide all facts and data which support your conclusion that the existing ratio of local measured to flat-rated local service rate should continue.
B.Does the inclusion of 180 minutes of local calling change the appropriate ratio?  Why or why not?
Response No. 73:
A.Specific mention of measured service was made only by way of example of an existing rate ratio that should be preserved.  Staff stands on the answers mentioned in its testimony and in earlier questions that existing rate ratios should be preserved in this case.
B.Staff did not consider any changes in appropriate ratios.  Staff analysis on page 28 of Eastlake Direct Testimony demonstrates that in the Company’s proposal the 180 minute call allowance is more than offset by the proposed increase in the per minute charge.  This prevents the increased allowance from having any major impact of the relative conditions affecting customer choice of flat versus measured rates.
Request No. 74:Eastlake p. 43
Please explain your statement at lines 9-12.  Does this relate to different charges for local measured service customers, to different rate group configurations or to some other proposal?
Response No. 74:The differential referred to here addresses higher rates for customers within EAS regions than for customers outside EAS regions and would reflect the fact that larger calling areas are more valuable than smaller ones.
Request No. 75:  Schneider p. 11
Provide a copy of the Telephony magazine article to which you refer in testimony on page 11.
Response No. 75:The article is in your response to IPUC Staff Audit Request       No. 78C.
Request No. 76:Carlock p. 3
Please provide all information upon which you rely for the statement that                U S WEST Communication has "unique" access to names, addresses and telephone numbers of all residents and businesses as compared with other users who have purchased the information from the directory publication subsidiary.
Response No. 76:On page 3, I state, “The incumbent local exchange carrier (LEC) will maintain unique access to names, addresses and telephone numbers of all residents and businesses.”  U S WEST Communications is the incumbent LEC, therefore it has primary access to names, addresses and telephone numbers of all residents and businesses taking local service.
Request No. 77:Carlock p. 8  
Upon what "USWD market research" do you rely for the claim that the U S WEST Direct directory "continues to be the primary directory referenced by customers and advertised in by advertisers."   Please specify by number all data responses which contributed to this understanding.
Response No. 77:I relied primarily on the U S WEST answer to Staff Production Request No. 265 including SIMBA Information, Inc. and SIMBA/Communications Trends articles and USWD Idaho market share data.
Request No. 78:Carlock p. 11
Please explain how allocation of 100% of the directory revenues to Title 61 (as recommended on page 11, line 3) is fair to other potential providers of Title 61 local exchange service, but is unfair to alternative providers of Title 62 service (See, page 11,
line 5).
Response No. 78:As explained on page 11, lines 6 - 15 of my direct testimony, I believe the price set by this Commission for local resale could reflect the directory revenue benefit and passed on to the local service customer.  This uniform benefit would be fair to all local service customers and would not disadvantage other potential Title 61 providers since the benefit is reflected in the resale price to all providers.  This would not necessarily be the case with Title 62 services because charges for all Title 62 services are not established by this Commission and the benefit may not be passed on to the end-user customer.
Request No. 79:Carlock p. 23
Please provide all information upon which you rely for the claim that  "competitive risks are less for U S WEST than for many telephone companies."
Response No. 79:The following documents were reviewed to support this statement:  Rating Agency and Market publications from Standard & Poors; Duff & Phelps; Salomon Brothers; Fitch; Furman Selz; Moody's Public Utility Manual, 1995 and 1996; Moody's Public Utility News Reports, 1996; C.A. Turner Utility Report, March and November 1996; Value Line Investment Survey for Windows, October 30, 1996 - data discs.  News releases and data off the Internet from PointCast and QuoteCom Services.
Request No. 80:Stockton
Please provide your source of information that indicates the existence of a State Executive Board in Idaho as referenced on page 6, line 5 & 6.
Response No. 80:The referenced statement does not indicate the existence of a State Executive Board in Idaho.  Those lines state:  “...Advisors (current members of the State Executive Boards ) are also eligible for concession...”  The information is from U S WEST Communications, Inc., Regional Policy and Procedures “RPP 1207 - Telephone Concession Plan” manual that was received in response to Staff Audit Request 41.  The source of information for the Advisors is found in Section 5 of the manual.  
Request No. 81:Stockton p. 8
Please list and describe each and every action taken by the Staff or the Commission to enforce Order No. 18188 as it pertains to the requirement of an informational tariff filing or other statement regarding the provision of telephone concession to employees.
Response No. 81:Staff is unaware of any specific actions to enforce Order             No. 18188 as it pertains to the requirement of an informational tariff filing or other statement regarding the provision of telephone concession to employees.
Request No. 82:Stockton p. 13
Please describe the process of your analysis and the basis of your decision to exclude any sub-account as not relating to Title 61 services.  Was this done entirely on the basis of the sub-account title?  If not, identify all other methods used to make this determination.  Please provide a list of all sub-account titles which you determined related entirely to    Title 62.  Please provide a similar list for all that you determined to be Title 61.
Response No. 82:Staff objects to the term “process of analysis” as being vague and ambiguous.  For clarity in responding to request No. 82, I have broken the request down into three parts.
A. Please describe the process of your analysis and the basis of your decision to exclude any sub-account as not relating to Title 61 services.  Was this done entirely on the basis of the sub-account title?  If not, identify all other methods used to make this determination.
The process of my analysis and  the basis of my decision to exclude any sub-account as not relating to Title 61 services is explained in my direct testimony.  I entered each and every account and sub-account heading into a lotus spreadsheet.  I then inserted the year-end dollar amounts into the spreadsheet in the appropriate accounts.  These dollar amounts, as previously stated in my direct testimony, are from the U S WEST southern Idaho Jurisdictional books.  The decision to classify an account as not being related to Title 61 services was not done entirely on the basis of the account title.  I also relied on the assistance of Staff Accountant Syd Lansing, when deciding which accounts to exclude as a part of the Chart of Accounts adjustment.  In addition to the account title, and the expertise of Syd Lansing, I also relied upon the FCC’s Part 32, Uniform System of Accounts, specifically Section 32.5999 through Section 32.7250.  Copies of these spreadsheets were provided on November 26, 1996.  A disk containing these spreadsheet files was also provided on November 27, 1996.
B.  Please provide a list of all sub-account titles which you determined related entirely to Title 62.
A list of sub-account titles which are identified as being “Not Title 61" expenses has previously be provided in Stockton’s work papers.
C. Please provide a similar list for all that you determined to be Title 61.
A complete list of all accounts has previously been provided in Stockton’s work papers.  The accounts that have been identified as being “Not Title 61" expenses are included in the complete listing of all accounts.  The accounts and sub-accounts of expenses on the complete list that are not included in the “Not Title 61" category are either Title 61 expenses or Title 61 and 62 expenses.
Request No. 83:Stockton p. 14
What numerical portion of your "adjustment to expenses" of $9,827,635 was included in Title 61 expenses in U S WEST's rate request in this docket?  Please provide work papers showing how you reached this conclusion.
Response No. 83:Staff did not calculate whether any portion of $9,827,635 was included as part of the Company’s Title 61 expenses.  U S WEST’s Title 61 rate request did not contain sufficient detail in the work papers for Staff to use it as the starting point to calculate Staff’s proposed revenue requirement.  These expenses should be directly assigned at the Idaho Intrastate level.  Staff’s case is based on the 1995 Idaho Intrastate JD booked amounts.
Request No. 84:Stockton pp. 21-22.
A.Is this adjustment made exclusively on the basis that the entries (in your opinion) related to expenses that should be allocated solely to Title 62 services, or does the adjustment also cover expenses that you believe should be allocated to a different jurisdiction?  If your adjustment covers both kinds of issues, please provide a breakdown of all components of the $857,352 adjustment as to whether they are made on the basis of  1) not being related to a Title 61 service or, 2) not being related directly related to the  southern Idaho jurisdiction.
B.What portion of the $857,352 adjustment was included by U S WEST in its rate request in this docket?   Please provide work papers showing your calculations for this response.
Response No. 84:
A.Staff provided my workpapers on November 26, 1996,  that identify the adjustment components.
B.Staff did not calculate whether any portion of $857,352 was included as part of the Company’s Title 61 expenses.  U S WEST’s Title 61 rate request did not contain sufficient detail in the work papers for Staff to use it as the starting point to calculate Staff’s proposed revenue requirement.  These expenses should be directly assigned at the Idaho Intrastate level.  Staff’s case is based on the 1995 Idaho Intrastate JD booked amounts.
Request No. 85:Stockton pp. 24-25
What portion of the $784,630 adjustment that you recommend for advertising was included by U S WEST in its rate request in this docket?  Please provide work papers showing your calculations for this response.
Response No. 85:Staff did not calculate whether any portion of $784,630 was included as part of the Company’s Title 61 expenses.  U S WEST’s Title 61 rate request did not contain sufficient detail in the work papers for Staff to use it as the starting point to calculate Staff’s proposed revenue requirement.  These expenses should be directly assigned at the Idaho Intrastate level.  Staff’s case is based on the 1995 Idaho Intrastate JD booked amounts.
Request No. 86:Faunce p. 15
A.Did Staff rely exclusively on the "brief description" information supplied by U S WEST in reaching the conclusion that $119,409 of charges from Strategic Marketing should be "directly assigned" to Part 64 and /or Title 62 services?
B.Please provide all supporting documentation used to determine which costs in each account were Title 62 and which were Title 61.  If the costs were assigned on a project by project basis, please explain the rationale used to assign each project either to Title 62 or to Title 61 on a project by project basis.
C.What portion of the Strategic Marketing expense discussed in this part of your testimony was included by U S WEST in its Title 61 rate request in this docket?  Please provide work papers showing  your calculations for this response.
Response No. 86:
A.Staff relied on STF000-069 Attachment B supplied by U S WEST and on the narrative description of Strategic Marketing contained in the August 1992, Final Report, Regulatory Impact Review of U S WEST, INC. for the Three-State Steering Committee (Schumaker report) Page 36-37.
B.Staff used STF000-069 Attachment B project description to determine which costs in each account were beneficial to Title 61.  Staff believes that where the project description information is lacking or unclear it is the responsibility of the Company to prove the benefit to Title 61.  Staff relied on STF000-026, Attachment A, to determine Strategic Marketing cost of $5,808,648 had been charged to USWC and $158,292 had been charged to Idaho from Inc.  In that U S WEST did not supply an answer in STF000-069 that matched the dollar amount from Inc. to USWC and neither STF000-026 or STF000-073 showed any direct charge to USWC from Strategic Marketing, Staff used a percentage of the amount that was provided to determine the total amount that should be beneficial to Title 61.
C.Staff did not calculate whether any portion of the $119,409 expense was contained in the Company’s Title 61 expenses in this docket.  U S WEST’s Title 61 rate request did not contain sufficient detail in the workpapers for Staff to use it as the starting point to calculate Staff’s proposed revenue requirement.  These expenses should be directly assigned at the Idaho Intrastate level.  Staff’s case is based on the 1995 Idaho Intrastate JD booked amounts.
Request No. 87:Faunce p. 16
What portion of the "yellow page cost of advertising" disallowance of $32,742 was included by U S WEST in its Title 61 rate request in this docket?  Please provide work papers showing your calculations for this response.
Response No. 87:Staff did not calculate whether any portion of the $32,742 expense was contained in the Company’s Title 61 expenses in this docket.  U S WEST’s Title 61 rate request did not contain sufficient detail in the workpapers for Staff to use it as the starting point to calculate Staff’s proposed revenue requirement.  These expenses should be directly assigned at the Idaho Intrastate level.  Staff’s case is based on the 1995 Idaho Intrastate JD booked amounts.
Request No. 88:Faunce p. 17
What portion of the $1,393,495 adjustment associated with U S WEST Communications Service was included by U S WEST in its Title 61 rate request in this docket?  Please provide work papers showing your calculations for this response.
Response No. 88:Staff did not calculate whether any portion of the $1,393,495 was included in the Company’s case as Title 61 expenses in this docket.  U S WEST’s Title 61 rate request did not contain sufficient detail in the workpapers for Staff to use it as the starting point to calculate Staff’s proposed revenue requirement.  These expenses should be directly assigned at the Idaho Intrastate level.  Staff’s case is based on the 1995 Idaho Intrastate JD booked amounts.
Request No. 89:Faunce p. 18
What portion of the $8,047 adjustment associated with U S WEST Communications Service was included by U S WEST in its Title 61 rate request in this docket?  Please provide work papers showing your calculations for this response.
Response No. 89:Staff did not calculate whether any portion of the $8,047 was included in the Company’s case as Title 61 expenses in this docket.  U S WEST’s Title 61 rate request did not contain sufficient detail in the workpapers for Staff to use it as the starting point to calculate Staff’s proposed revenue requirement.  These expenses should be directly assigned at the Idaho Intrastate level.  Staff’s case is based on the 1995 Idaho Intrastate JD booked amounts.
Request No. 90:Faunce p. 19
A.Please provide your analysis of each of the 600 USWAT projects and each of the 700 Bellcore projects.  For each project, please describe whether you place the project in the "re-engineering", Title 62, Part 64, "out-of period", FCC/Access, research, lobbying, state specific, or "support of 61/62 functions" categories.
B.For each project so analyzed, please provide a breakdown of the amount of expense, if any, that was allocated by U S WEST to the Title 61 portion of operations in this case.  Please provide work papers showing your calculations for this response.
Response No. 90:
A.See attached workpapers.  Staff did not directly assign projects or costs to Title 62, Part 64, “out-of-period”, FCC/Access, non-Idaho, non-Idaho regulatory, or lobbying.  These assignments are reflected in the “Not Title 61" column.  Many projects could be considered to fit two or more categories that Staff considers not to be Title 61.  The workpapers show projects assigned to re-engineering (RE-ENG) and repair and development (R&D).  All analysis was made from reading disks supplied by U S WEST in STF000-034, Attachment A and B.
B.Staff did not calculate whether each AT and Bellcore project expenses were contain in the Company’s Title 61 expenses in this case.  U S WEST’s Title 61 rate request did not contain sufficient detail in the workpapers for Staff to use it as the starting point to calculate Staff’s proposed revenue requirement.  These expenses should be directly assigned at the Idaho Intrastate level.  Staff’s case is based on the 1995 Idaho Intrastate JD booked amounts.
Request No. 91:Faunce p. 19
Please provide a spreadsheet on diskette in Excel format which shows the classification and related reasoning for each of the 1300+ AT and BCR projects, as well as the identified costs and related calculations.
Response No. 91:My worksheets are Lotus spreadsheets.  A diskette and hard copy is being provided.
Request No. 92:Faunce p. 23
Please identify all components of your analysis (including calculations) which result in the conclusion presented on page 23 of your testimony that "approximately 30% of USWAT's total costs and 19% of Bellcore's total costs" should be considered re-engineering.
Response No. 92:The information used to calculate these percentages are contained in the spreadsheets supplied in response to Request No. 91.
Request No. 93:Faunce p. 24
Please provide all information upon which you rely for the conclusion that "the monitoring of the FCC and legislation is a duplication of services provided by Inc. and USWC".  Please provide the numerical amount of the duplication that is associated with this adjustment.  What portion of the costs excluded under this adjustment was included by U S WEST in its Title 61 rate request in this case?
Response No. 93:
A.Interview with U S WEST attorney Dan Poole while Staff was auditing in Denver and STF000-070, Attachment A, columns titled client matter 0030, 0031, 0033.
B.See STF000-070, Attachment A, columns titled “client matter” 0030, 0031, 0033.
C.Staff did not calculate whether any portion of the expenses were contained in the Company’s Title 61 expenses in this docket. U S WEST’s Title 61 rate request did not contain sufficient detail in the workpapers for Staff to use it as the starting point to calculate Staff’s proposed revenue requirement.  These expenses should be directly assigned at the Idaho Intrastate level.  Staff’s case is based on the 1995 Idaho Intrastate JD booked amounts.
Request No. 94:Faunce p. 25
Please provide the source of that statement and the data that supports the statement "Only about one in ten research projects will result in a product that is both economically and functionally useful."
Response No. 94:Case No. MTB-T-90-3, Exhibit No. 105, page 42, copy attached.
Request No. 95:Faunce p. 27
Please define the term "subsidizing" as it is used on page 27  at  line 7.
Response No. 95:To support one region’s cost by charging some of the cost to another region.
Request No. 96:Faunce p. 27
Based on lines 8-11 of your testimony, is it correct to conclude that you believe that all BRI expenses allocated to Idaho were allocated to Title 61 by U S WEST?  If not, please provide your understanding of what portion of Idaho BRI expense was not allocated by
U S WEST to Title 61 in this rate case.
Response No. 96:No.  Staff believes that U S WEST allocates costs to Idaho according to it’s CAAS manual.  U S WEST’s Title 61 rate request did not contain sufficient detail in the workpapers for Staff to use it as the starting point to calculate Staff’s proposed revenue requirement.  These expenses should be directly assigned at the Idaho Intrastate level. Staff’s case is based on the 1995 Idaho Intrastate JD booked amounts.
Request No. 97:Faunce p. 31
Putting aside the allocations of BRI services between Title 61 operations and all other parts of U S WEST's business, upon what facts do you rely to conclude that the prices charged by BRI are not reasonable as compared with open market prices for similar services?  Provide all documents which support your conclusion.
Response No. 97:This question is vague and ambiguous.  My testimony does not compare BRI service prices with open market prices for similar services.
Request No. 98:Faunce p. 35
Please describe the process of analysis and the data analyzed in reaching your conclusion that "less than 7%" of the Board of Directors' discussion was "spent on what could be considered a Title 61/62 service."
Response No. 98:Staff objects to the term “process of analysis” as being vague and ambiguous.  Staff based its calculation on information contained in the Company’s response to Staff Audit Request 030.  Workpapers already supplied on November 26, 1996.
Request No. 99:Faunce p. 35
Please explain your statement at lines 16-20 of your testimony on page 35 and describe how you believe this to be relevant to your statement that "Inc.'s management is spending over 90% of their time on non-regulated business and purchases."
Response No. 99:The 5.8% of total capital distributed to USWC is indicative that the Board of Directors is spending more than 90% of its time and energies on non-regulated telecommunication services and businesses.  Staff believes that shows a stable mature market in communications that requires little or no management effort to finance compared to other segments of U S WEST.
Request No. 100:Faunce p. 36
A.Please describe the process of analysis and the data analyzed in reaching your conclusion that "only 7% of the executive, shareholder and finance expenses allocated to USWC from Inc. should be attributed to southern Idaho intrastate operations for allocation to Title 61/62 services."
B.What portion of the $422,000 decrease in revenue requirement associated with your analysis of U S WEST Inc. costs was included by the Company in its Title 61 rate request in this docket?  Please provide work papers showing your calculations performed in making this response.
Response No. 100:
A.Staff objects to the term “process of analysis” as being vague and ambiguous.  Staff based its calculation on  information provided by U S WEST in STF000-030, 053, 071, 083, 093, 096.  See worksheets already filed November 26, 1996 in response to
U S WEST’s first production request.
B.Staff did not calculate whether any portion of the $422,000 expense was contained in the Company’s Title 61 expenses in this docket.  U S WEST’s Title 61 rate request did not contain sufficient detail in the workpapers for Staff to use it as the starting point to calculate Staff’s proposed revenue requirement.  These expenses should be directly assigned at the Idaho Intrastate level.  Staff’s case is based on the 1995 Idaho Intrastate JD booked amounts.
Request No. 101: Faunce
In several instances (p. 36, l. 17; p. 37, l. 18; p. 40, l. 3; p. 43, l. 17), you remove costs associated with Title 62, Part 64 services and other categories.  Please provide work papers and analyses that support your statements that Part 64 are included in the Idaho intrastate amounts and have not already been removed.
Response No. 101:Staff found Part 64 enhanced services costs as described in USWC Cost Manual 11-29, May 1, 1996 release, Section II, Products and Services, Page 29, in reviewing U S WEST’s responses in STF000- 034, Attachment A and B.  Staff also found enhanced service and multi media charges (trips to Omaha to see video trial) in airplane cost in STF000- 053, Attachment A and questionable charges (Time Warner) in legal cost STF000-074, Attachment A.  Workpapers have been previously provided on November 26, 1996.  Staff did not specifically break out costs as Part 64 but did note that these costs are included in U S WEST’s allocation process.  Workpapers provided are copies of Part 64 page 17 and U S West Cost Manual Section II.
Request No. 102: Faunce p. 36
On page 36, you determined that 56% of the internal audit costs pertained to services that were not Title 61 and therefore should be removed.  Please provide all work papers listing the calculation of the 56%, a list of the audits that you removed (which make up the 56%) and those that you considered appropriate (the remaining 44%) and the information relied upon to determine whether each audit was either removed or left in.
Response No. 102:Staff relied on information provided by the Company in STF000-070, No. E and the audit of the actual field audit reports reviewed while in Denver.  Staff’s calculation is based on audits that do not benefit Title 61 as circled, divided by total audits over a three year period to arrive at a three year average (21/48=44%).  Staff is providing a copy of STF000-070E.
Request No. 103:Faunce p. 37
A.Please describe all information which you used in reaching the decision that "research" costs incurred at the U S WEST Inc. level should be entirely excluded from the southern Idaho intrastate costs.
B.Please describe all information which you used in reaching the decision that lobbying costs incurred at the U S WEST Inc. level should be entirely excluded from the southern Idaho intrastate costs.
C.Were any U S WEST Inc. "research" costs included by Staff in the southern Idaho intrastate rate base?  If so, please quantify the amount of such costs.
D.Were any U S WEST Inc. lobbying costs included by Staff in the southern Idaho intrastate Title 61 costs?  If so, please quantify the amount of such costs.
Response No. 103:
A.The referenced testimony on page 37 concluded that “research” costs incurred at the U S WEST Inc. level should be treated the same as the research costs at AT and Bellcore.  Refer to Staff testimony at pages 24-26.  Staff found that there were no projects that were properly allocated entirely to Title 61.  The Company has not provided sufficient information to prove that any cost should be allocated exclusively to Title 61.  Staff removed “research costs” that were to be allocated to Title 61 and Title 62.
B.The following past Commission Orders remove lobbying costs that do not benefit ratepayers from other costs.  Case No. IPC-E-94-5, Order No. 25880; Case No. U-1009-157, Order No. 20372; Case No. U-1025-51, Order No. 20592; Case No. SIL-T-88-2, Order No. 22237; U-1046-144, Order No. 20180; Case No. U-1025-48, Order No. 19902.
C.Staff did not make any adjustments to rate base for Inc. research costs.  There may be some costs included but they were not specifically identified.
D.Staff can not answer for all cost that Inc. may have allocated in some manner to USWC but Staff did remove costs for lobbying from southern Idaho intrastate where identified.
Request No. 104:Faunce p. 37
A.Is your conclusion that no part of the "Leadership Conference" expense should be included in Title 61 operations based entirely on your review of the agenda?  If not, please describe the analysis and all other data analyzed in reaching this conclusion.
B.What portion of the $16,500 cost of the Leadership conference associated with your analysis of U S WEST Inc. costs was included by the Company in its Title 61 rate request in this docket?  Please provide work papers showing your calculations performed in making this response.
Response No. 104:
A.Yes.  Staff relied on STF000-083 A.
B.Staff did not calculate whether any portion of the $16,500 expense was contained in the Company’s Title 61 expenses in this docket.  U S WEST’s Title 61 rate request did not contain sufficient detail in the workpapers for Staff to use it as the starting point to calculate Staff’s proposed revenue requirement.  These expenses should be directly assigned at the Idaho Intrastate level.  Staff’s case is based on the 1995 Idaho Intrastate JD booked amounts.
Request No. 105:Faunce p. 38
Referring to p. 38, ll. 8-10, please provide all documentation and rationale which led you to conclude that the majority of the cost for this function is caused by downsizing the workforce in USWC's re-engineering.
Response No. 105:Staff relied on Kent Schneider’s discussion with Margie Wright where she indicated that questions regarding re-engineering the workforce should be directed to workforce management.  See Staff Request No. 101.  Also the Company’s Proxy Statement discusses USWC downsizing policies.  Therefore, workforce management at USWC is in a downsizing mode and cost allocated to USWC for workforce management should reflect this fact.
Request No. 106:Faunce p. 38
A.Please describe the process of analysis and all data analyzed to reach the conclusion "the majority of the cost" for workforce management should be removed and amortized.
B.Please describe the total amount of the Workforce Management expense contained in the U S WEST Title 61 revenue requirement which matches the $13,000 adjustment to intrastate expense recommended at lines 4-15.  Please provide work papers showing your calculations performed in making this response.
C.Do you agree that any portion of work force management expense should be allocated to Title 61?  If so, please specify what amount and how it should be allocated.
Response No. 106:
A.Staff objects to the term “process of analysis” as being vague and ambiguous.  See response to 105.
B.Staff did not calculate whether any portion of the $13,000 expense was contained in the Company’s Title 61 expenses in this docket. U S WEST’s Title 61 rate request did not contain sufficient detail in the workpapers for Staff to use it as the starting point to calculate Staff’s proposed revenue requirement.  These expenses should be directly assigned at the Idaho Intrastate level.  Staff’s case is based on the 1995 Idaho Intrastate JD booked amounts.
C.Staff believes it is the burden of the Company to prove if any portion of workforce management should be allocated to Title 61.  Staff has not been provided sufficient information for audit purpose to prove that any portion of workforce management should have been allocated to Title 61.
Request No. 107:Faunce p. 38
Please describe the process of analysis and the data analyzed which enabled you to reach the conclusion that 80% the cost of recognition and rewards for Inc., staff "is based on improving shareholder's (sic) position."
Response No. 107:Staff objects to the term “process of analysis” as being vague and ambiguous.  Staff based its calculation on a combination of information obtained from reading STF000-044, Team Performance Award Components, and Proxy Statement that show the awards are based on improving earnings to the shareholders.  Reviewing all of the above information Staff concluded that 80% was not Title 61.
Request No. 108:Faunce p. 38
What portion of the $9,700 cost for rewards and recognition for U S WEST Inc.  associated with your analysis of U S WEST Inc. costs was included by the Company in its Title 61 rate request in this docket?  Please provide work papers showing your calculations performed in making this response.
Response No. 108:Staff did not calculate whether any portion of the $9,700 expense was contained in the Company’s Title 61 expenses in this docket.  U S WEST’s Title 61 rate request did not contain sufficient detail in the workpapers for Staff to use it as the starting point to calculate Staff’s proposed revenue requirement.  These expenses should be directly assigned at the Idaho Intrastate level.
Request  No. 109:Faunce p. 39
Please provide a detailed breakdown of each category of expense excluded in your "Image" adjustment on page 39.  Provide a detailed analysis for each expense stating why, in your opinion the expense should be totally excluded.
Response No. 109:See USW Inc. analysis workpaper lines 70, 71, 72, 73, 74, 75, 76, 77, 80, 82, 83, 86 and 87.  In Staff’s opinion these expense do not benefit Title 61 service in the State of Idaho based on prior Commission Order Nos. 18188, 19539, 20244 and 20964.
Request No. 110:Faunce p. 39
What portion of the $87,400 "Image" costs  associated with your analysis of U S WEST Inc. costs was included by the Company in its Title 61 rate request in this docket?  Please provide work papers showing your calculations performed in making this response.
Response No. 110:Staff did not calculate whether any portion of the $87,400 expense was contained in the Company’s Title 61 expenses in this docket.  U S WEST’s Title 61 rate request did not contain sufficient detail in the workpapers for Staff to use it as the starting point to calculate Staff’s proposed revenue requirement.  These expenses should be directly assigned at the Idaho Intrastate level.  Staff’s case is based on the 1995 Idaho Intrastate JD booked amounts.
Request No. 111:Faunce p. 40
Please explain the basis for your statement "there should not be any costs in southern Idaho for a subsidiary tax".
Response No. 111:There is no subsidiary tax in Idaho therefore, Idaho ratepayers should not be paying this tax.
Request No. 112:Faunce p. 40
What portion of the $16,000 subsidiary tax expense adjustment  associated with your analysis of U S WEST Inc. costs was included by the Company in its Title 61 rate request in this docket?  Please provide work papers showing your calculations performed in making this response.
Response No. 112:Staff did not calculate whether any portion of the $16,000 expense was contained in the Company’s Title 61 expenses in this docket.  U S WEST’s Title 61 rate request did not contain sufficient detail in the workpapers for Staff to use it as the starting point to calculate Staff’s proposed revenue requirement.  These expenses should be directly assigned at the Idaho Intrastate level.  Staff’s case is based on the 1995 Idaho Intrastate JD booked amounts.
Request No. 113:Faunce p. 41
Please show the calculation of the 1% referenced on line 2 and provide all backup documentation and rationale used in calculating this percentage.
Response No. 113:.2246*.0623=1.39% (total legal that could be considered a suitable charge for Title 61, times board of directors time spent on plain old telephone service).  For rationale read Staff testimony page 41, lines 2-14.
Request No. 114:Faunce p. 41
A.What portion of the removal of $204,042 of  legal expense associated with your analysis of U S WEST Inc. costs was included by the Company in its Title 61 rate request in this docket?  Please provide work papers showing your calculations performed in making this response.
B.Based upon the information provided by U S WEST in this case, what is the level of legal expense Staff believes should be allocated directly to Title 61?  What level should be allocated between Title 61 and Title 62?  Provide your work papers showing how these amounts were arrived at.
Response No. 114:
A.Staff did not calculate whether any portion of the $204,042 expense was contained in the Company’s Title 61 expenses in this docket.  U S WEST’s Title 61 rate request did not contain sufficient detail in the workpapers for Staff to use it as the starting point to calculate Staff’s proposed revenue requirement.  These expenses should be directly assigned at the Idaho Intrastate level.  Staff’s case is based on the 1995 Idaho Intrastate JD booked amounts.
B.Staff objects to the word “level” as being vague and ambiguous.  See workpapers provided on November 26, 1996 titled Legal Cost Analysis.
Request No. 115:Faunce p. 43
Please explain the relationship between the $204,042 legal expense cost adjustment and the $509,324 cost referred to on line 22 of your testimony on page 43.
Response No. 115:The $204,042 legal cost allocated from Inc. is included in Headquarters costs in STF000-073, Attachment A.  The $204,042 is not related to the $509,324 direct legal cost and outside legal cost identified in STF000-073.
Request No. 116:Faunce p. 43
What amount of total legal expense allocated by U S WEST to southern Idaho and included in the Title 61 revenue requirement in this case which relates to the $58,000 total that you recommend in your testimony?  Is the $58,000 number derived from directly assigning legal expenses incurred in particular cases?  If so, please list all such cases or matters for the test year.  Do you recommend any legal expense in addition to the $58,000 be allocated between Title 61 and Title 62 in this case?  If so, please describe those expenses and how you would recommend that they be allocated.
Response No. 116:
A.The question is ambigious and unclear.  Staff did not calculate whether any portion of the $58,000 expense was contained in the Company’s Title 61 expenses in this docket.  U S WEST’s Title 61 rate request did not contain sufficient detail in the workpapers for Staff to use it as the starting point to calculate Staff’s proposed revenue requirement.  These expenses should be directly assigned at the Idaho Intrastate level.  Staff’s case is based on the 1995 Idaho Intrastate JD booked amounts.
B.Yes.  Staff has provided worksheets (entitled “legal case analysis”) that show the cases and how Staff proposes these case be direct assigned and or pooled for allocation.
C.Yes.  Staff has provided worksheets (legal case analysis, column “Idaho 61/62 alloc”).  Staff witness Baldwin addresses the allocation of expenses between Title 61 and Title 62.
Request No. 117:Faunce p. 45
A.Is the $65,280 MIS adjustment based solely on your conclusion that there is a known and measurable cost savings associated with this expense?  If not, provide all analysis and data analyzed which support disallowing any portion of this expense on any other basis.
B.Provide your work papers for the $65,280 adjustment.
C.What portion of the removal of $65,280 in expenses associated with MIS associated with your analysis of U S WEST Inc. costs was included by the Company in its Title 61 rate request in this docket?  Please provide work papers showing your calculations performed in making this response.
Response No. 117:
A.Yes.  See Company response to Staff Audit Request STF000-121.
B.Workpapers have already been provided on November 26, 1996.
C.Staff did not calculate whether any portion of the $65,280 expense was contained in the Company’s Title 61 expenses in this docket.  U S WEST’s Title 61 rate request did not contain sufficient detail in the workpapers for Staff to use it as the starting point to calculate Staff’s proposed revenue requirement.  These expenses should be directly assigned at the Idaho Intrastate level.  Staff’s case is based on the 1995 Idaho Intrastate JD booked amounts.
Request No. 118:Faunce p. 47
Please explain how the $173,744 "known and measurable cost savings" was calculated.  Please further explain how this cost savings should be allocated between Title 61 and Title 62.
Response No. 118:See workpapers provided on November 26, 1996.  Staff removed this cost from the expense pool that was allocated between 61/62 by Staff witness Baldwin.
Request No. 119:Faunce p. 49
A.Please explain the basis for your claim that "80% of the Team Performance" award is "based on creating shareholder value."  Provide all documents upon which you rely for this conclusion.
B.Does Staff equate "creating" or "enhancing" shareholder value with Title 62 or other deregulated services exclusively?  If so, describe the analysis and all data analyzed which resulted in this conclusion.
C.What portion of the $797,431 Team Performance award expense associated  with your analysis of U S WEST Inc. costs was included by the Company in its Title 61 rate request in this docket?  Please provide work papers showing your calculations performed in making this response.
D.What numerical amount for Team Performance award does Staff conclude should be appropriately allocated to Title 61?
Response No. 119:
A.Staff based its calculation on a combination of information obtained from reading STF000-044, Team Performance Award Components, and Proxy Statement that show the awards are based on increasing earnings to the shareholders.  Reviewing all of the above information Staff concluded that 80% was not Title 61.
B.Yes, enhancing shareholder value per the proxy statement will be accomplished through new products and new lines of business.
C.Staff did not calculate whether any portion of the $797,431 expense was contained in the Company’s Title 61 expenses in this docket.  U S WEST’s Title 61 rate request did not contain sufficient detail in the workpapers for Staff to use it as the starting point to calculate Staff’s proposed revenue requirement.  These expenses should be directly assigned at the Idaho Intrastate level.  Staff’s case is based on the 1995 Idaho Intrastate JD booked amounts.
D.See workpapers (entitled “compensation”) provided November 26, 1996 showing the amount in the Idaho intrastate pool to be allocated between Title 61 and Title 62 by Staff witness Baldwin.
Request No. 120:Faunce p. 49
A.Please explain the basis for your claim that "80% of the Short Term Incentive bonus compensation" is "based on creating shareholder value."
B.What portion of the $43, 559 Short-Term Incentive compensation  associated  with your analysis of U S WEST Inc. costs was included by the Company in its Title 61 rate request in this docket?  Please provide work papers showing your calculations performed in making this response.
Response No. 120:
A.Staff based its calculation on a combination of information obtained from reading STF000-044, Team Performance Award Components, and Proxy Statement that show the awards are based on earnings to the shareholders.  Reviewing all of the above information Staff concluded that 80% was not Title 61.
B.Staff did not calculate whether any portion of the $439,559 expense was contained in the Company’s Title 61 expenses in this docket.  U S WEST’s Title 61 rate request did not contain sufficient detail in the workpapers for Staff to use it as the starting point to calculate Staff’s proposed revenue requirement.  These expenses should be directly assigned at the Idaho Intrastate level.  Staff’s case is based on the 1995 Idaho Intrastate JD booked amounts.
Request No. 121:Faunce p. 50
A.Please explain the basis for your claim that 27% of BRI's Team Award compensation is based on improving shareholder benefits.
B.What portion of the $25,182 BRI Team Award compensation associated  with your analysis of U S WEST Inc. costs was included by the Company in its Title 61 rate request in this docket?  Please provide work papers showing your calculations performed in making this response.
C.What numerical amount of BRI Team Award compensation does Staff agree should be allocated to Title 61?
Response No. 121:
A.Staff based its calculation on a combination of information obtained from reading STF000-044, Team Performance Award Components, and Proxy Statement that show the awards are based on earnings to the shareholders.  Reviewing all of the above information Staff concluded that 27% was not Title 61.
B.Staff did not calculate whether any portion of the $25,182 expense was contained in the Company’s Title 61 expenses in this docket.  U S WEST’s Title 61 rate request did not contain sufficient detail in the workpapers for Staff to use it as the starting point to calculate Staff’s proposed revenue requirement.  These expenses should be directly assigned at the Idaho Intrastate level.  Staff’s case is based on the 1995 Idaho Intrastate JD booked amounts.
C.See workpapers (entitled “compensation”) provided November 26, 1996 showing the amount in the Idaho intrastate pool to be allocated between Title 61 and Title 62 by Staff witness Baldwin.
Request No. 122:Faunce p. 50
Please explain the basis for your claim that "20% or less of Inc. Team Awards should be allocated to Title 61 customers.  Do you agree that the 20% should be directly assigned to Title 61 customers or do you advocate some further allocation of the remaining 20%?  If you advocate further allocation, please describe the basis for that allocation and the total amount of Inc. Team Award compensation expressed in a percentage of the whole and in absolute dollars that you recommend be covered in Title 61 rates.
Response No. 122:
A.See response to Request No. 119-A and workpaper supplied.
B.Staff does not agree that 20% should be directly assigned to Title 61 customers.  The allocation of these expenses between Title 61 and 62 is addressed in Staff witness Baldwin’s testimony.
C.See Staff witness Baldwin’s testimony.
Request No. 123:Faunce p. 51
What portion of the $75,868 of Inc.'s Team Award expense  associated  with your analysis of U S WEST Inc. costs was included by the Company in its Title 61 rate request in this docket?  Please provide work papers showing your calculations performed in making this response.
Response No. 123:Staff did not calculate whether any portion of the $75,868 expense was contained in the Company’s Title 61 expenses in this docket. U S WEST’s Title 61 rate request did not contain sufficient detail in the workpapers for Staff to use it as the starting point to calculate Staff’s proposed revenue requirement.  These expenses should be directly assigned at the Idaho Intrastate level.  Staff’s case is based on the 1995 Idaho Intrastate JD booked amounts.
Request No. 124:Faunce p. 51
Please explain the basis for your claim that  "20% or less of Inc. bonus (merit awards)"  should be allocated to Title 61 customers.  Do you agree that the 20% should be directly assigned to Title 61 customers or do you advocate some further allocation of the remaining 20%?  If you advocate further allocation, please describe the basis for that allocation and the total amount of Inc. bonus (merit awards) compensation expressed in a percentage of the whole and in absolute dollars that you recommend be covered in Title 61 rates.
Response No. 124:
A.See response to Request No. 119-A and workpaper supplied November 26, 1996.
B.Staff does not agree that 20% should be directly assigned to Title 61 customers.
C.The allocation of these expenses between Title 61 and 62 is addressed in Staff witness Baldwin’s testimony.
Request No. 125:Faunce p. 51
A.Please explain the basis of your claim that 100% of executive incentive pay at Inc. should be directly allocated to Part 64, Title 62 and/or shareholders who benefit.
B.Please also explain where and how you have removed 93% of executive costs at Inc. and the amount of this adjustment.  State your rationale for removing this cost.
Response No. 125:
A.Staff based its calculation on a combination of information obtained from reading STF000-044, board of director minutes, and the Proxy Statement that show the executive incentives are based on earnings to the shareholders.  Enhancing shareholder value per the proxy statement will be accomplished through new products and new lines of business.  Reviewing all of the above information, Staff concluded that executive incentive pay should be removed from Title 61.
B.See response to Request No. 100.
Request No. 126:Faunce
What portion of the $7,159 of executive incentive pay associated with your analysis of
U S WEST Inc. costs was included by the Company in its Title 61 rate request in this docket?  Please provide work papers showing your calculations performed in making this response.
Response No. 126:Staff did not calculate whether any portion of the $7,159 expense was contained in the Company’s Title 61 expenses in this docket. U S WEST’s Title 61 rate request did not contain sufficient detail in the workpapers for Staff to use it as the starting point to calculate Staff’s proposed revenue requirement.  These expenses should be directly assigned at the Idaho Intrastate level.  Staff’s case is based on the 1995 Idaho Intrastate JD booked amounts.  Staff  believes that it is U S WEST’s burden to trace these costs through U S WEST’s allocation process and prove what costs are included in it’s Title 61 numbers.
Request No. 127:Baldwin
Provide all correspondence, memos, notes of telephone conversations, E-Mail messages and files, and all other data of any kind pertaining to each and every contact and exchange between any member of the IPUC Staff (including persons who have subsequently left the Staff) and ETI, or any employee thereof including but not limited to Lee Selwyn and Susan Baldwin.
Response No. 127: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.  Further, Staff objects to this request on the grounds that it asks for information that is not relevant and not likely to lead to discovery of admissible evidence in this proceeding.  Staff members who have relevant information and who will be testifying for this docket have been identified in Staff's response to U S WEST's First Production Request No. 2.  In response to U S WEST's First Production Request No. 4 Staff provided copies of its workpapers in support of its testimony.  Staff also reviewed all production requests, audit requests, and annual reports of U S WEST in preparation for its testimony in this proceeding.
Request No. 128:Baldwin
Provide a copy of the agreement under which ETI was retained and all amendments, extensions and appendices which accompany, modify or update such agreement.
Response No. 128:Staff objects to this request on the grounds that it seeks information that is protected by attorney/client privilege and is work product.  Further, Staff objects to this request on the grounds that it asks for information that is not relevant and not likely to lead to discovery of admissible evidence in this proceeding.
Request No. 129:S. Baldwin p. 3
Provide the origin of the 5% allocation of local loop to custom calling features and explain why this particular percentage is chosen.
Response No. 129:The 5% allocation of the local loop was based on an analysis of    U S WEST's revenues.  U S WEST derives approximately that amount of its total revenues in southern Idaho from custom calling features.  Accordingly, 5% was chosen as a fair and conservative percentage of the local loop to assign to custom calling.  See Exhibit No. 114, Schedule 10.
Request No. 130:S. Baldwin p. 4
Explain the term "economically efficient" as it is used on page 4, line 6.
Response No. 130:"Economically efficient" production methods produce a given amount and/or type of output for the least possible cost.  As Ms. Baldwin's testimony makes clear, U S WEST has undertaken a number of investments in southern Idaho that do not represent the least-cost alternative in terms of the provision of Title 61 services.  For more on this topic, see:  Paul A. Samuelson, Foundations of Economic Analysis, Enlarged Edition, Harvard Economic Studies, v. 80, Cambridge, MA, Harvard University Press, 1983, Chapter IV; and Hal R. Varian, Intermediate Microeconomics:  A Modern Approach, Third Edition, New York, W. W. Norton & Company, Inc., 1993, Chapters 18 and 19.
Request No. 131:S. Baldwin p. 5
Please define the term "corrected plant in service" as  used at line 8.
Response No. 131:“Corrected plant in service” refers to Staff's allocation of plant in service between Title 61 and Title 62, which corrects for errors in U S WEST's proposal.
Request No. 132:S. Baldwin p. 8
Explain the statement at line 14, that Title 61 services are required "economically" to be "jurisdictionally separated from any services the Company might be offering simultaneously under Title 62".  Explain all economic theories or other economic principles which demand such separation.
Response No. 132:This statement is based on Commission directives that require    U S WEST to separate and allocate to Title 61 only those revenues and expenses derived from, and directly required for, the provision of Title 61 services.  As Ms. Baldwin observed in her testimony (pages 11-12), in a 1994 decision, the Commission set forth three criteria to be followed in an allocation method:
1.Title 62 services must not be subsidized by Title 61 services.
2."Title 62 services must be assigned a reasonable portion of the common and joint network costs as well as general overhead costs.  In particular, all services using the local loop should be included in the allocation of the loop costs."
3."Direct cost assignment must be used when facilities or other operating expenses are clearly necessary for only Title 61 or Title 62 services, when the level of costs is escalated beyond what is necessary for Title 61 services alone, the additional cost should be directly allocated to Title 62" (Order No. 25826, at 11, Case No. USW-S-94-3).
Request No. 133:S. Baldwin p. 14
Does Staff have evidence that any of the investment made by U S WEST in the alternative toll fiber route discussed at page 14 was allocated by U S WEST to Title 61 services in this case?  If so, please provide the numerical amount of any such allocation and all documents which support Staff's conclusion.
Response No. 133:Staff does not allege "that any of the investment made by          U S WEST in the alternative toll fiber route discussed at page 14 was allocated by U S WEST to Title 61 services in this case."
Request No. 134:S. Baldwin p. 19
Please describe each step taken by Ms. Baldwin and the amount of time spent on each step in attempting to "verify the validity of the logic" of each the special studies referred to in the CAAS system.  Provide the same information for each other member of the IPUC Staff and each ETI employee who was engaged in this process.
Response No. 134: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.  
Staff witnesses with relevant information pertaining to the CAAS system are Susan Baldwin and Sydney Lansing.  Susan Baldwin of ETI analyzed the CAAS and CARS data files provided by U S WEST, as well as the associated Cost Segregation and Accounting Manuals.  Additionally, Ms. Baldwin requested the Special Studies mentioned in the Cost Segregation Manual; however they were not readily provided by U S WEST (see Response to Staff Data Request 03-169).  Finally, in addition to other efforts, Ms. Baldwin traveled to Denver to discuss the CAAS system with Dallas Elder and other members of U S WEST's Finance Organization.
IPUC Staff member Sydney Lansing analyzed the CAAS and CARS data files provided by U S WEST, compared the CAAS procedure to U S WEST's regular books, and attempted to trace the process via which the CAAS and CARS systems derive their jurisdictional, product, and Title 61/Title 62 separations.  Mr. Lansing traveled to Denver to discuss the CAAS system with Dallas Elder and other members of U S WEST's Finance Organization.
Request No. 135:S. Baldwin p. 28
Provide each and every fact upon which you rely for your statement:  "The Company has invested in excess capacity far beyond what would be needed to meet a reasonable business projection of growth in demand for new lines."  Produce each document which embodies, reflects or relates to the facts which support this claim.
Response No. 135:This statement was based upon U S WEST's response to Staff Audit Request 18, Attachment A, in which the Company provides data that indicates that only 10% of the installed fiber plant in southern Idaho is currently "lit" (in use).  It is further based upon a comparison of U S WEST's objective and actual fill factors in southern Idaho, which also indicate the presence of a significant amount of spare capacity (Proprietary response to Staff Data Request 02-049, Attachment A).
Request  No. 136:S. Baldwin p. 28 / Exhibit 114, Schedule 1
Using the categories depicted on Exhibit 114, Schedule 1, identify in the dollar amount of alleged "over-investment" contained in each category under U S WEST's proposed allocation.
Response No. 136:ETI's research has indicated that there is a substantial level of over-investment in plant allocated to Title 61 in U S WEST's proposed allocation.  Performing a complete and accurate analysis of the dollar amount of this over-investment would require data regarding the specific types and amounts of plant and equipment allocated to Title 61 for each product category, a greater level of detail than U S WEST's CARS-based allocation between Title 61 and Title 62 provides.  An ETI analysis of over-investment would require that U S WEST provide any and all information required to develop measures of plant used to provide Title 61, Title 62, or a combination of the two services, and idle plant or spare capacity.
Request No. 137:S. Baldwin p. 27
Provide all facts upon which you rely for the conclusion that any substantial part of U S WEST's distribution plant was constructed and is being held for future Centrex Services.
Response No. 137:The text referenced on page 27 is a hypothetical statement.  See e.g., Selwyn, Lee L., Patricia D. Kravtin, and Paul S. Keller, “An Analysis of Outside Plant Provisioning and Utilization Practices of U S WEST Communications in the State of Washington,” prepared for the Washington Utilities and Transportation Commission, March  1990, Attachment 8.
Request No. 138:S. Baldwin p. 36
A.Provide all facts upon which you rely for the claim "the need for extensive spare capacity is driven primarily by discretionary and competitive services."
BProduce all documents which embody or reflect the facts identified in this response.
Response No. 138:
A.This statement is based upon calculations of the growth in demand for Title 61 versus Title 62 services.  Demand for, and revenues from, Title 62 services are growing at a substantially faster rate than Title 61 services.  The majority of U S WEST's spare capacity is therefore likely to be employed in the provision of Title 62 services.
B.See Exhibit No. 113, Schedule 2; Staff's response to U S WEST's Second Production Request No. 137.
Request No. 139:S. Baldwin p. 35
Describe how you would determine the "stand-alone" cost of regulated and non-regulated services.  What costs (i.e., embedded, TSLRIC) are to be determined under the procedure described at page 35, lines  2-10?
Response No. 139: In general, stand-alone costs would need to be developed by configuring a network and facilities mix that would be required solely to provide Title 62 services.  Since Title 62 services are, by definition, "competitive," these would be the costs that any non-ILEC competitor would incur in providing the same set of services without the ability or opportunity to utilize plant that is also used to provide monopoly Title 61 services on a joint basis.  An engineering cost analysis undertaken on this basis should develop TSLRIC type costs.  If costs are to be expressed on an embedded basis, the TSLRIC stand-alone costs could be transformed into embedded costs by application of conversion factors.
Request No. 140:S. Baldwin p. 35, ll. 19-21
What is the origin of the "requirement" that prices for "competitive, non-regulated services" be based on the "stand-alone" costs of the services?  Are the relevant costs for meeting this "requirement" embedded, historical costs or some form of marginal or incremental costs?
Response No. 140:See Staff's response to U S WEST's Second Production Request No. 139.  This requirement follows from the principle that all economies of scope derived from the simultaneous provision of regulated and non-regulated services be allocated to customers of the regulated, monopoly service.  As Ms. Baldwin states in her testimony    (p. 35, ll. 19-21), the benefits of such economies should flow to monopoly customers for two reasons:  first, because monopoly customers have funded the majority (indeed, before 1989, all) of the ILEC's investment in infrastructure, and second, because eliminating those economies from non-regulated services helps to ensure that the ILEC possesses no unfair advantage over new entrants.  Stand-alone costs for competitive Title 62 services should be developed on a forward-looking TSLRIC basis, since these are the costs that a new competitor would encounter when entering the market, and would reduce the potential for adverse impact on competition from many of the various incumbency advantages uniquely available to the ILEC.
Request No. 141:S. Baldwin p. 36, ll. 15-17
What incumbent "competitive entry" is referenced at line 15?  Do you refer to        U S WEST's entry into the interLATA toll market?  Would the proposed allocation in fact, create an incumbent LEC disadvantage?  Explain why or why not.
Response No. 141:"Competitive entry" of the incumbent refers to the provision of any competitive (that is, Title 62) service by the incumbent.  As Ms. Baldwin stated in her testimony (pp. 35-36), allocating the benefits of economies of scope to monopoly customers would reduce the inherent advantage the ILEC will possess upon entering a competitive market, for instance, the interLATA toll market.  In no way, however, would it make the ILEC any worse off than any other entrant that seeks to provide service in that market.  Indeed, the ILEC would retain substantial advantages over other entrants (e.g., its ownership of a near-ubiquitous local network, its experience and know-how in the provision of telecommunications services, and its substantial maintenance and support personnel and infrastructure).  The recommended allocation will only reduce some of the financial advantage the ILEC would otherwise possess.
Request No. 142:S. Baldwin p. 42
Please provide the factual basis for your statement on page 42, ll. 13-15, which indicates that Title 62 services face "little if any competition."  Please focus your response to such Title 62 services as long distance, dedicated private line services, speed calling services, dedicated point-to-point data services, high-speed packet-switched data services and voice messaging services.
Response No. 142:Staff witness Baldwin's testimony on page 42 does not indicate “that Title 62 services face 'little if any competition'”as implied in the request.  Rather, her testimony there addresses custom calling and CLASS services.
Request No. 143:S. Baldwin p. 45
A.Did Staff calculate the 1995 annual Title 62 revenue generated in the 52 rural wire centers that were upgraded to digital switching under the Tech Plus Program?  If so, provide the calculation and all documents and workpapers that support your calculation.
B.If your response is that Staff does not have sufficient information to provide this calculation, please identify all data requests in which the Staff attempted to obtain this information and describe whether the Company cooperated in providing it.  
C.What impact will the recent EAS order creating larger local calling areas have on the amount of Title 62 revenues generated in these rural wire centers?
Response No. 143:
A.No.
B.Staff did not make any specific data requests for Title 62 revenues in the 52 rural wire centers; however, U S WEST was generally highly non-responsive to any data requests regarding its provision of Title 62 services, for instance stating that "Title 62 services are not economically regulated and therefore would not lead to admissible evidence in this proceeding." (See, for instance, responses to Staff Production Request Nos.3 - 185).  See also responses to Staff Production Request Nos. 2 - 86 and Nos. 2 - 87.
C.Presumably the recent EAS order will reduce the relative quantity of Title 62 revenues, because calls that were considered toll (Title 62) will shift to being local (Title 61).  The costs associated with those calls, as well as some plant and equipment, will also presumably shift from Title 62 to Title 61, although the precise manner in which such shifts occur will be impacted by the toll-to-local reclassification as provided for in 47 CFR §36 (jurisdictional separations).  As a result, it is ambiguous as to whether U S WEST's Title 62 profits will rise or decline as a result of the shift to EAS.
Request No. 144:S. Baldwin p. 45, ll. 15-16
Provide all data upon which you rely for your statement "Title 61 services derive little if any direct benefit from Company-funded CO upgrades."
Response No. 144:The Commission has previously accepted Staff's statement, referenced in Ms. Baldwin's testimony, that "the 20 older electronic analog switches ... provide most if not all features otherwise provided by U S WEST's newer digital switches." (Idaho PUC Order No. 24506, at 10.)  Since the specific upgrades of analog to digital switches in this case do not provide any additional features for Title 61 customers, Staff concludes that Title 61 customers do not directly benefit from them.
Request No. 145: S. Baldwin p. 65
Provide all cost/benefit analysis Staff has performed regarding its recommendation U S WEST be required to develop "improved reporting and accounting systems, such as time management systems for its corporate and customer service operations."
Response No. 145:Staff has performed no such cost/benefit analyses.  Staff's recommendation in this case is not based upon a business case scenario, but rather upon the regulatory requirements that U S WEST accepted when it undertook to shift services to     Title 62.
Request No. 146:S. Baldwin p. 66, ll. 15-18
A.Has Staff performed an analysis of U S WEST's Title 62 operations and rate of return based on:
a)U S WEST's proposed allocation of costs to Title 62?
b)Staff's proposed allocation of costs to Title 62?
B.Provide the results of any such analyses and all supporting documents and workpapers.
Response No. 146:
A.No.
B.N/A
Request No. 147:S. Baldwin (generally)
List all currently offered Title 62 services which theoretically benefit from:
a)  "excess capacity" in distribution facilities; and
b)  "excess capacity" in feeder.
Response No. 147:All Title 62 services that involve the use of feeder and distribution plant theoretically benefit from excess capacity in distribution facilities and from excess capacity in feeder.  These would include, inter alia, centrex, PBX trunks, local private lines, digital access lines, video services, remote metering, alarm monitoring, and ISDN.
Request No. 148:Lansing
On your Exhibit 101, line 28 you show EAS switching costs of $1.546 million.  Please indicate where you estimate the interoffice trunking costs of providing EAS.  Please provide any calculations or work papers which calculate these costs.
Response No. 148:Answer prepared by Staff witness Eastlake
See Staff Response to U S WEST's First Production Request No. 66.
Request No. 149:Selwyn
On page 4, ll. 7 & 8, you discuss "Title 61 plant" and "Title 62 plant."  Please provide three examples of each type of telecommunications network plant that you believe belongs within each of the two categories.
Response No. 149:“Title 61 plant” is plant that is used to furnish Title 61 services; “Title 62 plant” is plant that is used to furnish Title 62 services.  The distinction that is being made here (in describing plant as belonging to either Title 61 or Title 62) is that, through use of a cost allocation process that is properly designed and implemented, plant can be divided as between Title 61 and Title 62 services.  In some cases, plant can be specifically assigned directly to either Title 61 or Title 62, but a significant portion of plant is shared by both service categories.  As discussed in Ms. Baldwin's testimony at pages 35-37, Title 62 plant consists of all plant that would be required to furnish Title 62 services on a stand-alone basis.  Title 61 plant consists of all remaining shared telephone plant in service that is not assigned to Title 62, plus any items that are used exclusively to furnish Title 61 services and are directly assigned.
Request No. 150:Selwyn
On page 4, ll. 18-20, you recommended no adjustments for "depreciation rates and lives that were last formally authorized for U S WEST in 1988 for Title 61 services."  Please explain how depreciation rates are set for Title 61 services.  Specifically, please provide the 1988 depreciation rates set for residential local exchange service and blocking service for "976" and "900" services.
Response No. 150:The reason for distinguishing the appropriate depreciation rates as specifically applying to Title 61 services is that since Title 62 services are non-regulated, U S WEST can choose to apply any depreciation rates it desires to Title 62 plant, whereas Title 61 services continue to be regulated by the Idaho PUC.  Dr. Selwyn's affirmative recommendation is that the Commission apply the last formally authorized depreciation lives to the categories of plant first identified on page 33 of the Direct Testimony of William R. Easton and as shown in the first column of Dr. Selwyn's Exhibit 112, Schedule 5, which is duplicated below:
1988 Idaho PUC Approved Depreciation Lives
Accountfor Southern Idaho Plant (projected years)
ESS - Digital20.0
Circuit - Digital13.0
Circuit - Analog13.0
Aerial Cable - Metallic22.0
Underground Cable - Metallic30.0
Buried  Cable - Metallic30.0
Fiber Cable 30.0
Intrastate “976 and “900" services are not available from U S WEST in Idaho, therefore blocking of these services is a moot issue.
Request No. 151:Selwyn
On page 5, ll. 10-13, you describe the service quality benefits of ISDN.  Please describe the consumer equipment, consumer equipment costs, service benefits, and actual applications for ISDN that the average residential consumer in Idaho would incur or enjoy as a result of having ISDN service.
Response No. 151:Page 5, 11. 10-13 does not describe any specific service quality benefits of ISDN as this request would seem to indicate, but simply notes that U S WEST has failed to deploy ISDN in a comprehensive manner even though this service could ostensibly be provided at little additional cost to the Company relative to the large amount of investment that has already been made to provide digital switches.  As a digital technology, however, ISDN greatly expands the versatility and utility of local telephone service and could provide, for example, high speed data connections and advanced voice services (see p. 57, 11. 12-14 of       Dr. Selwyn's testimony).  ISDN service would therefore represent a positive improvement on the overall quality of the service being provided when compared to traditional basic service, and could be offered to southern Idaho consumers with a relatively small amount of additional investment by U S WEST.  The cost of digital switches (already in place) represents a large percentage of the overall cost of providing ISDN service.  The remaining investment would consist of line cards and some associated software.  That ISDN has not been widely implemented to date suggests that the digital switches that were placed in service were installed merely to provide extremely expensive, advanced services to those willing to pay for them, while ordinary customers had no choice but basic analog voice services (which could have been provided equally well by analog switches).  Finally, consumer ISDN equipment, such as ISDN interface cares that would be installed in the consumer's personal computer, have been dropping rapidly, and can now be purchased for about $250 - only slightly higher than a high quality state- of-the-art modem card (which it replaces).
Request No. 152:Selwyn
Please provide the rationale and specific support for your statement on page 8, line 14 wherein you discuss the "subsidies of new U S WEST advanced digital and broadband services by basic local exchange service prices."
Response No. 152:See Ms. Baldwin's testimony at p. 9, lines 4-14, pp. 11-12, and   pp. 17-24.  When costs are incurred for plant that is not required for the ongoing provision of Title 61 services but that are assigned, in whole or in part, to Title 61 and utilized to provide Title 62 services, the effect is to create a subsidy flow of Title 61 revenues to Title 62 services.  This is because the costs that are confronted by U S WEST in providing the Title 62 services are less than those that would exist were the plant acquired solely for those services.  Thus, to the extent that the assignment of such costs to Title 61 services causes rates for the regulated services to increase (as U S WEST is proposing to do in this case), Title 61 ratepayers will be forced to pay more so that the Company's costs for providing Title 62 services can be less.
Request No. 153:Selwyn
Please provide specific support for your statement on page 10, line 19, that local exchange competition is not likely to occur in Idaho "in the near future."  Please define the "near future."
Response No. 153:The reference here is to facilities-based competition at the local exchange level.  See page 10, lines 20-22, lines 17-20 for specific examples that support          Dr. Selwyn's opinion.  The term “near future”, for the purposes of this testimony, can be defined as the next five to ten years, but the exact number of years is not critically important.  U S WEST has provided no support or foundation for its assertions concerning the expectation of significant facilities-based competition in the local service market in the short term.
DATED at Boise, Idaho, this               day of December 1996.
______________________________
Susan Hamlin
Deputy Attorney General
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