USWS965v2.docx

DONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO  83720-0074
[phone]
Street Address for Express Mail:
472 W WASHINGTON
BOISE ID  83702-5983
Attorney for the Commission Staff
BEFORE  THE  IDAHO  PUBLIC  UTILITIES  COMMISSION

IN THE MATTER OF THE APPLICATION OF U S WEST COMMUNICATIONS, INC., FOR AUTHORITY TO INCREASE ITS RATES AND CHARGES FOR REGULATED TITLE 61 SERVICES.
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CASE NO. USW-S-96-5
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO U S WEST
COMMUNICATIONS, INC.
The Staff of the Idaho Public Utilities Commission (IPUC; PUC), by and through its attorney of record, Donald L. Howell, II, Deputy Attorney General, requests that U S WEST Communications, Inc. (U S WEST; USW; USWC; Company) provide the following documents and information on or before OCTOBER 23, 1996.
This Production Request is to be considered as continuing, and U S WEST Communications, Inc. is requested to provide, by way of supplementary responses, additional documents that it or any person acting on its behalf may later obtain that will augment the documents produced.
For each item, please indicate the name of the person(s) preparing the answers, along with the job title of such person(s) and the witness who can sponsor the answer at hearing.
Provide responses in electronic form where possible, e.g., spreadsheets used to derive responses.  Any spreadsheets provided should include formulas rather than just values.
All data should be for Southern Idaho only, and for the 1995 test year except where specified.  Basic local exchange service means Title 61 lines, residential or business.
Request No. 46:  Attachment C to the Company's Application (i.e., the press release) states that Idaho customers “have benefited from our $500-million investment in new and advanced services and state-of-the-art technology during the past ten years.”
a.Define and describe “new and advanced services.”
b.List any and all new and advanced services that U S WEST has introduced in the past ten years.
c.For each of the services identified in response to part (a), indicate, based upon the most recent data available, the number and percentage of:
(i)residential lines that can subscribe to the service and
(ii)the number and percentage of business lines that can subscribe to the service.
d.For each of the services identified in response to part (b), indicate, based upon the most recent data available, the number and percentage of:
(i)residential lines that do subscribe to the service and
(ii)the number and percentage of business lines that do subscribe to the service.
Request No. 47:  Provide penetration rates separately for residence and business customers for each of the years 1986 through 1996 for each of the following services:
a.three-way calling
b.call waiting
c.caller identification
d.repeat dial
e.voice messaging service
f.ring identification
g.any other services identified in response to subpart (b) of previous question.  (Request No. 46)
Request No. 48:  For each of the services listed in the previous question:
a.indicate the date that the service was first introduced.
b.provide the projections prepared by the marketing (or other appropriate U S WEST department or unit) of the anticipated demand for the service at the time it was introduced.  
Request No. 49:  Provide the objective (i.e., design) and actual fill factors for
a.feeder plant
b.distribution plant
Request No. 50: Provide copies of any and all engineering and/or business guidelines, manuals, reference material that discuss:
a.the establishment of fill factors.
b.the deployment of fiber rather than copper in the outside plant.
Request No. 51:  Provide the following data:
a.The total number of residential (i) accounts and (ii) lines for each of the years 1986 through 1996.
b.The total number of residential accounts that subscribe to more than one line for each of the years 1986 through 1996.
c.The total number of residential accounts that U S WEST estimates to be eligible for Telephone Assistance Program.
d.The total number of residential accounts that are presently participating in the Telephone Assistance Program, separately at the most disaggregated level available (i.e., by county, city, or exchange area, if possible).
e.Provide penetration rates (percentage of households subscribing to local exchange service) separately, again at the most disaggregated level for which data is available, for ten most densely populated areas.
f.The total number of basic (for this and all other references, basic business local exchange service refers to “small business customers” with five access lines or less as defined in Idaho Code §62-603(8)) business local exchange service (i) accounts and (ii) lines for each of the years 1986 through 1996.
Request No. 52:  Provide the test year's directory assistance revenues from residential and basic business local exchange customers.
Request No. 53:  What are U S WEST's minimum standards (the lowest acceptable level) and objectives (the level of performance U S WEST strives to achieve) in Idaho for
a.installing residential dial tone as measured by the interval (i.e., number of days) between a request for service and the installation of the service?
b.installing business dial tone as measured by the interval (i.e., number of days) between a request for service and the installation of the service?
Request No. 54:  With reference to the previous question, what percentage of orders, on average, satisfy the minimum standards and the objective level for
a.residence service
b.business service
Indicate the time period upon which the responses are based.
Request No. 55:  At what level of geographic disaggregation (e.g., county, district, etc.) does U S WEST maintain data on the installation of its service.
Request No. 56:  Provide copies of any and all written memoranda, guidelines, manuals that discuss the Company's policies and procedures regarding installation intervals.
Request No. 57:  What are U S WEST's minimum standards (the lowest acceptable level) and objectives (the level of performance U S WEST strives to achieve) in Idaho for
a.the interval between when a problem is reported by a customer on a residential line and when the company fixes that problem?
b.the interval between when a problem is reported on a basic business local exchange line and when the company fixes that problem?
Request No. 58:  Provide copies of any and all written memoranda, guidelines, manuals that discuss the Company's policies and procedures regarding the response to troubles reported on local exchange lines.
The following questions are directed to Dallas R. Elder:
Re page 4:
Request No. 59:  Provide copies of the audits of the CAAS completed by Coopers and Lybrand.
Request No. 60:  Provide copies of any and all documents, manuals, memoranda prepared on or behalf of U S WEST that concern the Company's interpretation or plans to implement the FCC's NPRM regarding cost allocation methodologies described in the FCC's NPRM, Allocation of Costs Associated with Local Exchange Carrier Provision of Video Programming Services, CC Docket No. 96-112, released May 10, 1996.
Request No. 61:  Does U S WEST conduct any type of business case analysis (e.g., predictions of costs, revenues, reductions in operating costs, etc.) before undertaking a capital investment program?  If the answer is in the affirmative:
a.What size of investment requires the undertaking of a business case analysis?
b.Describe fully and provide an example of U S WEST's business case analysis (e.g., discounted cash flow predictions).
c.In conducting business case analyses, does the Company use the Commission-approved depreciation rates?
d.If the answer to part (c) is in the negative, explain fully the reason for the departure from Commission-approved depreciation rates.
Re page 9:
Request No. 62:  Describe and quantify in detail all non-plant-related expenses (e.g., marketing, customer support, etc.) associated with
a.residential local exchange access lines.
b.business local exchange access lines.
Request No. 63:  What is the annual dollar amount associated with non-plant-related expenses for
a.residential local exchange access lines.
b.business local exchange access lines.
Provide any and all workpapers and supporting documentation.
Request No. 64:  Please provide a complete list of the “local service products” to which you referred on p. 11, line 21.
Request No. 65:  Provide all studies, workpapers, analyses, and other materials that support the measure of
a.the local loop length for residential customers in southern Idaho,
b.the average usage for residential customers at present,
c.the projected usage for residential customers after the implementation of  U S WEST's proposed EAS plan.
Request No. 66:  Provide all studies, workpapers, analyses, and other materials that support the measure of
a.the local loop length for business customers in southern Idaho,
b.the average usage for business customers at present,
c.the projected usage for business customers after the implementation of     U S WEST's proposed EAS plan.
Request No. 67:  Please provide a complete and detailed definition of the hardware and equipment that make up the local loop as referred to in your testimony.  Does the local loop include any portion of the switch?
Request No. 68: If the local loop does include any portion of the switch, please provide details as to the allocation of the switch cost between non-traffic sensitive and traffic sensitive portions, and for each of those, provide details regarding the division between local and nonlocal.
Request No. 69: Please provide the switch cost allocations above revised to account for the proposed EAS routes (i.e., non-traffic sensitive local and nonlocal, and traffic sensitive local and nonlocal allocations of the loop).
Request No. 70:  On page 12, lines 7-21 Elder describes several problems with using the Commission's flat 15% allocation of the local loop for intrastate switched access and toll categories.  How would adopting U S WEST's proposed SLU basis for allocating the loop affect the percentage allocated to the various categories?  In answering, please provide data in the form of the following chart:
Allocation of Local Loop
Current Method
Proposed (SLU-based)
Interstate
Intrastate (of which:)
   Switched Access
   Toll
Local Service Products
Request No. 71:  Please clarify whether the data in the chart on page 19, lines 13-24, was calculated inclusive of the rural exchanges sold by U S WEST or exclusive of them.  If the data included the exchanges that were sold or are to be sold, please recalculate the table showing the correct post-sale information.
Request No. 72:  Please provide the information supplied in Exhibit No. 22 (Title 61 Base Results for 1995) for Title 61 and Title 62 services combined, and for Title 62 services alone.
The following questions are directed to Barbara L. Wilson:
Re page 2:
Request No. 73:  Define “unrealistic depreciation lives.”
Re page 10:
Request No. 74:  Has U S WEST offered any promotional discounts for additional residential lines (e.g., waivers of nonrecurring charges, etc.) in the last two years?     If the answer is in the affirmative, provide copies of any and all marketing literature (e.g., bill inserts, advertisements, etc.) regarding second lines.
Re page 15:
Request No. 75:  Provide any and all documents, workpapers, studies prepared by or on behalf of U S WEST that discuss or show the schedules “used by current competitors and likely to be used by the new local service providers.”
Request No. 76:  The testimony states that “[s]ince 1989 the Company has increased its depreciation expense by $56.9 million.  This additional expense was absorbed by the Company without increasing its Title 61 local prices, and in fact while substantially reducing prices for toll and access on the Title 62 side.”  
a. Was the referenced increase of $56.9 million in depreciation expenses a voluntary increase?  Explain fully.  
b.What portion, if any, of this expense is the Company seeking to recover in this case?
Re page 17, lines 6-8:
Request No. 77:  Explain fully (including all sources of information) the way in which U S WEST determines the level of investment that “Idaho has come to expect.”
Re page 18, lines 5 through 8:
Request No. 78:  Which of the FCC's three sharing/productivity options (under the First Report and Order, price cap regulations, FCC CC 94-1) does U S WEST use?
Re page 22:
Request No. 79:  If the Commission did not grant “substantially all of the price increase” that U S WEST seeks, but if all telecommunications service providers were required to contribute proportionally to a lifeline assistance program, would U S WEST oppose such a program?  Explain fully.
Request No. 80:  Identify any and all “old compact obligations.”
Re page 23, the statement that “[c]ompetitive businesses select their customers and set their own prices.”
Request No. 81:  Are you referring to other telecommunications service providers?
Request No. 82:  What is your understanding of other telecommunications service providers' current discretion to deny service to customers who request service?  Explain fully and provide the basis of the response.
Re page 24:
Request No. 83:  Identify any directives (either by the PUC, statute, or other) requiring U S WEST to charge average prices.
Request No. 84:  Identify and describe all relevant nondiscrimination requirements contemplated by your third point at line 5.
Re page 27:
Note:  In responding to Request Nos. 85-88, if the data are only available on a per residential line basis rather than a per-household basis, indicate such and provide the corresponding data.
Request No. 85:  Identify all exchanges that you consider to be high cost, and the basis for that classification.
Request No. 86:  What is U S WEST's average revenue per household (considering all households in Southern Idaho) for (a) Title 61 services and (b) Title 62 services?
Request No. 87:  Provide a decile distribution as follows.  Rank all households based upon total per-household revenues (Title 61 and Title 62 services), and split into ten groups
(such that each group includes the same quantity of households).  For each of the ten groups indicate the average revenue per household for that group.  
Request No. 88:  Based upon the response to Request No. 85, considering only the identified high cost exchanges, what is the average revenue per household for (a) Title 61 services and (b) Title 62 services?
Request No. 89:  Provide total annual revenues for the years 1986 through 1996 associated with vertical services offered to Title 61:
a.basic residential local exchange service customers.
b.basic business local exchange service customers.
Request No. 90:  Provide total annual revenues for the years 1986 through 1996 associated with all Title 62 services offered to
a.basic residential local exchange service customers.
b.basic business local exchange service customers.
Re page 28, lines 9 through 11:
Request No. 91:  Provide any projections prepared by or on behalf of U S WEST showing U S WEST's share of the basic residential local exchange service assuming (a) rates are restructured consistent with U S WEST's proposal and (b) rates are left intact.
Request No. 92:  What percentage of the basic residential local exchange market does U S WEST presently serve through each of the following:  (a) retail; (b) resale; (c) unbundled network?
Re page 30:
Request No. 93:  Provide copies of any studies, memoranda, presentations, or other material prepared by or on behalf of U S WEST concerning the pursuit of so-called “packaged services.”
Request No. 94:  Regarding your reference to a “customer who is truly a Title 61 customer,” indicate what percentage, if any, of U S WEST's Title 61 residential customers do not presently subscribe to any Title 62 services.
Request No. 95:  Regarding your reference to a “customer who is truly a Title 61 customer,” indicate what percentage, if any, of U S WEST's Title 61 business customers do not presently subscribe to any Title 62 services.
Re page 31:
Request No. 96:  Provide examples of historical interpretations that prohibit the discount of the recurring charges for Title 61 regulated services for promotions and the purpose of packaging.
Request No. 97:  Describe fully the modifications that you (B. Wilson) recommend.
The following questions are directed to William R. Easton
Re page 31:
Request No. 98:  Identify and quantify the specific costs associated with U S WEST's implementation of the federal act's mandates and indicate what percentage of these costs        U S WEST ascribes to the intrastate jurisdiction.
Request No. 99:  Please list the top ten accounts in terms of their contribution to the proposed rate increase and include the individual amounts they contribute to the proposed rate increase and the corresponding percentage of the total requested rate increase.
Request No. 100:  If there are any other accounts which contribute more than five percent toward the proposed increase, please provide information as requested in Request
No. 99.
Request No. 101:  The following questions are in reference to the Vanston and Hodges study, “Depreciation Lives for Telecommunications Equipment:  Review and Update” (Attached as Exhibit 20 of the Direct Testimony of William R. Easton).  For each of the factors identified below, please explain in detail how, if at all, in the methodology used in his study, the factor is applied as an input to the calculation of technology substitution curves underlying the determination of LEC asset lives:
a.The cost of capital;
b.Revenues from new services made possible by deployment of the new technologies substituting for LEC embedded investments;
c.Forecasts of LEC market share for those services furnished via the new technologies being deployed;
d.The rate of price inflation/deflation, either for the national economy or the specific types of new technologies being acquired;
e.Asset lives of new technology investments being undertaken;
f.Vintages of customer premises equipment used in conjunction with LEC services (e.g., telephone sets, modems, etc.).  
Request No. 102:  When were Title 61 depreciation rates last reviewed and approved by the Commission?  Has U S WEST undertaken any changes to depreciation rates on its own since then?  If so, please describe those changes, including their effective date.  
Request No. 103:  Describe the circumstances behind the U S WEST decision in 1991 to switch to using Equal Life Group depreciation rates.
Request No. 104:  Please explain how the Company reflects research and development (R&D) costs in the cost studies filed in this case.  In particular, please provide specific references to the location in each study in which R&D costs associated with SONET and, separately, SS7 R&D costs are included.
Request No. 105:  Please identify any research and development (R&D) expense undertaken by USWC itself over the past five years which was charged wholly or in part to USWC Idaho regulated operations.  Provide a list of all such projects, the amounts charged, the basis of that allocation, and an explanation of the purpose of the expenditure.
Re page 5, lines 20-22:
Request No. 106:  Mr. Easton states “New entrants to this marketplace throughout U S WEST have stated their intentions to deploy state of the art, fiber based networks.”  Provide documentation supporting this claim; list all entrants and the markets in which they are currently competing (by service, and by geography).
Re page 9, lines 9-10:
Request No. 107:  Regarding the statement that “Since depreciation rates were last modified in 1993, the pace of change has accelerated.”  List the modifications made in 1993 by major account.  Provide support for this claim of accelerated change.
Re page 10:
Request No. 108:  Provide the table that begins on line 1 with one additional column: Impact of proposed lives on depreciation expense.
Re pages 10-11:
Request No. 109:  Please describe any differences in the accounting procedures utilized by the following companies: Electric Lightwave Inc. (ELI), Teleport Communications Group (TCG) and Phoenix Fiber (Easton Direct, p. 10, lines 12-13) vis-à-vis those employed by U S WEST.  Are these companies required to comply with USOA accounting procedures?  Explain how such differences, if any, impact the comparison of depreciation lives (see chart, Easton Direct, p. 11.)
At pages 11-12 the prefiled Easton testimony states:
Re:  “This data is particularly relevant given that AT&T, ELI, TCG and Phoenix Fiberlink have recently filed to provide local service in several U S WEST states.”
Request No. 110:  For each company, separately, list the U S WEST states in which it:
a.is currently providing local exchange service.
b.has filed to provide local exchange service.
c.has been granted permission by the state commission in that jurisdiction to provide local exchange service.
Request No. 111:  For each company identified in Request No.101 (b), list separately, by state, the areas or exchanges in which competitive local exchange services are to be provided, the number of access lines in service (if known).
Request No. 112:  What other companies, besides those for which you have listed depreciation life information, have filed to provide local exchange service in U S WEST territory (list separately, by state)?  Has U S WEST attempted to obtain depreciation life estimates for these companies?  If so, please provide copies of all documentation supporting such efforts.
Request No. 113:  Please list the depreciation lives reported by these companies for accounts other than those shown in the table on p. 11 of Easton Direct testimony.  
Re:  Cable company comparisons (Easton Direct, pp. 12-13):
Request No. 114:  Mr. Easton notes in his testimony (p. 12) that “Some translation is required [between cable co. and telephone co. equipment] since the categories used for cable companies are somewhat different than those used by the FCC for telecommunications companies.”  Please describe in detail the assumptions used in this translation and provide accompanying justification for the same.
Re page 16, line 7:
Request No. 115:  Based upon the last depreciation rates approved by the Idaho PUC, what is U S WEST's Southern Idaho current composite depreciation rate (a) reflecting the depreciation reserve deficiency and (b) not reflecting the depreciation reserve deficiency.    Provide information for both Title 61 and Title 62 depreciation rates.  Provide any and all back-up calculations.
Re:  Composite depreciation rate comparison (Easton Direct, p. 16):
Request No. 116:  Relative to the specific technology substitution curves and asset lives determined by USWC in its calculation of the depreciation reserve deficiency in the 1996 Idaho Depreciation Study (Attached as Exhibit 19, Direct Testimony of William R. Easton), please respond to the following questions.  For each of the factors identified below, please explain in detail how, if at all, in the methodology used in his study, the factor is applied as an input to the calculation of technology substitution curves underlying the determination of LEC asset lives:
a.The cost of capital;
b.Revenues from new services made possible by deployment of the new technologies substituting for LEC embedded investments;
c.Forecasts of LEC market share for those services furnished via the new technologies being deployed;
d.The rate of price inflation/deflation, either for the national economy or the specific types of new technologies being acquired;
e.Asset lives of new technology investments being undertaken;
f.Vintages of customer premises equipment used in conjunction with LEC services (e.g., telephone sets, modems, etc.).
Re page 18, lines 2-3, regarding the competitive market:
Request No. 117:  For residence only, provide any and all predictions of market share, price, and/or demand prepared by or on behalf of U S WEST regarding the (a) local exchange market (5 lines or under); (b) the intrastate access market; and (c) vertical services market.  Specify separately the shares by retail; unbundled; resale; and facilities bypass.
For small business (5 lines or under) only provide any and all prediction of market share, price, and/or demand prepared by or on behalf of U S WEST regarding the (a) local exchange market; (b) the intraLATA toll market; (c) the intrastate access market; and (d) vertical services market.  Specify separately the shares by retail:  unbundled; resale; and facilities bypass.
Re page 18, lines 5 through 12:
Request No. 118:  Identify where (i.e., which wire centers) U S WEST's capital construction programs for the next three years would differ depending upon whether U S WEST had an obligation to serve; i.e., specify and quantify fully the specific investments that U S WEST plans to make during the next three years that it would not make if it were “free to determine whether, where and when to invest.”
Re page 19 at lines 3 through 13:
Request No. 119:  Provide U S WEST's most recent business plan for Southern Idaho.
Re:  “The lives detailed in the [1996 Idaho Depreciation Study] are based primarily on industry studies of new telecommunications technologies and their expected impact on the public telephone network.  The results of these studies were analyzed and, where necessary, modified by U S WEST to fit our company experience, direction and account profiles.”  (Easton Direct, p. 19.)
Request No. 120:  Describe in detail the specific ways in which the results of these studies were “modified by U S WEST to fit our company experience, direction and account profiles.” (Easton Direct Testimony, p. 19, lines 4-5.)
Re page 22:
Request No. 121:  Provide a version of the table shown that indicates for each of the 15 locations, the present switch type, the proposed replacement switch type, and the estimated retirement year reflected in the previous depreciation study.
Request No. 122:  For each of the 10 location names for which recovery of investment is sought in this proceeding, indicate:
a.whether a net present value and/or business case analysis was conducted regarding the planned investment
b.if the response to (a) is in the affirmative, was the projected NPV positive, and if so, what discount rate was used and what time horizon was reflected.
Re page 22, line 13, the reference to “declining costs of digital switching”:
Request No. 123:  Does this statement refer to (a) declining investment (i.e., purchase) costs of digital switching and/or (b) declining operating and maintenance costs associated with digital switching?  Explain fully.
Re page 22, line 14:
Request No. 124:  Identify any and all switches in Southern Idaho that are proposed for consolidation, and indicate the year for which such consolidation was planned.
Re page 23, lines 7-11:
Request No. 125:  Provide a table comparable to that provided on page 22 of your testimony that lists alphabetically by location the present digital switch type, the planned digital switch type, the replacement year reflected in the 1993 depreciation case and the replacement year now proposed.  Also, for each such location, indicate (a) the number of Title 61 lines served and (b) the number of Title 62 lines (including Centrex) served.
Request No. 126:  Has the Company prepared any business case evaluation of the switch replacements identified in response to the previous question (i.e., projections of cost, savings in operating and maintenance expenses, revenues from new services)?  If yes, provide copies of such studies.
Re page 23, lines 15-17:
Request No. 127:  Easton notes that switch evolution “will change as the customer demands more and more capabilities from the public switching network.”  What specific capabilities are being demanded from customers?  Provide supporting documentation which quantifies this demand.  Have studies been undertaken to determine the price elasticity that would accompany the services implied by such demand?  If so, provide these as well.
Re page 24, lines 10-13:
Request No. 128:  Mr. Easton asserts that “Switch consolidation will drive down the cost of the network as efficiencies are captured and digital switches are consolidated into larger digital switches or high capacity optical remotes, thus eliminating processors from the network.”  Since Mr. Easton characterizes this consolidation as a “near-term to midterm driver of Digital Switching” (p. 24, lines 7-8), please provide specific documentation showing the amount of switch consolidation undertaken since 1986.  Quantify the savings realized from this consolidation and the distribution of such savings, for the appropriate years, between Title 61 and Title 62 services.  Provide any and all workpapers.
Re page 24, lines 3-5:
Request No. 129:  Referencing “A previous internal study by U S WEST Communications of a sample of switches” which Easton states “was consistent with TFI results.”  Please provide a copy of this internal study, along with any supporting documentation.  Please also identify any areas where the U S WEST study results were not consistent with TFI's results and provide justification for such inconsistencies.
Re page 24, lines 7 through 16:
Request No. 130:  Provide copies of any and all projections of annual cost and savings prepared by or on behalf of U S WEST regarding switch consolidation.
Request No. 131:  Identify all digital switches proposed for consolidation, alphabetically by location.
Re page 26, line 15:
Request No. 132:  Provide any and all plans prepared by or on behalf of U S WEST regarding U S WEST's deployment of broadband in southern Idaho.
Re page 27:
Request No. 133:  Easton, p. 27, lines 1-2, “in order to estimate a reasonable projection life for Circuit Digital equipment, the company utilized industry studies developed by TFI.”  Provide copies of these industry studies and cite the specific portions of such studies relied upon in the determination of the projection life for Circuit Digital equipment.
Re page 27:
Request No. 134:  Delineate what “needs” of Idaho telecommunications consumers are met by the following technologies and how they meet such “needs” (see p. 27, lines 8-13):
1.higher speed circuit electronics to tap the transmission capacity of fiber;
2.ubiquitous fiber in the interoffice;
3.SONET technology throughout the network;
4.broadband switching;
5.fiber in the loop.
Re page 31:
Request No. 135:  Concerning the statement that “[w]hile most of the technologies I discussed are capable of providing other services, they are also being developed and deployed to provide improved (better, faster, more reliable) Title 61 services.”  Provide support for this statement, including specific documentation of improved service quality trends identified by the company for the years 1993 to 1996.
Re page 32 at lines 10-13 (this question is directed jointly to Mr. Easton and Mr. Elder):
Request No. 136:  Applying Mr. Elder's methodology, separate the Company's investment between Title 61 and Title 62 services and separately display the results among the 7 accounts shown on page 10 of Mr. Easton's testimony.  Provide any and all workpapers.
Request No. 137:  Using the results provided in response to the previous question, and based upon the lives proposed in this proceeding, separately identify the impact on U S WEST's depreciation expenses for the seven accounts and separately for Title 61 and Title 62 services.  Also provide any related (i.e., disaggregated in the same manner) calculations regarding the proposed recovery of the alleged depreciation reserve deficiency.
Re page 33:
Request No. 138:  Compute the increase in depreciation expenses associated with the lives that the Staff agreed to at the three-way meeting.  Also provide any related calculations regarding the proposed recovery of the alleged depreciation reserve deficiency that would be associated with the Staff-agreed upon lives.  Provide complete workpapers.
Re page 36, line 22 through page 37, line 3:
Request No. 139:  Describe fully the “competitive environment” that your statements contemplate.  For the environment to be competitive what minimum levels of market share
would U S WEST need to lose (a) in the retail local exchange (Title 61) market; (b) to facilities bypass; (c) to resellers; (d) to competitors purchasing unbundled network elements?
Re page 45, line 3:
Request No. 140:  If the Commission were to deny, in whole or in part, the $18.3 million in additional depreciation expense sought by U S WEST, please identify the specific impact that would have on anticipated future investments (i.e., which Title 61 and which Title 62 investments, if any, would be curtailed, what initiatives would not take place).
Request No. 141:  Provide workpapers associated with each adjustment made to the $36.7-million that leads to the $18.3-million.
The following questions are directed to Margaret J. Wright:
Request No. 142:  Please explain the statement that “eventually, the Title 61 customers are going to have to fund this capital recovery and other expenses” (p. 15, lines 7-8) in the context of an increasingly competitive market for local telephone services.
Request No. 143:  Is there an allocation of the revenues derived from the sale of the exchanges described at page 30, lines 10-21 between Title 61 and Title 62 revenue centers?  If so, provide the basis of that allocation, and actual amounts allocated to Title 61 and Title 62.
Request No. 144: Was an adjustment made to the test year revenue requirement to account for the reduced cost of debt capital for U S WEST (cf. Wright Testimony, page 31,     line 7)?  Please explain that adjustment, and provide all relevant workpapers, studies, and any other evidence showing that the customer will derive a benefit from the retirement of debt mentioned in Section 3.20.  If no adjustment was made, please justify that decision.
General Questions:
Request No. 145:  In response to Staff Audit Request No. 36, USWC responded “There are no credits applied to the residence or business bills for remote call forwarding.  USWC negates the charges on the service order.”  Please provide information on the number of instances where these charges have been negated, for both residential and business customers.  (WH)
Request No. 146:  The response to Staff Audit Request No. 36 also indicates “this data is voluminous and can be extracted and put on a disk for the IPUC by the end of August.”  Please provide an IBM/MS-Dos compatible disk with this data.  The preferred format would be a
Lotus 123 for Windows or Excel readable file, but an ASCI file with either defined field sizes or comma (or tab) separated values would also be acceptable.  (WH)
Request No. 147:  The response to Staff Audit Request No. 37 indicates “November, 1995 through May, 1996 will be available at the end of August.”  Please provide data for this time period.  A disk with November 1995 through September 1996 data in one of the formats identified in the previous question would be preferred.  (WH)
Request No. 148:  Please explain the terms “Co Miss” and “Sub Miss” as it is used in the table used in the reply to the Audit Request No. 37.  Is the number of missed commitments in the last two columns cumulative or duplicative?  For example, if there is an 02 in the “Co Miss” column, and an 02 in the “Sub Miss” column, does that mean there were a total of four missed commitments, with two being attributed to the Company and two attributed to the customer, or does it mean there were two missed committments, both of which were attributed to the customer, or is it something else?  (WH)
Request No. 149:  How is the determination made as to whether a commitment is missed due to the Company or the Customer?  For example, if a customer is told that the installation will be completed in the morning, but the technician does not make it to the home until the afternoon, and finds the customer no longer at home, is this considered a Company miss or a subscriber miss?  Please provide the criteria used by the Company to determine commitment-missed responsibilities.  (WH)
Request No. 150:  Please provide information regarding any policies or procedures used in estimating the number of lines that are assumed to be appropriate for residential and commercial development purposes.  Have these policies or procedures changed since 1990?  If so, describe any changes.  (WH)
Request No. 151:  Please identify the amount of all charges collected pursuant to the provisions of Basic Local Exchange Tariff , Section 4, Para. No. 4.6.A and C. for Southern Idaho for each year from 1990 through 1995, and January through August of 1996.  (WH)
Request No. 152:  Provide tracking of all interest expense from source of debt for Idaho intrastate operations.  Explain all allocations or assignments, particularly allocations between Title 61 and Title 62 services.
Request No. 153:  What percentage of existing plant in the following categories (ARMIS Acct. Reference in parenthesis) was placed in service on or after January 1, 1990; also list by category the amount of plant (in investment dollars) placed in each year from 1987 to the present:
—Buildings (2121)
—General Purpose Computers (2124)
—Analog Elect. Switch (2211)
—Digital Elect. Switch (2212)
—Circuit Equipment (Digital) (2232)
—Circuit Equipment (Analog) (2232)
—Circuit Equipment (DDS) (2232)
—Poles (2411)
—Aerial Cable - Metallic (2421)
—Underground Cable - Metallic (2422)
—Buried Cable - Metallic (2423)
—Aerial Cable - Non-Metallic (2421)
—Underground Cable - Non-Metallic (2422)
—Buried Cable - Non-Metallic (2423)
—Conduit (2441)
Request No. 154:  Please provide the number of trunk equivalent centrex lines (equivalent to those reported in ARMIS report 43-08, Table II, columns (ce) and (ch)) for end-of-year (EOY) 1989-1995.
Re page 45, line 3:
Request No. 155:  Please provide the most recent cost of service study for both non-published and non-listed directory listing services (recurring and non-recurring charges).  Is the cost justification different among the states that USWC serves?  If so, how and why does it vary.
Request No. 156:  Please provide samples of all business and residential forms provided to customers, i.e. notices, letters, receipts, bill, deposit guarantee form, etc. if updated since 1992.  (CJC)
Request No. 157:  When did USWC change its policy to implement Preferred Interexchange Carrier (PIC) freezes at the customer’s request?  (CJC)
Request No. 158:  In follow-up to prior Request No. 17:
a.  What constitutes a USW complaint?
b.  How does USW track complaints?
c.  Are executive complaints logged?  (CJC)
Request No. 159:  Please provide a copy of testimony filed, including confidential testimony, by witnesses Tom Riordan and Evan White in the U S WEST rate case before the Oregon Public Utility Commission, Case No. UT 125.  Please provide a copy of rebuttal testimony filed by U S WEST to the above witnesses.  (SEH)  
DATED  at Boise, Idaho, this            day of October 1996.
______________________________________
Donald L. Howell, II
Deputy Attorney General
umisc\prdreq\usws965.dh2