HomeMy WebLinkAboutUSWS965v21.docxSUSAN HAMLIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-0312
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION)CASE NO. USW-S-96-5
OF U S WEST COMMUNICATIONS, INC.)
FOR AUTHORITY TO INCREASE ITS)STAFF'S SUPPLEMENTAL
RATES AND CHARGES FOR)RESPONSES TO THE FIRST
REGULATED TITLE 61 SERVICES.)AND SECOND PRODUCTION
)REQUESTS 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 supplements its responses to U S WEST Communications, Inc.’s First and Second Requests for Production to the Idaho Public Utilities Commission Staff.
FIRST PRODUCTION REQUEST:
Request No. 5: Please identify by name and job description all persons employed on the Staff of the Idaho Public Utilities Commission who have been engaged in the gathering, review or analysis of information, documents or other date belonging to or pertaining to U S WEST Communications, Inc. or its parent and affiliate companies in connection with this docket or with the field audit performed by Staff in connection with this docket and/or any recent Revenue Sharing docket.
Supplemental Response No. 5: In addition to the Staff members who were previously identified in Staff's response to U S WEST's First Production Request No. 2, Staff identifies the following members of Staff: Stephanie Miller, Utilities Division Administrator, Joseph Cusick, Telecommunications Supervisor, and Beverly Barker, Director of Consumer Assistance.
Request No. 6: Please identify by name and job description each person employed by or acting as a consultant or employee of a consultant who has been engaged in the gathering, review or analysis of information, documents or other data belonging to or pertaining to U S WEST Communications, Inc. or its parent or affiliate companies in connection with this docket or with the audit performed in connection with the audit performed by Staff.
Supplemental Response No. 6: The ETI Project Team for work performed on behalf of Staff in this docket includes: Dr. Lee L. Selwyn, President; Susan M. Baldwin, Vice President; Scott C. Lundquist, Vice President; Paul S. Keller, Consultant; Joseph W. Laszlo, Senior Analyst; and Michael J. De Winter, Analyst.
Request No. 8: For each person identified in response to Request No 6, please provide an accounting of all hours billed or recorded for purposes of future billing for the work performed.
Supplemental Response No. 8: Through year-end 1996 the ETI Project Team have performed approximately 600 hours of work for the Idaho PUC consisting of the following:
Dr. Selwyn approximately 30 hours; Ms. Baldwin approximately 150 hours;
Mr. Lundquist approximately 50 hours; Mr. Keller approximately 100 hours; Mr. Laszlo approximately 160 hours; and Mr. De Winter approximately 70 hours.
SECOND PRODUCTION REQUEST:
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.
Supplemental Response No. 14: In addition to the information previously identified in Staff's response to U S WEST's Second Production Request No. 14, Staff provides the following. Late in 1994, the U S WEST Regional Oversight Committee (ROC) formed a service quality subcommittee to develop service quality standards that could be used as a model in all fourteen U S WEST states. The subcommittee was staffed by volunteers from various ROC states. For Idaho, the Staff was represented by Eileen Benner who, at the time, was the Telecommunications Section supervisor.
The subcommittee gathered information from all the ROC states on standards and reporting requirements already in use. Service quality standards and criteria was also gathered from states outside of U S WEST's territory.
The Idaho Staff shared information on the standards currently in place in the state as well as service quality data that was supplied by the Company. Documents in our possession pertaining to your request are attached.
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.
Supplemental Response No. 101:Faunce
In addition to the information included in Staff's response to U S WEST's Production Request No. 101, Staff believes the following projects for AT and BC are not Title 61 and maybe related to Part 64:
AT10465TP
AT11280BC
AT11283BD
AT11284BD
AT11946AD
AT11962AP
AT12070AC
AT2028CC
BC423228
BC5R1350
DATED at Boise, Idaho, this day of January 1997.
______________________________________
Susan Hamlin
Deputy Attorney General
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