USWS965v22.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)CASE  NO.  USW-S-96-5
OF U S WEST COMMUNICATIONS, INC.)
FOR AUTHORITY TO INCREASE ITS)STAFF'S SUPPLEMENTAL
RATES AND CHARGES FOR)RESPONSE TO THE SECOND
REGULATED TITLE 61 SERVICES.)PRODUCTIONREQUEST 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 response to U S WEST Communications, Inc.’s Second Production Request No. 134.
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.
Supplemental Response No. 134:
Step 1:  In addition to the answer previously provided to this request, Staff offers the following.  Staff requested “copies of any specific cost allocation studies done in support of this rate case.”  See STF-036.  The Company referred us to the documentation in response to STF01-030, which included the disks with the spreadsheet files and the CAAS manual.  The Company failed to provide us with the special studies referred to in the CASS manual.
In Request No. 33, Staff asked U S WEST to “[i]dentify the specific percentage of access lines and 'secondary allocation procedures' used to separate Title 61 and 62 revenues and expenses, Ref. Elder p. 11" and in response the Company stated, “See the documentation provided in response to STF01-030.”  Although Staff had asked for specific percentages, the Company referred Staff to the voluminous CAAS files and CAAS manual and did not directly respond to the request posed.
In Request No. STF-3-169, Staff asked U S WEST to “provide all of the Special Studies used in allocating costs and revenues between Title 61 and 62 services, as listed in U S WEST's Accounting Segregation Manual (Cost Manual), Section VI.I., Part D, pages 8-13.  These should include the Residence....any other relevant studies used but not listed here” (emphasis added).  In response to this question, the Company provided, among other things, lines reported for revenue sharing purposes, but did not provide any accompanying explanation.  Furthermore, these data did not include any data relating to PBX lines or to Public Lines.  It is my understanding that Staff attempted repeatedly to seek clarification regarding the Company's response.  More importantly the Company failed to provide the special studies implicitly used
by U S WEST to allocate costs between Title 61 and Title 62 - that is the special studies relied upon by U S WEST to allocate costs to products (i.e., the studies referred to on page 19 of
Ms. Baldwin's direct testimony).
DATED at Boise, Idaho, this               day of February 1997.
______________________________________
Susan Hamlin
Deputy Attorney General
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