USWS965v3.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
THIRD 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 29, 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.
General questions:
Request No. 160:  Regarding your response to previous requests (in STF01-049 and STF01-050) for information regarding fill factors for distribution and feeder plant, please provide any information not previously supplied, including objective (design) fill factors, engineering manuals, policies, procedures manuals, and any other documentation that supports those objective fill factors, and the actual fill factors used for (1) distribution and (2) feeder plant, for the years 1988 to the present.  (ETI)
Request No. 161:  Please provide a detailed description of each of the categories listed on the chart titled Idaho Non-Commission Complaints, provided as Attachment A to
U S WEST's response to STF01-017.  (ETI)
Request No. 162:  Please add a column to the chart titled Idaho Non-Commission Complaints, provided as Attachment A to U S WEST's response to STF01-017, showing customer complaints to date in 1996.  (ETI)
Request No. 163:  Please reproduce the chart provided in response to STF01-017 (U S WEST customer complaints not involving the PUC) for all customer complaints, including those that involved the PUC.  Include a column showing all complaints to date for 1996.  (ETI)
Request No. 164:  Please provide a breakdown of the MTAS Report 67 provided as Attachment A in U S WEST's response to STF01-038, distinguishing between Title 61 and Title 62 business services.  (ETI)
Request No. 165:  Please provide a complete description for each category abbreviation (line numbers 1-60) included in MTAS Report 67, provided as Attachment A in U S WEST's response to STF01-038.  (ETI)
Request No. 166:  Provide the number of Title 61 residential customers as of December 31, 1995, by class of service, who have:
a.one additional line; and  
b.more than one additional line.  (ETI/BE)
Request No. 167:  What is the total dollar value of the credits for local exchange service provided by the Company in southern Idaho as a result of delayed repair of a service outage (as described under paragraph 01 of Rule 503, IDAPA 31.41.01)?  Please provide details as to the accounting methodology used to record credits provided under this rule.  (ETI)
Request No. 168:  Please provide the missing information (May and June 1996) regarding U S WEST-southern Idaho's Out-of-Service Conditions Restored Within 24 Hours statistics (Measurement #1 and Measurement #2), as related in U S WEST's monthly Basic Service Measurement reports.  (ETI)
Request No. 169:  Please provide all of the Special Studies used in allocating costs and revenues between Title 61 and Title 62 services, as listed in U S WEST's Accounting Segregation Manual (Cost Manual), Section VI.1, Part D, pages 8-13.  These should include the Residence Revenue Special Study, the Residence Lines Special Study, the Business Revenue Special Study, the Business Lines Special Study, the PBX Revenue Special Study, the PBX Lines Special Study, the Public Revenue Special Study, the Public Lines Special Study, and any other relevant studies used but not listed here.  (ETI)
Request No. 170:  Please describe fully the way in which U S WEST allocates the cost of its (a) spare outside plant capacity and (b) spare switch capacity between Title 61 and Title 62 services.  (ETI)
Request No. 171:  Identify, separately, for each central office in U S WEST territory in Idaho, the following:
a.Total number of working lines, by class of service, for the following services:
(1)Title 61 Residential
(2)Title 61 Small Business
(3)Title 62 Business (other than Centrex)
(4)Centrex
(5)Coin
(6)Private Line and Special Access
(7)Other (if this category is used, please indicate what lines it encompasses)
b.The total number of loops in each central office, i.e., all available loops, regardless of whether they have been assigned to working lines.  (ETI)
Provide responses to parts (a) and (b) in the form of end-of-year data for each year since 1984.  (ETI)
Request No. 172:  For each central office in U S WEST territory in Idaho, identify the following:
a.Type of switch
b.Year switch was installed
c.Number of working lines
d.Number of equipped lines
e.Number of working loops  
f.Number of lines able to subscribe to ISDN  (ETI)
If the number of working lines and the number of working loops are different, explain the source of the difference.  (ETI)
The following questions are directed to James E. Wozniak:
Re page 2, lines 6-7:
Request No. 173:  With respect to rates of return:
a.What do you define as a “reasonable return” on U S WEST's economically regulated operations in Idaho?
b.What rate of return do you estimate that U S WEST is currently earning on its economically (i.e., Title 61) regulated operations in Idaho?
c.What rate of return do you estimate that U S WEST is currently earning on its nonregulated (Title 62) operations in Idaho?  (ETI)
Re pages 4 and 9 (referencing practice of setting business rates at 2.5 times residential):
Request No. 174:  Provide any and all specific evidence in any Order of this Commission relative to telephone service that the Idaho PUC requires this practice in order to provide a contribution to universal service.  (ETI)
Re page 5, lines 8-12:
Request No. 175:  Provide residential and business market share estimates for all alternative access providers (including, for example, Idaho Power Company) that operate in
U S WEST's Idaho service territory.  What percentage of the total residential and business access market is currently held by facilities-based competitors of U S WEST?  (ETI)
Re page 5, lines 13-14:
Request No. 176: What percentage of the provisioning costs for residential service do you estimate are currently covered by residential service prices?  (ETI)
Re page 8, lines 9 through 18 and page 12, line 12-13:
Request No. 177:  Please provide an alphabetical listing of all of the municipalities that U S WEST serves in southern Idaho and with that listing indicate:
a.the name of the wire center(s) that serve the municipality;
b.the number of residence lines in the municipality;
c.the number of small business lines in the municipality;
d.whether the exchange is rural;
e.whether you consider the exchange to be a “truly high-cost area”.  (ETI)
Re page 19, lines 11-14:
Request No. 178:  Please provide all reports, market share estimates and any other evidence on which you base your assertion that revenues earned by U S WEST through the production and dissemination of yellow pages (which you term “advertising revenues”), are “highly competitive.”  (ETI)   
Re page 20, lines 19-23:
Request No. 179:  Please provide any documents which support your contention that prices for residential local service “are among the lowest in the nation.”  (ETI)
Re page 21 lines 1-4:
Request No. 180:  On page 21 of your testimony you state that U S WEST “has introduced exciting new services that our customers want to Idaho including Voice Messaging, Caller ID and Frame Relay” and that 95% of the customer base will have access to custom calling features by year's end.  Please explain how U S WEST decided that residential customers (a) desired these services and (b) were willing to pay for these services.  Provide copies of any and all market studies, surveys, or other documents prepared by or on behalf of U S WEST that relate to customers' interest in, and/or willingness to pay for these new services.  (ETI)
The following question is directed to Mr. Wozniak and Mr. Elder:
(see Wozniak at 6, lines 6 through 8):
Request No. 181:  Please define “joint and common costs” as U S WEST uses the term.  (ETI)
The following questions are directed to Mr. Cummings:
Re pages 13-14:
Request No. 182:  Provide complete copies of the four investment analyst reports quoted.  (ETI)
Re pages 19-20:
Request No. 183: Provide a complete copy of the cited Morgan Stanley residential telephone customer survey and report entitled “Telecommunications Services: Who Will End Up Where and Why; A Look at Local Exchange Carriers.”  (ETI)
Re page 20, lines 12-28:
Request No. 184:  What year corresponds with the “future”?  Provide any and all source documentation.  (ETI)
The following questions are directed to Ms. Wright:
Re Exhibit 25:
Request No. 185:  Provide comparable hypothetical pages for Idaho-South Intrastate Title 62 operations for pages 1 and 11.  (ETI)
Re Exhibit 26 and Exhibit 27:
Request No. 186:  Provide comparable hypothetical pages for Idaho-South Intrastate Title 62 operations.  (ETI)
Re page 16, lines 6 through 11:
Request No. 187:  Assuming that Title 62 services did not support Title 61 services, identify any and all pricing changes that U S WEST would make to its (a) residential and (b) business Title 62 services, and the date(s) that such changes would occur.  Explain fully.  (ETI)
Request No. 188:  When do you anticipate that (a) intraLATA presubscription, (b) number portability, and (c) unbundled network elements will be available in southern Idaho?  (ETI)
The following questions are directed to Ms. Owen:
Re page 14:
Request No. 189:  Identify (alphabetically) each wire center:
a.Where U S WEST has received a request for collocation, the date of such request, the number of Title 61 lines served by the wire center, and the number of Title 62 lines served by the wire center;
b.Where U S WEST is actually providing collocation, the date that such collocation commenced; the number of Title 61 lines served by the wire center, and the number of Title 62 lines served by the wire center.  (ETI)
The following question is directed to Mr. Easton:
Request No. 190:  U S WEST proposes to amortize its current depreciation reserve deficiency over a three year period, and this amortization is incorporated into U S WEST's proposal for a rate increase.  Does U S WEST propose to reduce its rates once the deficiency is completely amortized?  Explain fully.  (ETI)
Request No. 191:  Please answer the following question instead of Staff Audit Request No. 132:
a.In the 1995 financial statements contained in the 1996 proxy on page C-19 Employee-related expenses for 1995 were $3,341M and $3,215M for 1994 and $3,068M for 1993.  On page C-1 Communication Group employees were 50,825; 51,402; and 52,598 for 1995, 1994 and 1993, respectively.

The average employee-related expenses per employee would be:
1995  $3,341M ÷ 50,825 = 65,735
1994  $3,215M ÷ 51,402 = 62,546
1993  $3,068M ÷ 52,598 = 58,329
Why would the projected savings per employee as netted in your response to Staff Audit Request No. 74A use only $50,000 per employee rather than $65,700 per employee?
b.Also, in response to Staff Audit Request No. 74A the Idaho savings are reflected as $2.3M of a total of $250M or .92%.  Why wouldn't the 2.75% (average % of Idaho to total) be used?
c.For A and B above please show calculations used to support differences.  (KS3)
Request No. 192:  Please explain and document why there is a difference between the Pre-merger Funded Debt Call Premium amount of $147,165,465 used as the basis to adjust the test year shown in the workpapers/exhibits behind Tab 20 in Margaret Wright's testimony and the $125,272,486 difference between the MR Books and the FR Books for Account 1407 Unamortized Debt Issuance Expense as shown in response to Staff Audit Request No. 92.  (KS3/TC)
Request No. 193: Please provide the following information related to the Service Guarantee program:
a.A schedule showing the total actual amount of the credits issued during
1995 per service.
b.How are these credits booked? (i.e., to what accounts are they booked?)
c.If these credits are treated only as a billing credit, please explain why this procedure is used rather than booking the credit.
d.Please provide a copy of any Company Policy or Procedure Manual related to the accounting credits for this treatment.  (TC)
Request No. 194:  As follow-up to Staff Audit Request No. 34, please show the dollar amount by project number and provide a description for each project number with the rationale for allocating project costs:
a.directly related to Title 61 services;
b.related to both Title 61 and Title 62 services;
c.projects caused by combining Title 61 and Title 62 services;
d.projects that are research;
e.projects caused or required for reengineering; and
f.any other categories.  (MF)
Request No. 195:  As a follow-up to Staff Audit Request No. 70A, please provide:
a.a list of all legal cases filed by and against U S WEST in Idaho; and
b.rationale describing how these charges relate to Title 61.  (MF)
Request No. 196:  Please provide a detailed rationale describing the relationship to the southern Idaho Title 61 services to document why any legal costs other than those identified in the answer to Request No. 195 should be assigned to southern Idaho Title 61 services.  Provide detail by case.  (MF)
Request No. 197:  Please provide a list of properties included in rents charged or allocated to southern Idaho and the amount of rent charged to southern Idaho.  (KS3/MF)
Request No. 198:  As a follow-up to Staff Audit Request No. 35, please provide a copy of all workpapers supporting these rent allocation cost studies.  (KS3/MF)
Request No. 199: Please provide a copy of all leases of buildings the costs of which are allocated or charged to U S WEST Communications; at the minimum include the building location, name of affiliate, and cost per square foot and number of square feet leased.  (KS3/MF)
Request No. 200:  For account 6727 (Research and Development Expenses), please provide an analysis showing:
a. the FC & Expenditure type codes;
b.a brief discription of each item/project;
c.state whether the expense was directly assigned, allocated or
a charge from an affiliate and state the name of the affiliate;
d.provide source documentation for any items considered to be
a Title 61 expense, either allocated or directly assigned.  (MF)
Request No. 201: For account 6724 (Information Management Expense) please provide an analysis showing:
a.the FC & Expenditure type codes;
b.a brief discription of each item/project;
c.whether allocated or direct expended and if the charge was
from an affiliate, the name of the affiliate.
d.provide source documentation for any items considered to be
a Title 61 expense, either allocated or directly assigned.  (MF)
Request No. 202:  For account 6722 (External Relations Expense) please provide an analysis showing:
a.the FC & Expenditure type codes;
b.a brief discription of each item/project;
c.whether allocated or direct expended and if the charge was from
an affiliate, the name of the affiliate.  
d.provide source documentation for any items considered to be
a Title 61 expense, either allocated or directly assigned.  (MF)
Request No. 203: For account 6623 (Customer Services Expenses) please provide an analysis showing:
a.the FC & Expenditure type codes;
b.a brief description of each item/project;
c.whether allocated or direct expended and if the charge was
from an affiliate, the name of the affiliate.  
d.provide source documentation for any items considered to be
a Title 61 expense, either allocated or directly assigned.  (MF)
Request No. 204:  In reference to the answer for Audit Request No. 76A, please provide a detailed description of each category for Function Codes 300, 302, 304, and 305 in Account 6613.  
Please show the following information in a spreadsheet similar to the one attached (Attachment A).
For each Function Code, please provide a schedule showing the dollar amount of sales advertising for:
1.Title 61 products and/or functions;
2.Title 62 products and/or functions
3.Title 61/62 products and/or functions.   
For Function Code 300, please separate out the dollar amount of sales advertising by small business (5 lines or less) and by large business (6 lines or more).
For function codes 300 and 304, please provide a listing of:
1.The individual products  
2.A description of each product
3.The total dollar amount of each product type
4.Which products are considered Title 61 products?
5.Which products are Title 62 products?
6.Which products are Title 61/Title 62 products?  
For Function Code 300, please separate out by small business advertising dollars (5 lines or less) and by large business (6 lines or more).  If business advertising in Function Code 300 is not separated on a line basis, please describe and show how Title 61 small business services are separated from Title 61 large business services, and show how the calculation is performed.  For each type, i.e., small business or large business, separate out the advertising dollars by Title 61 products, Title 62 products, and Title 61/Title 62 products.
For all advertising costs assigned to Idaho Title 61 Services, please provide a copy of the billing invoice and a copy of the advertisements showing how it relates to Idaho Title 61 Services.  For television and radio advertisements, a copy of the script will serve as a copy of the advertisement.   (MF/KS2)
Request No. 205:  As a follow-up to Staff Audit Request No. 71C, please define “equity infusions” as used to calculate the numbers provided to Staff.  (MF/KS2)
Request No. 206:  For Account 6611 and Account 6612, please provide the details of all expenses directly charged or allocated to Idaho-South in 1995 by function code (FC) and Expenditure Type (EXTC) and supply a description for each function code and expenditure type.  (MF/KS2)
Request No. 207:  For Account 6611 and Account 6612, please provide a list and description of all products sold.  
1.Provide a detailed analysis showing these products;
2.the number of each product sold in Idaho;
3.the total revenue for each product sold in Idaho; and
4.the total revenue produced in Idaho for each product.
Also show the FC and EXTC code for each product.  Is any of this revenue a Title 61 revenue and/or included in the 61 revenue for this case?  If so, how much and what account is the revenue booked to.  Please explain the rationale behind characterizing the product as a Title 61 product, and the revenue as Title 61 revenue.  (MF/KS2)
Request No. 208:  In regard to Audit Request No. 84B, The Presidents Club, for the Presidents Club held in 1995, please identify how many participants were from Idaho-South.   For each participant from Idaho-South, please provide a copy of the completed nomination form (letter of recommendation, recommendation form or other form of nomination) used to elect that participant to the President’s Club.  The name of the person attending is not necessary and may be blocked out.    
For attendees not from Idaho for the 1995 President’s Club, please provide an explanation of why Idaho Title 61 services should receive an allocation of the expenses of those participants.  
From the attendees on Attachment D, Audit Request No. 84, provide a sample of participants in the following manner:
1.Sort alphabetically the names of the attendees by Organization for the following organizations:  Finance, Total Quality, Human Resources, Small Business Marketing, and Home and Personal, and Network.  
2.Pick the 7th name from Total Quality, every 12th name from Human Resources, every 33rd name from Finance, every 50th name from Network and Small Business Marketing, and every 99th name from Home & Personal Services.

For each name selected, supply a copy of the nomination form, a job description, and the name of the organization whence it came.  (MF/KS2)
Request No. 209:  For BRI show any service and the dollar amounts charged to USWC, Idaho and Idaho Intrastate related to re-engineering, business and government, and/or a Title 62 service as defined by Idaho law.  Show the USWC account(s) where the above service were charged.  (MF)
Request No. 210:  For U S WEST, Inc. show any service and the dollar amounts charged to USWC,  Idaho and Idaho Intrastate related to re-engineering, business and government, and/or a Title 62 service as defined by Idaho law.  Show the USWC account(s) where the above service were charged.  (MF)
Request No. 211:  For U S WEST AT show any service and the dollar amounts charged to USWC, Idaho and Idaho Intrastate related to re-engineering, business and government, and/or a Title 62 service as defined by Idaho law.  Show the USWC account(s) where the above service were charged.  (MF)
Request No. 212:  For Bellcore show any service and the dollar amounts charged to USWC, Idaho and Idaho Intrastate related to re-engineering, business and government, and/or a Title 62 service as defined by Idaho law.  Show the USWC account(s) where the above service were charged.  (MF)
Request No. 213:  The following Staff Audit Requests have either no response as yet or only a partial response.  Please provide the IPUC Staff with a complete response to each audit request:
Request No.  DateRequest No.Date
367/29/961279/13/96
728/22/961299/18/96
808/27/961309/18/96
849/05/961319/20/96
879/10/961339/23/96
899/11/961349/23/96
959/11/961359/27/96
969/09/961369/27/96
989/10/961379/27/96
999/10/9613810/07/96
1049/11/96
1079/11/96
1129/11/96
1209/12/96
1239/12/96
1249/13/96
1259/13/96
Request No. 214:  What is USW's official policy on offering optional services to toll restricted and full toll denied customers.  (CJC)
Request No. 215:  Telephone customer relations rules (IDAPA 31.41.01.601.03) provide that each customer who wishes their name, address or telephone number to be listed in the white pages of the directory must be given one free listing.  What is USW's definition of an address?  Does USW consider an apartment number or suite number to be a part of the address?
a.Please give two examples of “Informational Listing” as provided in USW Exchange and Network Services Catalog Section 5.7.1. b.  (CJC)
Request No. 216:  What is the total number of USW directory assistance calls by month for the years 1985 through 1994?  What was the monthly revenue collected during this same period?  When did the calling allowances change?  When did the price-per-call changes occur?  (CJC)
Request No. 217:  The access data provided in response to Staff Question 38-D included data for “RMC/BSC” and “CSRA/RAL”, but did not include data for the Credit Management Center (CMC) and possibly other offices to which customers may be routed should they call
U S WEST about a service, billing, credit or repair concern.  The Monthly Access Report provided to Staff as an Excel file last year includes monthly data for nearly 50 different “centers.”  (A section of that report is provided for clarification.)  Please provide this level of detail for all possible locations to which a caller to U S WEST may be routed for each month in 1995, as well as all months for which data may be available for 1996.  (WH)
Request No. 218:  Please provide information as to the amount of money collected from Title 61 customers for the payment of non-recurring zone connection charges identified in Section 4.2.1 of the Exchange and Network Services Catalog or 4.2.1 of the Basic Local Exchange Tariff for each year from 1990 through 1995.  Please provide this same information regarding the amounts collected from Title 62 customers for similar construction charges that apply to those customers.  (WH)  
Request No. 219:  For how many access lines, by year for the years 1990 through 1995, and by exchange, were zone connection charges collected at the rate for a single zone.  How many paid the rate for two zones, three, four, five or additional zones?  (WH)
Request No. 220:  Please identify, by year for the years 1990 through 1995, and by exchange, the number of access lines located in the base rate area at the end of the year.  Provide the same information for Zone 1, Zone 2, Locality Rate Area 1, Locality Rate Area 2, Suburban Rate Area 1, Suburban Rate Area 2, etc.  (WH)
Request No. 221:  U S WEST was reported as implementing a trial of a block for international calls for their customers in the State of Minnesota.  Has it been completed?  Have any reports been prepared identifying the Company’s experiences with that trial?  Has the
Company considered providing Idaho customers with a similar block?  If not, why not?  If so, what are the results of that consideration?  (WH)  
Request No. 222:  Please provide any studies or other evidence that would measure or quantify the difference in the average load placed upon switches and other network facilities by measured service lines in comparison to flat rate service lines.  Provide such information for both residential and business lines.  (WH)
Request No. 223:  Does the Company have any studies or other evidence that the use of on-line services, fax machines, the Internet, or other data transmission applications are having an impact on the number of lines that can be accommodated by various elements of the network?  If so, please provide such evidence.  (WH)
Request No. 224:  Does the Company have the facilities to measure “incoming” as well as “outgoing” calls?  If so, would there be an incremental cost of measuring incoming calls or minutes, and if so, what would it be, on a per line basis?  If not, what would be required to obtain such facilities?  (WH)   
Request No. 225:  Please identify the number of instances, for both business and residential, where measured service has been provided to an address that has two or more lines of service at the same address.  For both residential and business accounts, please identify the number of these instances where the other service is flat rate, and the number of instances where the other service is measured.  Please provide an itemization of the number of lines by type of service, at each address with measured service where a total of five or more lines of either flat rate or measured service have been provided.  (WH)   
Request No. 226: Of the total amount of uncollectible revenue for the 1995 test year, how much, expressed as a percent of the total, is for basic local service, how much is for advanced or optional services, and how much is for toll?  What was the percentage in 1990?  What was it in 1980?  (WH)
Request No. 227:  How many claims for service under the Linebacker Program were requested in 1995?  How many were denied because the inside wiring had not been performed by U S WEST?  How many were denied because wiring originally installed by U S WEST had been modified or changed by someone other than U S WEST?  (WH)
Request No. 228:  Please provide the total number of primary listings in directories for southern Idaho for the 1995 test year.  Also, please provide the quanities for the following USOCs:  CLT, RLT, NLYXA, RNCAF, LBS, LRS, FAL, NLYXB, RAXID, XLL, NLYXC, L96, 9FK, SZS.  (JWC)
Request No. 229:  Provide the number of business customers, as of December 31, 1995, by class of service, who have:
a.one additional line;
b.two additional lines;
c.three additional lines;
d.four additional lines;
e.five additional lines; and
f.more than five additional lines.  (BE)
Request No. 230:  In USW's response to STF01-032, there is a notation that “quantities factored to .92 to reflect orders with two or more access lines.”  Provide documentation for the derivation of the .92 factor used to reduce average monthly quantities for non-recurring residential charges as they moved from $30 to $31.  What percentage of residential customers currently order two or more lines?  (BE)
The following questions are directed to Mr. Easton:
Request No. 231:  The following questions are in reference to page 23 of Mr. Easton's direct testimony:
a.To the extent not already provided in response to Staff Production
Request No. 125, what is USWC's time horizon for planning of digital switching technology deployments in southern Idaho?
b.To the extent not already provided in response to Staff Production
Request No. 125, provide USWC's current technology deployment plan that identifies all planned switch installations, replacements, or upgrades in southern Idaho, together with all available data regarding current (if any) and proposed switching machine type, office name and location identifier (CLLI), scheduled cut-over date, number of access lines, and total project cost.  
c.To the extent not already provided in response to Staff Production
Request No. 125, provide all studies, reports, memoranda, or other analyses prepared by USWC using capital utilization criteria (CUCRIT) or similar cost-benefit study methods that support the Company's planned switch installation, replacement, or upgrade projects in southern Idaho.
d.Provide the most recently prepared Demand and Facilities charts for each central office in southern Idaho for which USWC has planned a switch installation, replacement, or upgrade project.  (ETI)
Request No. 232:  The following questions are in reference to pages 26-27 of Mr. Easton's direct testimony:
a.What is USWC's time horizon for planning of digital circuit equipment technology deployments in southern Idaho?
b.Provide USWC's current technology deployment plan that identifies all planned digital circuit equipment installations, replacements, or upgrades in southern Idaho.  If not already specified in the technology deployment plan, provide the following data for each interoffice route for which digital circuit equipment installation is planned through the Company's time horizon (see prior question, or use the year 2000 as a default): facilities location/route, scheduled cut-over date, total usable capacity to be installed (in voice grade equivalent circuits) and total capital expenditures.
c.Provide all studies, reports, memoranda, or other analyses prepared by USWC using capital utilization criteria (CUCRIT) or similar cost-benefit study methods that support the Company's planned digital circuit equipment installations in southern Idaho.  (ETI)
The following questions are directed to Mr. Easton, in reference to Exhibit No. 19 (USWC 1996 Depreciation Rate Study) and supporting documents:
Request No. 233:  Please provide copies of the following Technology Futures, Inc. (TFI) studies referenced on page 14, footnote 10 of the General Methods narrative of
U S WEST Communications, Inc. (USWC) 1996 Depreciation Rate Study:
a.New Telecommunications Services and the Public Telephone Network (1993);
b.Average Projection Lives of Digital Switching and Circuit Equipment (1993);
c.Personal Communications (1993);
d.Transforming the Local Network (1994).  (ETI)
Request No. 234:  Please provide copies of all workpapers and analyses developed by, or on behalf of, TFI that support the findings made in the TFI studies referenced by USWC:
a.New Telecommunications Services and the Public Telephone Network (1993);
b.Average Projection Lives of Digital Switching and Circuit Equipment (1993);
c.Personal Communications (1993);
d.Transforming the Local Network (1994).  (ETI)
Request No. 235:  Please provide copies of all other TFI studies that USWC has relied upon in support of its 1996 Depreciation Rate Study, excepting the TFI 1995 study, Depreciation Lives for Telecommunications Equipment contained in Exhibit No. 20 to Mr. Easton's testimony.  (ETI)
Request No. 236:  Please provide copies of all workpapers and analyses developed by, or on behalf of, TFI that support the findings made in each TFI study supplied in response to Question No. 233.  (ETI)
Request No. 237:  With reference to page 11 of the TFI 1995 study, Depreciation Lives for Telecommunications Equipment, provide all comparisons of prior forecasts to actuals that TFI has prepared to validate the accuracy of the Fisher-Pry Model as applied to telecommunications technology substitution.  In addition, provide all similar analyses that USWC has prepared for the same purpose.  (ETI)
Request No. 238:  Please identify any and all other state regulatory commissions which have accepted, in whole or in part, USWC proposals for revised account lives and depreciation lives which are based on any of the TFI studies supplied in response to Question Nos. 233 and 234 above.  For each case that you identify, supply the docket number, decision number, and date of the commission order adopting the proposal, and provide a copy of the order.  (ETI)
Request No. 239:  Please identify any and all other state regulatory commissions that USWC is aware of which have accepted, in whole or in part, ILEC proposals for revised account lives and depreciation lives which are based in whole or in part on the Fisher-Pry technology substitution method.  For each case that you identify, supply the docket number, decision number, and date of the commission order adopting the proposal, and provide a copy of the order.  (ETI)
Request No. 240:  Provide a copy of each study, report, or analysis performed by, or on behalf of, USWC or TFI, that specifically examined the conditions pertaining in southern Idaho pertaining to the following depreciation parameters.  For each study, report, or analysis, indicate the pages therein which make specific, explicit, reference to Idaho conditions.
a.Historical life indications for accounts 2211.0, 2212.0, 2232.0, 2232.0, 2421.0, 2422.0, and 2423.0;
b.Historical life indications for all other accounts in the 1996 Depreciation Rate Study;
c.Life projections for accounts 2211.0, 2212.0, 2232.0, 2232.0, 2421.0, 2422.0, 2423.0;
d.Life projections for all other accounts in the 1996 Depreciation Rate Study;
e.Future net salvage values for accounts 2211.0, 2212.0, 2232.0, 2232.0, 2421.0, 2422.0, and 2423.0; and
f.Future net salvage values for all other accounts in the 1996 Depreciation Rate Study.  (ETI)
Request No. 241:  To the extent not already provided in response to Staff Production Request No. 134, provide a copy of each study, report, or analysis performed by, or on behalf of, USWC or TFI, that specifically examined the current and/or anticipated future demand for the following services in southern Idaho.  For each study, report, or analysis, indicate the pages therein which make specific, explicit, reference to Idaho conditions.
a.Frame Relay services;
b.Video dial tone services;
c.Vertical services, including caller identification and other SS7-based services;
d.Fractional T-1;
e.Internet access services; and
d.Other new services for which USWC expects significant demand.  (ETI)
Request No. 242:  For each study, report, or analysis provided in response to Question No. 238 above, explain in detail how, if at all, that material was used to develop and/or support the Company's depreciation proposals for southern Idaho contained in the 1996 Depreciation Rate Study.  (ETI)
Request No. 243:  Refer to the 1996 Depreciation Rate Study, Account 2211 detail, pages 13-14 ("Planned Retirements for Retirement Period 1996-1998), provide the following:
a.State the actual replacement switch cut-over date for each switch replacement/retirement shown scheduled for 1996;
b.Update the remainder of the "Planned Retirements" table to show the current status and schedule of these projects;
c.Provide the documentation that USWC management relied upon to approve the installation of the replacement switching equipment identified therein (see last column) as associated with each analog switch retirement; and
d.Provide all studies, reports, memoranda, or other analyses prepared by USWC using capital utilization criteria (CUCRIT) or similar cost-benefit study methods that support the Company's decisions to undertake the switch replacement projects identified therein.  (ETI)
The following questions refer to the General Methods narrative of USWC's 1996 Depreciation Rate Study.
Request No. 244:  Refer to the Digital Switching — Switch Replacements discussion appearing on page 15 of the narrative.  
a.Provide all studies, reports, memoranda, or other analyses supporting USWC's claim that "[c]apacity has increased dramatically for the 5ESS and DMS100;"
b.Provide the Company's most recent numerical estimates of the increase in capacity for the 5ESS and DMS100, indicating the time frame (e.g., 1988-1995), units of measurement (e.g., BHCA, processor msec, etc.), and specific machine types assumed for development of those estimates;  
c.Provide all studies, reports, memoranda, or other analyses supporting USWC's claim that "[s]witch prices continue to decline — Almost a 50% decrease in costs."
d.Indicate the time frame (e.g., 1988-1995) and units of measurement (e.g., BHCA) assumed for development of those estimates;
e.Provide all studies, vendor quotations, or other analyses supporting the original supplier cost and new supplier cost estimates for the Centralia and Sequim exchanges that are referred to on page 15;
f.Provide all studies, reports, memoranda, or other analyses prepared by USWC using capital utilization criteria (CUCRIT) or similar cost-benefit study methods that support the Company's decision to undertake the Centralia and Sequim, Washington, switch replacement projects;
g.Provide all studies, reports, memoranda, or other analyses supporting USWC's claims of "[operational and maintenance costs reduction;"
h.Indicate the time frame (e.g., 1988-1995) and units of measurement (e.g., BHCA) assumed for development of those estimates;
i.Provide all studies, reports, memoranda, or other analyses supporting USWC's claims that "[d]istance capabilities have increased between host and remote location;" and
j.Provide USWC's current planning guidelines that specify the maximum distances at which a remote switching unit may be placed from its associated host switch.  (ETI)
Request No. 245:  Refer to the Digital Switching — Declining Cost of Digital Switching discussion appearing on page 16 of the narrative.  
a.Provide all studies, reports, memoranda, or other analyses supporting USWC's claim that "[n]ew switch investment per access line is half what it was eight years ago."
b.Provide a table specifying all numerical values appearing in the graph "Digital Switch Investment / Access Line" on page 16, and indicate the source of each number.
c.Provide a version of the graph "Digital Switch Investment / Access Line" appearing on page 16 that is specific to USWC's southern Idaho territory, together with a table of numerical values and sources as supplied in response to part (b) above.
d.Provide all studies, reports, memoranda, or other analyses supporting USWC's claim that new digital switches provide "greater functionality and operational efficiencies" compared to older digital switches.  
e.Specify the machine types that USWC considers to be defined as "new" and "older" digital switching equipment, respectively, in the context of the prior statement.  (ETI)
Request No. 246:  Refer to the Digital Switching — Ongoing Switch Evolution discussion appearing on pages 17-18 of the narrative.  
a.Refer to table "Industry-Wide — ARL Development for Digital Switching" on page 18.  Is this table derived directly from Exhibit 12, page 30 of the TFI study, Depreciation Lives for Telecommunications Equipment?  If not, explain fully all adjustments that USWC made to the Exhibit 12 table to produce the table appearing on page 18.
b.Exhibit 12 is referred to as a "summary" of the TFI analysis (TFI study, page 29); provide all workpapers and analyses prepared by, or on behalf of, TFI which support Exhibit 12.  (ETI)
Request No. 247:  Refer to the Digital Switching — ATM Broadband Switching discussion appearing on pages 18-19 of the narrative.  
a.Refer to table "Industry Forecast of ATM Adoption - Percentage of Access Lines" on page 19.  Is this table derived directly from the data appearing on Exhibit 13, page 32 of the TFI study, Depreciation Lives for Telecommunications Equipment?  If not, explain fully all adjustments that USWC made to the Exhibit 13 table data to produce the graph appearing on page 18.
b.Provide the specific Fisher-Pry model equations and parameters used to generate the data appearing in the ATM Adoption forecast graph on
page 19.
c.Has USWC or TFI prepared a forecast of ATM Switching adoption specific to USWC's combined service territory?  If so, please provide that forecast, together with all supporting workpapers.
d.Has USWC or TFI prepared a forecast of ATM Switching adoption specific to the Company's southern Idaho territory?  If so, please provide that forecast, together with all supporting workpapers.
e.Has USWC prepared, or had prepared at its behalf, any analyses of the economics of migration to ATM Switching technology, using capital utilization criteria (CUCRIT) or other cost-benefit study methods?  If so, please provide all such studies, together with all supporting workpapers, prepared within the past three years.  (ETI)
Request No. 248:  Refer to the Circuit Equipment — Analog Circuit discussion appearing on pages 19-20 of the narrative.  
a.Identify the specific fiber and SONET ADM placements that USWC has undertaken in southern Idaho in the 1995-present time frame that have resulted in retirements of interoffice analog circuit facilities.  Include as part of your response the project start date and date of completion, affected facilities locations and routes, total capital expenditures, and total usable capacity installed on each affected route (in voice grade equivalent circuits).  Also, provide the following data with respect to the analog circuit plant retired as a result of the new facilities placements:  total analog circuit plant retired (gross dollars), original date of installation, and the total usable capacity of the analog circuit equipment taken out of service on each affected route (in voice grade equivalent circuits).
b.Did USWC perform any analyses using capital utilization criteria (CUCRIT) or similar cost-benefit study methods to support the projects identified in response to part (a)?  If so, please provide all such analyses together with all supporting workpapers.
c.Identify the specific fiber and SONET ADM placements that USWC plans to undertake in southern Idaho through 1998 that will result in retirements of interoffice analog circuit facilities.  Include as part of your response the planned project completion date, affected facilities locations and routes, total planned capital expenditures, and total usable capacity to be installed on each affected route (in voice grade equivalent circuits).  Also, provide the following data with respect to the analog circuit plant that will be retired as a result of the new facilities placements:  total analog circuit plant to be retired (gross dollars), original date of installation, and the total usable capacity of the analog circuit equipment to be taken out of service on each affected route (in voice grade equivalent circuits).
d.Has USWC performed any analyses using capital utilization criteria (CUCRIT) or similar cost-benefit study methods to support the projects identified in response to part (c)?  If so, please provide all such analyses together with all supporting workpapers.
e.Identify the retirements of USWC analog circuit equipment in southern Idaho that will result from the planned retirements of analog switches indicated in 1996 Depreciation Rate Study, Account 2211 detail, pages 13-14 ("Planned Retirements for Retirement Period 1996-1998").  Include as part of your response the following date regarding the planned replacement circuit equipment:  project completion date, affected facilities locations and routes, total planned capital expenditures, and total usable capacity to be installed on each affected route (in voice grade equivalent circuits).  Also, provide the following data with respect to the analog circuit plant that will be retired as a result of the new facilities placements:  total analog circuit plant to be retired (gross dollars), original date of installation, and the total usable capacity of the analog circuit equipment to be taken out of service on each affected route (in voice grade equivalent circuits).
f.Has USWC performed any analyses using capital utilization criteria (CUCRIT) or similar cost-benefit study methods to support the projects identified in response to part (e)?  If so, please provide all such analyses together with all supporting workpapers.
g.Refer to page 20: does USWC agree with TFI that "the analog switching account would be a good surrogate for estimating the life expectancy of analog circuit equipment"?  Provide all of the evidence that USWC relies upon to support this assessment.  (ETI)
Request No. 249:  Refer to the Circuit Equipment — Digital Circuit discussion appearing on pages 20-22 of the narrative.  
a.Please provide the Company's current deployment plan for broadband facilities.
b.Please explain in detail how the "deployment of the company broadband strategy" is driving the replacement of existing digital circuit equipment through the year 2000.  In your response, identify the specific interoffice routes in southern Idaho that will undergo such replacements in order to permit USWC to make broadband services available in the state.
c.Identify by vendor and equipment type the specific "older vintage digital pair gain systems that are not compatible with ISDN deployment."  In addition, specify the interoffice routes in southern Idaho on which all such facilities are currently installed.
d.Provide a table specifying all numerical values appearing in the graph "Western Region Digital Interoffice Links" on page 21, and indicate the source of each number.
e.Provide a version of the graph appearing on page 21 that is specific to USWC's southern Idaho territory, together with a table of numerical values and sources as supplied in response to part (d) above.  (ETI)
Request No. 250:  Refer to the "Industry Forecast Non-SONET Circuit Equipment Survivors" graph appearing on page 22 of the narrative.  
a.Is this graph derived directly from the data appearing on Attachment 3 to the TFI study, Depreciation Lives for Telecommunications Equipment?  If not, provide the source data used to produce the graph appearing on page 22.
b.Provide the specific Fisher-Pry model equations and parameters used to generate the data appearing in the graph on page 22.
c.Has USWC or TFI prepared a forecast of SONET technology adoption, and/or non-SONET circuit equipment survivors, that is specific to USWC's combined service territory?  If so, please provide that forecast, together with all supporting workpapers.
d.Has USWC or TFI prepared a forecast of SONET technology adoption, and/or non-SONET circuit equipment survivors, that is specific to the Company's southern Idaho territory?  If so, please provide that forecast, together with all supporting workpapers.
e.Has USWC prepared, or had prepared at its behalf, any analyses of the economics of migration to SONET technology, using capital utilization criteria (CUCRIT) or other cost-benefit study methods?  If so, please provide all such studies, together with all supporting workpapers, prepared within the past three years.  (ETI)
Request No. 251:  Refer to the Metallic Cable discussion appearing on pages 22-25 of the narrative.  
a.Does the U S WEST Network 21 program referenced at page 22 include plans to deploy facilities in any exchanges in southern Idaho?  If so, please identify those exchanges and describe in detail the specific deployment plans made therein.
b.Does the Self-Healing Loop Modernization Project referenced at page 23 include plans to deploy facilities in any exchanges in southern Idaho?  If so, please identify those exchanges and describe in detail the specific deployment plans made therein.
c.Please describe in detail any other modernization programs that USWC has committed to that will result in retirements of metallic cable facilities in southern Idaho.  In your response, include the project name, start and completion dates, purpose, and total capital expenditures.
d.Does ISDN technology require fiber transmission facilities to be used in any portion of the USWC network over which ISDN services are provided?  If so, explain fully how and were ISDN requires the use of such facilities.
e.Does ADSL technology require fiber transmission facilities to be used in any portion of the USWC network over which services using ADSL are provided?  If so, explain fully how and were ADSL requires the use of such facilities.
f.Provide all studies, reports, analyses, and/or memoranda prepared by, or on behalf of, USWC within the past three years that compare the annual recurring operating expenses (including, but not limited to, maintenance and repair expense) for copper feeder plant versus fiber feeder plant.
g.Provide all studies, reports, analyses, and/or memoranda prepared by, or on behalf of, USWC within the past three years that compare the annual recurring operating expenses (including, but not limited to, maintenance and repair expense) for copper distribution plant versus fiber distribution plant.  (ETI)
Request No. 252:  Refer to the "Industry Forecast Metallic Cable Survivor" graph appearing on page 24 of the narrative.  
a.Please indicate the source, and provide the source data used to produce the graph appearing on page 24.
b.Provide the specific Fisher-Pry model equations and parameters used to generate the data appearing in the graph on page 24.
c.Is the graph on page 24 specific to the feeder portion of the loop, the distribution portion of the loop, or combined feeder and distribution facilities?  In your response, assume that the terms "feeder" and "distribution" have the same meanings as they were used by USWC on
page 22.
d.Has USWC or TFI prepared a forecast of fiber cable adoption, and/or metallic cable survivors, that is specific to the distribution portion of the
loop?  If so, please provide that forecast, together with all supporting workpapers.
e.Has USWC or TFI prepared a forecast of fiber cable adoption, and/or metallic cable survivors, that is specific to USWC's combined service territory?  If so, please provide that forecast, together with all supporting workpapers.
f.Has USWC or TFI prepared a forecast of fiber cable adoption, and/or metallic cable survivors, that is specific to the Company's southern Idaho territory?  If so, please provide that forecast, together with all supporting workpapers.
g.Has USWC prepared, or had prepared at its behalf, any analyses of the economics of migration to fiber technology, using capital utilization criteria (CUCRIT) or other cost-benefit study methods?  If so, please provide all such studies, together with all supporting workpapers, prepared within the past three years.  (ETI)
Request No. 253:  Refer to the Fiber Cable discussion appearing on pages 25-26 of the narrative.  
a.Provide all studies, reports, analyses, and/or memoranda prepared by, or on behalf of, USWC relied upon in the development of the discussion of fiber cable life indications appearing in the last five paragraphs of this section (beginning "The composition of fiber..." and ending "...for all fiber accounts.").
The following are general questions and, as such, are not directed to a specific witness.
Request No. 254:  Provide the additions, retirements and ending balance in Idaho (equivalent to that reported in ARMIS Report 43-02, Table B1) for 1989-1995 (EOY), by year, for the following two accounts:
a.Digital Electric Switch (ARMIS Account 2212)
b.Cable and Wire (ARMIS Account 2410)  (ETI)
Request No. 255:  Provide the maintenance expense in Idaho for 1989-1995 (EOY), by year, for the following categories (Statistics of Communications Common Carriers (SOCC) Account Reference provided):
a.CO Switching (Acct. 6210)
b.Operator Systems (Acct. 6220)
c.CO Transmission (Acct. 6230)
d.Information Orig./Term. (Acct. 6310)
e.Cable and Wire (Acct. 6410)
f.Other Property, Plant and Equipment (Acct. 6510)
g.Network Operations (Acct. 6530)
h.Access (Acct. 6540)  (ETI)
Request No. 256:  An actual percentage of Idaho uncollectibles to revenues has been used for Revenue Sharing.  The 1995 Revenue Sharing Report shows the 1995 uncollectible ratio as 0.4403%.  (TC)  
a.Please explain why U S WEST used a different number for uncollectibles in the USW-S-96-5 rate case?
b.Please reconcile the difference between the 0.7497% used in USW-S-96-5 and the 1995 revenue sharing uncollectible ratio of 0.4403%.
Request No. 257:  Please provide a schedule showing how much revenue was recorded for billing and collection for the 1995 test year.
a.To which accounts are these revenues booked?
b.Please provide documentation showing the amount per bill charged
for billing and collection services.
c.How much is the total billing and collection expense amount during 1995?
d.How many bills were prepared during 1995?
e.Provide documentation by service and USOA account.  (TC)
Request No. 258:  Please provide by exchange for the exchanges of NuAcres, Arco, Mackay, Malad, Council, Ashton, Island Park, St. Anthony, Stanley, Oakley, Paris and Driggs the following information:
a.A complete list of all assets sold or to be sold.
b.The corresponding plant-in-service amounts as of
December 31, 1995.
c.The associated accumulated depreciation as of
December 31, 1995.  (TC)
Request No. 259:  Please provide at the total Idaho level the following:  rate base, revenue, and expenses related to the proforma adjustment by Margie Wright for the sale of exchanges adjustment.  (TC)
Request No. 260:  Please provide a reconciliation schedule with supporting documentation showing the differences in Intrastate revenues, expenses and jurisdictional plant in service numbers in the exhibits and workpapers of Margie Wright and Dallas Elder.
Please provide corrected schedules showing the corrected starting point for Intrastate Southern Idaho exhibits.  (TC)  
Request No. 261:  Please provide a copy of the allocations for U S WEST Direct’s 1995 revenue and expenses for Idaho and other states served by USWC.  Provide all workpapers.  (Reference allocation supplied in Oregon, UT 125, PUC 53-001, Doc. # 118190.)  
Request No. 262:  Please provide a complete and recent copy of the Rates and Data Book of the Yellow Pages Publishers Association.  (TC)
Request No. 263:  Please provide a schedule of rate indices showing trends in
U S WEST Direct’s advertising rates in Idaho over the past ten years.  (TC)
Request No. 264:  Please provide a complete set of U S WEST Direct’s rate schedules applicable to Idaho as of January 1, 1995 and January 1, 1996.  (TC)
Request No. 265:  Please make available for review in Boise, Idaho the following:
a.The Yellow Pages Market Forecast prepared by Communications
Trends, Inc. for 1994, 1995 and 1996.
b.The Yellow Pages and Directory Report for 1994 and 1995.
c.Studies showing the extent of competition in yellow pages
markets in Idaho.
d.Copies of all License Agreements signed by unrelated third parties
obtaining white pages listings for other directories in Idaho.
e.Copies of Agreements between U S WEST Communications and U S WEST Direct showing the terms of providing white pages listings to U S WEST Direct for Idaho directories.  (TC)
Request No. 266:  Please provide a schedule showing the revenues received for white pages listings; include at least the revenues per purchasing entity, total number of white page listings purchased, total revenues received and the accounts where these revenues are booked.  Are these revenues directly assigned to Idaho?  (TC)
Request No. 267:  Please provide a schedule showing the revenues received for yellow pages billing and collection charges and the accounts where these revenues are booked.  Are these revenues directly assigned to Idaho?  (TC)
Request No. 268:  Please provide a schedule showing U S WEST Direct’s net income, average equity and return on equity for 1989 through 1995 and 1996 to date.  (Reference Oregon Data Request PUC 60-010, Doc.  ID# 118339.)  (TC)
DATED  at Boise, Idaho, this            day of October 1996.
______________________________________
Donald L. Howell, II
Deputy Attorney General
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