USWS965v5.docx

DONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
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
FIFTH 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 MONDAY, FEBRUARY 10, 1997.
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.  The reference to Company witnesses and page numbers refer to rebuttal testimony.
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.
The information requested in the following Production Request Nos. 276 through 304 are to be made available in Denver to Staff auditors beginning February 3 and continuing until February 6, 1997.   
Request No. 276:  Please provide a schedule of the use of each capital lease included in account 2681.  (Darlene Danyo from Denver agreed to prepare this schedule.)  (SL)
Request No. 277:  Please provide audit workpapers and reports from Coopers and Lybrand related to the review of U S WEST’s Cost Allocation systems and practices.  (SL)
Request No. 278:  Please provide back up information related to a statement made by Margie Wright in rebuttal testimony to the effect that 62% of USWC expenses are directly assigned to state.  (Testimony page 9, line 6).  (SL)
Request No. 279:  Please provide back up information, procedures, terminology definitions, and specific accounts involved relating to the schedule of amounts and information at the top of page 10 of Margie Wright’s rebuttal testimony.  (SL)
Request No. 280:  Please provide back up information related to Pro Forma adjustments with specific attention to Adjustment No. 18 (p. 22, line 12) as well as the other depreciation issues discussed on pages 22-24 by Margie Wright.  (SL)
Request No. 281:  Related to RUC adjustments, of the entries that adjusted the sub ledger during the year 1995 that related to the RUC adjustment for 1994.  Please provide a copy
of the entries that adjusted the sub ledger during 1996 that related to the RUC adjustment for 1995.  (SL)
Request No. 282:  Please provide information explaining the calculation of the gross up factor, the Idaho effective tax rate, and the income taxes previously recorded and identify a person that would be available to discuss this issue during the Staff audit.  (SL)
Request No. 283:  Please provide information explaining the amortization of the capitalized leases and identify a person that would be available to discuss this issue during the Staff audit.  (SL)
Request No. 284:  Please provide all data explaining the calculation of the gross receipts tax and the uncollectibles as used in the calculation of the gross up factor and identify a person that would be available to discuss this issue during the Staff audit.  (SL)
Request No. 285:  Please provide all data explaining the calculation and recording of deferred income tax related to the Pension Asset and identify a person that would be available to discuss this issue during the Staff audit.  (SL)
Request No. 286:  Please provide an explanation and calculation of the credit posted to any account for the pension asset.  List of the years any credit was posted and the amount posted each year.  (SL)
Request No. 287:  Please provide all data explaining revenue posting related to PAL lines and coin revenue as well as the posting of general revenue and identify a person that would be available to discuss this issue during the Staff audit.  (SL)
Request No. 288:  Please explain or make Dallas Elder available to explain abbreviations used in the CAM and reports related to the CAAS / CARS system.  (SL)  
Request No. 289:  Please provide a copy of the CASB manual with
pronouncements.  (SL)
Request No. 290:  Please provide copies of Staff's previous audit requests with
answers in this case.  (SL)
Request No. 291:  Please provide general ledgers for USWC and Idaho
jurisdictional.  (SL)
Request No. 292:  Plummer page 5
Please provide the corrected data that should have been reflected on the ARMIS operating data report for the period January 1995 to December 1995 related to Table 1-A. (Outside Plant Statistics - Cable and Wire Facilities).  Provide copies of Table 1-A for calendar years 1994 and 1996.
Request No. 293:  Wright
For  BRI and Inc., please make available a person at each organization to discuss their chart of accounts, the RC coding, the grouping of costs into RC codes and the allocation of the total costs.  (MF)  
Request No. 294:  Wright
Please  provide budgets for 1995 for BRI and Inc. at each organization including, studies for the allocations and all backup documentation used in determining the 1995 allocation of costs.  (MF)
Request No. 295: Wright
Please provide total cost for BRI and Inc. that went into each billing cycle, all billing from each cycle to affiliates for 1995 costs.  (MF)    
Request No. 296:  Wright
For BRI and Inc., please make available payroll documentation that shows how each person's pay is to be allocated to an Reporting Code (RC).  (MF)

Request No. 297:  Wright
For BRI, please provide documentation that shows how regional costs are gathered and what that information is used for and if that information is then transmitted to USWC in any form.  (MF)

Request No. 298:  Wright
Please show how USWC used all “regional information” from BRI and provide documentation.  (MF)   
Request No. 299:  Wright
At USWC, for each billing from BRI, Inc.,  AT, and BC, provide information showing how that billing was booked to USWC.  If any adjustments and/or reclassifications were made to the original booking at any time of the year please provide a copy of the adjusting entry.  (MF)
Request No. 300:  Plummer page 4
Please provide copies of the most recent ARMIS reports for 1994, 1995,
and 1996.  (TC)
Request No. 301:  Plummerpage 4
Please provide and make available copies of any and all correspondence, reports and workpapers provided to or received from the FCC related to the 1994, 1995, 1996 ARMIS reports.  (TC) (SL)
Request No. 302:  Plummerpage 5, lines 12-13
Please provide workpapers showing the calculation of lit fiber as of
January 7, 1997.  (TC) (SL)
Request No. 303:  Gobat, Wright
Please provide the cost/benefit analyses that show the benefits from each incentive program described by U S WEST witnesses Gobat in Exhibit No. 36 exceeded the cost for that program.  (TC)
General production requests
Elder
U S WEST has raised the issue of the feasibility of adopting Staff recommendations given the nature of the CAAS system in its present form.
Request No. 304:  Elder
Setting aside the merits of such an exercise, please run the CAAS to reflect the allocation of 39% of the intrastate local loop investment (after the assignment of 15% of local loop to toll/switched access) to Title 61/62 based upon the following ratio:
Title 61: 25%; Title 62: 75%
Provide any and all assumptions.  Based upon this scenario (and making no other changes relative to the Company's proposal), provide revised tables that correspond with the tables shown in Schedule 1 of Ms. Baldwin's Exhibit 113.  (BE/ETI)
Request No. 305:  Elder
Setting aside the merits of such an exercise, please run the CAAS to reflect the allocation of 39% of the intrastate local loop investment (after the assignment of 15% of local loop to toll/switched access) to Title 61/62 based upon the following ratio:
Title 61: 45%; Title 62: 55%
Provide any and all assumptions.  Based upon this scenario (and making no other changes relative to the Company's proposal), provide revised tables that correspond with the tables shown in Schedule 1 of Ms. Baldwin's Exhibit 113.   (BE/ETI)
Request No. 306:  Elder
Setting aside the merits of such an exercise, please run the CAAS to reflect the following modification:
● Assign 5% of the local loop directly to Title 62 (in addition to the 15% to Title 62 for toll/switched access).
Provide any and all assumptions.  Based upon this scenario (and making no other changes relative to the Company's proposal), provide revised tables that correspond with the tables shown in Schedule 1 of Ms. Baldwin's Exhibit 113.   (BE/ETI)
Request No. 307:  Elder
Setting aside the merits of such an exercise, please run the CAAS to reflect the following modifications:
● Assign 5% of the local loop directly to Title 62 (in addition to the 15% to Title 62 toll/switched access).
●Reflect the allocation of 39% of the intrastate local loop investment (after the assignment of 15% of local loop to toll/switched access and 5% of the local loop to Custom Calling/CLASS) to Title 61/62 based upon the following ratio:
Title 61: 25%; Title 62: 75%
Provide any and all assumptions.  Based upon this scenario (and making no other changes relative to the Company's proposal), provide revised tables that correspond with the tables shown in Schedule 1 of Ms. Baldwin's Exhibit 113.   (BE/ETI)
Request No. 308:  Elder
Provide annual total revenues for Custom Calling and CLASS Services for the years 1989 through 1996 and projected annual total revenues for the years 1997 and 1998.  (BE/ETI)
Request No. 309:  Elder
See Note 3 of Schedule 10 of Exhibit 114, and Columns X and AC of Schedule 7 of Exhibit 114:
a.Provide total intrastate test-year revenues from custom calling/CLASS services exclusive of speed dial and voice mail.  
b.List any and all products encompassed in the revenue figure shown in Column X of Schedule 7 of Exhibit 114, and for each product, separately, provide the test-year revenues.
c.For each of last five years provide the ratio of custom calling/CLASS revenues to total revenues.  (BE/ETI)
Request No. 310:  Elder page 27, lines 1-19
Please provide the exact proportion of investment in cable considered 'exchange' under the provisions of Section 7 of U S WEST's Field Accounting Practice Manual which is actually toll, including all special studies, other studies, workpapers, and any other related materials used in making the calculation.  This proportion should take into account the toll switching and toll recording circuits that may be included in 'exchange cable' (See Note 1 of Section 7.01 b.)  (BE/ETI)
Request No. 311:  Elder page 27, lines 1-19
Please provide the exact proportion of investment in cable considered 'toll' under the provisions of Section 7 of U S WEST's Field Accounting Practice Manual which is actually exchange, including all special studies, other studies, workpapers, and any other related materials used in making the calculation.  (BE/ETI)
Request No. 312:  Elder page 33
There are references to incorrectly applied separations factors.
a.Setting aside any disagreements as to the methodology involved in Schedule 12 of Exhibit 114, please indicate each cost pool that have a 75% separations factor applied.  For each of these pools, indicate whether the
Commission directive to allocate 15% to toll also applies, and if not, why not.
b.For all the remaining cost pools shown in Schedule 12 of Exhibit 114, separately indicate the applicable separations factor.
c.Confirm that the total intrastate COE figure is **prop $195,221,000** prop (see CARS Report F (F-1-1.RPT) and Schedule 12 of Exhibit 114).
d.Please provide a version of Schedule 12 to Ms. Baldwin's Exhibit 114 that delineates U S WEST's proposed allocation, using the same COE categories.
e.Using the plant categories shown on Schedule 12 of Exhibit 114 and Schedule 10 of Exhibit 114, identify specifically the amounts associated with each of the relevant categories for which investments were made under the Tech II program.  (Also see Elder page 39, line 4)  (BE/ETI)
f.Provide separately the intrastate dollar amounts for CWF1; CWF2; CWF2a; CWF3; and CWF4 (see Schedule 14 of Exhibit 114).  (BE/ETI)
Request No. 313a:  Elder page 35, lines 17-19
a.What is the basis of the assertion that the assignment of the Tech Plus portion of the depreciation reserve directly to Title 61 is "not necessary in order to honor the Company's agreement that the Tech Plus investment would be 'expensed' and kept out of rate base"?  (BE/ETI)
b.How would Mr. Elder propose to keep the Tech Plus investment "out of rate base for Title 61"?  (BE/ETI)
c.Provide a table that identifies specifically and solely the (a) TPIS associated with the Tech Plus program; (b) the Company's proposed allocation of this TPIS to Title 61 or Title 62; and (c) the Company's proposed allocation of the associated accumulated depreciation. Provide an explanation of any product codes used in answering this question.  (BE/ETI)
d.Provide a table that identifies specifically and solely the (a) TPIS associated with the Tech II program, by product category; (b) the Company's proposed allocation of this TPIS to Title 61 or Title 62, again by product category; and (c) the Company's proposed allocation of the associated accumulated depreciation.  (BE/ETI)
Request No. 313b:  Elder page 39, lines 17-19 and Plummer page 25, lines 1-2
Provide quantities and percentages of (a) residential; (b) Title 61 business; and (c) Title 62 customers on pair gain.  Indicate the year that corresponds with the data provided.  (BE/ETI)
Request No. 313c:  Elder page 44
Separately for each of the following product categories listed below provide for each of the past five years the inward movement (lines in service added):  (1) Title 61 residence initial line; (2) Title 62 residence additional lines; (3) Title 61 business; (4) Title 61 PBX; (5) Title 61 coin; (6) Title 62 business; (7) Title 62 PBX; (8) Title 62 Centrex; and (9) private line (specify separately for analog vs. digital).  (BE/ETI)
Request No. 314:  Elder page 44
Separately for each of the following product categories listed below provide for each of the past five years the outward movement (lines removed from service):
(1) Title 61 residence initial line;
(2) Title 62 residence additional lines;
(3) Title 61 business;
(4) Title 61 PBX;
(5) Title 61 coin;
(6) Title 62 business;
(7) Title 62 PBX;
(8) Title 62 Centrex; and
(9) private line (specify separately for analog vs. digital).  (BE/ETI)
Request No. 315:  Elder page 44
For each of the lines identified in response to the previous question, identify the quantify that were re-installed within a 30-day period, separately by category.  (BE/ETI)
Plummer
Request No. 316: Plummer page 26-27 and Response to Staff No. 172
Please provide a listing of all digital switches deployed in Southern Idaho, and the date of deployment; list any and all remaining analog switches.  (BE/ETI)
Request No. 317: Plummer page 26-27 and Response to Staff No. 172
For each switch in Southern Idaho, identify whether the switch is analog or digital, the quantity of Centrex lines served by that switch, and the ratio of that number to the total lines served by the switch.  (BE/ETI)
Ilett
Request No. 318: Ilett page 3, line 16
Please identify the 15 special studies Mr. Ilett reviewed and the amount of time Mr. Ilett spent analyzing these studies.  (BE/ETI)
Request No. 319: Ilett page 11
Please provide the calculation and documentation supporting your statement that 62% of USWC’s costs are directly assigned to the state level.  (BE/ETI)
Request No. 320: Ilett page 11
Please provide a copy of the contract or other documentation that describe your consulting relationship with U S WEST Communications.  Provide the supporting documentation that shows the total compensation and compensation units, and a detailed description showing the amount of time and activities for Dr. Merz and Mr. Ilett individually.  (BE/ETI)
Wozniak
Request No. 321: Wozniak page 16
Please provide documentation supporting Mr. Wozniak’s calculation that 24% of residential place no intraLATA long-distance calls.  Describe how the Company made this calculation.  (BE/EIT)
Owen
Request No. 322: Owen page 14, lines 8-11 and 17-23
On page 14 Ms. Owens used the terms “tariff shopping” and “rate arbitrage”:
a.Please define each term;
b.To whom are these terms a matter of concern and why, and
c.How does the higher residential rate discourage tariff shopping?  (BE)
Koehler-Christensen
Request No. 323: Koehler-Christensen
Please provide the most current organizational charge for U S WEST Inc. and its subsidiaries.  (TC)
Request No. 324: Koehler-Christensen page 5, line 15
Regarding the term ‘publishing fees’:
a.Please provide documentation describing the publishing fees;
b.Please provide a schedule calculating the $21.6 million, and
c.Show the calculation by year for how much of the $21.6 million was received by Southern Idaho intrastate.  (TC)
Easton
Request No. 325: Easton page 7, line 10
What documents, facts or studies do you rely upon to support the statement that “past life indications are an irrelevant element the life...”?  (SL)
Request No. 326: Easton page 11, line 12-14
What date and time and with which staff member did U S WEST sit down with Staff to discuss the study prior to the three way meeting in 1996?  (SL)
Cummings
Request No. 327: Cummings page 12, line 16
Please provide the most recent I B E S consensus forecasts for U S WEST.  (TC)
Request No. 328: Cummings page 21, line 17
Please provide a copy of the Standard & Poor’s CreditWeek, June 8, 1992, page 57 article.  (TC)
Margaret A.  Barrington
Request No. 329:  Barrington
Please explain AT Project V11384TP (Omega) and when this project will be delivered to USWC.  (MF)

Request No. 330:  Barrington page 1, lines 12-16  
Please provide all processes, reports, workpapers and backup documentation that ensures compliance with Federal and Idaho regulatory requirements.  (MF)    
Request No. 331:  Barrington page 1, lines 12-16  
Please provide all reports, workpapers and backup documentation produced by the “Allocations Team” in 1994, 1995 and 1996.  (MF)    
Request No. 332:  Barrington page 1, lines 12-16  
Please provide detail of how the “Allocations Team” was formed, purpose, work preformed, number of people  and job descriptions of those people.  (MF)
Request No. 333:  Barrington page 3, lines 6-11, Exhibit No. 6
Regarding futures on Exhibit No. 6:
a.Please explain what is meant by the word ‘futures’;
b.What is included as futures, and
c.Please explain the difference between futures and research and development.  (MF)

Request No. 334:  Barrington page 3, line 20
For project 12112AC-Modeling Applied Research, Ms. Barrington states that  numerous applications of modeling were applied to solve business problems.  Please identify all applications of modeling applied under project 12112AC and the business problem solved.  (MF)
Request No. 335: Barrington page 3, line 20
Please show project numbers that were developed from Modeling Applied Research, name of project, description of project, show how the project was classified (Part 64, interstate, intrastate, Title 61 and/or Title 62) and total cost, cost to Idaho, cost to interstate and cost to Title 61 and/or Title 62.  (MF)
Request No. 336:  Barrington page 3, line 20
Please provide documentation showing the following for project 12112AC:
a.  the total cost of project 12112AC for 1995;
b.  total cost to USWC for 1995;
c.  total cost to Idaho for 1995;
d.  total cost to interstate Idaho for 1995;
e.  total cost to part 64 Idaho for 1995;
f.  total cost to Idaho intrastate for 1995; and  
g.  show method used to allocate costs.  (MF)    
Request No. 337:  Barrington page 4, line 24 through page 5, lines 3 and 4  
Please provide project number, name, description, date started, date completed, total cost by each year, all work and/or improvements accomplished under project,  where deployed and a cost/benefit analysis for each project referenced on page 4-5.  (MF)  
Request No. 338:  Barrington page 5, lines 5-6
Please provide all reports and workpapers to support claim of reduced capital expenditures.  (MF)  
Request No. 339:  Barrington page 5, line 19
On page 5, line 19 you referenced several modeling projects that have been in progress since 1995.  Please provide project numbers, name, description, date started, date completed, total cost by each year, all work and/or improvements accomplished under projects, where deployed and cost/benefit analysis for the several modeling projects that were in 1995.  (MF)
 Request No. 340:  Barrington page 7, line 8-17
For project 11278BC, please provide a cost/benefit analysis, date started, date completed, technology developed and deployed in the State of Idaho as a result of this project.
Request No. 341: Barrington page 7, line 10
Please provide the total number of fixed wireless loops installed in 1994, 1995 and 1996.  Please provide information by lines by exchange.  (BE)
Request No. 342:  Barrington beginning on page 8, line 21, Exhibit No. 46
On page 8, line 21, Exhibit No. 46, Ms. Barrington states that projects were classified as Title 61, combined, or Title 62 and has provided workpapers showing projects by her classification.  
a.Please provide for AT and BC, by project numbers and project name, an explanation in detail of how this classification was made.
b.Please give an analysis for each project showing why the project should be classified in the manner shown on Ms. Barrington’s workpapers.
c.Please show key phrases and product provided that is in service in Idaho Title 61 or supports Idaho Title 61 as well as any other service (interstate, non reg, Title 62 etc).
d.Please provide benefit analyses that shows percent of benefit to southern Idaho as a whole and Idaho Title 61.
e.For each AT and BC project identified in the workpapers for Exhibit 46, please show why the project was originally undertaken and what Title 61 service or system it replaces.  If it doesn’t replace a system or service why was it needed by Title 61?  Supply all supporting workpapers and documentation.
f.Please provide for AT and BC project numbers, project name and description of all projects classified as non-regulated and interstate.  Please explain in detail how this classification was made.  (MF)
Request No. 343:  Barrington page 10, line 22 through page 11, line 3  
Please list all projects by project number name, description and dollar amount that was directly assigned to FCC Part 64 as referenced on page 10, line 22 through page 11, line 3.  (MF)  
Request No. 344:  Barrington page 11, lines 6-10
Please list all projects by project number, name, description and dollar amount that was directly assigned to interstate services referenced on page 11, lines 6-10.  (MF)  
Request No. 345:  Barrington page 12, line 14-20
Please list all projects by project number, name, description and dollar amount that was directly assigned to Title 62 referenced on page 12, line 14-20.  (MF)
Request No. 346:  Barrington page 14, lines 5-12
Please provide the project number, name, and dollar amount for each project that make up each classification contained in the table on page 14, lines 5-12.  (MF)
Request No. 347: Barrington page 14, line 30
Please provide curriculum of workshops and conferences attended by AT employees, number of employees attending and all research papers received.  (BE)
Request No. 348: Barrington page 15, line 3
Please provide syllabi from workshops contained in paragraph starting at line 3.  (BE)
Paul E. Gobat
Request No. 349:  Gobat page 2
a.Please provide copies of your refiled testimony in the Washington, Utah and Oregon dockets referenced on page 2.
b.Please provide the “Total Compensation Survey Executive/Upper Management Position Hewitt Associates” as mentioned in Exhibit 36D, page 4.
Request No. 350:  Gobat page 4, lines 7-9  
Please provide customer service and financial goals for 1993, 1994, 1995, and 1996.  Please show how these goals where met, amount of the TPA paid out and percentage of goals met, and percentage of TPA paid.  Provide all workpapers.  (MF)   
Request No. 351:  Gobat page 4, lines 12-14
Please provide customer service and financial goals for 1993, 1994, 1995, and 1996.  Please show how these goals where met, amount of the STIP paid out and percentage of goals met, and percentage of STIP paid.  Provide all workpapers.  (MF)
Leslie Jones
Request No. 352:  Jones page 1, lines 22-27
Is all customer service for southern Idaho handled exclusively in either the Boise office or Salt Lake City center? Please explain.   (MF)    
Request No. 353:  Jones page 1, lines 22-27
Describe how the Boise center been impacted by the new Mega Centers, both positively and negatively?  (MF)
Request No. 354:  Jones page 1, lines 22-27
Please show how many residential and small business customer requests for Title 61 service were handled by Boise, Salt Lake and/or any other center.  Name the center and provide the percent of calls taken by each center.  (MF)  (WH)  
Request No. 355:  Jones page 1, lines 22-27
Does the Boise center handle calls for any other areas or states other than               U S WEST Communications-Southern Idaho.  If so please name the area or state and the percentage of calls.  Provide a copy of all reports and documentation.  (MF)
Request No. 356:  Jones page 3, lines 17
Why was access so low during the summer of 1993 and 1994?  If call volumes peaked during those time periods, what was the nature of those calls?  For example, were customers calling about delays in service installations?  (WH)
Request No. 357:  Jones page 13-15
Were calls to the Credit Management Center in Seattle included in the data you presented?  If not, please provide access data for this center in similar detail to that provided for the centers in your testimony.  What centers are included in the data in your testimony?  (WH)
Request No. 358:  Jones page 13-15
What caused the increase in call volumes between 1994 and 1995?  Did Staff reduction and office closures throughout the Company's service territory serve to concentrate the volume of calls at the remaining call centers?  (WH)
Carl Inouye
Request No. 359:  Inouye
Please provide the cost/benefit analyses related to restructuring for the following: a. 1993 Restructuring Plan;
b. The 1991 Restructuring Charge, and
c.All updates used by management to determine how the actual progress compared to the original goals.  (KS3)
Request No. 360:  Inouye
Are there any future restructuring plans that are being developed where a one-time expense will be recorded and a special liability account will be established?  If so, please provide all information compiled so far on these restructuring plans, including cost/benefit analysis.  (KS3)
Request No. 361:  Inouye
What accounting theory or principle was used to record a one-time expense and a long term liability in 1986, 1991 and 1993 for financial reporting purposes to the SEC and company shareholders?  (KS3)
Request No. 362:  Inouye
Please provide all documents, correspondence, reports, etc. provided to or received from the FCC relating to 1991 and 1993 restructuring projects.  (KS3)
Request No. 363:  Inouye
In the 1993 Form 10-K, page 11 the last two sentences on that page state:  “The restructuring plan is estimated to reduce total employee and related costs by approximately $525 (million) during the next three years, starting in 1994.  These savings are expected to be largely offset by higher employee salaries and wages for the remainder of the work force.”  (underline added)  Did management ignore growth and other business opportunities in this statement?  What does the Company mean when it uses the term “largely offset”?
Request No. 364:  Inouye
Please provide a listing showing the total numbers of contract workers and total dollars expensed in management and in occupational categories for the years 1991 through 1995.
Request No. 365:  Inouye page 1
Please list and case numbers, describe issues involved in cases, and participation on the issues in cases before the commissions or courts in Utah, Oregon and Washington.  (KS3)
Request No.  366:  Inouyepage 7
According to the accompanying table, nearly as many employees must have left without being paid to leave (note column 6 vs column 3) as left by “paid exit” for the numbers you have provided for total employees at each year-end to work mathematically.  Please review this schedule and make any necessary adjustments along with an explanation showing the difference between the calculated end of year total employees and your stated end of year total employees.  (KS3)
Request No. 367:  Inouyepage 7
Refer to the attached table for Request No. 3   in the last column.  After net declines of over 2000 employees each year from 1992 through 1994, there was a net increase in total employees in 1995 of 443.  Also, new hires in 1995 were nearly double the new hires of any year since 1988.  Please explain the significant change of direction in staffing requirements in 1995. (KS3)
Request No. 368:  Inouye page 7, lines 26 through 37
The total employee numbers don’t agree to company published numbers.  
a.Please provide the source for this table;
b.Why are these numbers different from company published numbers; and
c.Please provide numbers for 1982 and 1983 to expand the table.  (KS3)
Request No. 369:  Inouye page 7, lines 6-19, referring to Paid Exits
Please provide the number of people that left USWC that were not “paid exits”.  Also, provide documentation showing those people that took other jobs that are not related to the primary job of offering regulated telephony service and therefore are not shown as exiting the Company.  (MF)  
Request No. 370:  Inouye page 7, lines, 6-19, referring to Paid Exits
a.How many people where terminated in 1996?
b.How many people were terminated to present in 1997?  (MF)
Request No. 371:  Inouyepage 7, line 33
Should the total be 54,917 rather than 54,390 or is there another number on that line is incorrect?  Please provide the corrected numbers for line 33.  (KS3)
Request No. 372:  Inouye page 8, line 8-15
Please provide the number of employees hired for unregulated activities (Title 62) by year.  If  this information is not available, please fully explain why.  (KS3)
Request No. 373:  Inouye page 8, lines 8-15
a.Please provide documentation that shows positions, areas of work and state for the new hires for 1994 and 1995 as referenced on the table on page 88.
b.Please provide the rationale for the new hires.
c.Please indicate how many and which positions are permanent, temporary and contract labor.  (MF)
Request No. 374:  Inouye page 8, lines 17-18
The expense of contract workers is included in the employee related expenses.  Referring to the 1993 Form 10-K, page 11, when management stated “The restructuring plan is estimated to reduce total employee and related costs by approximately $525 (million)”....  Does this statement include contract worker, non-company employees and their related costs?  Did the restructuring plan meet its savings goals in 1995?  (KS3)
Request No. 375:  Inouye page 17, lines 4 and 11
Do “increase in other operations” and “new business opportunities” relate to Idaho Title 61 services?  If so, what services are represented by these comments?  (KS3)
Request No. 376:  Inouye page 17, line 15
How is employee related expense data as referenced on page 17, line 15 for USWC allocated to Idaho?  Please explain how employee related expense data is kept for Idaho.   (KS3)
 Request No. 377:  Inouye page 17, lines 12-22
Was there a change in Idaho payroll tax rates in 1995 or is this just a sample for other employee expenses such as benefits and payroll taxes that would go up if salaries went up?  (KS3)
Request No. 378:  Inouye page 20, lines 2-3
On page 20, lines 2-3, Mr. Inouye states “Evidence proves restructure in an ongoing business activity.”  Dealing only with the restructuring plans announced in 1986, 1991 and 1993:
a.Do these plans have set parameters such as starting and ending dates and planned outcomes?
b.Are these plans rare or unique in their scope?
c.Aren't these plans reported differently than on-going operations for financial reporting purposes?
d.Provide all evidence there is that these plans are on going business activity.  (KS3)
Request No. 379:  Inouye page 20, lines 8-9
 On page 20, line 8-9, Mr. Inouye states “The above proves expense reduction benefits far exceed the test year expense.”
a.Has the 1993 plan produced the savings called for in the 1993 10-K report?  
b.Have the factors of growth, service quality problems and other business opportunities caused the original savings goals planned for 1995 not to be met?  (KS3)
Request No. 380:  Inouye page 27, lines 17-28  
Please provide the full report and order for Docket No. 89-057-15, Utah Public Service Commission, November 21, 1990.  (MF)
Request No. 381:  Inouye page 54, Exhibit 38c
Exhibit 38c, page 54 is missing and the copies of the tables are unreadable.  Please provide a complete, readable copy of this exhibit.  (KS3)
Margaret J Wright
Request No. 382: Wright
Provide the costs associated with implementation of regional EAS of each region and for each route, broken down into transport cost (per mile), tandem switching cost (per minute of use), and local switching cost (per minute of use).  Costs should be embedded costs.  Transport miles should be included.  Attached are matrices providing a suggested format for the data.  (BE)
Request No. 383:  Wright
Please provide the calculation of the 1995 average account balance for each of the following accounts:
Account No.  2681 - Capital leases;
Account No.  2682 - Leasehold improvements; and
Account No.  2690 - Intangibles.  (SL)
Request No. 384:  Wright
Please provide a statement from Beth Reiman about the procedures followed to determine and record missing asset retirements.  (SL)
Request No. 385:  Wright
Of the total 905,475 square feet leased by USWC at 1801 California, please provide the following:
a.How many square feet is re-leased to entities other than USWC;  
b.Provide a listing showing the net lease rate in effect in 1995 by sub-lease tenant;
c.Provide the total square footage assigned to each tenant (including common area);
d.How many square feet of the total 905,475 square feet leased by USWC at 1801 California was vacant at December 31, 1995;
e.Provide a listing showing the square footage available for lease, and
f.Provide the square footage of unused portions of floors still occupied by USWC but waiting for a “restacking” of cubicles and offices .  (KS3)
Request No. 386:  Wright Exhibit No. 43I
Related to Exhibit 43I:
a.Please reconcile your Exhibit 43I including “Client Matter” numbers and dollar amounts to STF000-070 A designated as PPL pages 1-45.
b.Explain why there is a difference in the dollar amounts and why not all of the PPL numbers agree to those originally given to Staff.
c.For cases identified in Exhibit 43I, please provide the following:
1.a complete description of the work preformed;
2.the purpose of the work;
3.a list of employees who preformed the work; and
4.a benefit analysis for Title 61. (MF)
Request No. 387: Wright page 22 table
In reference to the table on page 22:
a.Please explain the relationship between the columns.
b.How can Title 61, i.e. at line 14, be larger than intrastate?  (SL)
Request No. 388: Wright page 26-27
To the extent not already provided, please provide:
a.A table that identifies specifically and solely the $5,523,038 in additions to TPIS referenced in Ms. Wright's rebuttal testimony (at Exhibit 43F) that U S WEST claims was not accounted for in Staff's analysis;
b.The Company's proposed allocation of all expenditures by type of plant and to Title 61 or Title 62, and
c.The Company's proposed allocation of the associated accumulated depreciation.  Provide an explanation of any product or accounting codes used in answering this request.  (BE/ETI)
Request No. 389: Wright page 30, line 3
Please provide all retirements for each year from 1986 through 1996 for the following accounts:
Account 2211 - Analog Switch
Account 2212 - Digital Switch
Account 2232 - Circuit Analog
Account 2423 - Buried Cable Metalic (SL)

Request No. 390: Wright Rebuttal Testimony, page 34, lines 20-21
Please provide the following related to pension expense:
a.Provide all company records that reflect that the reduction in rates in 1989 were based on a review of USWC results of operations that included a credit for Pension Expense, and
b.Provide all supporting data that shows that the USWC application in 1988 to resolve the IPUC’s pending investigation considered credits in USWC’s pension expense as a factor in calculating the revenue reductions proposed.  (KS3)
Request No. 391: Wright page 36, lines 11-14
Please provide a schedule showing the number of employees at U S WEST Inc.  and all subsidiaries for the years 1988 through 1996:
a.That are allocated to providing basic regulated telephone service (Title 61 services in Idaho), and
b.Those providing other non-regulated service.  (KS3)
Request No. 392: Wright page 36, lines 11-14
Please provide U S WEST Inc. and all subsidiaries current plans for future areas of focus and growth, noting those that are regulated and those that are non-regulated.  (KS3)
Request No. 393: Wright page 36, lines 16-21
Regarding deferred taxes on pensions discussed on page 36:
a.How much has been recorded by USWC as a deferred income tax liability?
b.How much is related to Southern Idaho Intrastate?
c.Please provide copies of the journal entries recording both the asset and the deferred income tax.  (SL)
Request No. 394: Wright page 42, lines 13
When will the last amortization expense for compensated balances be booked?  (KS3)
Request No. 395 : Wright page 46, lines 1-2
Please provide a copy of the analysis completed showing that the new lease was the least costly alternative.  (KS3)
Request No. 396:  Wright page48
Please provide all records that verify the expenses of the President’s Club.  (KS2)
Request No. 397:  Wright page48
Please provide all records that verify the “value” of the President’s Club to the Title 61 customer.  (KS2)  Please provide at least the following:
a.the letter of recommendation stating why the employee was nominated (or similar nomination form);
b.criteria for nomination by each organization;
c.a list of the objectives of the specific organizations and the distinguished contribution by the attendees to the Company and their specific organizations.
Request No. 398:  Wright page57
Please provide copies or make available in Boise all 1995 advertising efforts designed specifically “to attract and retain” Title 61 customers.  (KS2)
Request No. 399:  Wright page 62, lines 7-9  
Is USWC required formally or informally to take all of the type of services offered by BRI from BRI?  If not, does, or in 1995 did, USWC take any of the same services offered by BRI from any other vender?  If yes, supply contracts and state if this service was done through a bid.  (MF)
Request No. 400:  Wright page 62, lines 7-9
Is the Media Group required either formally or informally to take all of the type of services offered by BRI from BRI?  If not, does, or in 1995 did, USWC take any of the same services offered by BRI from any other vender.  If the requirements are different for USWC and the Media Group please explain all differences and why there is a difference.  (MF)
Request No. 401:  Wright page 62, lines 15-18
Please provide the cost/benefit analysis used to show:
a.this method is less costly;
b.this method shows similiar results.  (MF)
Request No. 402:  Wright page 63, lines 1-2
Please provide the cost/benefit analysis used to show:
a.this method is less costly;
b.this method shows similiar results.  (MF)
Request No. 403:  Wright page 63, lines 5-9
a.Please provide all studies that show actual usage, hours, square footage, items purchased, block hours, etc. that show how each service at BRI is to be charged.
b.Please identify those items that are actual and those items that are budgeted.    
c.Please supply supporting documentation for these studies.  (MF)
Request No. 404:  Wright page 69, lines 5-12
Please provide all documentation, including payroll and any other reports that show when employees left AT.  Also show actual salary and benefits associated with each employee that left.  (MF)
Request No. 405:  Wright page 70, lines 6-9  
a.Please show all functions that USWC received prior to the transfer and what functions will be received from USWMRG.  Please provide the following:
1.  a complete description of each function;
2.  the purpose for the function; and
3. a cost benefit analysis of the function to Title 61 Idaho ratepayers.
b.Please show why, if the employees were transferred, the function was not transferred to USWC.
c.Show what the employees that were transferred to USWC job functions were before the transfer and what they are after the transfer.  (MF)
Request No. 406:  Wright page 72, lines 3-7
Please provide documentation showing where the revenue for CS is booked.
a.Please provide account numbers.
b.How much is assigned to Title 61?
c.Where is the expense associated with CS booked?  (MF)
Request No. 407:  Wright page 72, line 16 through page 73, line 2
a.Please identify all network service sales planning, sales support and customer account service provided by CS to customers in the State of Idaho.
b.Name each customer and identify the number of lines each customer has.
c.Please provide a copy of customer base CS maintains for Idaho customers.
d.Identify all Title 61 services these customers take.  (MF)
Request No. 408:  Wright page 73, lines 10-12
Please provide a calculation of the number USWC believes should be assigned.  (TC)  
Request No. 409:  Wright page 79, lines 13-16
On page 79 Ms. Wright states the research done at U S WEST, Inc. is totally different than that performed by affiliates.
a.Please provide copies of all research work done at Inc. in 1995 and 1996.  
b.Show projects, description, benefit analysis for Title 61 dollar amount and amounts charged to USWC, Idaho, interstate Idaho, Part 64, Idaho intrastate for 1995 and 1996.
c.Please provide copies of all tests developed and selection procedures used for screening applicants for 1995 and 1996.
d.Please provide number of employees that used these tests in 1995 and 1996 for USWC and Idaho.  (MF)
Request No. 410:  Wright page 80, lines 1-4
Relating to the lobbying expense discussed on page 80:  
a.Please provide for 1995 journal entries that show by month the booking of all costs from Inc.
b.Also provide copies of all adjusting journal entries made on the 1995 records at USWC to Inc.  costs.  Include moving of amounts from one account to another as well as actual adjustments to previously booked amount.
c.Supply all back up for original and adjusting entries.  (MF)   
Request No. 411:  Wright page 80, lines 4-6   
Please provide a reconciliation showing cost identified to USWC in
STF000-096A and cost identified in page 9-10 in STF000-073.  (MF)
Request No. 412: Wright page 80, lines 9-18
Relating to the “Delaware Regulator Group” referenced on page 80:
a.Please provide time cards for 1995 that show amount of time each employee of the Delaware group spent on each activity, including interaction at the FCC and all other activities.
b.Please provide budgets, work plans, work schedules, etc. for 1995 that support your contention that the work performed identified as Delaware regulator-legislative affairs - external relations benefited Idaho.  
c.Please list all expenses accrued and the justification for each expense at during 1995 at the federal or state level in regards to legislation and rule changes and/or other matters including the Telephone Rules of 1996 for the Delaware Regulatory Group.
d.Show time spent on the stock division between Communications (USW) and Media (UMG).
e.Please show when this unit was formed, number of people, and location.
f. Please provide a benefit analysis showing the benefit to Idaho Title 61.
g.Please show how the determination was made as to the amount to charge to USWC and to all other affiliates.  
h.Show USWC's accounting entries for this service during 1995.  (MF)
Request No. 413:  Wright page 81, line 5
Related to the leadership conference referenced on page 81:
a.Please identify and describe the subjects that applied to U S WEST as a whole; and
b.Provide a description and provide a copy of the benefit analysis to Idaho Title 61.  (MF)  
Request No. 414:  Wright page 81, line 7
Please identify and describe subjects that were specific USWC issues during the four hours identified.  Identify the state(s) in which these specifically relate to. (MF)
Request No. 415:  Wright page 83, lines 11-12
Please provide copies of all information that this group provided to customers in Idaho during 1995.  (MF)  
Request No. 416:  Wright page 85, line 15-20
Related to the subsidiary tax group referenced on page 85:
a.Please provide the total number of employees and average salaries in 1995 for the subsidiaries tax group.
b.Show how the charge to USWC was determined.
c. Please provide documentation of all work performed in 1995.
d.Show tax work done by this organization that was filed in Idaho. (MF)

Request No. 417:  Wright page 90, lines 3-11
Please provide a complete description of the work preformed and a benefit analysis for costs charged to Idaho Title 61 for items identified.  (MF)  
Request No. 418:  Wright page 90, lines 4-11, page 91, lines 4-11
Please identify actual amounts that have been double counted.  Provide workpapers and back-up support for the amounts identified.  (MF)  
Request No. 419: Wright page98, lines 2-4
Please provide for the incentive compensation plans the following:
a.copies of all strategic initiatives included in the Company’s plans;
b.a benefit analysis for Title 61 service; and
c.a copy of all reports, workpapers and supporting documentation that shows how these goals where met for all bonus costs allocated and/or directly charged to Idaho from all sources.  (MF)  
Request No. 420: Wright page98, line 15
Related to the service quality discussion on page 98:
a.Please provide copies of all service and quality criteria included in the Company’s incentive compensation plans.
b.Provide a benefit analysis for expenditures charged to Title 61 service.
c.Provide a copy of all reports, workpapers, and supporting documentation that shows how these goals were met for all bonus cost allocated and or direct charged to Idaho from all sources.  (MF)  
Request No. 421:  Please provide data and workpapers showing the derivation of the average quantity of Title 61 lines used (290, 752 for residence and 62,668 for business) in the spread of the proposed revenue requirement to residence and business lines.  The basic data should be sorted by rate group and by USOC by TIM Code as already provided in response to STF-01-029 and in workpapers submitted with the Company's rebuttal testimony (labeled as WP-EX40D-BUS and WP-EX40C-OOR-EAS-CON).  The data should have the sale of exchanges removed and should be arranged by rate groups as they existed before consolidation due to implementation of EAS.  (BE)
Request No. 422:  Provide the costs associated with implementation of regional EAS for each region and for each route, broken down into transport cost (per mile), tandem switching cost (per minute of use), and local switching cost (per minute of use).  Costs should be embedded costs.  Transport miles should be included.  Attached are matrices providing a suggested for mat for the data.  (BE)
Owen
Request No. 423:  Owen
Please supply U S WEST Communications' intraLATA MTS, WATS, and private line revenues for the years 1990 through 1995.  (BE)
Request No. 424:  Owen page 3, line 4
The testimony agrees to withdraw the non-recurring “restructure” charge.  Does this mean the non-recurring “installation” charge referred to at page 44, lines 5 and 6?  (BE)
Request No. 425:  Owen page 4, line 19
Provide the specific page numbers of the “7 pages” referred to in the Boise Yellow Pages as evidence of the existence of telecommunications competition.   (BE)
Request No. 426:  Own page 14, lines 8-11, lines 17-23
The question mentions the potential for “tariff shopping” and “rate arbitrage” as if they were serious concerns.
a.Please define each term.
b.To what specific parties are they a matter of concern and why?
c.How does a higher residential rate discourage tariff shopping?
Request No. 427:  Own page 16, lines 15-20
Ms. Own refers to “an accepted belief” that U S WEST will lose “many more of their revenues associated with long distance and witched access.”  
a.What parties have specifically accepted this belief?
b.What is the evidentiary basis for the answer to a?
c.Does the reference to revenues refer to absolute loss of revenues or to relative loss of market share?
d.What is the evidentiary basis for the answer to c?  (BE)
Request No. 428:  Own page 18, lines 20-27and page 19, lines 1-7
There is reference to loop costs “assigned to deregulated services.”  In the discussion it appears that this “assignment” is being treated as a subsidy and therefore as the creator of an inequitable burden.  Is this an accurate reading of the U S WEST position?  (BE)
John Souba
Request No. 429:  Souba page 2, line 20
On page 2, line 20, Mr. Souba states he will be addressing U S WEST's PIC freeze policy.  However, this issue was not addressed.  What is U S WEST's position with respect to discontinuing its practice of discouraging customers from requesting PIC freezes?  (CJC)
Request No. 430:  Souba page 3, line 13 and several places thereafter
Please indicate where Staff in its testimony characterized its recommendation to establish the return on equity at the lower end of the range of reasonable returns as a “penalty”?  (WH)
Request No. 431:  Souba page 4, line 16-17
Please explain how U S WEST’s BSM’s were developed and how the target levels were established.  How many Idaho customers were included in the focus groups used by U S WEST while developing its indices?  What other mechanisms were used to gather input from Idaho customers.  (WH)
Request No. 432:  Souba page 4, line 20-23
Is it U S WEST’s position that direct customer input is not an important indicator of performance?  Explain.  Are customer complaints indicative of customer dissatisfaction?  (WH)
Request No. 433:  Souba page 5, line 1
On page 5, line 1 Mr. Souba states that there is no Commission-approved standard for level of complaints.  Does U S WEST have a level of complaints that it believes the Commission should use as a standard?  Please describe.  (WH)
Request No 434:  Souba page 8, line 18-20
Please list and provide documentation that the Commission has “accepted” the Company’s method of calculating compliance with the out of service standard.  (WH)
Request No 435:  Souba page 10, line 22
Is it U S WEST’s position that every customer who is dissatisfied with U S WEST calls the IPUC to file a complaint?  Is it U S WEST’s position that every customer who is dissatisfied with U S WEST calls U S WEST to complain?  (WH)
Request No. 436:  Souba page 11, line 2
Please list and provide documentation that the Commission has been satisfied with the overall level of U S WEST’s service quality from 1994 to the present.  (WH)
Request No. 437:  Souba page 14, lines 20-22, page 15, lines 1-15, page 16,
lines 15-17
Please cite any evidence that either the Commission or Staff now oppose the establishment of statewide service quality standards?  (WH)
Request No. 438:  Souba page 17, line 20-22
Do the Company’s records allow it to identify an average or total  number of held orders per month?  Would this not be a more accurate indication of the number of customers experiencing a delay in obtaining service?  Explain.  (WH)
Request No. 439:  Souba page 21, line 6
What percentage of customers ordering service request a due date that is more than two days in the future?  Please break this down as to business and residential customers.  Is this percentage increasing, decreasing or remaining stable during the past three years?  (WH)
Request No. 440:  Souba page 25, line 10
Does the Company object to the option of providing a cellular loaner plan to customers without phone service?  If so, why?  (WH)
Request No. 441:  Souba page 26, line 20
While conducting its performance audit, Staff was told that the information used to determine whether a customer had experienced a missed commitment or repeat repair was readily available from the LMOS database.  Please describe what prevents the Company from using a list of customers who have experienced such missed commitments or repeat repairs as the basis for issuing credits.  To what extent does volume influence the Company's claim that automatically providing credits is an onerous task?  (WH)
Request No. 442:  Souba page 28, line 1
During the Idaho Universal Service Task Force meetings, what was the primary concern of participants?  Were task force participants primarily concerned that a local only service be offered, or was their primary concern preventing access to toll?  (WH)
Request No. 443:  Souba page 28, line 7-9
Please list and provide any documentation of an “approval”, as opposed to acceptance for filing, by this Commission of Toll Restricted service as a Title 62 service.  (WH)
Request No. 444:  Souba page 29, line 10
Please provide working papers and any other documentation to support the estimate of a $20.00 rate for a one time charge for toll restricted service.  (WH)
Request No. 445:  Souba page 30, line 10
Can two customers equally distant from the central office, but in different directions have totally different costs of service?  Explain.
a.Does the density of customers contribute to the cost of serving customers in rural areas?  Explain.  
b.Is it possible for the Company to reduce the per customer costs of service by using trunk lines and other facilities to serve the more heavily populated areas, regardless of the distance from the central office?  Explain.  (WH)
Request No. 446:  Souba page 30, line 10
What is U S WEST's criteria for establishment of a base rate area?  When was the last time a review was completed to ensure that the Company's base rate areas were in compliance with this criteria?  When was the last time the base rate area for an Idaho exchange was adjusted to accommodate changing conditions?  What are the criteria and/or standards for determining whether an area is Zone 2, Locality Rate Area 2 or Suburban Rate Area 2?  What distinguishes an “SRA1” from a “SRA2”?  (WH)
Request No. 447:  Souba page 41, line 18-21
Please provide the number and percentage of risk accounts that were denied local service and/or toll service because of non-payment of charges for telephone service for 1996.  For each of the years 1995 and 1996, please provide the number and percentage of risk accounts put on toll restriction because of an unpaid final bill owing from a previous account.  By year, how many of those customers were disconnected due to non-payment within one year of establishing toll-restricted service?  By year, what was the average amount owing at the time of disconnection?  What was the average length of toll-restricted service prior to disconnection?  (CJC)
Request No. 448:  Vanston
The following questions are in reference to Figure 3 ("Comparison to 1989 Digital Switching Forecast") of Dr. Vanston's rebuttal testimony:
a.Provide the numerical values for each datapoint of the data sets appearing in the figure, including the "Data for 1989 Forecast" and "New Data for 1994 Forecast."
b.Please provide a complete specification of the data points and/or formulas used to produce the "1989 Forecast" and "1994 Forecast" curves appearing in the figure.  The data provided in response to this request should be sufficient to reproduce each of the two forecast curves.
c.Provide all source documents, workpapers, analyses, and/or studies that were used in obtaining or deriving the numerical values supplied in response to part a.
d.Provide all source documents, workpapers, analyses, and/or studies that were used in obtaining or deriving the data supplied in response to    part b.
Request No. 449:  Vanston
The following questions are in reference to Figure 4 ("Comparison of Life Calculations for Analog ESS Switching -- U S WEST - IOWA") of Dr. Vanston's rebuttal testimony:
a.Provide a complete copy of the study from which these results were obtained.
b.To the extent not already supplied in response to part a., provide all source documents, workpapers, analyses, and/or studies that were used in obtaining or deriving the "Life based on retirements" data appearing in Figure 4.
c.To the extent not already supplied in response to part a., provide all source documents, workpapers, analyses, and/or studies that were used in obtaining or deriving the "Life based on actual" data appearing in Figure 4.
d.To the extent not already supplied in response to part a., provide all source documents, workpapers, analyses, and/or studies that were used in obtaining or deriving the "Fisher-Pry Industry Study" data appearing in Figure 4.
Request No. 450:  Vanston page 11
The following questions are in reference to page 11 of Dr. Vanston's rebuttal testimony:
a.Provide all materials prepared by Dr. Vanston or TFI that document the specific procedures that are followed in conducting a "Multiple Substitution Analysis."
b.Identify, by title, date, and sponsoring client or firm (if applicable), all TFI reports, studies, and analyses that TFI has prepared over the past five years which apply "Multiple Substitution Analysis."
c.Identify each article or report published in a refereed academic journal during the past five years that applies or otherwise addresses "Multiple Substitution Analysis."
d.Identify each article or report published in a non-refereed academic journal during the past five years that applies or otherwise addresses "Multiple Substitution Analysis."
e.Identify each article or report published in a non-academic periodical (e.g. industry trade press) during the past five years that applies or otherwise addresses "Multiple Substitution Analysis."
f.Identify each article or report published in a book, conference proceedings, or other media not encompassed by parts c.-e. above, during the past five years that applies or otherwise addresses "Multiple Substitution Analysis."
Request No. 451:  Vanston
Please provide the following information regarding Technology Futures, Inc. (TFI):
a.List all TFI documents (reports, studies, papers, etc.) submitted in state or federal proceedings over the last five years.
b.List all proceedings in which TFI has submitted one or more of the documents listed in response to part a. above and provide:
(1)the jurisdiction of the proceeding;
(2)the case or docket number in which the report(s) was(were) submitted;
(3)the date on which the report(s) was (were) submitted;
(4)the party on whose behalf the report was submitted, and
(5)whether expert witness testimony was submitted in addition to the report(s)
c.Is Dr. Vanston's use of the term "independent research institution" in describing TFI as cited above meant to imply that TFI is a 501(c)(3) corporation or other type of not-for-profit organization?
d.If the answer to c. is in the affirmative, does TFI's charter or by-laws permit its employees or principals to accept consulting or testimonial engagements from for-profit organizations such as U S WEST?
Request No. 452:  Vanston
Regarding use of substitution analysis in other jurisdictions:
a.List all jurisdictions over the past five years where TFI has submitted testimony in support of the use of substitution analysis to recommend depreciation lives (or life ranges) for one or more of the telecommunications plant accounts identified in Exhibit 112, Schedule 6 of the Direct Testimony of Lee L. Selwyn.
b.For each of the jurisdictions listed in response to part a. above:
(1)list the individual proceedings within the jurisdiction in which TFI participated;
(2)provide the case or docket number(s);
(3)list the party or parties on whose behalf the testimony was submitted, and
(4)provide the dates of testimony submission (indicate whether direct, rebuttal, etc.)
c.For each of the regulatory proceedings listed in response to part b. above, in which, if any, of these proceedings did the regulatory agency (e.g., PUC) adopt depreciation lives that fall within the ranges recommended by TFI.  Provide a cite to the page and decision where such a finding was made.
d.For each of the regulatory proceedings listed in response to part b. above, in which, if any, of these proceedings did the regulatory agency adopt the methodology recommended by TFI.  Provide a cite to the page and decision where such a finding was made.
Request No. 453: Vanston
a.To what extent does Dr.Vanston believe that the rate of technology substitution is demand-driven, i.e., that new technology will be acquired in order for U S WEST to develop and provide new services that its customers will demand and whose demand will be growing over time, vs. supply-driven, i.e., that new technology will be acquired by
U S WEST because it will permit the company to produce the existing mix of services, including proportionate growth thereof, more efficiently?
b.To the extent that Dr. Vanston believes that the rate of technology substitution is demand-driven, please provide the specific service-by-service demand forecasts through year 2005 upon which U S WEST relies in formulating and justifying its capital construction and acquisition program.
c.To the extent that Dr. Vanston believes that the rate of technology substitution is supply-driven, please provide the specific service-by-service cost savings projections through year 2005 upon which U S WEST relies in formulating and justifying its capital construction and acquisition program.
d.Under what conditions does Dr. Vanston believe that firms such as
U S WEST will (or should) pursue technology substitution strategies in cases where the Net Present Value projected by a capital-budgeting Discounted Cash Flow (DCF) type of analysis (e.g., CUCRIT or its equivalent) is negative?
e.Is U S WEST currently pursuing plant replacement, construction or acquisition programs that do not produce a positive NPV over the forecast economic life?
f.If the answer to e. is in the affirmative, please provide the non-financial rationale for the undertaking(s) for which this condition applies.
g.For those plant replacement, construction or acquisition programs that
U S WEST is currently undertaking or planning and that are forecast to produce a positive NPV, please provide the following information:
(1)The nature of the undertaking (e.g., central office, feeder, distribution, interoffice, etc.);
(2)The economic life that is used for purposes of the DCF analysis;
(3)The depreciation rate that will be used for this plant;
(4)The specific services that the plant acquisition makes possible and that U S WEST would not have been able to offer without the subject plant acquisition;
(5)The dollar amount of the "incremental revenues" available to
U S WEST as a result of the undertaking.  "Incremental revenues" refer to revenues from services that U S WEST would not have been able to offer without the subject plant acquisition, and
(6)The dollar amount of specific "cost savings" or other efficiency gains that are projected to result from the undertaking.  "Efficiency gains" could include, but not be limited to, capital cost savings resulting from avoidance of the need to expand preexisting capacity in plant that has become technologically obsolete.
Request No. 454: Easton page 17, lines 19-22
a.Describe with specificity the "straight forward methods" used by
U S WEST to determine plant age.
b.Please provide any and all workpapers and other supporting documentation for the assumptions associated with the "straight forward methods" (p. 17, line 19) used by U S WEST to determine plant age.
c.Describe with specificity the "actual U S WEST investment data, as of 1/1/96" used by U S WEST to determine plant age.
d.Describe how each of the investment data series used by U S WEST in its analysis compares to the data reported in ARMIS 43-02, Tables B1 and B5.
e.Provide the "actual U S WEST investment data, as of 1/1/96" referenced on p. 17, line 20.
f.Provide the depreciation data including the depreciation rates and survivor curves used in the U S WEST analysis.
g.Provide the calculations, assumptions, workpapers, supporting documentation and any other information relied upon to derive the result that 36.13% of U S WEST plant was placed in the last five years.
h.If the data referenced in response to parts a.-g. above are for the entire
U S WEST region, please provide similar calculations specific for
southern Idaho.
DATED  at Boise, Idaho, this            day of January 1997.
______________________________________
Donald L. Howell, II
Deputy Attorney General
umisc\prdreq\usws965.dh5