USWS965v6.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
SIXTH 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 FEBRUARY 14, 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.
For each item, please indicate the name of the person(s) preparing the answers, along with the job title of such person(s) and the witness who can sponsor the answer at hearing.
Provide responses in electronic form where possible, e.g., spreadsheets used to derive responses.  Any spreadsheets provided should include formulas rather than just values.
All data should be for Southern Idaho only, and for the 1995 test year except where specified.  Basic local exchange service means Title 61 lines, residential or business.
Request No. 455:  Plummer page 21-22
Concerning the data referred to on page 22, lines 6-15:
1.Please provide the data shown separately for (a) feeder fill; and               (b) distribution fill.
2.Confirm that the data shown are for actual as opposed to objective fill.
3.What portion of the fill corresponds to plant set aside for maintenance and administrative purposes?  Explain fully and include any underlying assumptions.
4.Provide the data separately by wire center.
5.Provide the complete referenced analysis, completed in November 1996, of the outside plant distribution areas, any and all assumptions, workpapers, and other relevant documentation.  (ETI)
Request No. 456:  Plummer page 21-22
Referring to the Company's response to STF02-049, which is reproduced as Schedule 8 in Exhibit 114 of Ms. Baldwin's testimony:
(a)Are the data in the Company's response to STF02-049 still accurate?
(b)If the answer to part (a) is negative, explain any and all reasons for the differences between the data provided in response to STF02-049 and the data referred to on pages 22-23 of Mr. Plummer's testimony.
(c)If the answer to part (a) is in the negative; please provide a revised response to the Staff's data request.  (STF02-0497)  (ETI)
Request No. 457:  Plummer page 22, lines 19-20
Why would one "not expect any cable to be greater than eighteen kilofeet in length?"  (ETI)
Request No. 458:  Plummer page 22, lines 19-20
Please explain the statement on lines 1-2 of page 23: "In Idaho, the Tech II program established the distribution area to be less than six kilofeet in length."

(a)Is this characteristic a result of the Tech II program?
(b) Is this characteristic a goal of the Tech II program.
(c)Is this characteristic a condition that existed prior to the Tech II program.
(d)Why is the distribution area less than six kilofeet in length?  (ETI)
Request No. 459:  Plummer page 22, lines 19-20
(a)Specify the percentages of Title 61 lines in service that are in each of the four categories of distribution areas (low, medium, high, saturated).
(b)Specify the percentages of Title 62 lines in service that are in each of the four categories of distribution areas (low, medium, high, saturated).
(c)Separately for each of the four categories, indicate the numbers of lines in service that are (a) Title 61 and (b) Title 62.  (ETI)
Request No. 460:  Plummer page 22, lines 19-20
Line 1 of page 22 indicates that Idaho's outside plant is "largely comprised of copper cable."  Quantify the "largely."  (ETI)
Request No. 461:  Plummer page 22, lines 19-20
Who conducted the November 1996 analysis at whose directive?  Please provide any and all written documentation that provides guidance as to the scope and/or reason for undertaking the outside plant analysis.  Also indicate the frequency with which such studies are typically undertaken, e.g., annually, every five years, etc.  (ETI)
Request No. 462:  Plummer page 14, lines 16-18
What assumptions are reflected in this statement as to the costs of fiber, electronics, copper and as to the capacity being served?  Provide any and all supporting documentation.  (ETI)
Request No. 463: Vanston
Has the Company ever sought or used Mr. Vanston's advice or counsel in forecasting economic lives in connection with capital budgeting decisions?  If so please describe fully the nature of his involvement in these decisions, the acquisition in question, and the dates of such consultation.   (ETI)
Request No. 464: Wozniak page 5, lines 9-10
List separately by product any and all price reductions in Title 62 services that US West has implemented during the last five years.  In the response, specify the rate reduction and the date of such reduction.  (ETI)
Request No. 465: Wozniak page 5, lines 9-10
List separately by product, any and all price increases in Title 62 services that US West has implemented during the last five years.  In the response, specify the rate increase and the date of such increase.  (ETI)
Request No. 466: Wozniak page 12, line 7-11 and page 12, line 12-13, line 2:
Do the cost data that you reference represent separated or unseparated costs?  See the FCC's Local Competition Order 96-98 at para. 364.  Explain.  (ETI)
Request No. 467: Wozniak page 12, line 7-11 and page 12, line 12-13, line 2:
Please provide any and all "actual Idaho-specific information" that you used to "populate" AT&T's cost model and the sources of such information.  (ETI)
Request No. 468: Wozniak page 13, lines 14-16
Explain fully the universal service assistance funds (state and/or federal) to which you refer, explain the way in which the Commission should identify and quantify such assistance, and explain the relationship of such a deliberation to this proceeding.  (ETI)
Request No. 469: Wozniak 16, at lines 3-4
You indicate that approximately 24% of US West's residential lines place no intraLATA long distance calls and that nearly 62% of US West's residential lines have no vertical service features.  (ETI)
1.What percentage of US West's primary residential lines place no intraLATA long distance calls?
2.What percentage of US West's additional residential lines place no intraLATA long distance calls?
3.What percentage of US West's primary residential lines have no vertical service features?
4.What percentage of US West's additional residential lines have no vertical service features?
Request No. 470: Wozniak page 20 at lines 13 through 15
Does the $15-million figure include all custom calling and CLASS revenues?
1.Identify and quantify the total sales, marketing, customer support, and other operating costs associated with the referenced Title 62 revenue stream.  
2.Separately quantify the revenue stream associated with residence lines and the revenue stream associated with business lines.  (ETI)
Request No. 471: Barrington page 7, lines 8-17
How many equivalent local loops using “fixed” wireless were:
1.in existance, and
2.in service.
Provide average numbers for the 1995 test year and for 1996.  (BE)
DATED  at Boise, Idaho, this            day of February 1997.
______________________________________
Donald L. Howell, II
Deputy Attorney General
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