USWS965v8.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
EIGHTH 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 18, 1997.
On February 11, 1997, U S WEST submitted its response to Staff's Fifth and Seventh Production Requests indicating that additional information was needed to respond to several of Staff's production requests.  This supplemental request provides the information needed.
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.
For all of the following responses, exclude the adjustments for the EAS and for the Sale of Exchanges.
Request No. 477:  Follow-up to U S WEST's Response to STF05-306
The Company indicates that it does not have the capabilities to assign a portion of the local loop to custom calling and CLASS products and that it would take as long as two weeks of programming plus an additional three or four days for processing to provide the results that Staff has requested.  
a.As an alterative and less-time consuming approach, please run the CAAS so that the value of 15% that is used in the CAAS to allocate intrastate local loop to toll is increased to 20%, and provide the resulting output for TPIS disaggregated by the following categories (CWF1; all other CWF; COE) that would be allocated to Title 61.  Staff recognizes that the results for Title 62 products would be meaningless.  
b.Please indicate if there is any reason that the results for Title 61, however, would be inaccurate and if the answer is in the affirmative, provide any and all reasons.  Include any assumptions that were necessary to conduct the run of the CAAS.  (It appears to Staff that the Company could simply rerun the CARS portion of the CAAS process for the Test Year, replacing the 15% allocation in Section C of the CARS with 20%.  If this is the case, please
perform the run, and provide copies of CARS Output Reports from sections C, D, E, and F of the CARS, in printed and electronic form.  If this suggested approach is not feasible and/or appropriate, please explain why, and perform the analysis using a different approach.)
Request No. 478:  Follow up to U S WEST's Response to STF05-304
The Company has requested additional assumptions and that the total plant being allocated add up to 100%.  Staff supplements its original data request as follows:
Please run the CAAS twice:
Run A: change the value for the CWF1 (i.e., the value in FORMULAS.XLS, at Cell E180) to 61% of its present value (see e.g., ALFI analysis worksheet in the CAASALFI.XLS file), and make no changes to the drivers or to any other inputs or assumptions.  Indicate the Title 61 and the Title 62 values in the Cable and Wire facilities that results and that corresponds with Schedule 1 of Exhibit 114 of Baldwin's direct testimony (which is from "95SALEEX.xls" Tab "95CARS").
Run B: change the value for the CWF1 to 39% of the value that is presently in the CWF1 (i.e., the value in FORMULAS.XLS, at Cell E180), leaving all drivers and assumptions unchanged, except for the following drivers.  For each of the following, replace the quantity that presently corresponds with the driver so that the value becomes 13.4 times the value that presently corresponds with the driver.  For example, if the value for the driver DALP0129 were 1000, in this run, the revised value would be 13,400.  This change should be made to the following drivers:
DALP0129
DALP0131
DALP0133
DALP0134
DALP0140
DALP0141
DALP0142
DALP0149
DALP0150
DALP0160
DALP0168
DALP0169
DALP0170
DALP0171
DALP0172
DALP0175
Note:  This list is drawn from the list of in-service DALP drivers associated with access lines, but not specifically inward- or outward- moving, from Section IV of the CAAS Manual, Page 5, amended based on the supplied ALFI spreadsheets, at Tab DT01.XLS.  If any drivers specified above are not applicable to Southern Idaho, please ignore them, and change only the appropriate ones.
Indicate the Title 61 and the Title 62 values in the Cable and Wire facilities that results that corresponds with Schedule 1 of Exhibit 114 of Baldwin's direct testimony (which is from "95SALEEX.xls" Tab "95CARS").
Request No. 479: Follow-up to STF05-308
The Company indicates that the CAAS for 1996 has not yet been processed.  When does the Company typically process the prior year's CAAS?  How many hours/days does it take for the Company to process the prior year's CAAS?
Request No. 480: Follow-up to STF05-312
Please explain the difference between the amount given for total intrastate CWF in response to part f., and the amount shown for Total Intrastate CWF on the Tab 95CARS of the file 95SALEEX.xls, provided to Staff in response to Data Request 030.  Please provide a complete accounting for all adjustments made in deriving the latter figure, by category of CWF (i.e., CWF1, CWF2, CWF2a, CWF3, and CWF4).
DATED  at Boise, Idaho, this            day of February 1997.
___________________________
Donald L. Howell, II
Deputy Attorney General
umisc\prdreq\usws965.dh8