USWS965v9.docx

APPENDIX TO THE MOTION
STAFF'S FOURTH PRODUCTION REQUEST
Request No. 269:  Please provide Staff with all correspondence, reports and workpapers provided to or received from the FCC and\or other state jurisdictions regarding Part 64 in 1994, 1995 and 1996. (MF)
STAFF'S FIFTH PRODUCTION REQUEST
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. 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. 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. 302:  Plummerpage 5, lines 12-13
Please provide workpapers showing the calculation of lit fiber as of
January 7, 1997.  (TC) (SL)
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. 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)
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. 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)
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)
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)
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. 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. 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. 394: Wright page 42, lines 13
When will the last amortization expense for compensated balances be booked?  (KS3)
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. 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. 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. 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. 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. 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. 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. 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. 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)
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. 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. 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.
STAFF'S SIXTH PRODUCTION REQUEST
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.
STAFF'S EIGHTH PRODUCTION REQUEST
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).
umisc\prdreq\usws965.dh9