980922.docx

Q.Please state your name and address.
A.My name is Wayne Hart.  My business address is 472 West Washington, Boise, Idaho.
Q.By whom are you employed, and in what capacity?
A.I am employed by the Idaho Public Utilities Commission (IPUC; Commission) as a Telecommunications Analyst in the Telecommunications Section.
Q.Are you the same Wayne Hart who previously filed direct testimony in this proceeding?
A.Yes, I am.
Q.What is the purpose of this rebuttal testimony?
A.I will respond to concerns expressed by
U S WEST and ITA witnesses about the extent of the region, compensation and EAS bridging.
Q.On page 3 of the testimony prefiled in this case by U S WEST witness John Souba, he refers to a new “Standard” of granting EAS to an entire region.  Does Staff support such a “Standard?”
A.No.  Staff believes this issue should be decided on a case by case basis.  In this particular case, I think considering the U S WEST Treasure Valley extended calling region as a whole makes sense and equally important there is no compelling reason to do otherwise.  However, there are circumstances where this may not be the case, and Staff does not believe the Commission should limit its options in all cases to those that only consider the entire region.
Q.What about the EAS arbitrage issue he also raised on page 3?
A.EAS bridging is a valid concern, but there are ways of addressing this concern other than denying customers options that are otherwise within the public interest.  The Company now has prohibitions against EAS bridging services in its tariffs, which provide it the tools to address this potential problem in a timely manner.  Staff also believes the Company’s concerns on this issue are out of proportion to the actual risk.  It is technically possible to bridge calls between New Plymouth, which has EAS into Payette, and Ontario, which also has EAS into Payette, right now, yet Staff is not aware of any problems in this area.
Q.What about his concern about customer’s perceptions about not having the “whole thing?”
A.I don’t think that would be a significant problem, as long as they were not paying the same rates as those who do get the “whole thing.”
Q.Near the bottom of page 15 of his testimony, Mr. Souba identifies an approximate increase of 32 cents to each in-region line.  Do you agree with his calculation?
A.Not entirely.  In Mr. Souba’s calculation, the amount of the cost to be recovered is based upon the total volume of toll minutes, from both Title 61 and Title 62 customers, yet he distributes this requirement solely among Title 61 customers.  Staff was concerned that this would allow rates paid by Title 61 customers to subsidize services used by Title 62 customers.  Staff discussed this concern with U S WEST.  U S WEST asserted that the calculation of the cost shifts between Title 61 and Title 62 customers made by Ms. Wright in the rate case, Case No. USW-T-96-5, that was the basis from which the cost per minute compensation rate was developed already adjusted for the Title 61 and Title 62 redistribution.  Therefore, U S WEST took the position that since the costs and cost method already accounted for these shifts, it was not appropriate to make any further adjustment.  Staff agreed to split the difference and include half of the Title 62 lines in the calculation.  The result of this change is a decrease in the approximate increase to slightly more than 30 cents per month per in-region line.  It was also agreed that the actual calculations would be completed at the time of implementation of any extended calling area, and the number of lines used in the calculation would be updated to the most recently available data.
Q.Do you see any merit to the ideas expressed on pages 6 and 7 of the testimony of the Idaho Telephone Association’s witness, Mr. Ray Hendershot, that an extended calling region involving Payette, Washington, and portions of Adams County, hubbed on Payette and Ontario, Oregon, is a better option to including Payette, Weiser and New Plymouth in the Treasure Valley extended calling region?
A.The only relatively recent data I have concerning calling to Ontario is from Case No.
MTB-T-90-7, where the Commission denied EAS between New Plymouth and Ontario.  That calling data, which is nearly ten years old, indicates the volume of calls per line between Ontario and New Plymouth in 1990 was approximately half of the volume of calls per line in 1996 from New Plymouth to the Treasure Valley extended calling region, and in the same range as the volume of calls from Weiser to the Treasure Valley region.  That data provides at least some support to an option of a separate region hubbed by Payette and Ontario.  However, it also indicates that for many customers, especially in the New Plymouth exchange, it may not be preferred over an option that includes the Treasure Valley extended calling area.
Q.Does this conclude your rebuttal testimony in this proceeding?
A.Yes, it does.