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Letter to IPUC - Dec 6, 1996

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from: Michael Gray

Idaho Public Utilities Commission
472 W. Washington, Statehouse
Boise, Id 83702


      Thank you for providing me with a copy of testimony and the 22 factors considered for the granting of EAS. After reading the 22 factors, I wish to express the following opinions.

County Seat Relationships
      County Seat Relationships are listed as an important factor. I tend to agree. I would suggest State Capitol Relationships would also be an appropriate consideration. Since the State of Idaho employs more people than the Counties, the EAS area should be appropriately larger to accommodate employees (spouses and children) calling work.

Economic Development
      Whenever communication increases, the economic development of the affected area should also increase. As an example, if a person is looking for a product and they do not find it in the local calling area, they may simply give up and assume it is unavailable. The wider the calling area, the more likely a customer is to find what they are looking for. In my experience, people in this state would rather pay the cost of gas to go 30 miles than to pay the long distance fees to call 30 miles.

Toll Call Density
      I previously commented on Toll Call Density in public testimony. I continue to express the opinion that Toll Call Density would be more accurately referred to as the Inverse Population Density. Population definitely has more impact on the outcome of this formula than any other parts of the formula, including Call Frequency.

Referring to the plan adopted by resolution in the Idaho Legislature in the 1993 session:

Local calling areas should include the largest appropriate community of interest that is economically feasible. The Idaho Public Utilities Commission should review existing local calling areas to determine the largest economically feasible extended area service (EAS) local calling areas and to develop policies that will achieve that expansion.

      Obviously, whatever phone plan we adopt, someone must pay for it. If we are to accomplish this resolution by including the "largest economically feasible extended area service (EAS)," then we should target areas with the lowest cost of installation and maintenance.
      Part of my concern about the Toll Call Density is the apparent disregard for cost of installation and maintenance of the phone system. In essence, the Toll Call Density formula tends to eliminate the most practical areas for EAS while providing EAS to the most expensive areas to maintain. This seems the opposite of what is expected.
      As a Computer Technician I often work on Networks. While these are not exactly like phone systems, I suggest they are quite similar.
      The cost of a network (per station) increases quite dramatically as the distance between station's increase. The increase in wire and mounting costs are just the beginning. Wire inherently loses signal strength as distances increase. This would require equipment to boost the signal strength at certain points within the system.

Phone Access Line Density
      I would suggest a formula indicating the number of phone access lines per square mile might be a better indicator of area of interest. It would certainly be a more accurate representation of the cost of phone service. People tend to associate and do business more often with other people who either share similar needs or are conveniently nearby. Those who are nearby would also tend to have some similar needs. This in itself would suggest an increased Community of Interest with an increase in Phone Access Line Density. I believe this would also be consistent with previous IPUC granting of EAS areas.
      The cost of service would be the lowest in a high density area. High Density networks also increases the possibility of low cost redundancy in the system making it more reliable and easier to maintain.
      I feel that Phone Access Line Density would be a fair assessment of the actual cost of providing phone service to the general public and thereby fulfill the resolution of the Idaho Legislature. On the other hand, Toll Call Density appears to best serve the various phone companies who see larger profits in the higher population density areas and do not want US West to "re-monopolize" the area.

In Conclusion:
      If we drew a north-south line through downtown Boise and used the current "Toll Call Density" formula, the town of Boise would remain long distance from one side to another. The "Phone Access Line Density" formula would show the need for both sides of Boise to communicate with each other. This would also point out a need for Boise, Nampa and Caldwell (Ada and Canyon Counties) to communicate as an EAS. Over 9000 signatures have requested this EAS area.

Thank You,
Michael T. Gray, mET



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