Anschutz Company and Subsidiaries - Page 20

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          conduits were added.                                                        
               Qwest’s incremental cost allocation method is described as             
          follows:  (1) Qwest allocated to the customer contracts what it             
          determined to be direct costs associated with those contracts;              
          (2) Qwest allocated to its retained assets what it determined to            
          be the direct costs associated with its retained conduits and               
          fibers; and (3) Qwest allocated what it determined to be indirect           
          costs incrementally between the customer contracts and its                  
          retained assets.  The incremental cost allocation method was used           
          for both the conduit installation projects and the IRU projects,            
          but the method varied slightly.                                             
               A.   Incremental Cost Allocation Method in the Conduit                 
                    Installation Projects                                             
               To determine what costs should be allocated to Qwest’s                 
          retained conduits in the conduit installation projects, Qwest               
          developed an incremental base rate.  By evaluating Qwest’s                  
          construction costs, Senior Vice President for Construction Daniel           
          O’Callaghan (Mr. O’Callaghan) and Qwest Assistant Vice President            
          Ronald Pearce (Mr. Pearce) determined that an incremental base              
          rate of $6,019 per conduit mile should be utilized.  The                    
          incremental base rate included:  (1) $2,376 for conduit material,           
          assuming a cost to Qwest of 45 cents per foot; (2) $370 for other           
          material related to installation; (3) $2,640 for labor                      
          attributable to the installation of the additional conduit; (4)             
          $581 for equipment costs; and (5) $53 for overhead.  The                    





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