May 1, 1997



VIA FEDERAL EXPRESS


Mr. Steve McLellan
Secretary, Washington Utilities
  and Transportation Commission
1300 So. Evergreen Park Dr. S.W.
Olympia, Washington  98504

 Re: In re Payphone Rulemaking, Docket No. UT-970301

Dear Mr. McLellan:

 AT&T Communications of the Pacific Northwest, Inc. ("AT&T") provides the 
following comments in response to the Commission's notice of potential 
rulemaking in the above-referenced docket.

 AT&T submits that revisions to the existing rules governing payphones should 
incorporate the following general standards:
 
•Provide consumers with rights, price disclosure, and information to make 
informed decisions;

•Continue to ensure consumer access to dialtone, emergency calls, and 
telecommunications relay service for the hearing disabled be available from all 
pay phones at no charge to the caller;

•Ensure that local exchange carriers ("LECs") do not discriminate in favor of 
their own payphones in the provisioning (and rates) of basic telephone service, 
i.e., service provisioning and quality should be at parity with that which the 
incumbent LEC provides itself and the incumbent LECs must offer individual 
central office coin transmission services to all payphone providers under 
nondiscriminatory, public tariffed offerings if the LECs provide those services 
for their own operations.

 AT&T is continuing to evaluate the existing WAC provisions referenced in the 
Commission's notice, but AT&T's initial suggestions for amendment to those 
rules include, but are not necessarily limited to, the following:

480-120-137 -- This rule appears to be duplicative of WAC 480-120-138 and thus 
could be deleted.

480-120-138 -- The definition of "payphone" should be amended to reflect the 
FCC's most recent definition;

     -- All exemptions from the rule for LECs should be eliminated, and the 
rule should be revised to allow all payphone providers to compete on an equal 
basis; 

     -- Except for public interest payphones, the location provider should be 
entitled to determine if the payphone on its premise will be one or two way;

     -- The limitation of a separate access line per payphone should be 
eliminated, and providers should be allowed to aggregate more than one payphone 
per access line similar to stations behind a PBX.

 480-120-141 -- Competitive neutrality should be fostered, e.g., by modifying 
rate notification language and deleting reference to any carrier's name.

 AT&T appreciates the opportunity to provide these comments and will 
participate in the May 5 (and any future) workshop or other proceedings in this 
docket.

      Sincerely yours,

      DAVIS WRIGHT TREMAINE LLP



      Gregory J. Kopta

cc: Ron Gayman
bcc: Brooks Harlow