September 22, 1997       


Steve McLellan, Secretary
Washington Utilities and Transportation Commission
1300 S. Evergreen Park Drive S.W.
P.O. Box 47250
Olympia, Washington 98504-7250

Re: Comments of GTE Northwest; Docket No. A-970591

Dear Mr. McLellan:

This letter will serve as the comments of GTE Northwest in this docket.  GTE 
appreciates the Commission’s willingness to entertain constructive comments 
regarding the potential revision of the Commission’s procedural rules.

GTE has already submitted comments on July 31, 1997, in Docket No. A-971104 
regarding the impact of Governor Locke’s recent Executive Order, and GTE will 
not repeat those comments here.  GTE does desire to address, however, one 
provision identified in the Staff Proposal attached to the Notice for this 
Docket.  This is WAC 480-09-520.

As Staff correctly notes, GTE -- and other members of the telecommunications 
industry --urged the Commission to broaden the scope of WAC 480-09-520 in 
Docket No. A-950243. GTE continues to urge the Commission to expand the scope 
of that procedure.  GTE incorporates into these comments the comments it 
offered in Docket No. A-950243.

Without repeating those observations in detail, WAC 480-09-520 could 
productively be modified in at least two regards.  First, there is nothing in 
the statute which mandates that these abbreviated procedures be limited to 
petitions under RCW 80.36.320 and 80.36.330. To the degree that these 
procedures are helpful, they should be utilized in any of the types of 
proceedings identified in RCW 80.36.145(2).  Second, there is nothing in the 
statute which restricts the use of these shortened procedures to proceedings 
which do not involve confidential material.  As telecommunications becomes a 
more competitive business, parties  will  need to  be  able to  submit  
material  which  contains  valuable  competitive
information.  Companies must be able to keep such information confidential.  
Since the procedure under WAC 480-09-520 involves issues which are likely to be 
non-controversial, there is no good reason to exclude consideration of 
confidential information.

Ten copies of these comments, and an electronic copy, will accompany the 
original of this document.  Thank you in advance for your consideration in this 
matter.

Sincerely,



Timothy J. O’Connell
Attorney

Enclosures