Via Internet: bobw@wutc.wa.gov
July 31, 1997



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

 RE: Rules Review Pursuant to Executive Order 97-02
  Docket No.UT-971104

Attention:  Bob Wallis, Review Judge and Jeffrey W. Showman, Policy Specialist

Dear Mr. McLellan:

 On July 11, 1997, the Commission issued a notice that invited interested 
persons to submit written comments on the Commission rules review pursuant to 
Executive Order 97-02.  Areas for immediate comment were identified as follows:

1. Suggestions for standards to determine which rules meet the criteria in the 
Executive Order as well as suggestions for rules or chapters that need not be 
reviewed.

2. Suggestions as to specific rules that the Commission should review, 
including the reasons why the rule should be reviewed.

3. Suggestions for schedule and format for the four-year review.

Following are U S WEST Communications, Inc. (U S WEST) very preliminary 
comments:

I.  SUGGESTIONS FOR STANDARDS TO DETERMINE WHICH RULES MEET THE CRITERIA IN THE 
EXECUTIVE ORDER 

The standards identified by the Executive Order are necessity, effectiveness, 
efficiency, clarity, statutory authority, consistency with statutory intent, 
cost/benefit relationship and fairness to regulated entities.   U S WEST 
supports these standards, particularly in light of the enormous changes rapidly 
occurring in the telecommunications industry.  The Washington Administrative 
Code (WAC) has evolved over time with a predominant assumption that the 
telecommunications industry would always be regulated as a de jure monopoly.  
As a result, many rules are badly out of date.  Indeed, a strong case can be 
made for elimination of many rules.  It is critical that the Commission and the 
industry review current rules with a strong bias for eliminating any regulatory 
requirements that operate to treat competing telecommunications companies in an 
unfair way, or discriminate between companies.  WAC 480-140, WAC 480-143, WAC 
480-80 and WAC 480-120 contain numerous requirements that must be rewritten for 
clarity and for fairness to differently regulated entities.  They also contain 
requirements that are no longer effective or efficient. WAC 480-09 and WAC 
480-122 may not need to be reviewed.

II. SUGGESTIONS AS TO SPECIFIC RULES THAT THE COMMISSION SHOULD REVIEW 

Due to the press of business associated with the consolidated cost dockets, U S 
WEST has not yet had time to extensively analyze each rule for possible 
changes. U S WEST will do its best to circulate a rule by rule discussion prior 
to the workshop scheduled for August 12, 1997.


III. SUGGESTIONS FOR SCHEDULE AND FORMAT FOR THE FOUR-YEAR REVIEW.

 The schedule for rule review should prioritize the review of rule provisions 
based on the relevant standard for review.  Following is the U S WEST proposal 
for the order of a proposed priority schedule:

1. Rules that harm competition by treating competing carriers differently.
2. Rules that are inconsistent with statutory intent or are no longer 
consistent with statutory requirements. 
3. Rules that impose significant costs to either the industry or the Commission 
with little or no benefit.  

Participants should identify those rules that do not meet one of the three 
above standards or any other standard yet to be identified.  The list should 
then be consolidated and distributed to interested parties.  Participants 
should then file a proposal for the elimination, modification or addition of  
proposed rule language for each WAC.  As each rule is reviewed, proponents for 
retention of current rule provisions should address why the rule is necessary 
and whether the current rule language is effective and efficient. Suggestions 
should also include proposals for improvement of any current rule language that 
is uncertain or ambiguous.  Comments should then be consolidated and a 
determination made if a workshop or further comment cycle is necessary. 

New rules should also be considered as rules are eliminated or modified. 
Traditional rules should be replaced with more concise and relevant 
requirements.  For example, detailed tariff requirements should be re-examined 
in light of the new competitive environment.

We will be pleased to receive others' comments and correspondence in regard to 
this docket by E-Mail at:  etshaw@uswest.com.

Very truly yours,



Edward T. Shaw
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