BEFORE THE
WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION

Adopt a methodology for determination of just and reasonable rates for 
attachments to transmission facilities	Docket No. UT-970723


Ref: TCI Petition for Rulemaking dated April 28, 1997

Washington Water Power (WWP) provides the following comments on the proposed 
rule making by the Washington Utilities and Transportation Commission (WUTC) on 
“a methodology for determination of just and reasonable rates for attachments 
to transmission facilities.”  
The term “transmission” in the title is very limiting.  From the perspective of 
an electric utility, this would refer to facilities supporting voltages over 60 
kV.  The accounts in the formula are only for distribution facilities (those 
which are less than 60 kV).  A more universal title would be “a methodology for 
determination of just and reasonable rates for attachments to utility 
facilities.”
TCI 5.  The WUTC is not required to follow the FCC formula to the letter.  The 
formula should represent the facilities in the WUTC jurisdiction and those 
facilities may be different from those average nation-wide facilities which are 
represented by the FCC formula.  
The FCC formulas are complicated. For WWP, the calculation for TV cable 
attachments on distribution poles in the State of Washington involves
•30 items from FERC Form 1,
•11 items from studies by WWP’s Finance Department ,
•1 pole count and
•7 allocation calculations.
The 11 items from Finance are those figures that are not reported publicly.  
They include allocation of common plant, depreciation for electric plant by 
state and FERC account and accumulated deferred income tax (ADIT) allocation by 
state.
The pole count is the result of a continuous rotating field audit that WWP 
started in 1984.  The data provides an accurate count of distribution poles and 
identifies unauthorized attachments.
The 7 allocations are necessary to divide system values between states. 
The WUTC should develop a formula that is fair and clear to both licensee and 
licensor without being an administrative burden to the WUTC or the utility. 
TCI 6. WWP supports the adoption of one or more formulas to cover attachments 
of TV cable, telephone cables and telecommunications (fiber optic) cables to 
•distribution poles,
•transmission poles,
•distribution ducts and
•transmission ducts.
These formulas should be tailored to the type of user and the type of utility 
structure.  They should include the utility’s investment in the structure, the 
scarcity of the available space, the cost of alternatives and the value of the 
attachment to the licensees.  Traditionally, the FCC has based the rate on the 
utility’s original cost less depreciation.  However, the book value of older 
facilities like downtown network duct systems are considerably less than the 
cost of replacement and much less than the market value of the space. 
All revenue realized from the rental of space is treated as a reduction in the 
cost to serve the utility’s retail customers.
The Legislature intended that the playing field be level for all participants 
in telecommunications development.  This does not mean that the rates should be 
rock bottom, just that they be “fair and reasonable.”
It is not likely that any formula will eliminate complaints about rates. The 
FCC has already stated that a number of its assumptions are refutable with 
additional data.  In addition it has invited comments on major changes to its 
methodology (FCC Docket numbers 97-98 and 97-151).
WWP supports the initiation of a dialogue between the WUTC, utilities and 
telecoms in the state.  However, the FCC has two major Notice of Proposed Rule 
Makings open at this time (FCC Docket Nos. 97-98 and 97-151). Orders could be 
issued at any time and are expected no later than February 1998. There may be 
court challenges following the orders. 
It would be premature to enter too deeply into discussions, comments and rule 
making before the FCC orders are issued. 
WWP will participate in the December 3 workshop.  This will be an opportunity 
for the WUTC to better understand the positions and concerns of the parties who 
will be affected by future rate formulas and rule making for telecom 
attachments on utility structures.
Respectfully submitted this 6th day of November, 1997.
	Washington Water Power
	By: 

	Timothy J. Rahman, P.E.
	Joint Use Administrator