Docket UT-970325
October 8, 1997
Page 1

Agenda: October 8, 1997
Item:  

Docket: UT-970325
Company: AT&T Communications of the Pacific Northwest, Inc.
“Petition for Investigation into the Cost of Universal Service
and to Reform Intrastate Carrier Access Charges”


Staff:  Tim Zawislak, Policy Research Specialist
  Glenn Blackmon, Assistant Director-Telecommunications


Recommendation:

1. Grant the Petition to Commence an Investigation (via the Rulemaking Process).

2. Direct the Secretary to file a Preproposal Statement of Inquiry (CR-101) 
with the Code Reviser in Docket UT-970325.

3. Encourage industry participation in the potential rulemaking and data 
collection efforts that will be needed to address Universal Service and Access 
Charge Reform at the Washington Intrastate level.


Discussion:

On August 8, 1997, AT&T Communications of the Pacific Northwest, Inc. (“AT&T”), 
filed a Petition for Investigation into the Cost of Universal Service and to 
Reform Intrastate Carrier Access Charges (“Petition”).  The Petition outlines 
relevant information, describes some of the recent and historical developments 
used to address these issues, and seeks relief in various ways. A copy of the 
Petition can be obtained through the Commission’s Record Center.

Although staff does not totally agree with everything in AT&T’s Petition, it 
does, in staff’s opinion, logically relate Universal Service with Access Charge 
Reform as “inextricably intertwined”.  Given this interconnectedness of issues, 
and the need for states to identify and remove implicit subsidies and to 
develop intrastate cost studies and funding mechanisms, staff also believes 
that AT&T’s Petition is a good launching pad to develop the long awaited 
competitively neutral rules for Universal Service and Access Charges in 
Washington state.
In fact, several industry participants have recently acknowledged the need for 
Universal Service and Access Charge Reform, and most favor a “global” approach, 
similar to the process that AT&T has now formally proposed.

Given that staff is recommending a “Preproposal Statement of Inquiry (see 
CR-101) into a potential rulemaking, all parties will have plenty of 
opportunity to file comments, participate in

workshop(s), and air the issues to the fullest extent.  However, as staff has 
also recommended, data collection efforts will also be important and encouraged 
for all industry participants to become involved and to contribute toward an 
effective outcome.

Staff therefore recommends that the Commission grant the petition to commence 
an investigation (via the rulemaking process) and to direct the Secretary to 
file a Preproposal Statement of Inquiry (CR-101) with the Code Reviser in 
Docket UT-970325.  Staff also recommends the Commission encourage industry 
participation in the potential rulemaking and data collection efforts that will 
be needed to address Universal Service and Access Charge Reform at the 
Washington Intrastate level.