BEFORE THE
WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION

      )
Petition for Investigation into      ) DOCKET NO. UT-970325
the Cost of Universal Service and    )   
to Reform Intrastate Carrier    ) COMMENTS OF 
Access Charges     ) RAINIER CABLE, INC. ON
      ) COMMISSION STAFF
      ) REVISED PROPOSAL
________________________________) 

 These Comments are filed on behalf of Rainier Cable, Inc. (RCI).  These 
Comments are intended to address the revised proposal advanced by Commission 
Staff in the Notice of March 18, 1998. 
 RCI is a competitive local exchange carrier (CLEC) that is providing 
facilities-based competition to US WEST Communications, Inc. (US WEST) in rural 
portions of Pierce County.
 RCI believes that the proposal advanced by Commission Staff is absolutely the 
wrong direction for access reform.  
 As a CLEC investing millions of dollars to build plant to provide service on a 
facilities-based competitive venture, RCI believes that it should be able to 
recover its investment through prices charged for a variety of services, 
including access services. Under Staff’s proposal, costs for access would be 
driven to total service long-run incremental cost.  Such a move would prevent 
RCI from recovering a reasonable portion of its investment from access charges 
and make it much more difficult to continue to provide facilities-based 
competition.
 RCI is in the position where it is trying to compete with US WEST in a rural 
area.  Yet the rates for competitive purposes are US WEST’s average residential 
and business rates which do not reflect the true cost of providing service in a 
rural area. RCI believes that to benefit competition in both urban and rural 
areas, US WEST should be allowed to price residential and business services 
differently in rural areas than in urban areas.  The Commission should not 
artificially constrain US WEST’s pricing structure to statewide average local 
service rates. If this disadvantage in making a return on investment in 
facilities is compounded by driving down the ability to recover a reasonable 
portion of that investment from access service, the situation becomes virtually 
impossible.  
 RCI had ambitious plans to provide facilities-based competition to US WEST. 
This Commission has already been moving in a direction that removes the 
incentives to provide facilities-based competition.  The Commission’s decisions 
in the interconnection area appear to favor resale over facilities-based 
competition.  When the Commission’s orders in the US WEST and GTE Northwest 
Incorporated interconnection cases came out in 1996, RCI felt it had no choice 
but to stop plans for further expansion.  RCI decided that the construction of 
facilities would stop prior to completing its fully engineered design.  RCI had 
planned to engineer and construct additional facilities, but the 
interconnection orders from this Commission caused RCI to pause because of the 
poor incentives for facilities-based competition.  RCI must now consider a much 
narrower focus for facilities placement.  Adopting Commission Staff’s revised 
proposal will make it even worse.  It is further disincentive from providing 
facilities-based competition, particularly in rural areas.
 RCI urges the Commission not to adopt Staff’s proposal.


 DATED this _____ day of April, 1998.




      ___________________________________
      RICHARD A. FINNIGAN, WSBA        #6443
      Attorney for Rainier Cable, Inc.