BEFORE THE WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION

WASHINGTON UTILITIES AND 
TRANSPORTATION COMMISSION,

                                       Complainant,

                 v.

WASHINGTON EXCHANGE 
CARRIERS ASSOCIATION, et al.,

                                       Respondent.	)
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		 DOCKET NO.  UT-971140
		
		U S WEST Motion for Clarification and/or Reconsideration
		

 U S WEST Communications, Inc. (“U S WEST”), pursuant to RCW 34.05.470 and WAC 
480-09-810, respectfully requests the Commission to clarify certain portions of 
its Fifth Supplemental Order Rejecting Tariff (the “Order”) and, depending upon 
the Commission’s clarification, would request the Commission to modify portions 
of the Order.  Specifically, U S WEST requests the Commission to clarify 
certain portions of the Order pertaining to the continuing viability of the 
Orders in Cause No. U-85-23, codified, in part at WAC 480-80-047. In support of 
this motion, U S WEST states:
 As U S WEST noted in its briefing papers, U S WEST limited its participation 
in this docket to addressing two issues.  First, U S WEST urged the Commission 
to reject WECA’s tariff filing on the basis that the tariffs were unsupported 
insofar as the WECA companies refused to allow participating parties access to 
necessary information.  Second, U S WEST requested the Commission to consider 
the continuing viability of the Orders in Cause No. U-85-23, particularly in 
light of the proceedings held in the Universal Service Docket, No. UT-980311, 
and the Access Charge Reform Docket, No. UT-970325, and changes wrought by the 
Telecommunications Act of 1996, requiring universal service subsidies to be 
equitable, non-discriminatory, specific, predictable and sufficient.  See 47 
U.S.C. 254.
 U S WEST is gratified that the Commission rejected the WECA tariff filings 
due, in part, to the WECA companies’ failure to provide sufficient back-up to 
the filings.  U S WEST also supports the Commission’s decision to address “.  
.  .  the continuing viability of the ORDERS in Cause No. U-85-23.”  Order at 
17 (emphasis in original).  U S WEST, however, needs clarification as to how 
the Commission decided to address the continuing viability of the U-85-23 
orders.  
 As U S WEST interprets the Order, the Commission apparently concluded the 
parties should begin discussions on this issue:
The Commission will require WECA, the individual company members, and 
Commission Staff, at a minimum, to begin informal discussions on a monthly 
basis to address these issues; U S WEST and AT&T, and any other party, should 
be offered the opportunity to participate in this process.  .  .  .  We expect 
the parties to submit a final report no later than April 1999.

Based upon this language, U S WEST has found at least three separate ways in 
which the Commission has decided to address the ongoing viability of the orders 
in Cause No. U-85-23. U S WEST, therefore, requests the Commission to specify 
which (if any) of these interpretations is accurate.  
 1. Cause No. U-85-23 remains viable for the foreseeable future and the 
Commission has ordered the parties to begin discussions to better implement it 
to avoid the problems raised in this docket.  If this is what the Commission 
ordered, U S WEST respectfully requests the Commission to change its decision.  
The problems with the orders in Cause No. U-85-23 are insurmountable.  The 
orders are of questionable value in light of changes in the toll market, and 
are of suspect legality.  See U S WEST Brief at 2-4.  Rather than attempt to 
fix what is unfixable, the Commission should initiate a formal process As 
alluded to above, this process could include both rulemaking and adjudication 
and could provide the framework necessary to formulate and implement a clear 
methodology for the future recovery of carrier universal service expenses.  
This would allow the Commission to integrate the heretofore separate 
considerations of access charge reform, universal service support, and the 
historical funding mechanism of U-85-23. to establish a support process more in 
concert with the goals and mandates of the Telecommunications Act of 1996.
 2. Cause No. U-85-23 is to be abandoned and the Commission has requested the 
parties to devise an acceptable and appropriate substitute.  If this is the 
Commissions’ decision, U S WEST agrees in part: the process in Cause No. 
U-85-23 should be abandoned.  U S WEST, however, submits the proper procedure 
should be a formal process, rather than informal discussions.  The orders in 
Cause No. U-85-23 have been codified; any changes thereto should take place in 
a formal, open context.
 3. The Commission has decided to replace the orders in U 85-23 but, pending 
replacement, the parties should meet to discuss how to conform to U 85-23 until 
such time as it will be replaced in a formal process.  If this is the 
Commission’s decision, U S WEST is in agreement.  U S WEST, however, urges the 
Commission to commence the process as soon as possible, in order to limit the 
artificially lengthened life of a process that has already been in place too 
long.
 If the Commission’s Order is not susceptible to any of the above 
interpretations, U S WEST respectfully requests the Commission to specify its 
exact decision as to the viability of the process implemented in Cause No. 
U-85-23.
 WHEREFORE, U S WEST respectfully requests the Commission to clarify and/or 
modify the Order in the manner requested herein.

 Dated this 9th day of November, 1998.

      U S WEST COMMUNICATIONS, INC.

      By: _________________________________
       Peter J. Butler
       Lisa A. Anderl, WSBA No. 13236