BEFORE THE WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION


WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION,

                                                      Complainant,

                      v. 

U S WEST COMMUNICATIONS, INC.,

                                                      Respondent.	)
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		Docket No. UT-970010
		
		U S WEST’S ANSWER TO MOTIONS TO REJECT TARIFF FILING 

 U S WEST Communications, Inc. (U S WEST) files this answer in opposition to 
the motions to reject U S WEST’s tariff filing in this docket.  U S WEST filed 
a tariff on January 3, 1997, with a proposed effective date of February 3, 
1997,  to introduce an “Interconnection Cost Adjustment Mechanism” (ICAM).  The 
ICAM is a mechanism to allow U S WEST to recover the specially mandated network 
modification and rearrangement costs associated with opening the local markets 
to competition.  The transition fee established by the ICAM filing is to be 
assessed as a charge to new local exchange companies who interconnect with U S 
WEST, buy unbundled elements, or resell U S WEST’s services.  Alternatively, 
the fee may be assessed against individual access lines, as set forth in the 
filing.

Background
On January 23, 1997, TCG Seattle, Shared Communications Services, Inc., 
Northwest Payphone Association, Nextlink Washington, MFS Communications 
Company, MetroNet Services Corporation, MCImetro Transmission Services, Inc., 
Electric Lightwave, Inc., and AT&T Communications of the Pacific Northwest, 
Inc., (Joint Commenters) filed comments with the Commission, urging rejection 
of the tariff filing on the grounds that it was discriminatory, 
anti-competitive, and in violation of various state and federal laws.
The Commission heard opposition to the filing during its open meeting on 
January 29, 1997.  The Commission rejected the suggestion of the Joint 
Commenters that the tariff be rejected outright, and on January 29 the 
Commission entered a complaint and order suspending the tariff revisions.  The 
operation of the tariff was suspended in order to allow the Commission to 
investigate the justness and reasonableness of the rates contained therein.  
The complaint and order specifically stated that the Commission would enter 
upon public hearing or hearings concerning the changes.
The matter was set for prehearing conference on July 2, 1997.  Several parties 
requested leave to file motions to reject or dismiss the filing without 
hearing.  Pursuant to the Administrative Law Judge’s order of July 8, 1997, the 
parties were to file any such motions, and to brief those issues, before this 
matter proceeds to discovery, pre-filed testimony, and hearings.
On July 29, 1997, a new alliance of joint parties (TCG Seattle, Nextlink 
Washington, MetroNet Services Corporation, MCImetro and MCI Telecommunications 
Corp., Electric Lightwave, Inc., Sprint Communications Company L.P., and AT&T 
Communications of the Pacific Northwest, Inc.) (Joint Parties) filed a motion 
to dismiss the tariff filing on essentially the same grounds as were raised in 
the January comments.  Staff and Public Counsel have also filed motions to 
reject the tariff filing, on essentially the same grounds.
Summary of Argument
The parties who have moved to reject or dismiss this filing base their 
arguments on either a mischaracterization of the ICAM filing, or on allegations 
that rely on factual determinations that cannot be made without a hearing.  
The issues raised in opposition to this tariff filing are all issues upon which 
a hearing must be held in order to make a decision.  Opposing parties have 
stated no legal basis upon which this tariff filing may be dismissed or 
rejected without hearing.  U S WEST has a right to file this tariff and present 
its proposals to the Commission for decision on a fully developed factual 
record.  
The parties allege that the ICAM is retroactive ratemaking.  This is simply 
incorrect. U S WEST does not seek retroactive rates through a true-up, but 
rather seeks only to ensure accurate cost recovery.  In any event, this is a 
rate-design question, not a question which can or should be answered at this 
stage of the proceedings and certainly not without a hearing.  
The parties allege that the ICAM is discriminatory and is a barrier to entry.  
This too is incorrect.  The ICAM will apply to all carriers in a fair and 
non-discriminatory manner, depending upon the costs the carrier imposes on U S 
WEST.  The ICAM will not prevent entry into the local market, but will simply 
send a clear and accurate signal to new entrants about what their costs will 
be.  These are also allegations that depend upon the development of a factual 
record and therefore require a hearing.  
The parties allege that the costs U S WEST seeks to recover in the ICAM are 
costs which should be included in the TELRIC cost studies presented in the 
arbitrations or the generic cost docket.  U S WEST must be allowed an 
evidentiary hearing to address this allegation.  The costs which ICAM will 
identify and recover are not included in TELRIC, and must be recovered somehow 
in order to comply with the mandate of the Act that the LEC will recover its 
costs for interconnection and access to unbundled elements.  
U S WEST previously offered to consolidate this filing with the generic 
proceeding to assure the Commission and the parties that the costs were in fact 
different.  U S WEST absolutely commits that there will be no double recovery 
of any costs, and that costs which are included in TELRIC or otherwise 
recovered will not be a part of the ICAM costs. 
Finally, the parties allege that U S WEST has presented insufficient cost 
support for the filing.  Clearly, U S WEST is entitled to a hearing to present 
such support.  There is no requirement that the support provided at filing be 
the entire record, in fact just the opposite is true – the record sufficient to 
approve the tariff may be developed at the hearing, as provided in RCW 
80.04.130 and 80.36.140.
U S WEST is willing to waive the suspension date of December 3, 1997, for this 
tariff for an additional four months, to April 3, 1998, in order to allow the 
Commission and all the parties to complete the cost and pricing proceeding.  
This will enable the Commission to verify that the ICAM will identify 
legitimate, recoverable costs which are not included in the generic proceeding.
Argument
1. Retroactive Ratemaking
All three parties raise the issue of retroactive ratemaking as grounds for the 
Commission to reject the ICAM filing.  They are uniformly wrong about two 
things: what constitutes retroactive ratemaking and whether the ICAM fits that 
definition.  
a. The ICAM is not retroactive ratemaking
No party has provided any case law or statutory citations which clearly define, 
in Washington, the parameters of the rule against retroactive ratemaking.  
Joint parties rely heavily on the Oregon ruling (attached to Staff’s motion), 
which was premised on Oregon law and should be of no guidance to this 
Commission.  Joint commenters cite only the Oregon Attorney General’s opinion, 
which in turn cites a Rhode Island case, for a definition of retroactive 
ratemaking as the recovery of past deficits in future rates.  (Joint motion at 
page 13.)  Public Counsel defines retroactive ratemaking as the attempt to 
recoup (past or already incurred) costs that were greater than projected from 
future rates.  (Motion at page 2.)  Staff states that the rule against 
retroactive ratemaking is designed to ensure that present customers are not 
required to pay for past deficits in the future.  Staff states that the 
Commission has concluded that retroactive ratemaking occurs when a rate is 
applied to a service without prior notice and review.  (Motion at page 5, 
citing the Commission’s Sixth Supplemental Order in WUTC v. Puget Sound Power & 
Light, Docket No. U-81-41 at page 18).
U S WEST agrees that retroactive ratemaking is prohibited in Washington.  
Specifically, the Commission is authorized by statute to conduct hearings and 
to determine the rates and charges “to be thereafter observed” (emphasis 
added).  RCW 80.36.140.  Thus, it is permissible to establish rates to apply 
after the date of the hearing, and not before.  As will be seen, the ICAM 
filing does not run afoul of this rule.
The main characteristic of the filing which the parties find as evidence of 
retroactive ratemaking is the true-up mechanism proposed by U S WEST.  U S WEST 
does not believe that the true-up it proposes, to be calculated (updated) on a 
quarterly basis and at the end of three years, is evidence of retroactive 
ratemaking.
 U S WEST does not require a true-up as an essential part of the filing, and 
would be willing to forego it on the basis that the estimated costs are 
reasonably accurate.  However, it is puzzling that the new entrants would be 
willing to accept U S WEST’s calculations without the assurance of a true-up.
  Nor is the ICAM tariff itself an attempt at retroactive ratemaking.  U S WEST 
does not seek to recover past costs in future rates.  Rather, the tariff is 
designed to recoup present and ongoing costs associated with the mandated 
reconfiguration of U S WEST’s network to comply with the Telecommunications Act 
of 1996.  (See, Advice No. 2821T, at Attachment B, page 3.)
In the Puget Power case cited above, both Commission Staff and Public Counsel 
sought to have Puget’s “Energy Cost Adjustment Clause” or ECAC declared illegal 
as retroactive ratemaking.  Both raised similar arguments to those presented 
here, and cited many of the same cases.  The Commission correctly rejected 
those arguments, as it should here.  Puget’s cost recovery mechanism, and the 
true-up, involved a rate to be applied prospectively, after hearing.  The 
Commission held such a mechanism to be valid, stating that a cost adjustment 
clause is prospective, not retroactive.  The Commission specifically 
acknowledged that all ratemaking has as an element the review of actual 
historical performance, and rejected the notion that such an analysis 
necessarily implicates retroactive ratemaking.      Thus, the argument that the 
ICAM should be rejected because it includes costs incurred to reconfigure the 
network prior to the filing of the application is irrelevant at best.  The 
argument that the true-up provision is impermissible because the actual 
imposition of the rate occurs at the time of the true up and because it 
accounts for past costs and revenues must fail for the same reason.  Under 
Staff's analysis, which is patently incorrect, even a rate case, based on a 
historical test year, would be impermissible.

 
Through the ICAM filing, and the adjustments to the surcharge, all interested 
parties will have an opportunity to participate in the proceeding that 
establishes the rates to be charged.  Hearings in this matter will be held and 
concluded before the first ICAM transition fee is assessed or billed to a new 
entrant.  While these hearings will necessarily involve an analysis of U S WEST’
s historical performance, and an evaluation of costs already incurred, this is 
no more impermissible retroactive ratemaking than it was in the Puget case.
In a further discussion of what constitutes retroactive ratemaking, the 
Commission addressed this issue in U S WEST’s most recent rate case.  
(Fifteenth Supplemental Order, Docket UT-950200, 169 PUR 4th 417, April 11, 
1996.)  There, the Commission considered a recommendation by Public Counsel 
that some of U S WEST’s research and development costs be disallowed, with a 
side record kept for future recovery, with interest, if those costs are later 
shown to benefit ratepayers.  U S WEST raised the concern there that such a 
deferral and recovery might be precluded by the rule against retroactive 
ratemaking.  The Commission adopted Public Counsel’s proposal, stating “[w]e 
find no legal bar to using a side record for potential recovery.”  169 PUR 4th 
417, 458. This is clearly an allowance of recovery of past expenses, which the 
Commission did not consider to be retroactive ratemaking.  The ICAM filing 
calls for even more immediate recovery of present and ongoing costs.  The ICAM 
cannot be deemed to be retroactive ratemaking in light of this discussion.
b. The Commission is authorized to allow the recovery of ICAM expenses, 
past and present.

“The Commission notes that it has on rare occasions authorized the recovery of 
past expenses in instances where doing so is consistent with the public 
interest and sound regulatory theory. . . .  The test is . . . whether there 
are sound policy and evidentiary reasons for exercising the Commission’s 
judgment to do.”   The Commission’s description of its authority, as stated in 
the Puget decision, is applicable to this proceeding.  Examples of past 
expenses which should be recovered are legal fees, recovery of extraordinary 
weather-related expense, and expensing of investment in abandoned plant.  The 
Commission should exercise its judgment to conclude that proper cost recovery 
mandates the approval of the ICAM.  
The ICAM costs, as evidenced in this filing and as will be shown at hearing, 
are only those specially mandated costs for network rearrangements in order to 
meet the obligations imposed by the Telecommunications Act of 1996.  These 
costs, which U S WEST has no choice but to incur, benefit the new entrants and 
their subscribers, not U S WEST and not U S WEST’s ratepayers.      Public 
Counsel claims, without evidence or argument to support the contention, that U 
S WEST will also benefit from these expenditures.  U S WEST does not agree, but 
again notes that this is a matter to be determined at a hearing.
  Because U S WEST is required by law to incur these costs, and is restricted 
by law as to the rates it may charge, the law must operate consistently to 
allow recovery on the one hand of the costs it orders on the other.  While the 
Commission has discretion to order those costs recovered from all subscribers, 
or from the new entrants who benefit, there is no basis whatsoever to require U 
S WEST to recover them only from its own ratepayers or shareholders.
c. WAC 480-80-300 does not prohibit the ICAM filing.
Public Council cites WAC 480-80-300 as authority for Commission to reject any 
tariff reflecting retroactive ratemaking.  U S WEST submits that the discussion 
above amply demonstrates that the ICAM filing does not reflect retroactive rate 
treatment and that the cited provision provides no basis upon which to reject 
the filing.
2. Barrier to Entry/Discrimination.
All three parties raise the argument that the ICAM is a barrier to entry as 
well as being discriminatory.  Interestingly, for all their reliance on the 
Oregon decision cited in support of the retroactive ratemaking argument, the 
parties fail to note that the Oregon Commission considered these issues as ones 
upon which a hearing would be necessary to determine the factual underpinnings 
of the allegations.  U S WEST believes that the ICAM is neither a barrier to 
entry nor discriminatory, but agrees with the Oregon Commission that at a 
minimum there would have to be a hearing to make an affirmative determination 
on these issues. 
a. The ICAM is Not Discriminatory
The parties contend that ICAM is in violation of Washington law prohibiting 
“the practice of unreasonable preferences or discrimination in rates and 
practices.”  (RCW 80.36.170, and 80.36.180)  Specifically, the parties claim 
that in practice, the ICAM “discriminates between customers and classes of 
customers” and is not “competitively neutral.” The main thrust of their 
contention is that the ICAM penalizes early entrant CLECs over LECs who 
currently interconnect with U S WEST and are not required to pay these costs, 
as well as future CLECs who enter the market after ICAM has expired.  The 
parties suggest that this creates a competitive disadvantage and “undue 
prejudice” to current CLECs seeking to enter the market in violation of RCW 
80.36.186.  As an addendum argument, the parties allege the ICAM also allocates 
“100% of network rearrangement costs” to the CLECs alone, rather than 
apportioning the cost burden fairly among all parties involved.
The essence of a discrimination claim is that similarly situated carriers or 
customers are treated differently, and that such different treatment is 
unreasonable.  U S WEST submits that the ICAM transition fee does neither.  As 
shown in the filing itself, the ICAM seeks to recover real costs during the 
time they are incurred in a manner which accurately and reasonably reflects 
cost causation.  This is the most fair apportionment of the cost burden, as 
only those who cause the costs, and are benefited thereby, are required to pay 
the costs.  To that end, the filing distinguishes between types of carriers, 
i.e., resellers versus purchasers of unbundled elements, in a manner which 
reflects and captures the different types of costs that each will impose on U S 
WEST.  (Attachment B, page 5.)  
The notion that it is discriminatory to apply the ICAM to CLECs initially 
entering the market and not to CLECs which enter the market post-ICAM is 
unfounded.  Today’s CLEC customers are, by definition, not similarly situated 
to CLECs entering the market three years hence.      The recovery of the costs 
for constructing a bridge through a usage toll would be an analogous example.
 Furthermore, existing incumbent LECs are not given a preference either.  Their 
existing interconnection arrangements with U S WEST have not caused any 
extraordinary network rearrangement costs.  To the extent that existing 
incumbents seek to resell U S WEST’s services or to purchase unbundled 
elements, they will also be subject to the ICAM transition fee as set forth in 
the tariff.

The Eighth Circuit Court of Appeals, in its recent order vacating many of the 
FCC’s pricing and service quality rules, briefly discussed the 
nondiscrimination requirements contained in the Act.  Explaining that these 
requirements did not justify the FCC’s “superior quality service” rules, the 
Court stated that the requirement for nondiscriminatory treatment “merely 
prevents an incumbent LEC from arbitrarily treating some of its competing 
carriers differently than others. . . .”  Iowa Utilities Board v. FCC, ___ F.3d 
___, 1997 WL 403401 (8th Cir. 1997).  This is a clear and accurate statement of 
the law, and it does not implicate the ICAM filing as discriminatory in any way.
b. The ICAM is Not a Barrier to Entry  
The parties assert that the ICAM rates are very high, which they claim many 
CLECs may find it difficult, if not impossible, to pay.  Because of this, the 
parties allege the ICAM presents a barrier to entry and is anti-competitive in 
violation of both federal and state law.
In support of their positions, the parties cite 47 U.S.C. Section 253, which 
prohibits barriers to entry.  Specifically, the Act states that no state or 
local statute, regulation, or legal requirement may “prohibit or have the 
effect of prohibiting the ability of any entity to provide any interstate or 
intrastate telecommunications service.”  Staff claims that the ICAM violates 
section 253 because it would discourage entry, and because many CLECs may be 
unable to pay the ICAM rates.  Even if this were true (which cannot be 
determined without a hearing, including specific evidence of various CLECs’ 
financial situations and their ability to pay), a valid charge to recover costs 
incurred which discourages entry is not the same as a barrier to entry.  The 
magnitude of the charge cannot be used to prevent its imposition, when it 
reflects actual costs that U S WEST is entitled to recover.
The parties also rely on state law to support their claim that the ICAM is a 
barrier to entry.  However, they fare no better under state law than they did 
under federal law.  RCW 80.36.300 is the general policy statement of the State 
to promote diversity of supply of telecommunications services.  Staff claims 
that the ICAM places unreasonable economic burdens on CLECs and does not afford 
them a reasonable opportunity to compete, in violation of the statutory 
provision cited above.  Indeed, Staff notes that the Commission views its 
responsibility as one of ensuring that new entrants have a reasonable 
opportunity to compete. (Staff motion at page 7, citing the Fourth Supplemental 
Order in the Interconnection case, Docket Nos. UT-941464, et al.)
Staff’s argument must fail for at least two reasons.  First, there is no 
factual evidence in this case that any new entrant would be prevented from 
entering the market by the ICAM filing.  A hearing would be required to reach 
that conclusion, if one could.
Second, and more importantly, Staff would have the Commission rule on the 
merits of the filing without a hearing, by having the Commission conclude, with 
no evidence whatsoever, that the tariff revisions proposed in the ICAM filing 
are unreasonable.  U S WEST submits that regardless of the magnitude of the 
charges, U S WEST must be allowed to assess them, if, after hearing, the 
Commission determines that they are just and reasonable.  U S WEST’s evidence 
at hearing will establish that the costs upon which the ICAM is based are real, 
necessary, and reasonable.
In other cases, the Commission has interpreted its duty under RCW 80.36.300 as 
a neutral one, to promote diversity in the supply of telecommunications 
services, not to favor one carrier over another.  Thus, the Commission has 
rejected the notion that a carrier may cite RCW 80.36.300 as a way to avoid 
paying its fair share of network costs, regardless of whether the carrier stays 
in business as a result.  Discussing a company’s attempt to avoid paying access 
charges, the Commission held, in pertinent part, as follows:
[When Metrolink comes] into compliance with Commission laws and rules, it will 
be obliged to pay its fair share of network costs through an appropriate access 
charge. . . .Whether Metrolink will continue to be an attractive service 
alternative when its customers are required to pay all of the appropriate costs 
of service is not a matter of concern to the Commission.  While the policy of 
the state is to promote diversity in the supply of telecommunications services 
(See RCW 80.36.300), that policy falls short of a duty to underwrite or 
subsidize developing competition. . . . Metrolink has no hope of escaping its 
obligation of making an appropriate contribution toward the fixed and variable 
costs associated with accessing the public switched telecommunications network.

In the Matter of Determining the Proper Classification of U. S. Metrolink 
Corp., Docket No. U-88-2370-J, Second Supplemental Order, page 4, May 1, 1989. 
The parties also argue that ICAM is a barrier to entry because it (a) prevents 
new entrants from accurately predicting the costs associated with 
interconnection; (b) creates difficulties for new entrants in forecasting costs 
when making business decisions; and (c) “creates uncertainty” for those CLECs 
having negotiated/arbitrated interconnection agreements with U S WEST and who 
might face costs in addition to those set forth in their agreements.
While all businesses have concerns about uncertainty, these are not a basis 
upon which to reject the filing.  In fact, the ICAM will increase certainty by 
providing a mechanism for calculating and imposing the real costs of market 
entry.  The alternative is that U S WEST, who gets no benefit from the required 
network reconfigurations, bears both the uncertainty and the cost.  This does 
not withstand even minimal scrutiny under the cost recovery requirements of the 
Act or of the Constitution.
3. Consistency with Cost Recovery Provisions of Sections 251 and 252 of the 
Act. 
The Joint Parties and Public Counsel contend that the ICAM filing is in 
violation of the Act because it does not follow the methods prescribed therein 
for cost determination and recovery.  Specifically, the parties argue that the 
ICAM issues are more properly determined through a negotiation and/or 
arbitration venue, or in a generic cost docket proceeding.  Joint Parties and 
Public Counsel conclude there is no provision in the 1996 Act for recovery of 
separate and additional interconnection and unbundling costs in the manner 
proposed by the ICAM filing. 
Staff raises a similar objection in its claim of “premature filing” argument, 
stating that the ICAM filing is premature because the Commission has not yet 
determined interconnection costs in the generic cost proceeding (UT-960369).  
To support its contention, Staff raises the spectre of double recovery by 
claiming that not only has U S WEST failed to prove it is not already 
recovering these costs, but that U S WEST has not differentiated between the 
ICAM cost claims and the cost studies presented in the generic cost docket.
These arguments are not well taken, and cannot form a basis for dismissal or 
rejection of this filing.  No party describes where in the Act or the FCC’s 
rules, or any negotiated or arbitrated agreement, there is a mechanism for this 
type of cost recovery.  In fact, AT&T and MCI have opposed the recovery of what 
they refer to as “competition onset costs” in the cost docket, as well as here, 
thus leaving U S WEST no avenue for recovery, except to recover those costs 
from its own end users.      See the testimony of Dr. Zepp on behalf of 
AT&T/MCI in Docket No. UT-960369, et al.  Direct testimony, exhibit 162, pages 
22-23; rebuttal testimony, exhibit 163, page 7; Tr. 2446.
  U S WEST’s tariff filing makes it clear that these costs are not included 
elsewhere (Attachment B, page 2) and that no other mechanism exists for their 
recovery.
The Eighth Circuit’s recent decision makes it clear that if the LEC incurs 
costs to modify its network, the new entrants must pay those costs.  The Court 
specified that the new entrants are allowed access to the LECs existing network 
– not to a yet unbuilt superior one.  1997 WL 403401, *24.  The Court confirmed 
that “[u]nder the Act, an incumbent LEC will recoup the costs involved in 
providing interconnection and unbundled access from the competing carriers 
making these requests.” Id. at *21.
Furthermore, U S WEST must be allowed an evidentiary hearing to address these 
allegations.  The costs which ICAM will identify and recover are not included 
in TELRIC, and must be recovered somehow in order to comply with the mandate of 
the Act that the LEC will recover its costs for interconnection and access to 
unbundled elements.  
U S WEST previously offered to consolidate this filing with the generic 
proceeding to assure the Commission and the parties that the costs were in fact 
different.  U S WEST absolutely commits that there will be no double recovery 
of any costs, and that costs which are included in TELRIC or otherwise 
recovered will not be a part of the ICAM costs.      For example, to the extent 
that U S WEST seeks recovery in ICAM of reseller-related costs, those costs may 
in fact be addressed if the Commission establishes the proper wholesale 
discount in the generic docket.  In other words, if the Commission calculates a 
net discount, adding back wholesaling costs, there may be no need for a 
reseller charge under ICAM.
  
4. Insufficient Cost Support
The Joint Parties and Staff raise the objection that U S WEST has offered 
insufficient cost support to justify the imposition of ICAM rates.  
Specifically, the Joint Parties state that U S WEST does not define specific 
costs it seeks to recover or the revenues it will receive, and therefore the 
ICAM is unfair, unjust, and unreasonable and that U S WEST fails to link costs 
associated with OSS, rearrangement, etc., with specific CLECs and resellers.  
Staff states that there is no proof that U S WEST will even incur these costs 
at all.
 These arguments do not form a basis upon which to reject or dismiss this 
filing.  First, U S WEST did file significant, detailed cost support with its 
tariff revisions, including the following documentation:  1) an executive 
overview; 2) a summary of costs, including workpaper flow, cost workpapers, and 
calculation of return and percent intrastate; 3) source data, including an 
overview of the estimation process, the assumptions, and source data for 
detailed network and systems costs.  
Second, U S WEST is not required to file all of its testimony and evidence with 
a tariff. That is why the Commission suspended the tariff for further 
investigation and that is why parties have an opportunity to present testimony 
at hearings.  The evidentiary hearings which are required in this docket will 
provide an opportunity for proof of the costs. 
Conclusion
 The Commission should deny the motions to dismiss or reject the ICAM filing.  
The Commission should schedule another prehearing conference to establish a 
schedule for discovery, prefiled testimony, and hearings, which will allow the 
Commission to enter a final order by April 3, 1998.
Respectfully submitted this 29 th day of August, 1997.
 
     U S WEST COMMUNICATIONS, INC.

     By _____________________________
      Lisa A. Anderl, WSBA # 13236