BEFORE THE WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION

In the Matter of:

MFS Communications Company, Inc.'s

Petition for Arbitration Pursuant to 47 U.S.C. Section 252(b) of the 
Interconnection Rates, Terms and Conditions with U S WEST Communications, Inc.
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In the Matter of:

TCG Seattle's

Petition for Arbitration Pursuant to 47 U.S.C. Section 252(b) of the 
Telecommunications Act of 1996
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In the Matter of the Interconnection Agreement Between :

Electric Lightwave, Inc. and U S WEST Communications, Inc. pursuant to 47 
U.S.C. Section 252	)
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		DOCKET NO.  UT-960323
		
		
		
		DOCKET NO.  UT-960326
		
		
		
		DOCKET NO.  UT-960337
		
		



DIRECT TESTIMONY OF DICK GOSSELIN

U S WEST COMMUNICATIONS, INC.


March 12,1998

U S WEST Communications
Direct Testimony of Dick Gosselin
Docket Nos. UT-960323, 960326, 960337
Page 1


Q. PLEASE STATE YOUR NAME, EMPLOYER, AND BUSINESS ADDRESS. 
A. My name is Dick Gosselin.  I am employed by U S WEST Communications ("U S 
WEST"  In my testimony, all references to U S WEST Communications, Inc., and U 
S WEST refer exclusively to the U S WEST Communications Group, Inc., and have 
no connection with the U S WEST Media Group or its subsidiaries.) as a Planning 
Specialist - Interconnection Strategies.  My business address is 700 W. Mineral 
Avenue, MN F19.10, Littleton, Colorado. 

Q. PLEASE REVIEW YOUR WORK EXPERIENCE AND PRESENT RESPONSIBILITIES. 
A. In my current responsibilities, I am a Planning Specialist in U S WEST's 
Interconnection Strategies Group which is responsible for the development of 
strategies to implement the unbundling of the U S WEST network as specified in 
the FCC's First Report and Order, Docket 96-98, and to provide technical 
support regarding unbundling issues to the U S WEST Network and Public Policy 
departments.  I have thirty five (35) years experience with three Bell 
Companies in the network department, primarily with outside plant local loop 
planning and engineering and construction. 

Q. PLEASE PROVIDE AN OVERVIEW OF YOUR TESTIMONY. 
 I am responding to two of the four items listed in the Commission’s letter of 
remand dated February 25,1998, and in the Administrative Law Judge’s notice 
dated February 26,1998.  Specifically, I will address the reasonableness of 
reserved administrative space on the eighth and fourteenth floors of the 
Seattle Main Central Office Building; and the distinction between obsolete and 
useful equipment, and between declining utilization and spare capacity for 
growth. 

Q. IN AN INITIAL ORDER, THE ADMINISTRATIVE LAW JUDGE MADE SOME PRELIMINARY 
CONCLUSIONS ABOUT THE USE OF THE ADMINISTRATIVE SPACE ON THE 8TH AND 14TH 
FLOORS OF THE SEATTLE MAIN CENTRAL OFFICE.  DO YOU HAVE ANY COMMENTS ON THAT 
USE OF SPACE? 
A. Yes, I would like to clearly and specifically define what these spaces are 
used for now and the consequences of relinquishing these spaces for other uses.

Q. DOES U S WEST NEED ADMINISTRATIVE SPACE ON MORE THAN ONE FLOOR OF A 
FOURTEEN-FLOOR CENTRAL OFFICE?
A. Yes.  Network reliability is directly related to locating technicians in 
strategic locations in the building close to where the bulk of their work 
activity occurs.  Typically, in a central office this large, it is critical to 
ensure that technicians have adequate access to equipment, test sets and 
elevators in order to respond to maintenance requests in a timely manner.  The 
loss of this space would adversely affect productivity and service response 
strategies for the Seattle Main Building.  In addition, there are numerous work 
groups in this building that have specific responsibilities that require them 
to be located on, or close to, the specific floors that they service.  The 
Seattle Main Central Office has approximately 53 technicians that work in the 
building.  The space on the fourteenth floor is primarily a conference room 
that measures 16 feet wide and 27 feet long.  This is the only room in the 
building that will accommodate a meeting of twenty to thirty employees.  The 
managers have regular training and safety meetings in this room.  This room is 
the only room in the building that is environmentally equipped to handle this 
sort of activity.  In summary, if U S WEST were mandated to relinquish these 
spaces, it would cause considerable loss of productivity and expense to conduct 
this business outside the building.  It should also be noted that if U S WEST 
were to make this room ready for collocation space, the resulting 432 square 
feet would only provide enough space for two or three CLECs. There are 
currently requests pending for in excess of 700 square feet, so all of the 
requests would not be met.

    Q. THE FLOOR PLANS SHOW THAT ON THE 8TH FLOOR THERE IS A ROOM IDENTIFIED AS 
“NETWORK SERVICES ADMINISTRATION SPACE”. PLEASE DESCRIBE WHAT THAT SPACE IS AND 
WHAT IT IS USED FOR.
A. This is a fireproof room that is 1680 square feet in size designed for use 
as an equipment installation area.  These types of rooms exist in all major 
central office buildings and are required to minimize the impact of 
installation and equipment upgrade on the switching equipment environment, and 
also help ensure the safety of the employees in the office and those performing 
the work.  The rooms are designed to handle crated 11-foot frame assemblies, 
cable ladders racks, associated hardware, cable reels, cable reel handling 
equipment, large tool boxes, cable pulling equipment, safety equipment and 
adequate space for equipment installers to work safely.  To provide a clearer 
picture of this room, I have detailed the following activities that would be 
required in a typical big installation job.  First, equipment crates are 
brought into this room.  During this period, the room needs to be closed off to 
inhibit the dust and possibility of electrostatic discharge from packing 
material.  Second, the equipment is uncrated and all packing material is 
removed from the building before the end of the work day.  Absolutely no 
combustible material is left in the building overnight.  Finally, any mock-ups 
or pre-assembly which are required are done in this room to minimize the impact 
on the switch environment.  It is important to separate these construction 
processes from the switch environment because the solid state equipment is more 
susceptible to malfunctions than the old electro-mechanical equipment.  Once 
foreign particulates lodge themselves in backplane receivers, empty slots and 
circuit pack slides, the contamination can completely ruin the circuits, cause 
severe noise on lines or cause disconnects and degrade transmission.  It should 
also be noted that the close proximity of this room to the elevators 
facilitates moving equipment in and out without creating safety hazards by the 
temporary blocking of aisle space and without having to construct temporary 
partitions for dust walls.  In summary, as this example demonstrates, the need 
for this space is critical to ongoing operations at the central office. 

    Q. IS THERE OTHER SPACE AVAILABLE IN THE SEATTLE MAIN CENTRAL OFFICE THAT 
COULD BE USED TO FULFILL THE ADMINISTRATIVE SPACE REQUIREMENTS?
    A. No.  There is no other space available in the Seattle Main Central 
Office that can be used for these purposes.
    
    Q. HAVE YOU PREPARED A NARRATIVE DESCRIPTION OF THE FLOOR SPACE IN SEATTLE 
MAIN AND THE USE OF THAT SPACE?
    A. Yes, I have.  It is attached to my testimony as confidential Exhibit 
___C (RRG-1).
    
    Q.  PLEASE DESCRIBE THE DIFFERENCE BETWEEN OBSOLETE AND USEFUL EQUIPMENT.
    A. Equipment becomes obsolete when a particular technology is no longer 
supported by manufacturers and replacement parts are no longer available, or 
when the associated service or feature can be provisioned by a replacement 
product.  The same obsolete equipment may have some useful purpose in another 
location where the demand for any compatible equipment exists and furnishing 
piece-parts may extend the life of that obsolete technology until it is 
economical to replace.
    
    Q.  DOES U S WEST STORE UNUSED OR OBSOLETE EQUIPMENT IN ITS CENTRAL OFFICES?
    A. U S WEST will in the normal course of scheduling switch and transport 
jobs leave equipment in place in some offices if the intent is to reuse that 
equipment in another location and the receiving location is not yet prepared.
    
    Q. IS THIS PRACTICE EFFICIENT AND PRACTICAL?
    A. This practice is done to save storage and transportation expense and can 
be both efficient and practical.  However, this is not done in central office 
locations where space is at a premium such as Seattle Main Central Office.
    
    Q. THE INITIAL ORDER IN THIS CASE DISCUSSES BOTH UNUSED AND UNDERUTILIZED 
EQUIPMENT.  PLEASE DESCRIBE THE DIFFERENCE BETWEEN THE TWO?
    A. Unused equipment is equipment that has been replaced by another 
technology, such as a new switch, and the old equipment has not yet been 
totally removed. Underutilized equipment is equipment that is in the process of 
being replaced, and the migration of equipment is taking place over an extended 
period of time for a variety of reasons.  One of the reasons is to avoid 
disruption of service.  This is because sometimes it is more efficient to allow 
natural attrition to vacate some equipment until fewer customers will be 
affected.  Underutilized equipment may also include equipment that is being 
“grown.”  New equipment that has been placed, such as Digital Loop Carrier, is 
built with a three to five year growth forecast.  This type of equipment 
requires spare capacity for growth which will be fully utilized during the 
equipment’s life cycle.
    
    Q. CAN UNDERUTILIZED EQUIPMENT BE CONSOLIDATED IN ORDER TO RECLAIM SPACE?
    A. Yes it can.  Such consolidation can be costly, however, and may include 
the possibility of service interruption to the customer.
    
    Q. WHAT IS REQUIRED TO CONSOLIDATE CIRCUITS IN ORDER TO ALLOW EQUIPMENT TO 
BE REMOVED FOR SPACE RECLAMATION?
    A. Under most conditions this work requires the job first to be 
engineered.  This includes inventorying of the circuits to be moved and 
inventorying the space to which the circuits will be moved.  Next, a moratorium 
is imposed on the flow-through assignment process so that no additional 
services are assigned to this transitioning equipment.  Simultaneously, all the 
identified circuits are placed on a “cut sheet.”  Once this is accomplished 
each circuit is sent to be redesigned by the circuit redesign group.  A 
cut-over schedule is then established and sent out to the departments involved, 
along with the new designs.  Finally, technicians are scheduled to perform the 
work and a release date and time is negotiated with the customer.  When all 
this has been coordinated, the circuit or circuits are cut over to the new 
equipment.
    
    Q. WHAT IS U S WEST’S CURRENT TIMETABLE FOR EVALUATING REQUESTS FOR 
PHYSICAL COLLOCATION?
    A. Evaluating normal requests for collocation depends on the type of 
collocation that is requested, i.e., virtual, physical, common or shared.  U S 
WEST can and will make every effort to analyze the requirements and space 
availability within 15 days.
    
    Q. WHEN AND IF U S WEST DETERMINES THAT A REQUEST FOR PHYSICAL COLLOCATION 
CANNOT BE MET BECAUSE OF SPACE LIMITATIONS, DOES U S WEST DENY THE REQUEST?
    A. No.  U S WEST will at that time offer other options such as common, 
virtual or shared.
    Q. IN THE CASE OF THE SEATTLE MAIN CENTRAL OFFICE, WHAT OTHER ALTERNATIVES 
ARE AVAILABLE TO A CLEC NEEDING TO HAVE PHYSICAL COLLOCATION?
    A. U S WEST can offer physical collocation in the Mutual Building which is 
connected to the Seattle Main Central Office by a tunnel.  This space is 
readily available and will meet, or exceed, all of the transmission 
requirements that are requested.  The use of this space would be very 
advantageous for several reasons.  First, it would allow the CLEC to move in 
very quickly and provide service to its customers.  Second, U S WEST will 
provide, at no cost to the CLECs, a high capacity fiber system between the two 
buildings that will ensure DS3 and DS1 service that is equivalent to what would 
be available to the CLECs if they were collocated in Seattle Main.  It should 
be noted, that if the CLECs were to locate in the Seattle Main Central Office, 
notwithstanding all the other reasons previously addressed, extensive space 
preparation would be necessary and the probable collocation locations within 
the building would require expensive in-house repeatering.  This, in turn, 
would require an electrical hand-off using coaxial transport, which is less 
than optimal, and introduces more possibility of maintenance problems.  
Additionally, as previously addressed, not all CLECs who have requested space 
could be served in the space addressed in the initial order.  Ultimately, the 
Mutual Building offers better access, superior interconnection, and adequate 
space for planned growth. 
    Q. DOES THIS CONCLUDE YOUR TESTIMONY?
    A. Yes, it does.





BEFORE THE WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION


In the Matter of:

MFS Communications Company, Inc.'s

Petition for Arbitration Pursuant to 47 U.S.C. Section 252(b) of the 
Interconnection Rates, Terms and Conditions with U S WEST Communications, Inc.
_______________________________________
In the Matter of:

TCG Seattle's

Petition for Arbitration Pursuant to 47 U.S.C. Section 252(b) of the 
Telecommunications Act of 1996
_______________________________________
In the Matter of the Interconnection Agreement Between :

Electric Lightwave, Inc. and U S WEST Communications, Inc. pursuant to 47 
U.S.C. Section 252	)
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		DOCKET NO.  UT-960323
		
		
		
		DOCKET NO.  UT-960326
		
		
		
		DOCKET NO.  UT-960337
		
		



DIRECT TESTIMONY OF MARK S. REYNOLDS

U S WEST COMMUNICATIONS, INC.

March 12, 1998




	Direct Testimony of Mark Reynolds
	Docket Nos. UT-960323, UT-960326, UT-960337
	March 12, 1998
	Page 1
	
	

Q. PLEASE STATE YOUR NAME, POSITION, EMPLOYER, AND BUSINESS ADDRESS.
A. My name is Mark S. Reynolds.  I am employed by U S WEST as Director - 
Regulatory Affairs.  My business address is Room 3208, 1600 7th Ave., Seattle, 
WA 98191.

Q. PLEASE REVIEW YOUR EDUCATION, WORK EXPERIENCE AND PRESENT RESPONSIBILITIES.
A. I have a Bachelor of Arts, in English, from Oregon State University (1977), 
and a Masters of Business Administration (1979) from the University of 
Montana.  I joined Pacific Northwest Bell in 1983 as a business sales account 
manager.  I moved to product management where I was responsible for a wide 
range of product, pricing, and costing support for PNB products and services.  
I assisted in PNB’s post-Divestiture state regulatory pricing dockets involving 
local telephone service, long distance and switched/special access services.

 I have held various director positions in costs, economic analyses, pricing, 
planning and interconnection for U S WEST Communications in the marketing and 
regulatory areas.  I was responsible for ensuring economic pricing 
relationships between and among U S WEST’s product lines, including telephone 
exchange service, long distance, and switched/special access services.  I 
represented U S WEST, both as a professional pricing policy witness, and as the 
lead company representative, in a number of state regulatory and industry 
pricing and service unbundling workshops.  I managed a staff of over 100 
employees responsible for the economic analyses and cost studies that supported 
U S WEST’s tariffed product and service prices and costs before state and 
federal regulators.

 In the recent past, I managed U S WEST’s interconnection pricing and product 
strategy and the interconnection negotiations teams that were in pursuit of 
interconnection and resale contracts with new local service providers.  Also, I 
managed U S WEST’s cost advocacy and witness group which was responsible for 
providing economic cost representation in telecommunications forums, workshops 
and regulatory proceedings.

 I am currently the Regulatory Affairs Director responsible for managing all 
wholesale oriented regulatory matters in the state of Washington.

Q. HAVE YOU PREVIOUSLY TESTIFIED?
A. I have witnessed to pricing, costs, and policy issues in regulatory 
proceedings in the states of Washington, Oregon, Colorado, Iowa, Idaho and 
South Dakota.  I have participated in interconnection, pricing and cost 
workshops sponsored by the state commissions in Washington, Oregon, Colorado, 
Nebraska, Minnesota, North Dakota, and Montana.

Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY?
A. I am responding to two of the four items listed in the Commission’s letter 
of remand dated February 25, 1998 and in the Administrative Law Judge’s Notice, 
dated February 26, 1998.  Specifically, I will address the recovery of costs 
associated with mandated reclamation, including equipment removal costs, and 
whether those costs are recovered through depreciation.  I will also address 
the reasonable timetable for U S WEST to review requests for physical 
collocation and for review of U S WEST’s denials of requests for physical 
collocation.

Q. IF “CAGED” PHYSICAL COLLOCATION IS DENIED DUE TO SPACE LIMITATIONS,  AND 
COMMON OR VIRTUAL COLLOCATION IS NOT ACCEPTABLE, WHAT OTHER ALTERNATIVES ARE 
THERE?
A. Under these conditions, U S WEST has stated it is willing to evaluate the 
Central Office for reclamation opportunities (see Exhibit 2, Page 4, Physical 
Collocation Space Determination Process and Evaluation Criteria).

Q. SHOULD U S WEST BE ALLOWED TO RECOVER THE COSTS OF RECLAIMING VACANT SPACE 
THROUGH SPECIFIC CHARGES TO THE CLECS?
A. Yes.  This Commission requires that prices be based on Total Service Long 
Run Incremental Costs (TSLRIC) for services, and Total Element Long Run 
Incremental Costs (TELRIC) for unbundled network elements.  (See, the 15th 
Supplemental Order in Docket No. UT-950200 regarding TSLRIC as a basis for 
pricing services.  In the arbitrations conducted pursuant to the 
Telecommunications Act, the Commission has approved interim rates based on 
TELRIC studies.  No party to the generic proceeding, Docket Nos. UT-960369, et 
al., including Commission Staff, has advocated anything other than a TELRIC 
methodology to establish costs as a basis for pricing.)  A fundamental tenet of 
these methodologies is that costs, and subsequently prices, be based on cost 
causation.  When U S WEST is required to remove obsolete equipment or 
consolidate working equipment to reclaim vacant space for CLECs, the CLEC is 
clearly the cost causer and should pay for the reclamation.  Furthermore, U S 
WEST is entitled to just and reasonable rates for collocation in accordance 
with Section 251(6) of the Telecommunications Act of 1996.  Reclamation for 
collocation is clearly a cost which U S WEST is entitled to recover in those 
rates.

Q. DON’T RECLAMATION CHARGES CONSTITUTE “DOUBLE-RECOVERY” IF EQUIPMENT REMOVAL 
COSTS ARE INCLUDED IN BOOK DEPRECIATION?
A. Absolutely not.  First, the cost to consolidate working equipment is not 
included in book depreciation, so there is truly no question of double-recovery 
for these costs.  Likewise, the cost of conducting an inventory of working, 
inactive, and underutilized equipment in the pursuit of vacant space are 
identifiable costs associated with interconnection rate elements (i.e., 
collocation) that are not included in book depreciation.  Finally, as I 
previously stated, this Commission ascribes to forward-looking long run 
incremental costs as the basis for prices.  Book depreciation costs are 
embedded costs that are used to establish revenue requirements, not prices.  
This means that, in the case of obsolete equipment removal, as well as other 
forms of reclamation, the costs should be based on a forward-looking 
incremental cost methodology.

Q.  IS THE USE OF EMBEDDED COSTS BEING CONSIDERED BY THE COMMISSION IN THE 
CURRENTLY PENDING INTERCONNECTION COST DOCKET (UT-960369, ET AL.)?
A. No.  Even though all of the interconnection elements discussed in the 
generic docket utilize equipment that has corresponding book depreciation 
costs, no party, including the CLECs, filed cost models based on embedded costs 
or book depreciation.  Clearly, U S WEST is entitled to cost recovery based on 
cost methodology standards that are consistent with other interconnection rate 
elements.

Q. HOW LONG DOES THE PROCESS TAKE FOR EVALUATING A REQUEST FOR PHYSICAL 
COLLOCATION?
A. The process takes 40 days; 15 days for the feasibility study and 25 days for 
planning and quote preparation.

Q. DOES U S WEST BELIEVE THIS IS A REASONABLE TIMEFRAME TO ASSESS THE 
AVAILABILITY OF SPACE IN ITS CENTRAL OFFICES AND, SUBSEQUENTLY, PLAN AND 
ESTABLISH QUOTES FOR PHYSICAL COLLOCATION?
A.  Yes.  Most requests for physical collocation require scheduling with common 
systems planners and extensive central office floor plan reviews, while some 
situations actually require physical “walk-throughs” of central offices.  
Fifteen days is certainly a reasonable period for these activities plus the 
communications that need to take place between the account representatives and 
the requesters.  Once space has been determined to be available, planning and 
engineering needs to take place regarding cable routing, racking and equipment 
placement.  Once again, 25 days is quite reasonable when considering the 
coordination of these activities for over 1,000 central offices and hundreds of 
CLEC requests throughout the U S WEST territory.  

Q. IS U S WEST AWARE OF ANY OTHER RECOMMENDATION REGARDING TIMEFRAMES FOR SPACE 
EVALUATION AND PHYSICAL COLLOCATION PLANNING IN THIS PROCEEDING?
A. Although U S WEST is certainly aware that all parties would like to have 
these issues resolved more expeditiously, no other party has provided a 
definitive timeline for these activities.  Furthermore, U S WEST believes that 
its timeframes for space evaluation and subsequent denial notification, where 
appropriate, are not the bottlenecks in this process.

Q. DOES U S WEST HAVE A POSITION ON THE PROCESS THAT THE COMMISSION SHOULD USE 
TO EVALUATE DENIALS OF SPACE FOR PHYSICAL COLLOCATION?
A.  Yes.  First, it should be noted that U S WEST has an obligation under the 
Federal Telecommunications Act and the FCC’s Rules to file its central office 
floor plans with the Commission within 20 days after it denies a request for 
physical collocation space.  U S WEST believes that if this filing remains 
unchallenged, no further action need occur.  If, however, the collocator 
challenges U S WEST’s filing, the Commission should hold fact-finding hearings 
to allow the parties to present their positions and to develop a record upon 
which findings of fact and conclusions of law can be established regarding the 
availability of space in the central office.

Q. DOES U S WEST HAVE A POSITION ON HOW LONG THIS PROCESS SHOULD TAKE AT THE 
COMMISSION? 
A. U S WEST believes that the process could be accomplished within a few 
months, particularly given that we will have refined this process as a logical 
outcome of this proceeding.  U S WEST is willing to file floor plans and a 
narrative of why the request has been denied when it makes its initial filing 
with the Commission notifying that space is not available.  If parties wanted a 
hearing, one could be scheduled expeditiously.

Q. PLEASE SUMMARIZE YOUR TESTIMONY.
A. U S WEST maintains that the Telecommunications Act, the FCC Rules, and the 
Commission Rules all support U S WEST’s recovery of space evaluation and 
reclamation costs.  This is based on the fact that these costs are 
interconnection costs, as defined by the Act, developed on a forward-looking 
long run incremental cost basis, as required by the FCC and the WUTC.  The fact 
that equipment removal costs are added to book depreciation costs have no 
bearing on the prices for interconnection elements, or for that matter, any 
services.  
 Finally, U S WEST’s 40 day timetable for evaluating requests for physical 
collocation is reasonable based on 15 days required for a feasibility study and 
25 days for the planning and engineering required to design the collocation 
installation.  

 In cases of space denial, U S WEST agrees to file the relevant central office 
floor plan, with a narrative explaining why space was denied, within 20 days of 
the notice of denial.  To the extent that this is challenged by another party, 
U S WEST would consent to an expedited proceeding.

Q. DOES THIS CONCLUDE YOUR TESTIMONY?
A. Yes.  It does.