April 7, 1998

Paul Curl, Acting Secretary
Washington Utilities and Transportation Commission
1300 S. Evergreen Park Drive, SW
P.O. Box 47250
Olympia, WA  98504-7250

RE:  UT-980311

Dear Mr. Curl:

At the Universal Service Issue meeting held in Olympia on March 31, parties 
were invited to provide comments on the procedural aspects of the Universal 
Service Docket.  United appreciates this opportunity and offers the following 
comments.

It is United’s understanding that Governor Locke has signed the USF bill in its 
entirety.  The bill calls for the Commission to report to the legislature by 
November 1, 1998 on the estimated costs to support all lines located in high 
cost areas, and the estimated cost to support only one primary line for each 
residential or business customer located in high-cost locations under a 
universal service program. Additionally, the Commission is required to report 
on steps taken toward implementation of  a universal service program as 
outlined in Section 1(2) of the bill. This new deadline will necessitate some 
modification in the schedule proposed at the March 31 meeting, and perhaps a 
change in approach as well. 

To expedite this process, United recommends that a rulemaking/workshop 
approach  be utilized to address not only administrative and procedural 
aspects, but also any policy aspects not addressed in the legislation that 
would affect cost development. It would be helpful to define the scope of the 
proceeding within the context of the USF legislation, and solicit feedback from 
the parties on an issues list delineated by those issues affecting cost 
development, and all other policy issues. The policy issues affecting costing 
could be resolved first, in order that companies could complete cost studies in 
a consistent manner.  Other issues, dealing with implementation, how funds will 
be assessed, administration, etc., could be decided on a parallel track with 
the costing work.  The advantage of this approach over the March 31 schedule, 
is that it should eliminate at least one round of cost studies.  At the same 
time an issues list is established, a timeline should be developed that would 
allow at least 3 months to prepare cost studies after resolving policy 
decisions that affect costing.  Cost studies should be completed 2 months prior 
to the November 1 deadline in the event that cost study revisions are 
required.     


Mr. Paul Curl
April 7, 1998
Page 2


There are currently several other open dockets/issues that will potentially 
affect the universal service fund, such as access reform, EAS, and the WECA 
CCL/USF filing. These issues should not affect forward-looking costs, but will 
impact the target affordability rate, or the revenue benchmark and thus will 
have a direct bearing on the size of the fund.  United proposes that a decision 
be made in October as to how each of these issues will be reflected in the 
benchmark for sizing the fund.  Hopefully, by that time the Commission will be 
closer to resolution on the peripheral issues. 

The appropriateness of the cost studies could be decided through an 
adjudicative process  (ideally, stipulation) once the cost studies are 
completed.  Even if the cost proceedings become protracted, the Commission 
should be able to fulfill its obligation to supply the legislature with cost 
estimates (for instance, by averaging the range of costs that are proposed by 
parties).

Hopefully, these suggestions will be useful to the Administrative Law Judge.  

Sincerely,



Nancy Judy


cc:  Bob Wallis