BEFORE THE WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION


WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION,

                                       Complainant,

                       v.

U S WEST COMMUNICATIONS, INC.,

                                       Respondent.	)
	)
	)
	)
	)
	)
	)
	)
	)
	)	
		DOCKET NO.  UT-980340
		
		
		U S WEST’S REPLY BRIEF 


 U S WEST Communications, Inc. (U S WEST) hereby files this reply brief to the 
other parties’ memoranda in support of and in opposition to Staff’s Motion for 
Summary determination.
Response to AT&T, Nextlink, SCS and MCI.
 AT&T, Nextlink, SCS, and MCI all filed in support of Staff’s motion.  These 
parties suggest that U S WEST wishes to delay competition, and that the 
Commission should order 1+ dialing parity to give consumers superior quality 
service and better prices.  These parties are incorrect in a number of ways.
 U S WEST does not seek to delay competition, only to have it implemented in a 
balanced way.  Thus, U S WEST advocates that intraLATA competition should occur 
coincident with U S WEST’s ability to compete for interLATA traffic.  Further, 
these parties present no evidence in support of their claims that they would 
offer superior service, nor do they substantiate or detail how and to what 
degree prices might go down.  It is incomprehensible that these parties can 
advocate that the Commission can consider the public interest without 
considering these factors, or the revenue impact to U S WEST, but that is what 
they advocate.  U S WEST submits that these factors must be considered, and 
that the arguments raised by these parties should be rejected.
Response to Public Counsel
 U S WEST believes that Public Counsel correctly recognizes that all of the 
issues and outcomes should be considered and recommends that the Commission 
conduct a fact-finding proceeding.  U S WEST agrees, in large part, with Public 
Counsel’s recommendation. However, U S WEST believes that the Commission has 
sufficient factual information available to it concerning the potential revenue 
implications to U S WEST to resolve this issue without further investigation, 
and that resolution of this issue is not prohibited as single issue 
ratemaking.  In addition, Theresa Jensen’s Second Declaration, which is 
attached, provides additional factual information available to U S WEST 
concerning its experience in other states. If the Commission makes the decision 
to reduce U S WEST’s revenues, which have only very recently been established 
at levels which are fair, just, reasonable and sufficient, January, 1998 Tenth 
Supplemental Order in UT-970766. a Commission-ordered reduction to these 
revenues would result in insufficient revenues, as determined in Docket 
UT-970766.  As such, the decision to recover these revenues in some other way 
would not be a “rate case” type decision, and would not require a “rate case” 
type proceeding.  The Commission 

should either decline to order dialing parity, or should resolve all of the 
issues implicated in such an order, including the revenue impact issues.
 Respectfully submitted this 16th day of September, 1998.

      U S WEST Communications, Inc.


      ________________________________
      Lisa A. Anderl, WSBA No. 13236