BEFORE THE
WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION


                                                                                
    
       )
In the Matter of     )
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MFS COMMUNICATIONS COMPANY, INC.’S) DOCKET NO. UT-960323
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Petition for Arbitration Pursuant to 47 U.S.C.  ) 
§ 252(b) of the Interconnection Rates, Terms and ) 
Conditions with U S West Communications, Inc. )
                                                                                
    )
       )
In the Matter of     )
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TCG SEATTLE     ) DOCKET NO. UT-960326
       )
Petition for Arbitration Pursuant to 47 U.S.C. )
§ 252(b) of the Telecommunications Act of 1996. )
                                                                                
    )
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In the Matter of the Interconnection Agreement )
Between:      )
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ELECTRIC LIGHTWAVE, INC., and   ) DOCKET NO. UT-960337
U S WEST COMMUNICATIONS, INC.  )
       )
Pursuant to 47 U.S.C. § 252.    )
                                                                                
    )


REBUTTAL TESTIMONY OF HERBERT J. POZDRO ON BEHALF OF 
WORLDCOM TECHNOLOGIES, INC. 
(FORMERLY KNOWN AS MFS INTELENET, INC.)

Q. PLEASE STATE YOUR NAME, BUSINESS ADDRESS, AND EMPLOYER.
A. My name is Herbert J. Pozdro.  My business address is 1 Tower Lane, Suite 
1600, Oakbrook Terrace, Illinois, 60181.  I am employed by WorldCom 
Technologies, Inc (“WorldCom”).
Q. HAVE YOU FILED TESTIMONY IN THIS PROCEEDING ALREADY? 
A. Yes, I filed testimony on March 12, 1998.  
Q. WHAT IS THE PURPOSE OF YOUR REBUTTAL TESTIMONY?
A. I address three issues: 
(1) WorldCom’s decision to settle the dispute over physical collocation at the 
Seattle Main Central Office by collocating instead at the Mutual Building; 

(2) the reasonable timetable for U S WEST to evaluate requests for physical 
collocation and the Commission to review U S WEST’s denials of such requests; 
and 

(3) U S WEST’s recovery of space reclamation costs in the depreciation rates 
for the equipment being removed.
PHYSICAL COLLOCATION AT THE SEATTLE MAIN CENTRAL OFFICE
Q. HAS WORLDCOM WITHDRAWN ITS REQUEST FOR PHYSICAL COLLOCATION AT THE SEATTLE 
MAIN CENTRAL OFFICE?
A. Yes, it has.
Q. WHY HAS WORLDCOM DONE SO?
A. WorldCom could not wait any longer for physical collocation.  WorldCom, 
through MFS, first requested physical collocation in the Seattle Main central 
office in June of 1996.  U S WEST resisted our request and introduced untenable 
delays by litigating the issue before the Commission.  WorldCom has been unable 
to execute its business plan in Seattle during this dispute and therefore could 
not compete against U S WEST effectively.  WorldCom now has agreed to accept 
physical collocation at the Mutual Building (which includes a high-speed 
connection to Seattle Main) because further delays would seriously compromise 
our position in the Seattle local exchange market.

Q. DOES WORLDCOM STILL MAINTAIN THAT IT HAS A LEGAL RIGHT TO COLLOCATE AT 
SEATTLE MAIN?
A. Yes, it does.  WorldCom’s decision to enter a settlement on this issue does 
not represent any comment on its substantive legal position.
Q. IS PHYSICAL COLLOCATION AT THE MUTUAL BUILDING EQUAL TO PHYSICAL COLLOCATION 
AT SEATTLE MAIN?
A. No, it is not equal.  In accepting the offer of physical collocation at the 
Mutual Building, WorldCom is compromising with U S WEST in order to avoid 
further delays to its business plan.
Q. IN WHAT WAY IS PHYSICAL COLLOCATION OF LESS QUALITY AT THE MUTUAL BUILDING 
THAN AT SEATTLE MAIN?
A. Since U S WEST’s technicians will be located in Seattle Main and not in the 
Mutual Building, there is a serious risk that maintenance problems for 
collocators will not be addressed as promptly as they could be if collocators 
were in Seattle Main.  In addition, collocators in the Mutual Building will 
depend on connectivity with Seattle Main in a manner that collocators in that 
building would not.  In other words, if the line between the Mutual Building 
and Seattle Main experiences an outage, all collocators would be affected (and 
it is likely that U S WEST would not suffer similar problems at the same time).
THE REASONABLE TIMETABLE FOR EVALUATING PHYSICAL 
COLLOCATION REQUESTS AND THE TIMETABLE FOR THE COMMISSION 
TO EVALUATE DENIALS OF PHYSICAL COLLOCATION

Q. DID U S WEST ADDRESS THE REASONABLE TIMETABLE FOR IT TO EVALUATE PHYSICAL 
COLLOCATION REQUESTS IN ITS TESTIMONY?
A. Yes, Mark Reynolds, on behalf of U S WEST, addresses the reasonable 
timetable for U S WEST to evaluate requests for physical collocation.
Q. WHAT TIMETABLE DOES U S WEST FIND TO BE REASONABLE? 
A. Mr. Reynolds states that U S WEST needs 15 days for the feasibility study 
and an additional 25 days for planning and quote preparation.  Reynolds Direct, 
at 5.  The whole process would take 40 days.  Id.
Q. DOES THIS TIMETABLE CONFLICT WITH WORLDCOM’S INTERCONNECTION AGREEMENT WITH 
U S WEST?
A. Yes, it does.  As I stated in my earlier testimony, U S WEST contractually 
bound itself to perform this alleged 40-day process in 25 business days.  
Pozdro Testimony, at 6-7.  The agreement gives U S WEST “15 business days to 
confirm whether space is available at a central office in which WorldCom wishes 
to collocate.  US West then has ten business days after that period (25 days 
from the initial request) to provide WorldCom with a quote of the collocation 
costs.”  Id.
Q. DO YOU THINK U S WEST WANTS THE COMMISSION TO SANCTION ITS ABROGATION OF THE 
INTERCONNECTION AGREEMENT WITH WORLDCOM?
A. Yes, I do.  U S WEST clearly seeks to have the Commission relieve it of 
burdens that it undertook, in exchange for benefits that it received, during 
the negotiations on the agreement.  
Q. HOW SHOULD THE COMMISSION RESPOND TO U S WEST’S REQUEST?
A. The Commission should decline to unravel the interconnection agreement 
between U S WEST and WorldCom.  If the Commission wants to set a general 
timetable for U S WEST to evaluate collocation requests, it should do so 
without disturbing parties’ interconnection agreements.
Q. DO YOU HAVE ANYTHING FURTHER TO ADD REGARDING THE REASONABLE TIMETABLE FOR U 
S WEST TO EVALUATE COLLOCATION REQUESTS?
A. As I explained in my earlier testimony (at 7-10), the Commission should not 
permit U S WEST to extend the timetable for evaluating physical collocation 
requests in its interconnection agreement with WorldCom by resorting to the 
network interconnection unbundled element request (“NIUER”) process.
Q. WHAT PROCEDURE DOES U S WEST RECOMMEND THAT THE COMMISSION EMPLOY TO REVIEW 
DENIALS OF COLLOCATION REQUESTS?
A. U S WEST’s preferred procedure calls for it to submit floor plans of the 
relevant central office and a “narrative” explaining why it denied the request 
within 20 days.  Reynolds Direct, at 6-7.  If challenged by the party 
requesting physical collocation, U S WEST states that the parties can engage in 
an evidentiary hearing before the Commission.  Id., at 7.  Although U S WEST 
believes that “the process could be accomplished with a few months,” it did not 
specify a timetable for the hearing or subsequent Commission review. Id.
Q. DO YOU DISAGREE WITH U S WEST’S POSITION ON COMMISSION EVALUATION OF 
COLLOCATION DENIALS?
A. I think U S WEST is on the right track, but I stand behind the 
recommendations in my earlier testimony (at 10-11), which were as follows:
(1) within 30 days of the denial, U S WEST should: 

(a) submit floor plans and blue prints of the central office space in question;

(b) file a sworn affidavit with the Commission, attesting to the accuracy of 
the floor plans and blueprints; 

(c) allow Commission staff and the requesting collocator to conduct a 
walk-through of the entire central office;

(d) file, and serve upon the requesting collocator, the report specified in the 
Commission’s Initial Order on US West Request for Exception from Duty to 
Provide Physical Collocation (dated December 23, 1997), at 16; 

(2) within 60 days of the denial, the Commission should rule whether U S WEST 
has acted reasonably and issue whatever orders are appropriate at that time.

Taking U S WEST up on its suggestion, WorldCom supports having an expedited 
evidentiary hearing before the Commission makes its determination within 60 
days of the collocation denial.
Q. IN ADMINISTERING THESE PROCEDURES, WHAT OTHER STEPS SHOULD THE COMMISSION 
TAKE TO PROTECT REQUESTING COLLOCATORS WHOSE APPLICATIONS HAVE BEEN DENIED?
A. First, as I mentioned in my earlier testimony (at 11), the Commission should 
treat the requesting collocator’s denied application as a placeholder while it 
reviews U S WEST’s refusal to provide physical collocation.  
 Second, the Commission should not let U S WEST delay the start of the 60-day 
review process by diverting the requesting collocator’s application to 
alternative arrangements, instead of simply denying it.  My concern regarding 
this latter point stems from the statement in the direct testimony of Dick 
Gosselin (at 8) that U S WEST does not intend to deny physical collocation 
requests that cannot be met because of space limitations.  Mr. Gosselin 
indicated that instead of issuing a denial, U S WEST “will at that time offer 
other options such as common, virtual or shared.”  Id.  While WorldCom 
appreciates U S WEST’s effort to be accommodating, it worries that U S WEST 
could delay the review process by issuing what would be only a de facto 
denial.  For that reason, the Commission should treat as a denial any U S WEST 
response to a request for physical collocation that fails to offer space for 
physical collocation.
RECLAMATION OF SPACE IN US WEST’S CENTRAL OFFICES
Q. DO YOU AGREE WITH STAFF’S POSITION THAT U S WEST HAS ALREADY RECOVERED THE 
COSTS OF RECLAIMING CENTRAL OFFICE SPACE IN THE DEPRECIATION RATES FOR THE 
ASSOCIATED EQUIPMENT?
A. Yes, I do.  Future net salvage value always includes the cost of removing 
the equipment being depreciated.
Q. WHAT ABOUT U S WEST’S POSITION THAT THE COSTS OF SOME WORK FUNCTIONS 
INVOLVED IN RECLAIMING SPACE FOR PHYSICAL COLLOCATORS — SUCH AS CONSOLIDATING 
AND INVENTORYING EQUIPMENT — ARE NOT RECOVERED IN THE ALLOWANCE FOR REMOVAL 
THAT FUTURE NET SALVAGE CONTEMPLATES?
A. Again, I agree with Commission staff.  In the absence of requests for 
physical collocation, U S WEST nonetheless would incur the costs of 
consolidating and inventorying obsolete equipment simply as a cost of doing 
business.  See Reynolds Direct, at 4 (discussing the costs of consolidating and 
inventorying equipment).  Its attempt to pass those costs onto CLECs is not, as 
it suggests, justified by principles cost causation.  
Q. WHAT IS YOUR REACTION TO U S WEST’S POSITION THAT COSTS OF REMOVAL RECOVERED 
IN DEPRECIATION RATES ARE EMBEDDED AND NOT EQUIVALENT TO THE FORWARD-LOOKING 
COSTS OF RECLAIMING CENTRAL OFFICE SPACE TO WHICH U S WEST IS ENTITLED?  
(REYNOLDS DIRECT, AT 4-5)
A. I find U S WEST’s sudden interest in recovering only forward-looking costs 
to be rather self-serving.  As a practical matter, U S WEST’s objection on this 
point is not worth very much.  The forward-looking costs of reclaiming space 
are likely to be less than the embedded costs of equipment removal that are 
recovered in the depreciation rates.  So, from a forward-looking perspective, U 
S WEST is currently being over-compensated for its costs of reclaiming space.  
U S WEST cannot rely upon that fact to levy an additional charge for equipment 
removal upon parties requesting physical collocation.
Q. DOES THIS CONCLUDE YOUR TESTIMONY?
A. Yes.