GTE NORTHWEST INCORPORATED

DIRECT TESTIMONY OF

LIDA TONG

WUTC UT-961638


Q. PLEASE STATE YOUR NAME, ADDRESS AND PRESENT POSITION.
A. My name is Lida Tong.  My business address is 1800 41st Street, Everett, 
Washington, 98201.  I am employed by GTE Northwest Incorporated as State 
Director - External Affairs for Washington.
Q. PLEASE BRIEFLY DESCRIBE YOUR EDUCATIONAL BACKGROUND.
A. I received my B.A. Degree in Business Administration from the University of 
Southern California, in 1972.
Q. BRIEFLY DESCRIBE YOUR WORK EXPERIENCE WITH GTE.
A.. I have been employed by various GTE companies for 25 years.  For 24 of 
those years, I have held positions involving regulatory or governmental affairs.
Q. WHAT ARE THE RESPONSIBILITIES OF YOUR CURRENT POSITION?
A. I am responsible for GTE’s regulatory, governmental and industry affairs in 
the State of Washington.
Q. HAVE YOU PREVIOUSLY TESTIFIED WITH ANY REGULATORY BODIES?
A. Yes.  I have previously testified before this Commission, as well as the 
California Public Utilities Commission.
Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY?
A. The purpose of this testimony is to explain why GTE supports the tariff 
filed by  U S West Communications, which is the subject of this proceeding.  I 
will explain why any other action, other than approving that tariff, would not 
be competitively neutral.  I will address the harms which will occur if this 
Commission attempts to impose obligations which are not competitively neutral.
Q: WHAT ARE THE IMPLICATIONS OF THIS PROCEEDING?
A: The proposed Tariff Advice 2920T, which mirrors those of many other 
Washington telecommunications providers, renders any carrier of last resort 
(COLR) obligations that USWC has in the State of Washington subject to a rule 
of reasonableness.
Q: DOES THE LANGUAGE USED IN USWC’S PROPOSED TARIFF AND OTHER SIMILAR TARIFFS 
AND PRICE LISTS SATISFY THE STATUTORY REQUIREMENTS OF RCW 80.36.090?
A: Yes.  USWC’s proposed tariff makes clear that it will offer service under 
“reasonable conditions,” using “reasonable efforts,”; the tariff elaborates on 
those obligations.  By definition, any rejection of this tariff would suggest 
that USWC was required to offer service even if it were unreasonable for USWC 
to do so.  GTE does not believe that it is good public policy for this 
Commission to impose avowedly unreasonable obligations on any local exchange 
company.  Moreover, such an imposition goes far beyond the requirements of the 
statute.  I will leave for the Company’s lawyers to argue in the Company’s 
brief the implications of the wording of RCW 80.36.090.

Q: DOES THE REQUIREMENT UNDER RCW 80.36.090 THAT SERVICE BE FURNISHED ON DEMAND 
APPLY EQUALLY TO ALL TELECOMMUNICATIONS CARRIERS IN WASHINGTON?
A: Yes, RCW 80.36.090 applies equally to every telecommunications company in 
Washington.  In Docket UT-940403, the Commission found that RCW 80.36.090 
applies equally to companies that are classified as competitive.  RCW 80.36.090 
is not identified in RCW 80.36.320 or RCW 80.36.330 as a statutory provision 
which can be waived for competitive telecommunications companies or services. 
Q: COULD THE WUTC JUSTIFY ASYMMETRIC TREATMENT OF CARRIERS WITH RESPECT TO RCW 
80.36.090 ON THE BASIS OF THE COMPETITIVE CLASSIFICATIONS UNDER RCW 80.36.320 
AND 80.36.330?
A: No.  The competitive classifications under RCW 80.36.320 and 80.36.330 hinge 
on a firm’s command of market power and the general availability of alternative 
services. Market power relates to the price a carrier, absent regulatory 
constraint, could charge a customer that it would otherwise choose to serve.  
Competitive classification is a justification for treating carriers differently 
with respect to pricing flexibility.  USWC’s proposed tariff raises issues 
different than those considered in competitive classification; these tariff 
changes implicate universal service concerns.
Q: HOW SHOULD THE COMMISSION ENSURE THAT UNIVERSAL SERVICE IS MAINTAINED, EVEN 
FOR CUSTOMERS THAT A LOCAL EXCHANGE COMPANY FINDS UNREASONABLE TO SERVE?
A: The Commission must establish a separate, competitively neutral policy for 
awarding and compensating for universal service obligations.  As affirmed by 
GTE in its July 25, 1997, filing in Docket UT-971121, carriers that receive 
state universal service support should undertake service obligations that are 
consistent with the universal service objectives.  Carriers which agree to 
provide services which generate unreasonable costs should be guaranteed 
explicit support for such services from a universal service fund. The WUTC 
should address the establishment of an explicit and sufficient state universal 
service mechanism at its earliest convenience.
Q: HOW WOULD REJECTION OF THIS TARIFF IMPACT USWC, WHEN IDENTICAL LANGUAGE HAS 
ALREADY BEEN APPROVED FOR COMPETITIVE LOCAL EXCHANGE COMPANIES IN USWC’S 
SERVING AREAS?
A: USWC would, almost by definition, be placed at an enormous competitive 
disadvantage. Requiring USWC to provide service, even when it is unreasonable 
to do so, will guarantee that USWC will always have a higher cost structure 
than its competitors. Again, while I will leave legal arguments for the Company’
s lawyers in its brief, I do not understand how disparate obligations, which 
are clearly not competitively neutral, can be thought permissible in light of 
the Telecommunications Act of 1996.
Q. DOES THIS CONCLUDE YOUR TESTIMONY?
A. Yes.