April 7, 1998


Paul Curl, Acting Secretary
Washington Utilities and Transportation Commission
P.O. Box 47250
Olympia, WA 98504-7250


 Re: Docket No. UT-980311 - Proposed Process and Schedule


Dear Mr. Curl:

 At the March 31, 1998 meeting in this docket, a proposed two-track process 
using rulemaking and adjudication was discussed.  In addition, a tentative 
agenda was set forth. All participants were given the opportunity to comment on 
that process and agenda on or before April 7, 1998. 

 The Washington Independent Telephone Association (WITA) offers the observation 
that perhaps a short period of time should be allowed for the parties to take a 
breath.  On March 31, 1998, it was not certain whether the Governor would sign 
or veto all or a portion of Engrossed Substitute Senate Bill 6622 addressing 
universal service issues.  We now know that the bill has been signed intact.  
This means that there are some very specific deliverables that must be 
addressed to the Legislature by November 1, 1998.  It may be helpful to focus 
on those deliverables and to determine what must be done by November 1, 1998 
and what can follow, albeit shortly, after the November 1 date.

 WITA is aware that GTE Northwest Incorporated (GTE) is submitting a detailed 
issues list dividing their issues between those that should be addressed in 
rulemaking and those that should be addressed in adjudication.  Perhaps other 
parties will be submitting issues lists as well.  WITA suggests that a workshop 
be scheduled in the very near future to develop an issues list.  Each party 
would be able to put forward their perspective of what an issues list would 
contain, and whether an issue is better addressed through adjudication or 
rulemaking.  Putting that in the context of the deliverables under Engrossed 
Substitute Senate Bill 6622 can then lead to the development of an agenda or 
time line.  WITA suggests that the afternoon of April 16 might be an 
appropriate date.  April 20 also appears to be available, as does April 23.


 In reviewing the proposed schedule, it is not at all clear at this point in 
time what the adjudicative portion of the proceeding should address or how that 
process starts.  Is the Commission intending to issue a complaint?  If the 
thought is, as expressed at the March 31, 1998 meeting, that the incumbent 
local exchange carriers will file some type of cost study demonstrating costs 
to serve high-cost areas and advocating a particular benchmark, then June 1 as 
an initial filing date is not possible to meet.  

 The Legislature has directed that an estimated cost to support all lines 
located in high-cost locations and a primary line in high-cost locations must 
be developed by November 1.  It does not appear necessary to develop final, 
actual costs.  Certainly the estimate must be reasonable, but it need not be 
established with final precision.  This may mean that an approach can be 
developed which does not require the filing of cost studies, particularly at 
such an early date.  WITA recognizes that at some point in this process, some 
sort of cost analysis will need to be done.  However, at this stage, it is not 
clear exactly what that would entail (embedded cost studies, forward-looking 
economic cost estimates, or some other approach).  Clarification of these 
issues at a workshop will help develop an appropriate process and schedule.  

 WITA also offers the caution that this Docket UT-980311 is interrelated with 
other dockets the Commission is pursuing at this time.  Certainly some of the 
issues identified by Commission Staff to be addressed in this docket overlap 
with the Cost of Universal Service and Access Reform docket, which is also 
addressing obligation to serve issues, conducted under Docket UT-970325.  
Determining the cost of universal service and any cost study information that 
would be submitted in this docket would also be affected by the Commission’s 
determinations in the minimum local calling area rulemaking docket 
(UT-970545).  Even the work in Docket UT-970380 focusing on how to target 
universal service support has some relationship with this docket.  The 
Commission must keep in mind what each of those dockets is doing and how they 
may affect one another.  It may be appropriate at some point in time to 
consider consolidation of one or more of those dockets.  

 WITA thanks the Commission for its consideration of these comments.  WITA is 
committing to do the work necessary to aid the Commission in meeting its 
obligations under Engrossed Substitute Senate Bill 6622 and to develop a 
comprehensive universal service program for Washington State.

       Sincerely,



       TERRY VANN
       Executive Vice President