BEFORE THE WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION


In Re Petition of 

US WEST COMMUNICATIONS, INC.

for a Declaratory Order Ending Imputation
of Revenues Derived from Transferred Yellow
Pages Publishing Business 


 DOCKET NO. UT-980948
 
 RESPONSE OF COMMISSION STAFF
 TO THE PETITION TO INTERVENE 
 OF AMERICAN ASSOCIATION OF 
 RETIRED PERSONS 
 
 The American Association of Retired Persons (AARP) has filed a petition to 
intervene in the present docket, the subject of which is US West’s petition to 
end the imputation of yellow pages revenue.  Commission Staff supports the 
motion for intervention and urges that it be granted.
 The petition for intervention states, at page 2, that
  AARP is concerned about the effect the loss of revenue from yellow page 
imputation would have on affordable telephone service.  AARP is concerned that 
ratepayers receive fair compensation for the transfer of the yellow pages.

AARP further states that it would seek to “establish the value of [the] yellow 
pages” and “see that ratepayers receive just credit for the past transfer of 
[the] yellow pages.”
 These are all matters in which AARP has a substantial interest in this 
proceeding. Furthermore, the participation of AARP would further the public 
interest.  See WAC 480-09-430(3).  AARP represents a distinct organization 
which has long been interested in the issues concerning the imputation of 
yellow page revenues, and the impact of such imputation on telecommunications 
rates.  AARP sought and was granted intervention in the 1995-97 US West rate 
case, Docket No. UT-950200, in which the imputation of yellow pages revenues 
was a central issue.  AARP provided briefing on this matter before the state 
Supreme Court.  Its intervention was proper in that proceeding and is so again 
today.  Commission Staff asks that the petition for intervention, therefore, be 
granted.
 DATED this 29th  day of September, 1998.  

      CHRISTINE O. GREGOIRE
      Attorney General



      _____________________________________
      GREGORY J. TRAUTMAN, WSBA No. 15501
      Assistant Attorney General
      Counsel for Commission Staff