BEFORE THE WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION


In the Matter of Determining the  )
Proper Classification of:   )     DOCKET NO. UT-971515
      )
UNITED & INFORMED CITIZEN  )     
ADVOCATES NETWORK   )    
      )
________________________________)
    


DIRECT TESTIMONY OF
TOMMY C. ROSE


MARCH 30, 1998
DIRECT TESTIMONY OF
TOMMY C. ROSE - 1
Q. PLEASE STATE YOUR NAME AND BY WHOM YOU ARE EMPLOYED.
A. I am Tommy C. Rose.  I am employed by GTE Northwest Incorporated as a 
Consultant - Market Response.
Q. PLEASE DESCRIBE YOUR PROFESSIONAL BACKGROUND.
A. I have been employed by GTE Northwest or its affiliates for 19 years.  I was 
originally employed as a Traffic Facilities Engineer, and I have also held 
positions as Data Base Administrator, Technical Support Engineer, and Sales 
Engineering Manager.  I have been in my current position for five years.
Q. WHAT ARE YOUR DUTIES IN YOUR CURRENT POSITION?
A. As a Consultant - Market Response, I am responsible to coordinate GTE 
Northwest’s response to a variety of market situations.  I am also responsible 
for  monitoring companies offering new or unusual services, such as bypassing 
toll charges.
Q. HAVE YOU TESTIFIED BEFORE THIS COMMISSION PREVIOUSLY?
A. Yes.  I testified in UT-951240.
Q. PLEASE SUMMARIZE YOUR TESTIMONY.
A. I will describe how United and Informed Citizens Action Network (“U&I CAN”) 
received service from GTE.  I will describe how those services could be used to 
operate an EAS bridging service.
Q. WHAT DO YOU MEAN BY AN EAS BRIDGING SERVICE?
A. An EAS bridging service (or “EAS bridger”) takes advantage of the fact that 
some of the extended area service territories approved by this Commission 
overlap.  A good example is GTE’s Halls Lake exchange, in Lynnwood, 
Washington.  Halls Lake is in an EAS territory for Seattle; it is also covered 
by the EAS territory for Everett.  An EAS bridger obtains service in the 
overlapping exchange; using customer supplied equipment, or network services, 
the EAS bridger arranges to transfer a call from one EAS territory to the 
other.  Using this example, an EAS bridger in Halls Lake could offer a “local” 
call from Everett to Seattle -- which would appropriately, under the approved 
rate structure, be an intraLATA toll call.
Q. WHAT MAKES YOU THINK U&I CAN IS OR WAS AN EAS BRIDGER?
A. If nothing else, their own literature.  U&I CAN’s newsletter and other 
documents made clear that they were offering “free” calling throughout the 
Puget Sound area, by dialing certain numbers where they established service.  
See Ex. A.
Q. WAS THERE ANYTHING UNUSUAL ABOUT THE SERVICE U&I CAN OBTAINED FROM GTE THAT 
MAKES YOU THINK IT WAS BEING USED AS AN EAS BRIDGER?

A. Yes.  U&I CAN publicized one number in GTE’s serving territory, in Halls 
Lake.  That number was in a grouping with two other numbers, and all were 
receiving GTE’s Centranet 1000 package.  This package allows the customer to 
obtain various Centranet features of their choice.  Among the features selected 
for these lines were call transferring and forwarding capability.  In order to 
operate a Centranet line, a customer must have at least one Network Access 
Register (“NAR”).  Because NARs have an additional monthly charge, customers 
normally try to minimize the number of NARs for which they subscribe.
 In this case, the customer selected 10 NARs -- triple the maximum number we 
would normally expect.  This high number of NARs for three lines greatly 
facilitates using these lines for call transferring and forwarding purposes.
Q. WOULD THIS ARRANGEMENT PERMIT EAS BRIDGING?
A. Yes.  An EAS bridger could utilize this set up to offer call forwarding and 
transfer across EAS territories.  Obviously, using only three lines suggests 
that there is a limit to how much traffic could be accommodated through this 
“network” -- but using this many NARs for that number of lines would permit U&I 
CAN to handle many calls, certainly up to several hundred per day.
Q. DO YOU HAVE ANY FURTHER TESTIMONY AT THIS TIME?
A. At this time, no.  GTE continues to investigate this situation, however, and 
more information may be available later in these proceedings.