BEFORE THE WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION

In the Matter of the Pricing Proceeding for Interconnection, Unbundled 
Elements, Transport and Termination, and Resale

In the Matter of the Pricing Proceeding for Interconnection, Unbundled 
Elements, Transport and Termination, and Resale for U S WEST COMMUNICATIONS, 
INC.,

In the Matter of the Pricing Proceeding for Interconnection, Unbundled 
Elements, Transport and Termination, and Resale for GTE NORTHWEST INCORPORATED 
	) ) ) ) ) ) ) ) ) ) ) ) ) ) )	 
		DOCKET NO. UT-960369
		
		
		DOCKET NO. UT-960370
		
		
		
		
		DOCKET NO.  UT-960371
		
		
		SHARED COMMUNICATIONS SERVICES' POST-HEARING BRIEF

Introduction
 Shared Communications Services ("SCS") submits this brief pursuant to Judge 
Stapleton's Notice in this matter dated August 4, 1997.  SCS will not attempt 
to repeat here the extensive arguments it anticipates that other parties will 
make.  Instead, SCS will identify its positions on issues of key importance to 
SCS.
 As set forth in its petition to intervene, SCS is a registered 
telecommunications company that resells services purchased from US West 
Communications, Inc. and GTE Northwest, Inc.  SCS is directly affected by cost 
methodology and pricing for interconnection, unbundled network elements, 
transport and termination, and wholesale and resale discounts.  SCS is also 
affected by number portability costing and pricing.  SCS may wish to provide 
local exchange service exclusively through resale or through a combination of 
resale and its own facilities.
Argument
I. LEGAL PARAMETERS AND ISSUES
 SCS takes no position on these issues.  
II. COST METHODOLOGY:  PRINCIPLES
 A. What should be the goal(s) of the proceeding?
 The goal of the proceeding should be to promote fair and open competition 
among facilities-based and other carriers consistent with federal and state law.
 SCS takes no position on the other issues raised in Section II.  
III. COST MODELS
 SCS takes no position on these issues.  
IV. OTHER MODEL AND INPUT ISSUES
 G. Model Validation
 No model should be adopted without validation.  
 H.  Switch Models
 SCS' preference is that switch models be based on public data and an open 
process, so that any interested person can determine what data is used and how 
it is used.  SCS also recognizes the importance of using data that is current 
and is company-specific.  If the Commission determines that fully public data 
cannot be used consistent with these principles, SCS would support use of 
"proprietary" data if that data were made available to interested persons who 
agreed to be bound by the terms of a protective order.  The Commission should 
be highly skeptical of any process that would allow an incumbent LEC to control 
the selection and input of data, without any meaningful opportunity for 
oversight by interested persons.  See generally TR vol. 18, page 310 L.9 - 311 
L.13 Citations to the transcript in this brief refer to the volume, page and 
line numbers contained in the electronic version of the transcript that was 
provided by the Commission. (Ms. Dodds).
 SCS takes no position on the other issues raised in Section IV.  
V. AVOIDED COSTS
  SCS takes no position on these issues.  
VI. NON-RECURRING CHARGES
 In order to protect the emergent competitive environment in the 
telecommunications industry, it is crucial that non-recurring charges be 
limited to actual cost.  Non-recurring charges imposed by a carrier such as U S 
West are a significant barrier to entry for new entrants because they 
discourage customers from moving their business to a new provider.  See TR vol. 
18, page 29 L.5 - 30 L.7 (Dr. Zepp).
 SCS takes no position on the other issues raised in Section VI.  
VII. DEAVERAGING COSTS
 SCS takes no position on these issues.  
VIII. COLLOCATION
 SCS takes no position on these issues.  
IX. LOCAL NUMBER PORTABILITY 
 SCS has a strong interest in local number portability.  This is essential to 
the ability of a reseller to do business.  In evaluating the availability and 
cost of portability, it is important that costs generally associated with 
forward-looking technology not be inappropriately allocated to portability.  
See  TR. vol. 10, pages 61-62 (Dr. Cornell).  Number portability should not be 
treated as a profit center; neither profit (beyond the cost of invested 
capital) nor common costs should be recovered through permanent number 
portability.  TR vol. 15, pages 56-57 (Dr. Blackmon).  Number portability is a 
"very low cost service."   TR vol. 17, pages 62-63 (Mr. Dunkel). 
X. SIGNALLING, INTERCONNECTION/TRANSPORT AND TERMINATION
 SCS takes no position on these issues.  


XI. OTHER ISSUES
 SCS takes no position on these issues.  



 DATED this 12th day of September, 1997.

Respectfully submitted,

Preston Gates & Ellis LLP



By__________________________________
     Elizabeth Thomas, WSBA # 11544
     Beth Karan Kaye
Attorneys for Shared Communications Services


Certificate of Service
 
 
 I hereby certify that I have this day served the foregoing document upon all 
parties of record in this proceeding by mailing a copy properly addressed with 
postage prepaid to each person on the service list.
 
 Dated at Seattle, Washington this 12th day of September, 1997.
 
 
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