BEFORE THE WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION


In the Matter of the Pricing Proceeding )
for Interconnection, Unbundled Elements ) DOCKET NO. UT-960369
Transport and Termination, and Resale )
) 
)
In the Matter of the Pricing Proceeding )
for Interconnection, Unbundled Elements ) DOCKET NO. UT-960370
Transport and Termination, and Resale )
for U S WEST COMMUNICATIONS, INC. )
) 
)
In the Matter of the Pricing Proceeding )
for Interconnection, Unbundled Elements ) DOCKET NO. UT-960371
Transport and Termination, and Resale )
for GTE NORTHWEST INCORPORATED )
)




PHASE I POST-HEARING BRIEF OF
TCG SEATTLE
and
NEXTLINK WASHINGTON, L.L.C.

September 12, 1997


TABLE OF CONTENTS
Page

INTRODUCTION   1 

DISCUSSION   3 

I. LEGAL PARAMETERS AND ISSUES   3 

 A. Federal Law   3 

  The Act   4 

  FCC Local Competition Order   5 

  FCC Ameritech Michigan Order   6 

  FCC Number Portability Order   7 

  FCC Physical Collocation Order   9 

 B. Washington Law   11 

II. COST METHODOLOGY: PRINCIPLES   12 

 A. What Should Be the Goal(s) of the Proceeding?   12 

 B. How Will the Cost Models Be Used?   14 

 C. What Criteria Should the Commission Follow in Examining the Models?   15 

 D. TELRIC and Its Definition   15 

 E. Common Costs and Their Definition   18 

 F. Actual or Embedded Costs and Their Utility   18 

III. COST MODELS   19 


Page

IV. OTHER MODEL AND INPUT ISSUES   20 

 Structure Sharing   20 

 Placement Costs   21 

 Integrated Digital Loop Carrier   22 

 Capital Factors   22 

 Model Validation   23 

V. AVOIDED COSTS   25 

VI. NONRECURRING CHARGES   25 

VII. DEAVERAGING COSTS   27 

VIII. COLLOCATION   28 

IX. LOCAL NUMBER PORTABILITY   32 

X. INTERCONNECTION/TRANSPORT AND TERMINATION   33 

CONCLUSION   37 

TCG/NEXTLINK POST-HEARING BRIEF - 1
35955\18\00109.BRF/8.15.97
Seattle
INTRODUCTION
 The Federal Telecommunications Act of 1996 ("Act") was hailed as a watershed 
event when it was enacted over 18 months ago.  Unfortunately, the Act has yet 
to bear significant fruit in Washington.  TCG Seattle ("TCG") has an arbitrated 
interconnection agreement with U S WEST Communications, Inc. ("U S WEST") which 
NEXTLINK Washington, L.L.C. ("NEXTLINK") has adopted, but the prices in that 
agreement remain interim and the agreement itself continues under the cloud of 
U S WEST's complaint in federal district court. TCG operates in the service 
territory of GTE Northwest Incorporated ("GTE"), but the companies currently 
have only an interim interconnection agreement.  This proceeding presents the 
Commission with the opportunity to take an important step toward realizing the 
goals of the Act by establishing cost-based rates for interconnection, 
unbundled network elements, interim local number portability, and collocation 
-- all of which are critical aspects of effective access to, and 
interconnection with, the networks of U S WEST and GTE.
 TCG and NEXTLINK both currently provide facilities-based local exchange 
service to customers in Washington and thus offer a unique perspective on the 
issues before the Commission in this proceeding.  As facilities-based 
providers, TCG and NEXTLINK desire to rely on their own networks to the 
greatest extent possible and to limit their use of the incumbent local exchange 
companies' ("ILECs'") existing network to best control the nature and quality 
of their local exchange services.  Of course, principles of economic 
efficiency, not to mention practical constraints on capital and time, dictate 
that no firm can instantly duplicate the ILECs' networks in terms of ubiquity.  
TCG's and NEXTLINK's go