1

BEFORE THE WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION
 

In the Matter of Determining Costs  ) DOCKET NO. UT-980311(a)
      )
for Universal Service    ) 



AT&T’S RESPONSE TO STAFF’S MOTION
FOR CLARIFICATION OF THIRD
SUPPLEMENTAL ORDER

 AT&T Communications of the Pacific Northwest, Inc. (“AT&T”) submits this 
response to Commission Staff’s Motion for clarification of Third Supplemental 
Order.
 Staff’s motion seeks clarification that the testimony the Commission refused 
to strike in the Third Supplemental Order will only be considered “for 
illustrative purposes.” Staff’s motion in effect seeks the same result as would 
striking the testimony and simply rehashes its earlier arguments.  
 The Commission’s stated purpose in establishing this adjudicative proceeding 
was to “produce an estimate of the size of the fund required” and “to produce 
specific universal service support to which qualifying companies will be 
eligible, at least initially.”  Prehearing Conference Order, June 3, 1998 at 
8.  The size of the fund can only be determined based upon consideration of 
such “cost-related” issues as the use and level of a benchmark, the size of the 
geographic area on which the cost estimates are to be made and the number of 
lines to be supported.   Certainly, the Commission will want to have a complete 
record, one that fully explores the impact of these various issues upon the 
size of the fund.  Its report to the legislature will only be able to discuss 
the various options along with the Commission’s recommendations on each of 
these issues, if there is support in the record in this proceeding. 
 Decisions on the “cost-related” issues which determine the size of any 
universal service fund were intended to made—and should be made—in this phase 
of the proceeding.  Staff’s motion should be denied.
 
Respectfully submitted this 13th day of August, 1998.

 
      AT&T COMMUNICATIONS
      OF THE PACIFIC NORTHWEST, INC.
 
 
 
 
      _________________________________
      Susan D. Proctor
      Maria Arias-Chapleau
      1875 Lawrence Street, Suite 1575
      Denver, CO  80202
      (303) 298-6164