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	)
	)
	)
	)
	)
	)
	)
	)
	)
	)
	)
	)
	)
	)	PHASE II
		
		DOCKET NOS. UT-960369, UT-960370, 
		                           UT-960371
		
		
		U S WEST’S OBJECTIONS TO PREHEARING CONFERENCE ORDER


 U S WEST Communications, Inc. (U S WEST) hereby files its objections to the 
prehearing conference order (1st Memorandum) entered in this matter on May 21, 
1998. Pursuant to WAC 480-09-460(2), objections must be filed within 10 days of 
the order.  
 The Commission convened a prehearing conference in this matter on May 18, 
1998. The conference continued off the record on May 20, 1998.  The Commission 
proposed a schedule by letter dated May 19, 1998.  That schedule was adopted by 
the Administrative Law Judge and established in the prehearing conference order 
dated May 21, 1998.  The ordered schedule is as follows:

April 16, 1998	Commission enters the Eighth Supplemental Order establishing costs
May 18, 1998	U S WEST and GTE file compliance tariffs and cost studies.  Prehearing 
conference convened.
June 11, 1998	U S WEST and GTE to file direct testimony, with overnight delivery.
June 15-22, 1998	Development of Issue List
July 10, 1998	Other parties to file responsive testimony, with overnight delivery.
July 20, 1998	Hearings for oral rebuttal of July 10 testimony and for cross 
examination of all witnesses.
July 30-31, 1998	Additional hearing dates for response to new information arising 
during first week of hearing.

OBJECTION TO SCHEDULE
 U S WEST believes that there is a substantial likelihood that this expedited 
schedule may not allow it a meaningful opportunity to participate in the 
hearings and to fully present its case.  All of the parties to this case have 
significant time and resource commitments in other telecommunications 
proceedings during the summer.  All of the parties indicated their willingness 
to schedule hearings during October.
 U S WEST can file testimony on the June 11 schedule.  However, it is unclear 
that U S WEST will be able to prepare effective oral rebuttal with only seven 
days to review the parties’ filings before the hearings.  As noted in the 
scheduling order, the parties are only required to serve their testimony by 
overnight delivery.  That means that the July 10 filing would not be received 
until July 13, 1998.  (U S WEST’s offices, and many attorneys’ offices, do not 
accept overnight deliveries on Saturday.)  Thus, even if U S WEST read all the 
testimony and prepared and served all of its data requests on July 13, 1998 
(which is not a realistic expectation), the responses to those data requests 
would not be due until July 20, 1998, which is the first day of hearing in this 
matter.  Further, this assumes that the respondent would be able to provide a 
response within five business days.  However, as U S WEST will describe below, 
the 5-day turn-around imposed by the Administrative Law Judge, without any 
limits on the volume of discovery, is unrealistic and potentially prejudicial 
to all parties.
OBJECTION TO DISCOVERY REQUIREMENTS
 Given the extraordinarily compressed schedule in this matter, some parties 
proposed a shortened timeframe in which to respond to discovery.  U S WEST 
suggested that a shortened timeframe might work so long as the number of 
discovery requests was limited.  The Administrative Law Judge ruled, on May 20, 
1998, that discovery responses would be due in five (5) business days and that 
no limit would be imposed on the number of requests.  This ruling was not made 
on the record and was not included in the prehearing conference order.  
However, if the Commission were to consider imposing these requirements, U S 
WEST will set forth its objections.
 U S WEST explained that a 5-day turn-around on responses would not be 
workable.  The time required to distribute the requests to the appropriate 
respondents, prepare draft answers, obtain and check draft answers, copy any 
attachments, approve final responses, and serve the data request responses, is 
such that five days is insufficient.  This may prejudice all parties, although 
U S WEST will certainly use its best efforts to provide timely responses.  
However, the Administrative Law Judge erred in imposing a shortened response 
time without limiting the amount of discovery.  The Administrative Law Judge 
also erred by imposing filing and hearing requirements that deny U S WEST all 
meaningful opportunity to conduct discovery on the July 10 testimony.
 U S WEST respectfully requests that the prehearing conference order and 
schedule be amended as described herein.
 Respectfully submitted this ____ day of May, 1998.

      U S WEST Communications, Inc.



      By:_______________________________
       Lisa A. Anderl, WSBA No. 13236