BEFORE THE WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION


WASHINGTON UTILITIES AND  )
TRANSPORTATION COMMISSION, ) DOCKET NO. UT-950200
      )
  Complainant,   )
      )
v.      )
      )
U S WEST COMMUNICATIONS, INC. )
      )
  Respondent.   )


RESPONSE OF AT&T AND MCI


 AT&T Communications of the Pacific Northwest, Inc. ("AT&T) and MCI 
Telecommunications Corporation ("MCI") submit the following comments in 
response to the Washington Utilities and Transportation Commission's ("the 
Commission") Request for Comments dated December 24, 1997.  In order to 
implement its decision, the following needs to occur:
 1. Rates must be established.  The Commission should accordingly direct U S 
WEST to file within ten (10) calendar days, tariffs that fully comply with the 
Fifteenth Supplemental Order.  While the Order established specific rates for 
certain services, appropriate rates for switched access and toll services have 
to be calculated.  The Commission should further direct that such filing must 
use the appropriate demand and revenue assumptions utilized by the Commission 
in its Order.  As stated in the Comments of the Interexchange Carriers on 
Compliance Filing for Fifteenth Supplemental Order dated April 30, 1996, and 
Comments of Sprint Communications Company L.P., U S WEST's Advice Nos. 2762T 
and 2763L, dated April 24, 1996, did not calculate the correct rate for 
switched access as required by the Commission.  U S WEST's Attachment B to its 
Advice Nos. 2762T and 2763L, which sets forth a revenue impact summary, 
describes an $18,356,603 difference between the Commission's and U S WEST's 
calculations for the annual revenue effect.   U S WEST stated that this amount 
was then added to switched access revenues,  resulting in a switching rate of 
over 3 cents per minute when the Order set the rate at 2 cents.  U S WEST 
withdrew these tariffs on April 30, 1996, after the Superior Court granted its 
stay of the Order.  The Commission's determinations of the revenue effect are 
summarized on page 129.  Thus, switched access revenues should be reduced $34.3 
million, and message toll services would be reduced $26.9 million.  
 2. Rate changes should be coordinated.  Once rates have been established for 
switched access, In anticipation of controversy, the Commission may wish to 
establish a short period for interested parties to comment upon the U S WEST 
rate calculations.  AT&T and MCI will be able to file price lists implementing 
their commitments to reduce their Washington State toll prices.  In addition, 
if the Commission approves increases for basic residential customers in Docket 
No. UT 970766, consideration should be given to assuring that toll reductions 
take effect at the same time as any increases
  Customer confusion would also be minimized if reductions to business rates 
were coordinated with the proposed increase of $2.00 from Docket No. UT-970766. 
by mandating these vary significant reductions in Docket No. UT 950200 in a 
timely manner with the Commission's decisions in UT 970766, Washington 
consumers would find their total telecommunications bill easier to understand 
as well as potentially unchanged or even reduced.  
 3. Refunds will be decided by the Superior Court.  At U S WEST's request over 
the objections of all the other parties (to this case), the Superior and 
Supreme Court stayed the Commission's Order pending U S WEST's appeals.  As a 
result of the Court's Stay orders, U S WEST has been collecting revenues from 
Washington ratepayers substantially in excess of revenues permitted by the 
Commission's Order.  The Supreme Court will issue its mandate to the Superior 
Court which has jurisdiction to order the refunds due as a result of the 
courts' stays of the Commission's Order.  Any Commission action must await the 
remand from the Superior Court.
 AT&T and MCI suggest the schedule as set forth above and do not believe that a 
prehearing conference is necessary.  Washington consumers have been overpaying 
for telephone service almost $100 million annually since mid-1996.  The 
Commission should give U S WEST specific directions in order to  assure that 
this situation is now, at last, remedied.
 Respectfully submitted this 2nd day of January, 1998.
MCI TELECOMMUNICATIONS CORPORATION

Rogelio E. Peņa
Senior Attorney
707 17th Street, Suite 3600
Denver, Colorado 80202
888-475-7218, ext. 91


Clyde D. McIver
Miller, Nash, Weiner, Hager & Carlsen 
4400 Two Union Square
601 Union Street
Seattle, Washington 98101-2352
206-622-8484


AT&T COMMUNICATIONS OF THE PACIFIC NORTHWEST, INC.


______________________________
Maria Arias-Chapleau
Susan D. Proctor
1875 Lawrence Street, Suite 1575
Denver, Colorado  80202
(303) 298-6164