BEFORE THE WASHINGTON UTILITIES AND TRANSPORATION COMMISSION

In the Matter of the pricing Proceeding for)
Interconnection, Unbundled Elements,)DOCKET NO.  UT-960369
Transport and Termination, and Resale)
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)
In the Matter of the pricing Proceeding for)DOCKET NO. UT-960370
Interconnection, Unbundled Element,)
Transport and Termination, and Resale for)
U S WEST Communications, Inc.)
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)
In the Matter of the pricing Proceeding for)DOCKET NO. UT-960371
Interconnection, Unbundled Elements,)
Transport and Termination, and Resale for)SPRINT’S COMMENTS TO THE 
GTE Northwest Incorporated)NINTH SUPPLEMENTAL ORDER 
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CLARIFICATION


Pursuant to the Commission’s Ninth Supplemental Order of Clarification issued 
on June 5, 1998, the following comments are submitted by Sprint Corporation on 
behalf of United Telephone Company of the Northwest (“Sprint”) and Sprint 
Communications Company, LP.

 OTHER UNBUNDLED NEWORK ELEMENT COSTS
Ninth Supplemental Order Paragraphs 34 – 44

In this section of the Ninth Supplemental Order on Clarification, the 
Commission directed the parties to file comments regarding: (1) the 
reconciliation of US West’s cost studies and the Hatfield Model with regard to 
dedicated, common and direct transport costs (para. 38); (2) UNE pricing for 
public telephones (para. 42); (3) the reconciliation of US West’s cost studies 
and the Hatfield Model regarding cost estimates for common channel signaling 
(para. 43); and (4) cost estimates for DS1 and DS3 service (para. 44).  With 
regard to these issues, Sprint believes that other parties are in a better 
position to respond. Thus, Sprint has no comment on these issues. 
 DEFERRED TAXES
Ninth Supplemental Order Paragraphs 65 - 71

 Additionally, in paragraph 71of the Ninth Supplemental Order the Commission 
directed the parties to “re-run the loop cost studies” with deferred taxes for 
the purpose of correcting the calculation error in the BCPM that effectively 
added deferred taxes rather than deducting them.  In attempting to re-run the 
BCPM, Sprint discovered that the model Sprint had filed in this proceeding had 
already been corrected for this error.   The incorrect calculation read 
C14-(D14-F14)/(1-$C$7).  (Where 14 is one of several row numbers, C is 
beginning of period capital, D is depreciation, F is deferred taxes, and $C$7 
is future net salvage).  Since deferred taxes are expressed as a negative 
figure, the effect would be to add deferred taxes.  We have confirmed that the 
calculation in the model filed by Sprint correctly reads: 
C14-(D14+F14)/(1-$C$7). This calculation is found in the folder called FACTOR 
where the CapCost.xls file is retained for each view created.  For Washington, 
the CapCost  file is labeled WACapcost.xls.  Within this file, under the tab 
called CAPITAL CALCULATION, the formula resides in column [G13 through G73].  
There is one entry for each year 1 through 60.  Therefore, no change is 
required to correct the alleged error.
We apologize if we were not clear on this matter. Neither Sprint witness 
refuted AT&T’s assertion that deferred taxes were incorrectly calculated in the 
Cap Cost Module.  Mr.Dunbar indicated during hearings that he was fully aware 
of the deferred tax error that had (earlier) been found in the Cap Cost Module 
without realizing that this error had been corrected prior to filing. Trans. 
Vol. 13, p. 1208-1209.  Throughout the proceeding Sprint advocated the use of a 
carrying charge approach rather than the use of the Cap Cost Module because of 
perceived deficiencies in the Cap Cost Module at that time. For this reason, 
Sprint did not focus on the Cap Cost Module. Judy Direct, Ex. 88 at 23, Trans. 
Vol. 13, pp. 1209-1211, 1236-1237 Judy, Sprint Brief at 61, 62. 
Incidentally, the current version of the model, BCPM 3.1, correctly applies 
deferred taxes and corrects the deficiencies that were inherent in the earlier 
version.  




Respectfully submitted this 19th day of June 1998.
 
    SPRINT CORPORATION on behalf of
    UNITED TELEPHONE COMPANY OF THE 
    NORTHWEST AND SPRINT COMMUNICATIONS
    COMPANY, LP


    ________________________
     Nancy L. Judy
    AVP External Affairs