BEFORE THE WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION In the Matter of Determining Costs ) ) Docket No. UT-980311(a) for Universal Service ) ) NEXTLINK'S PETITION TO ) INTERVENE ) Pursuant to WAC 480-09-430(1), NEXTLINK Washington, L.L.C. ("NEXTLINK") hereby petitions the Commission for leave to intervene in the above-entitled docket. As grounds for intervention, NEXTLINK states: I. The names, addresses, and telephone numbers of the persons to whom communications should be addressed on behalf of NEXTLINK are: Gregory J. Kopta Deborah Whiting Jaques DAVIS WRIGHT TREMAINE LLP Director - Regulatory 2600 Century Square NEXTLINK 1501 Fourth Avenue 1003 Montello Avenue Seattle, WA 98101-1688 Hood River, OR 97031 voice: (206) 628-7692 voice: (541) 386-6398 fax: (206) 628-7699 fax: (541) 386-6397 e-mail: gregkopta@dwt.com e-mail: djaques@nextlink.net II. NEXTLINK is a telecommunications company authorized to provide intraexchange and interexchange telecommunications services throughout Washington. NEXTLINK currently competes with U S WEST Communications, Inc. ("U S WEST") in the provision of intrastate switched and dedicated services, principally in the greater Spokane area. III. NEXTLINK has a substantial interest in the Commission's determination estimating the cost of providing telecommunications services in each area that may qualify as a high-cost location for purposes of quantifying universal service fund support. As a provider of telecommunications services in the State of Washington, NEXTLINK contributes to the existing universal service fund and will contribute to the universal service fund established in the Commission's rulemaking. Contributions to the universal service fund must match the needed revenues, which in turn, are based on the costs of providing service in qualifying areas. NEXTLINK, therefore, has a substantial interest in how those costs -- and hence the level of required contributions -- are determined, as well as the actual amount of those costs. Should NEXTLINK seek designation as an eligible telecommunications company that may draw from the universal service fund, moreover, NEXTLINK has a substantial interest in how the Commission determines or will determine the cost of providing telecommunications service in the qualifying area(s) that NEXTLINK serves. IV. The evidence to be presented by NEXTLINK, if any, will be of material value to the Commission in its determination of the issues involved in this proceeding, and NEXTLINK's intervention will not broaden those issues or delay the proceedings. WHEREFORE, NEXTLINK prays for leave to intervene as a party to this proceeding, with a right to discovery, to have notice of and appear at the taking of testimony, to produce and cross-examine witnesses, and to be heard in person or by counsel on brief and at oral argument. RESPECTFULLY SUBMITTED this _____ day of May, 1998. DAVIS WRIGHT TREMAINE LLP Attorneys for NEXTLINK Washington, L.L.C. By Gregory J. Kopta WSBA No. 20519 Deborah Whiting Jaques Director - Regulatory NEXTLINK 1003 Montello Avenue Hood River, OR 97031