September 8, 1998

Carole Washburn, Secretary
WUTC
Box 47250
Olympia, WA  98504    

Attn: Tom Wilson
Re: Docket UT 980311(r)


Dear Ms. Washburn:

The Washington Association of Internet Service Providers, representing 38 
Internet Service Providers across the state would like to take this opportunity 
to provide comments on a portion of the proposed Universal Service rules.

WAISP fully supports the WUTC's efforts to advance universal service throughout 
the state of Washington, and while the majority of WAISP members are not 
telecommunications carriers as defined by the Commission, they all are 
consumers of a significant amount of telecommunications products.  And perhaps 
more importantly, it is the customers of the ISPs that will gain the most from 
the proposed universal service regulations -- particularly those in rural areas.

Of particular concert to the members of WAISP are the technical standards for 
universal service fund supported lines. It is imperative that such lines be 
capable of transmitting voice at 3,500 hertz, in order to be able to also 
reliably and efficiently transmit data and allow those lines to be used to 
access the Internet.  Earlier this year, we petitioned the FCC to reconsider CC 
96-45, and we would again echo those comments here.  It would be unfortunate if 
the WUTC were to adopt lesser technical standards for rural areas than urban 
areas, just as it would be if the FCC were to do so.  

Getting reliable high-speed Internet Service to rural areas is a major concern 
for policy makers nationwide.  Indeed it is one of the most common concerns 
raised by state legislators when meeting with WAISP.  Because at this stage of 
the game, especially in rural areas, the only cost-effective way to access the 
Internet is through the switched telephone network, that network must be of 
high enough quality so that those in 

WAISP Comments to WUTC 
Docket  UT 980311(r)
9/8/98
2



underserved areas will be able to access the Internet.  In order to not 
disadvantage our rural residents who are already disadvantaged by a lack of 
high-quality telecommunications service, we must make the effort to insure that 
service is comparable between rural and urban locations.

WAISP's members believe that the Commission should not adopt, a frequency range 
for voice grade services which may impact rural Americans' ability to access 
advanced telecommunications and information services.  

Cordially,



Gary Robert Gardner
Executive Director

GRG/bhs