BEFORE THE WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION


In the Matter of the Pricing proceeding for Interconnection, Unbundled 
Elements, Transport and Termination, and Resale
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In the Matter of the Pricing Proceeding for Interconnection, Unbundled 
Elements, Transport and Termination, and Resale for U S WEST COMMUNICATIONS, 
INC.
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In the matter of the Pricing Proceeding for Interconnection, Unbundled 
Elements, Transport and Termination, and Resale for GTE NORTHWEST INCORPORATED	)
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	)	PHASE II
		
		DOCKET NOS. UT-960369, UT-960370, 
		                           UT-960371
		
		
		U S WEST’S RESPONSE TO COMMISSION REQUEST TO CROSS REFERENCE TESTIMONY WITH 
ISSUES LIST AND OBJECTIONS TO CERTAIN ISSUES


 U S WEST Communication, Inc. (U S WEST) responds to the Commission’s Notice of 
Publication of Issues List; Notice of Requirement to Cross-Reference Testimony 
Filed July 9, 1998 in the above dockets.  Following is the cross-reference of U 
S WEST’s testimony to the published Issues List. 



Issues	
	Reference

Order Section IV — Transition Costs	
	¶40; 41; 523

Issue IV-1 (Legal): Does the 96 Act require the Commission to provide for 
recovery of all “transition” costs which an ILEC incurs in complying with the 
Act?	
	M. Reynolds at 9-10.
	D. Buhler at 1 and 23

Issue IV-2 (Legal): If the answer to Issue IV-1 is yes, does the Act allow the 
Commission to apply the wholesale discount to an ILEC’s transition costs?	
	U S WEST will address on brief.
 
Issue IV-3 (Legal): If the answer to Issue IV-1 is no, to what extent may the 
Commission provide for recovery of ILEC transition costs?	
	D. Buhler, generally and specifically, at 23-24.

Issue IV-4 (Policy): If the answer to Issue IV-3 is yes, to what extent should 
the Commission provide for recovery of ILEC transition costs in this proceeding?	
	D. Buhler, generally and specifically, at 23-24.

Issue IV-5 (Factual/Methodological): If the Commission decides under Issue IV-4 
that is should provide for recovery, what are U S WEST’s and GTE’s transition 
costs?	
	D. Buhler at 15-20.

Issue IV-6 (Methodological): If the Commission decides under Issue IV-4 that is 
should provide for recovery, what is the most appropriate recovery mechanism?	
	D. Buhler at 15-20.

Order Section V — Element Costs	
	¶ 20; 25; 61; 148; 152; 251; 257; 491; 525

Issue V.1 (Legal): Does the 96 Act require the Commission to provide for 
recovery of all of an ILEC’s “actual costs” through UNE Prices?	
	U S WEST will address this issue on brief.

Issue V.2 (Legal): Does the 96 Act allow the Commission to provide for interim 
recovery of universal service costs through UNE prices?	
	U S WEST will address this issue on brief.

Issue V.3 (Policy): If the answer to Issue V.2 is yes, to what extent should 
the Commission to provide for interim recovery of universal service costs 
through UNE prices?	
	U S WEST will address this issue on brief.





Issue V.4 (Policy): To what extent should the Commission provide for recovery 
of Direct Costs through UNE prices?	
	U S WEST’s prices are all based on and provide recovery for direct costs. See, 
generally, M. Reynolds testimony; specifically at 3:17-4:19.

Issue V.5 (Legal): If the answer to Issue V.1 is no, does the 96 Act require 
the Commission to provide for recovery of all of an ILEC’s common costs through 
UNE Prices?	
	M. Reynolds at 7:1-14.

Issue V.6 (Policy): If the answer to Issue V.5 is no, to what extent should the 
Commission provide for recovery of common costs?	
	M. Reynolds at 7:1-14.

Issue V.7 (Factual/Methodological): If the Commission must or should provide 
for recovery of common costs, what are GTE’s common costs?	
	Not addressed.

Issue V.8 (Factual/Policy): To what extent is Staff’s 20% markup for 
attributable costs appropriate?	
	M. Reynolds at 7:1-14.

Issue V.9 (Policy): to what extent should the Commission provide factor market 
share loses, or other competitive loses, into UNE prices?	
	Not addressed in testimony; U S WEST will address on brief.

Issue V.10 (Policy): To the extent the Commission decides to provide for 
recovery of more than the direct cost of UNE’s, should the Commission adopt a 
uniform markup or a percentage that varies by UNE?	
	M. Reynolds at 4:17 -5:25.

Issue V.11 (Policy): To what extent should the Commission provide for recovery 
of “conditioning” (i.e. removal of load coils and bridge taps)?	
	M. Reynolds at 11:22 -12:25.

Issue V.12 (Methodology): If the Commission resolves Issue V.11 by providing 
for cost recovery, what is the most appropriate cost recovery mechanism?	
	M. Reynolds at 11:22 -12:25.

Order Section VIII. Avoided Costs	
	¶ 349 (OS/DA Avoided Costs Studies); 356; 533
 
Issue VIII-1 (Policy): What avoided cost discount should the Commission apply 
to resold operator services and directory assistance services?	
	M. Gude testimony generally; specifically at 3 and 12.



Order Section IX: Collocation	
	¶ 417; 418; 419; 515

Issue IX-1 (Factual): Do the collocation cost studies which U S WEST and GTE 
submitted comply with the FCC’s collocation orders?	
	M. Reynolds at 15 - 17.

Issue IX-2 (Policy): To what extent should the Commission authorize U S WEST 
and GTE to recover to following costs through collocation prices:	
	See, generally, M. Reynolds.  Further, U S WEST objects to the inclusion of 
these issues as set forth herein.

Direct costs?	
	See above.

Directly and indirectly attributed and assigned costs?	
	See above.

Common costs?	
	See above.

Other costs?	
	See above.

Issue IX-3 (Policy): Should the Commission cap ILEC collocation charges at 
prevailing market rates, and if so, how should those rates be determined?	
	U S WEST objects to the inclusion of this issue.

Issue IX-4 (Policy): If the answer to Issue IX-3 is yes, how should the 
Commission determine the prevailing market rates?	
	U S WEST objects to the inclusion of this issue.

Issue IX-5 (Factual): If the answer to Issue IX-3 is yes, what are the 
prevailing market rates?	
	U S WEST objects to the inclusion of this issue.

Issue IX-6 (Policy): To what extent should the Commission require ILECs to 
allow requesting carriers to self-provision or to arrange for a mutually 
acceptable third party to provide collocation site preparation and nonrecurring 
collocation facilities construction services?	
	M. Reynolds at 17:22.

Issue IX-7 (Policy): To what extent should the Commission require, or allow 
requesting carriers to require, ILECs to solicit bids from outside contractors 
for site preparation work?	
	M. Reynolds at 17:22.




X. Local Number Portability	
	¶ 435

Issue X-1 (Policy): What is the most appropriate cost recovery method for 
recovering interim local number portability (INP)?	
	U S WEST will address this issue in subsequent rounds of testimony.

Issue X-2 (Policy): If the Commission resolves Issue X-1 by requiring or 
allowing LEC’s to charge other LECs for INP, to what extent should the 
Commission require the LEC providing INP to pay any interexchange access 
charges for the call to the LEC paying for INP?	
	U S WEST objects to the inclusion of this issue.

XI. Transport & Termination	
	¶ 443; 518; 536

Issue XI-1 (Policy): What is the most appropriate recovery mechanism for 
unbundled interoffice transport?	
	U S WEST has addressed this issue in comments previously filed in this docket, 
and discusses it in M. Reynolds testimony at 8:16-26 and 9:1-2.  U S WEST 
proposes prices for transport in accordance with Exh. MSR-2.

XII. Nonrecurring Costs	
	¶ 461; 478; 481; 519; 538

Issue XII-1 (Factual): Do the UNE nonrecurring cost studies which U S WEST 
filed on May 18, and revised on June 19, 1998, and GTE filed on May 19, and 
revised on June 5, 1998, comply with the Commission’s Eighth and Ninth 
Supplemental Orders?	
	M. Reynolds at 12:26 - 13:24.

Issue XII-2 (Policy): To what extent should the Commission facilitate 
competitive entry by requiring ILECs to recover nonrecurring UNE costs on a 
recurring basis?	
	U S WEST objects to the inclusion of this issue.

Issue XII-3 (Policy): To what extent should an ILEC recover the costs of 
“turning up” additional channels once a transport facility is in place?	
	M. Reynolds at 13:25 - 14:3.

Issue XII-4 (Policy): To the extent the Commission resolves Issue XII-3 by 
requiring or allowing cost recovery, what is the best cost recovery mechanism?	
	M. Reynolds at 13:25 - 14:3.




Issue XII-5 (Factual): What nonrecurring costs do U S WEST and GTE incur in 
separating an unbundled port from unbundled switching?	
	M. Reynolds at 14.

Issue XII-6 (Policy): What is the appropriate cost recovery mechanism for the 
cost of separating the loop and the switch?	
	M. Reynolds at 14.

Issue XII-7 (Policy): Should the Commission require separate charges for 
connection and disconnection?	
	U S WEST proposes a single charge and will address this issue in subsequent 
rounds of testimony.

XIV. Findings Section	
	¶ 510

Issue XIV-1 (Factual): Are U S WEST’s and GTE’s resale customer transfer cost 
estimates reasonable?	
	M. Reynolds at 11:2-21; D. Buhler at 21 and 22.

Issue XIV-2 (Policy): Should the Commission allow ILECs to recover customer 
transfer costs through a non-recurring charge?	M. Reynolds at 11:2-21; D. Buhler at 21 
and 22.

Compliance Filings	
	

Issue CF-1 (Factual/Legal): Are the terms and conditions for in the tariffs U S 
WEST and GTE in compliance with the Commission’s 8th and 9th Supplemental 
Orders in this proceeding consistent with those orders, federal law, and state 
law?	
	U S WEST has stated its position on these issues in its Petition for 
Reconsideration filed earlier in this docket and did not file testimony on 
these issues.

Issue CF-2 (Legal/Policy): What relationship, if any, exists between the terms 
and conditions in these tariffs and negotiated or arbitrated interconnection 
agreements?	
	U S WEST has stated its position on these issues in its Petition for 
Reconsideration filed earlier in this docket and did not file testimony on 
these issues.


OBJECTIONS TO CERTAIN ISSUES
 U S WEST objects to the inclusion of certain of the above issues in this 
proceeding, as noted in the table.  U S WEST had no meaningful opportunity to 
participate in the preparation of this Issues List and therefore believes it is 
inappropriate to move forward with this designation of the Issues for purposes 
of this proceeding.  U S WEST, in compliance with the Commission’s direction, 
filed its Issues List on June 24, 1998.  U S WEST received a copy of GTE’s 
Issues List on or about that same date.  U S WEST did not receive a copy of the 
CLEC’s Issues List and was entirely unaware that the CLECs had filed an Issues 
List until after the Administrative Law Judge published his Issues List 
referencing CLEC issues.  Subsequent investigation revealed that U S WEST had 
not been served with the CLEC Issues List.  This is reflected by the 
Certificate of Service.  U S WEST did not receive a copy of that list until it 
was requested on July 20, 1998.  
 Thus, U S WEST had no opportunity to comment on the CLEC proposed issues and 
to explain prior to the publication of the Issues List why many of the CLEC 
issues were not appropriate for inclusion in this docket.  Specifically, as set 
forth in U S WEST’s objections to various discovery requests and the pleadings 
which will be filed concerning that issue on July 22, 1998, U S WEST believes 
that the inclusion of collocation issues as set forth by the CLECs is entirely 
inappropriate for this stage of the proceeding.
 Respectfully submitted this 21st day of July, 1998.

      U S WEST Communications, Inc.



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