BEFORE THE WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION


In the Matter of Customer Proprietary)
 Network Information (CPNI)  ) DOCKET NO. UT-971514



COMMENTS OF AT&T
AT&T Communications of the Pacific Northwest, Inc. (“AT&T”) appreciates the 
opportunity to provide these comments to the Washington Utilities and 
Transportation Commission (“Commission”) in response to the September 21, 1998 
notice on revisions to Customer Proprietary Network Information (CPNI) rules.
AT&T commends the Commission for their efforts to follow the federal CPNI 
rules. Consistency between the state and federal rules maximizes the customers’ 
privacy protection in the most economic fashion while concurrently eliminating 
confusion brought on by differing sets of rules.
That said, there are a few items that AT&T wants to bring to the attention of 
the Commission:
AT&T believes the Commission inadvertently referenced the wrong section in the 
following rule.  The convention AT&T uses to demonstrate what it believes to be 
the incorrect reference is a score through and the correct reference is shown 
by an underscore.
WAC 480-120-151(b)(2) A telecommunications carrier may not use, disclose or 
permit access to CPNI to market to a customer service offerings that are within 
a category of service to which the customer does not already subscribe to from 
that carrier, unless the carrier has customer approval to do so, except as 
described in (c) (3) of this subsection. 

(2) The proposed Washington rules differ from the FCC rules regarding customer 
notification on CPNI, by the omission of one rule.  Again, AT&T believes this 
to be an oversight and is providing the information, underscored below, for the 
Commission’s consideration.
WAC 480-120-152(6)(b)(vi) If any portion of a notification is translated into 
another language, then all portions of the notification must be translated into 
that language.
 
The numbering scheme, shown above, is the point where AT&T believes the 
Commission intended to insert the rule.  Upon insertion of this rule, the 
remainder of the rules in WAC 480-120-152(6)(b)(current vi through ix) will 
need to be renumbered, forward, appropriately.
The Washington proposed rules differ from the FCC rules by excluding commercial 
mobile radio service (CMRS) providers from the definition of telecommunications 
carriers, except where used as a substitute for wire line telecommunications in 
locations where wire line services are not available. AT&T agrees that this 
difference is appropriate since the FCC has jurisdiction over CMRS providers 
while the WUTC does not.
The FCC recently released an order CC Docket No. 96-115, Order, FCC 98-239      
(rel. September 24, 1998), that extended the deadline by which all 
telecommunications carriers must implement effective electronic safeguards to 
protect against unauthorized access to CPNI.  AT&T is providing this order as 
an attachment, for your review.  This extension of time is temporary and 
applies only to the electronic safeguards requirement while the FCC solicits 
comments on alternatives to the proposed rule.  AT&T recommends that the 
Commission monitor this proceeding and modify the Washington rules, as 
appropriate, to conform with whatever electronic safeguard is eventually deemed 
appropriate.
AT&T appreciates this opportunity to submit these comments and looks forward to 
participating with other interested parties in the Commission’s rulemaking 
hearing on October 28, 1998.

Respectfully submitted this 2nd day of October, 1998.

     AT&T COMMUNICATIONS
     OF THE PACIFIC NORTHWEST, INC.




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