BEFORE THE WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION


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


 Pursuant to the Commission's Thirteenth Supplemental Order; Order on 
Prehearing Conference dated September 3, 1998, in the above-referenced 
proceeding, U S WEST is providing the following table cross-referencing the 
Responsive Testimony of Mark Reynolds filed August 20, 1998, and Rebuttal 
Testimonies of Mark Reynolds and Dean Buhler filed on September 4, 1998. 



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?	
	D. Buhler Rebuttal at 17:7-14.
	M. Reynolds Rebuttal at 7:5-19.

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 Rebuttal generally and specifically, at 30.

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 Rebuttal generally and specifically, at 30.

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 Rebuttal at 3 and 30.

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 Rebuttal at 8:12-20.
	D. Buhler Rebuttal at 30.

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?	M. Reynolds Rebuttal at 2:16-3:2.
	M. Reynolds Rebuttal at 12:10 -13:3.

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 Responsive at 1:10-19, 2:1-6, 3:1-7, and 4:1-7:6.
	M. Reynolds Rebuttal at 1:14-3:19, 5:8-6:6, and 24:2-25:2.

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 Responsive at 1:10-19, 
2:1-6, 3:1-7, and 4:1-7:6.
	M. Reynolds Rebuttal at 1:14-3:19, 5:8-6:6, and 24:2-25:2.

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 Responsive at 1:10-19, 2:1-6, 3:1-7, and 4:1-7:6.
	M. Reynolds Rebuttal at 1:14-3:19, 5:8-6:6, and 24:2-25:2.

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 Responsive at 5:17-6:6.
	M. Reynolds Rebuttal at 1:14-3:19, 12:10-13:3, and 18:14-19:6.

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 Rebuttal at 8:2-18 and 9:2-15.

Issue V.12 (Methodology): If the Commission resolves Issue V.11 by providing 
for cost recovery, what is the most appropriate cost recovery mechanism?	
	Not addressed.

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?	Not addressed.

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?	
	Not addressed.

Issue IX-2 (Policy): To what extent should the Commission authorize U S WEST 
and GTE to recover to following costs through collocation prices:	
	Not addressed.

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?	
	Not Addressed.

Issue IX-4 (Policy): If the answer to Issue IX-3 is yes, how should the 
Commission determine the prevailing market rates?	
	Not Addressed.

Issue IX-5 (Factual): If the answer to Issue IX-3 is yes, what are the 
prevailing market rates?	
	Not Addressed.

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?	
	Not Addressed.

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?	
	Not Addressed.




X. Local Number Portability	
	¶ 435

Issue X-1 (Policy): What is the most appropriate cost recovery method for 
recovering interim local number portability (INP)?	
	M. Reynolds Responsive at 8:16-12:6.

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?	
	Not addressed.

XI. Transport & Termination	
	¶ 443; 518; 536

Issue XI-1 (Policy): What is the most appropriate recovery mechanism for 
unbundled interoffice transport?	
	M. Reynolds Rebuttal at 11:9-17, 14:11-15:7, 22:1-13, and 23:13-18.

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 Responsive at 2:8-3:7, and 7:8-12.
	M. Reynolds Rebuttal at 4:1-5:5, 6:8-7:19, 8:9-18, 17:1-10, and 18:2-11.

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?	
	Not addressed.

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?	
	Not addressed.

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?	
	Not addressed.


Issue XII-5 (Factual): What nonrecurring costs do U S WEST and GTE incur in 
separating an unbundled port from unbundled switching?	
	M. Reynolds Rebuttal at 9:17-11:7 and 22:15-23:10.

Issue XII-6 (Policy): What is the appropriate cost recovery mechanism for the 
cost of separating the loop and the switch?	
	M. Reynolds Rebuttal at 9:17-11:7 and 22:15-23:10.

Issue XII-7 (Policy): Should the Commission require separate charges for 
connection and disconnection?	
	M. Reynolds Responsive at 8:4-14.

XIV. Findings Section	
	¶ 510

Issue XIV-1 (Factual): Are U S WEST’s and GTE’s resale customer transfer cost 
estimates reasonable?	M. Reynolds 15:9-17:10.

Issue XIV-2 (Policy): Should the Commission allow ILECs to recover customer 
transfer costs through a non-recurring charge?	Not addressed.

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.

 
 Respectfully submitted this 14th day of September, 1998.

      U S WEST Communications, Inc.



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