STATE OF WASHINGTON

MILITARY DEPARTME NT

Camp Murray - Tacoma, Washington  98430-5000


October 29, 1998

Washington Utilities and Transportation Commission
1300 S. Evergreen Park Dr. S.W.
P.O. Box 47250
Olympia, Washington  

RE:  COMMENTS ON DOCKET UT-980311(r)

The Washington State Enhanced 911 Program submits the following comments 
concerning Docket No. UT-980311(r) Establishing Universal Service Mechanisms:

WAC 480-123-200 Services Supported By the Universal Service Fund. 
 Paragraph (1), Line (e)

"Access to emergency services (911)" should be replaced with "Enhanced 911 
Service".  

The Federal Communications Commission in Docket 96-45 (72-74) has supported 
enhanced 911 service as the standard level of access to emergency services. 
Additionally, the Commission has, under WAC 480-120-340, established that all 
exchange companies be capable of providing enhanced 911 services, and RCW 
38.52.510, approved in 1991 by the voters of Washington as Referendum 42, 
mandates statewide enhanced 911 services by December 31, 1998.  Enhanced 911 is 
clearly the expected level of service, which should be considered a basic 
service to be supported by the Universal Service Fund.

Attention is also brought to WAC 480-120-530 concerning testing and operational 
assurance for 911 circuits.  Because of the critical nature of those circuits 
and the expectation of continuous service on the part of the customer, it is 
reasonable that such testing also be considered an integral part of the 
universal service fund supported, provisioning for enhanced 911 service.

WAC 480-123-100 Access-Line Equivalent.

It should be noted that the application of Enhanced 911 excise taxes is based 
on the number of trunks in service for DS1 and DS3 circuits.   


Robert G. Oenning, E9-1-1 Administrator
Washington Military Department
Camp Murray
Tacoma, Washington 98430-5011
253-512-7011
b.oenning@emd.wa.gov