BEFORE THE WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION


In the Matter of the Pricing Proceeding )
for Interconnection, Unbundled Elements ) DOCKET NO. UT-960369
Transport and Termination, and Resale )
) 
)
In the Matter of the Pricing Proceeding )
for Interconnection, Unbundled Elements ) DOCKET NO. UT-960370
Transport and Termination, and Resale )
for U S WEST COMMUNICATIONS, INC. )
) 
)
In the Matter of the Pricing Proceeding ) DOCKET NO. UT-960371
for Interconnection, Unbundled Elements )
Transport and Termination, and Resale ) NEXTLINK/TCG/ELI COLLOCATION
for GTE NORTHWEST INCORPORATED ) TESTIMONY SUMMARIES
)
)


 Pursuant to the Commission's Sixteenth Supplemental Order on Prehearing 
Conference, NEXTLINK Washington, Inc. ("NEXTLINK"), TCG Seattle ("TCG"), and 
Electric Lightwave, Inc. ("ELI") respectfully supplement the previously filed 
summaries of their witnesses' testimony to include the following summaries of 
their collocation testimony, all of which address Issue IX (Collocation) on the 
Commission's Issues List.  
NEXTLINK/TCG/ELI
 NEXTLINK, TCG, and ELI prefiled Collocation Response Testimony of Steven E. 
Turner, which focuses on the issue of whether the collocation (including 
Expanded Interconnection Channel Terminations) cost studies filed by U S WEST 
Communications, Inc. ("U S WEST") and GTE Northwest Incorporated ("GTE") comply 
with the FCC's Physical Collocation Order.  Mr. Turner testifies that these 
cost studies do not comply with that order in several respects.  Neither U S 
WEST nor GTE provide the Commission with the information necessary to determine 
collocation costs as the FCC required.  Both U S WEST and GTE simply state an 
investment amount for a collocation category without providing any information 
supporting or explaining the development of that investment, and neither 
company uses a forward-looking, systemic methodology to determine collocation 
costs.  
 In addition, Mr. Turner testifies that the ad hoc collocation costing U S WEST 
and GTE propose conflicts with specific directives in the FCC order.  Both U S 
WEST and GTE include individual case basis ("ICB") pricing for some collocation 
elements, which the FCC expressly prohibited.  The FCC also refused to allow 
incumbent local exchange carriers ("ILECs") to cost collocation facilities 
based on the assumption that those facilities are dedicated solely to 
requesting carriers -- an assumption that permeates U S WEST's collocation cost 
study.  Mr. Turner concludes that the Commission cannot establish cost-based, 
nondiscriminatory rates for collocation as the FCC and the Telecommunications 
Act of 1996 ("Act") require by using the collocation cost studies submitted by 
U S WEST and GTE.  Mr. Turner, therefore, recommends that the Commission reject 
these cost studies and open another phase of this proceeding to allow a full 
exploration of the forward-looking costs associated with collocation. 

NEXTLINK
 NEXTLINK prefiled the Direct and Response Collocation Testimony of Douglas 
Sobieski and the Response Collocation Testimony of Rex Knowles.
 Sobieski.  Mr. Sobieski's Direct Testimony presents the results of his efforts 
to develop a market price for collocation.      Because this testimony was 
stricken prior to filing responsive testimony and reinstated after responsive 
testimony was filed, portions of Mr. Sobieski's Direct Testimony have been 
included in his and Mr. Knowles' Collocation Response Testimony.  Accordingly, 
NEXTLINK will file revised Direct Testimony for Mr. Sobieski that minimizes the 
duplication among the collocation testimony NEXTLINK has submitted.  Mr. 
Sobieski provided third party contractors with specifications for collocation 
construction and requested that these contractors provide a quote for what they 
would charge to undertake that construction.  The price quotes Mr. Sobieski 
received were substantially lower than the rates U S WEST proposes to charge 
for collocation.  Accordingly, Mr. Sobieski recommends that the Commission 
establish collocation rates no higher than these market prices -- and lower if 
the economies of scope and scale enjoyed by U S WEST and GTE enable them to 
undertake that construction at a lower cost -- and that the Commission allow 
competing local exchange carriers ("CLECs") to self-provision collocation site 
preparation in U S WEST and GTE central offices.
 In his Collocation Response Testimony, Mr. Sobieski briefly describes what is 
involved in constructing collocation space and how U S WEST actually provisions 
collocation.  Mr. Sobieski testifies that U S WEST provides collocation with 
facilities used by all carriers located in U S WEST's central office -- 
including U S WEST -- as contemplated by the FCC Physical Collocation Order.  U 
S WEST's actual provisioning, therefore, sharply contrasts with U S WEST's cost 
study assumption that facilities are dedicated to three requesting carriers.  
Mr. Sobieski also explains why U S WEST's generic power cabling cost estimates 
do not accurately reflect costs in U S WEST's central offices in Washington and 
why GTE's ICB pricing is problematic.  On other collocation issues, Mr. 
Sobieski recommends that the Commission reject U S WEST's proposal to require 
the use of a single point of termination ("SPOT") frame because use of a SPOT 
frame does not provide CLECs with access to unbundled loops that is equivalent 
to the access U S WEST has to those loops.  In addition, Mr. Sobieski explains 
why U S WEST's offer to allow third party contractors to construct cage 
enclosures is not sufficient to enable carriers requesting collocation to 
ensure reasonable rates, terms, and conditions for collocation site preparation.
 Knowles.  The Collocation Response Testimony filed by Mr. Knowles explains the 
importance of collocation to NEXTLINK and other facilities-based CLECs and how 
U S WEST's insistence on payment of nonnegotiable, exorbitant rates as a 
prerequisite for collocation, without regard for U S WEST's contractual 
obligations, constitutes a barrier to entry in the local exchange market.  Mr. 
Knowles testifies that neither U S WEST nor GTE has provided sufficient 
information to enable the Commission to base collocation rates on their cost 
studies.  The information the ILECs have provided, however, demonstrates their 
failure to comply with FCC directives in its Physical Collocation Order, 
particularly the FCC's prohibition on ICB pricing.  Even a rough comparison of 
U S WEST's proposal with GTE's proposal (as well as with U S WEST's federal 
virtual collocation tariff and proposal in Utah), moreover, shows that U S 
WEST's cost and pricing proposals in this proceeding are excessive.  Mr. 
Knowles recommends that the Commission establish just, reasonable, and 
nondiscriminatory collocation rates; adopt market price caps and/or authorize 
CLECs to self-provision all aspects of collocation site preparation; and 
prohibit the ILECs from imposing any charges for collocation that the 
Commission has not approved, including prohibiting U S WEST and GTE from 
denying or delaying collocation on the basis of a CLEC's refusal to pay 
unapproved charges.
 DATED this _____ day of October, 1998.

      DAVIS WRIGHT TREMAINE LLP
            Attorneys for NEXTLINK Washington, Inc., TCG Seattle, and Electric 
Lightwave, Inc.
    



      By        
       Gregory J. Kopta
       WSBA No. 20519