BEFORE THE WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION WASHINGTON UTILITIES AND ) DOCKET NO. UT-961638 TRANSPORTATION COMMISSION, ) ) ANSWER OF GTE TO Complainant, ) PETITION FOR ) RECONSIDERATION v. ) ) U S WEST COMMUNICATIONS, INC. ) ) Respondent. ) ) GTE’S ANSWER - 1 A:\961638.PAN GTE NORTHWEST INCORPORATED (“GTE”) opposes Staff’s Petition for Reconsideration in this proceeding. Staff’s Petition should be denied for at least two reasons. First, Staff’s Petition suggests that universal service support can be considered independently of universal service obligations. Staff does not appear to deny that the obligation to provide service in an area will impact universal service -- but nonetheless argues to defer consideration of those issues. To the contrary, the Commission simply cannot fairly determine support for universal service without considering the require-ments generated by an obligation to provide service. Simply put, in this regard, the Commission’s Order is entirely correct: We agree with GTE’s suggestion that “it is in other proceedings in which the obligation provides service upon demand, and the costs generated by such an obligation, can be determined.” The Fourth Supplemental Order Rejecting Tariff Filings, at 21. Second, the Staff’s Petition should be rejected because it elevates process over purpose. The costs generated by an obligation to serve, and the manner in which those costs will be supported by universal service funds, are critical issues. If Staff cannot accomplish this task by the currently scheduled March 11, 1998 date, that date should be extended. DATED this 4th day of February, 1998. GTE NORTHWEST INCORPORATED Timothy J. O’Connell Its Attorney 1800 41st Street WA0105LE Everett, WA 98201 Phone: (425) 261-5008 Fax: (425) 258-9275