BEFORE THE WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION


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


 Pursuant to the requirements of the Commission's and the Administrative Law 
Judge’s Orders in this matter, U S WEST is providing the following summary of 
its testimony.  The issues identified in the Issues List are cross referenced.
 On October 9, 1998, U S WEST filed the testimony of Garrett Y. Fleming and 
Robert J. Hubbard, addressing collocation cost and technical issues.  Mr. 
Fleming adopts the physical collocation testimony filed to date by Mark 
Reynolds, and provides additional testimony regarding physical collocation 
costs.  This testimony summary covers the testimony filed by those two 
witnesses.
 Garrett Y. Fleming addresses the issues in Order Section IX., Collocation.  
Mr. Fleming’s testimony explains how U S WEST’s cost studies comply with the 
FCC’s order, and he addresses  and responds to the specific criticisms raised 
by the intervenors.  Specifically, Mr. Fleming agrees that costing of the 
collocation cage on an ICB basis is not consistent with the FCC’s order.  
Pursuant to paragraph 417 of the Eighth Supplemental Order in this docket, Mr. 
Fleming explains why an ICB approach was reasonable.  Nevertheless, U S WEST is 
also developing standard cage enclosure prices, and will file those when they 
are completed if the Commission so orders.  Mr. Fleming’s testimony also 
addresses why the criticisms regarding costing power cable on a per foot basis, 
and labor on a per hour basis, are unfounded, and why those costs do comply 
with the FCC’s order.  Mr. Fleming’s testimony explains how U S WEST’s cost 
studies comply with the “cost causation” principles in the FCC’s order, 
including the recovery of non-recurring costs through non-recurring charges.  
 This testimony also supports U S WEST’s projected demand for collocation 
facilities at 3 collocators.  U S WEST’s experience is that, on average, there 
are fewer than 3 CLECs per central office.  Thus, U S WEST is 
under-compenstated with this cost calculation, not over compensated as alleged 
by the intervenors.  The alternative to the use of this demand assumption, 
which is permitted by the FCC, is to require the first collocator to pay all 
the costs, and obtain reimbursement only from subsequent collocators.
 Finally, Mr. Fleming addresses the issue of the EICT cost study.  He sponsors 
a revised EICT cost study to address some of the issues raised by the 
intervenors.  The revisions include a shorter cable length in the EICT study 
that reflects U S WEST’s actual experience to date.  The study continues to use 
a 70-75% fill factor, which Mr. Fleming explains is reasonable.
 Robert J. Hubbard also addresses collocation issues, but from a technical 
perspective.  Mr. Hubbard explains why U S WEST does not allow third party 
contractors to perform work other than collocation site preparation.  He 
explains the technical necessity for a separate manhole for the CLECs’ entrance 
facilities.  He explains how the SPOT frame concept works in practice, and why 
it is more efficient than not using such an arrangement.  He also explains how 
the SPOT frame is essentially an intermediate connecting frame, which is used 
by U S WEST in its own network configurations.  
 Mr. Hubbard addresses the contention that a BDFB (battery distribution fuse 
bay) should be used for power, as opposed to a direct feed from the main power 
board, and explains that U S WEST does assume the use of the BDFB for under 60 
amps, which is the only appropriate assumption, since a fuse for more than 60 
amps will not fit on a BDFB.  Finally, Mr. Hubbard explains the time necessary 
for fiber splicing, including set up and actual splicing time, which supports U 
S WEST’s cost study on this matter.
 U S WEST’s responses to the specific questions on the issues list are as 
follows:
Order Section IX: Collocation

Issue IX-1 (Factual): Do the collocation cost studies which U S WEST and GTE 
submitted comply with the FCC’s collocation orders?

 U S WEST believes that although it is difficult to find direct correlation 
between the referenced FCC ruling and the collocation cost studies U S WEST has 
filed in this proceeding, U S WEST generally complies with the FCC directives 
in CC Docket 93-162. 

Issue IX-2 (Policy): To what extent should the Commission authorize U S WEST 
and GTE to recover to following costs through collocation prices:  Direct 
costs?  Directly and indirectly attributed and assigned costs?  Common costs?  
Other costs?

 The Act requires prices that allow incumbent LECs such as U S WEST to recover 
the cost of providing interconnection and unbundled elements.  Section 
251(c)(6) requires rates for physical collocation to be just and reasonable.  
Only rates that are based on and allow for cost recovery can be deemed to be 
just and reasonable.  Thus, consistent with the pricing advocacy in Mr. 
Reynolds’ testimony, U S WEST advocates that collocation prices be established 
by starting with direct costs, including factors for attributed and common 
costs, and include (for recurring charges only) an additional markup to reflect 
an equitable contribution to that provided by the company’s retail customers.
Issue IX-3 (Policy): Should the Commission cap ILEC collocation charges at 
prevailing market rates, and if so, how should those rates be determined?

 U S WEST does not believe that the Commission should cap U S WEST’s 
collocation charges at prevailing market rates. The rates established in this 
proceeding must be based on cost.  The only costs that are relevant to this 
question are U S WEST’s costs.  Thus, any “market” cap, which bears no 
relationship to U S WEST’s costs, and which precludes cost recovery by U S 
WEST, would violate the provisions of the Act.  Prevailing market rates have 
not and will not be established in this record with any degree of certainty or 
accuracy.  To the extent that those rates are proposed in Mr. Sobieski’s July 
9, 1998 testimony, U S WEST will file reply testimony on November 9, 1998. 

Issue IX-4 (Policy): If the answer to Issue IX-3 is yes, how should the 
Commission determine the prevailing market rates?

Issue IX-5 (Factual): If the answer to Issue IX-3 is yes, what are the 
prevailing market rates?

 As noted above, prevailing market rates are not U S WEST’s costs, and 
therefore have no bearing on the issue of proper collocation pricing.

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?

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?

 U S WEST will allow CLECs the ability to self-provision, or to contract with 
3rd party contractors (U S WEST approved) for their collocation enclosure 
construction.  This position is consistent with the FCC’s rules, which 
explicitly state that U S WEST is not required to permit CLECs or third party 
contractors to perform installation outside of the CLEC’s collocation space.  
47 CFR 51.323(h)(2) provides as follows:  “An incumbent LEC is not required to 
permit collocating telecommunications carriers to place their own connecting 
transmission facilities within the incumbent LEC’s premises outside of the 
actual physical collocation space.”
 
 Respectfully submitted this 12th day of October, 1998.

      U S WEST Communications, Inc.



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