BEFORE THE WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION


Proposed Rulemaking to Adopt a Methodology the Determination of Just and 
Reasonable Rates for Attachments to Transmission Facilities	)
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	)	DOCKET NO.  UT-970723
		
		APRIL 27, 1998 SUPPLEMENTAL COMMENTS OF U S WEST COMMUNICATIONS, INC.

 U S WEST Communications, Inc. ("U S WEST"), pursuant to the Notice of 
Opportunity to File Comments dated March 31, 1998, submits the following 
supplemental comments pertaining to the adoption of a methodology for 
determination of just and reasonable rates for attachments to transmission 
facilities:
I. OVERVIEW
 On November 7, 1997, U S WEST filed its first set of comments on the 
Commission's proposal to adopt the FCC's current methodology for determining 
just and reasonable rates for attachments to transmission facilities.  U S WEST 
filed supplemental comments in this docket on January 13, 1998.  U S WEST 
stands by these previously filed comments and specifically incorporates them 
herein, except to the extent that such comments have been modified by this 
current filing.

II. U S WEST SUPPORTS STAFF'S PREFERENCES FOR THE FCC'S METHODOLOGY, NEGOTIATED 
AGREEMENTS AND A FLASH CUT.

 In its Notice of Opportunity to File Comments dated March 31, 1998, the 
Commission noted that Commission Staff took the following three positions:
1) Staff generally agreed with the FCC's methodology, as amended in the Report 
and order in CS Docket No. 97-151; 

2) Staff desired a "flash cut" rather than the five-year FCC transition period; 
and

3) Staff preferred negotiated agreements as the primary means of attachment 
rates.

After considering Staff's positions, and reviewing the filings submitted by 
other parties, U S WEST agrees with each of the positions taken by Staff.  In 
particular, after reviewing the submissions of other parties, U S WEST believes 
that an immediate flash cut to the FCC’s methodology is the most appropriate 
manner in which to implement the FCC ultimate methodology to be in place in 
2008 on the state level.  A flash cut would have the twin virtues of 
implementing, in one step, a consistent and certain methodology and, further, 
eliminating the need for separate rulemakings and implementations for each step 
taken during the five-year transition period.
III. ALL OWNERS AND ATTACHERS OF TRANSMISSION FACILITIES MUST BE TREATED 
EQUALLY.

 In its Supplemental Comments, U S WEST urged the Commission to adopt a 
methodology which explicitly treats all owners of similar transmission 
facilities in an equal, nondiscriminatory manner.  Such treatment would 
disregard the type of service provided by the attacher and acknowledge that all 
attachers should pay similar fees for the amounts of space used.  Any other 
type of arrangement would effect a subsidy in favor of some attachers to the 
disadvantage of other attachers and facility owners.  This is an anomaly which 
should be avoided in this era of increasing competition.  In this regard, U S 
WEST joins in the position taken by GTE that all parties using or owning 
transmission facilities must be treated alike.  See, Additional Comments of GTE 
Northwest, filed January 15, 1998 at pp. 9-10.
IV. THE COMMISSION SHOULD INTERPRET THE FCC GUIDELINES CONSISTENTLY WITH THE 
FCC'S INTERPRETIVE ANNOUNCEMENTS.

 In recommending that the Commission adopt the FCC's methodology, U S WEST also 
urges the Commission to establish a policy of adopting and applying 
interpretative announcements issued by the FCC as to that methodology.  U S 
WEST was recently confronted by this issue when it was forced to request 
clarification from the FCC regarding its recent Report and Order.  (See, 
Attachment "A" hereto).  In the event that the Commission chooses to adopt the 
FCC's methodology, U S WEST submits that consistency and reason also require 
the Commission to apply that methodology in a manner consistent with the FCC.  
Such a policy should be made explicit in the Commission's own rules.
 Respectfully submitted this 27th day of April, 1998.
 U S WEST Communications, Inc.
        ________________________________
 Lisa A. Anderl, WSBA #13236
 Peter J. Butler, Attorney at Law