BEFORE THE WASHINGTON UTILITIES AND TRANSPORTATION       COMMISSION


In the Matter of the Pricing    ) DOCKET NO. UT-960369
Proceeding for Interconnection,   )
Unbundled Elements, Transport  )
and Termination and Resale   )
      )
In the Matter of the Pricing   ) DOCKET NO. UT-960370
Proceeding for Interconnection,  )
Unbundled Elements, Transport  )
and Termination, and Resale  )
for U S WEST COMMUNICATIONS,  )
INC.      )
      )
In the Matter of the Pricing   ) DOCKET NO. UT-960371
Proceeding for Interconnection,  )
Unbundled Elements, Transport  ) SUBMISSION OF AT&T AND
and Termination, and Resale for  ) MCI IN RESPONSE TO 
      ) FOURTEENTH SUPPLEMENTAL
      ) ORDER

 In its Fourteenth Supplemental Order, the Commission required parties to 
respond to certain requirements within ten days of entry of the Order.
 At ¶58, the Commission required that the parties identify the relevant number 
of ports for GTE and for U S WEST in order to determine the STP costs.  The 
Commission requested this information for both the Hatfield Model and for the 
ILEC models.  For the Hatfield Model, the number of ports are shown as links on 
the unit cost output sheet for UNEs under signaling.  The value appears in cell 
D70 of this spreadsheet.  AT&T and MCI assume that the ILECs will provide the 
comparable information, if it exists, for their models.
 At Paragraph 42, the Commission ordered the ILECs to provide cost studies for 
shared transport.  This is a critical unbundled network element that both ILECs 
have been refusing to provide or even to price.  U S WEST has requested an 
extension of two weeks from the established date of October 19, 1998.  The time 
provided for other parties to file supplemental testimony is very limited and 
does not appear to contemplate any discovery.  In order to allow other parties 
a meaningful opportunity to review these new studies, there should be a 
requirement that the ILECs serve the other parties personally on the due date.  
There should also be a requirement that the ILECs provide the studies and any 
models in electronic form.  There should be a requirement that the ILECs 
provide supporting explanation of the inputs and assumptions used in the 
study.  In studies filed recently in other jurisdictions, U S WEST has used 
expense factors that have been updated—and substantially increased -- since 
those used in the studies filed in Phase I of this case.  No supporting 
documentation for these factors is typically filed by U S WEST and such should 
be required if the expense factors have changed.  Without this information, at 
a minimum, other parties will not be able to adequately review and respond to 
these studies.  The time allowed for such review does not appear to be 
sufficient and should be extended by at least one week.  Finally, there should 
be an opportunity provided for cross-examination of a U S WEST witness on this 
study, should any party wish to do so.

 Respectfully submitted on October 13, 1998.
 AT&T COMMUNICATIONS OF 
 THE PACIFIC NORTHWEST, INC.
 
 
 
 _________________________
 Susan D. Proctor
 Maria Arias-Chapleau
 1875 Lawrence Street, Suite 1575
 Denver, CO  80202
 (303) 298-6164
 
MCI TELECOMMUNICATIONS CORPORATION
 
      Rogelio E. Peña
      Senior Attorney
      MCI Telecommunications Corporation
      707 Seventeenth Street, Suite 3600
      Denver, CO 80202
      (303) 390-6106