00001 1 BEFORE THE WASHINGTON UTILITIES AND 2 TRANSPORTATION COMMISSION 3 4 In the Matter of the Pricing ) Docket No. UT-960369 Proceeding for Interconnection,) Phase II 5 Unbundled Elements, Transport ) Volume I and Termination, and Resale ) Pages 1-262 6 _______________________________) In the Matter of the Pricing ) Docket No. UT-960370 7 Proceeding for Interconnection,) Unbundled Elements, Transport ) 8 and Termination, and Resale ) for US WEST COMMUNICATIONS, ) 9 INC. ) _______________________________) 10 In the Matter of the Pricing )Docket No. UT-960371 Proceeding for Interconnection,) 11 Unbundled Elements, Transport ) and Termination, and Resale ) 12 for GTE NORTHWEST, ) INCORPORATED. ) 13 _______________________________) 14 15 A hearing in the above matter was 16 held on October 15, 1998, at 8:32 a.m., at 1300 17 Evergreen Park Drive Southwest, Olympia, Washington, 18 before Administrative Law Judges TERRENCE STAPLETON 19 and KARL CRAINE and CHAIRWOMAN ANNE LEVINSON and 20 COMMISSIONERS WILLIAM R. GILLIS and RICHARD HEMSTAD. 21 22 The parties were present as 23 follows: 24 AT&T, by Susan Proctor, Attorney at Law, 1875 Lawrence Street, Suite 1575, Denver, 25 Colorado, 80202. 00002 1 US WEST COMMUNICATIONS, INC., by Lisa A. Anderl and John Devaney, Attorneys at Law, 2 1600 Seventh Avenue, Room 3206, Seattle, Washington 98191. 3 THE COMMISSION, by Ann Rendahl and Shannon Smith, Assistant Attorneys General, P.O. Box 4 40128, Olympia, Washington 98504-0128. PUBLIC COUNSEL, by Robert 5 Manifold, Attorney at Law, 900 Fourth Avenue, #2000, Seattle, Washington 98164. 6 NEXTLINK WASHINGTON, TCG SEATTLE, and ELECTRIC LIGHTWAVE, INC., by Gregory J. Kopta, 7 2600 Century Square, 1501 Fourth Avenue, Seattle, Washington 98101-1688. 8 GTE, by Lewis Powell and Robert Merhige, Attorneys at Law, Hunton & Williams, 951 E. 9 Byrd Street, Richmond, Virginia, 23219, and Christopher S. Huther, Attorney at Law, Collier, 10 Shannon, Rill & Scott, PLLC, 3050 K Street, N.W., Washington, D.C. 20007. 11 COVAD COMMUNICATIONS COMPANY, by Prince Jenkins, Attorney at Law, 2330 Central 12 Expressway, Santa Clara, California, 95050. MCI WORLDCOM, by Rogelio Pena, 13 Attorney at Law, 707 17th Street, Suite 3600, Denver, Colorado, 80202. 14 TRACER, by Arthur A. Butler, Attorney at Law, 601 Union Street, Suite 5450, 15 Seattle, Washington 98101-2327. 16 17 18 19 20 21 22 23 24 Barbara L. Spurbeck, CSR 25 Court Reporter 00003 1 ____________________________________________________ 2 INDEX OF WITNESSES 3 ____________________________________________________ 4 WITNESS: PAGE: 5 STEVEN TURNER 6 Direct Examination by Mr. Kopta 14 7 Cross-Examination by Ms. Anderl 15 8 Cross-Examination by Mr. Merhige 69 9 Cross-Examination by Mr. Manifold 75 10 Cross-Examination by Ms. Rendahl 76 11 Examination by Dr. Gabel 85 12 Redirect Examination by Mr. Kopta 90 13 Recross-Examination by Ms. Anderl 92 14 TERRY MURRAY 15 Direct Examination by Mr. Jenkins 93 16 Cross-Examination by Ms. Anderl 100 17 Cross-Examination by Mr. Powell 150 18 Examination by Dr. Gabel 168 19 Cross-Examination by Ms. Rendahl 173 20 Recross-Examination by Mr. Powell 176 21 Recross-Examination by Ms. Anderl 180 22 DAVID GRIFFITH 23 Direct Examination by Ms. Rendahl 184 24 Cross-Examination by Ms. Anderl 186 25 Cross-Examination by Mr. Huther 202 00004 1 Cross-Examination by Mr. Kopta 213 2 Examination by Dr. Gabel 218 3 Redirect Examination by Ms. Rendahl 219 4 MICHAEL HYDOCK 5 Direct Examination by Mr. Pena 223 6 Cross-Examination by Mr. Merhige 224 7 Cross-Examination by Mr. Manifold 231 8 Cross-Examination by Mr. Devaney 235 9 Redirect Examination by Mr. Pena 257 10 Recross-Examination by Mr. Manifold 258 11 Recross-Examination by Mr. Devaney 261 12 13 14 15 16 17 18 19 20 21 22 23 24 25 00005 1 ____________________________________________________ 2 INDEX OF EXHIBITS 3 ____________________________________________________ 4 EXHIBIT: MARKED: OFFERED: ADMITTED: 5 Number 501 6 15 15 6 Number 502 6 99 100 7 Number 503 6 99 100 8 Number 504 7 185 185 9 Number C-505 7 185 185 10 Number 506 7 185 185 11 Number 507 7 -- -- 12 Number 508 7 224 224 13 Number 509 7 -- 7 14 Number C-510 7 -- 7 15 Number 511 7 -- 7 16 17 18 19 20 21 22 23 24 25 00006 1 JUDGE CRAINE: The first thing I'd like to 2 address is marking exhibits. And we had asked the 3 parties to provide lists of their witnesses and 4 exhibits, and do the parties have those available? 5 MR. KOPTA: I was bad. I didn't do my 6 homework. 7 MS. PROCTOR: I'm working under the 8 assumption you're talking about witnesses in this set 9 of hearings, as opposed to December? 10 JUDGE STAPLETON: Yes, ma'am. 11 MS. ANDERL: We overcomplied. 12 JUDGE STAPLETON: The kind of company an 13 arbitration like this just loves to have around, 14 overcomplying. 15 MS. ANDERL: Here you go. Actually, all 16 these people might be getting on the stand today, 17 because it's just -- it's not our Gary Fleming and 18 Jeff Hubbard stuff. It's Reynolds, Buhler, and Gude. 19 JUDGE CRAINE: We'll go off the record for 20 a minute. 21 (Discussion off the record.) 22 JUDGE CRAINE: Let's go back on the record. 23 While we were off the record, we marked exhibits as 24 follows: Steven Turner's testimony as 501. For 25 Covad, we have Terry Murray's opening testimony as 00007 1 502, her reply testimony as 503. 2 For Staff witness David Griffith, the 3 opening testimony is 504, the confidential portion of 4 that is C-505, and the reply testimony is 506. Then 5 we've marked Staff witness David Dittemore is 507, 6 and then, for MCI, Hydock's testimony is 508. And 7 that's as far as we got marking testimony. 8 For preliminary matters today, we have no 9 cross for either US West witness Gude or Staff 10 witness Strain, and so under our agreement at the 11 prehearing conference, the parties agreed to 12 stipulate to the foundation for that testimony, and 13 so I will go ahead and receive that at this point, 14 which raises the issue of the numbers to give that, 15 and -- I hear someone dialing in. Who is that, 16 please? Maybe not. 17 Are there any cross-examination documents 18 for Hydock? 19 MS. ANDERL: No. 20 JUDGE CRAINE: None, okay. Then let's mark 21 Gude as 509. Does she have reply testimony? 22 MS. ANDERL: She did not. 23 JUDGE CRAINE: And Strain would be 510. 24 MS. ANDERL: Your Honor, Excuse me. Ms. 25 Gude, though, did have DMG-1, her exhibit, her 00008 1 confidential exhibit. 2 JUDGE CRAINE: Oh, okay. Let's make that 3 C-510. And then Ms. Strain would be 511. Does she 4 have confidential attachments? 5 MS. RENDAHL: No, no exhibits. 6 JUDGE CRAINE: And did she have reply 7 testimony or just the direct? 8 MS. RENDAHL: Just the direct. 9 JUDGE CRAINE: Okay. The only other 10 preliminary matters I'm aware of is that US West has 11 submitted revisions to the Buhler testimony, which we 12 can mark when the time comes, but Ms. Anderl, could 13 you explain, just briefly for the record, what those 14 are? 15 MS. ANDERL: Yes, Your Honor. I 16 distributed to all the parties today and filed at the 17 Records Center an original and 19 copies of a revised 18 version of Mr. Buhler's July 9th testimony. The 19 cover letter describes what exhibits are also 20 revised. The reason we did that was because there 21 were a number of small revisions that would have made 22 an errata sheet confusing. Numbers changed, the 23 dollar amounts changed in a number of places in his 24 testimony. We have shown those revisions in 25 legislative style format, so the parties don't have 00009 1 to go on a treasure hunt for where the changes are. 2 With regard to Mr. Buhler's rebuttal 3 testimony, there were only about four changes 4 sprinkled throughout the 30 pages of testimony, and 5 it was the same change throughout, a number -- I 6 believe it was $14.91 changed to $14.54, and I just 7 submitted a one-page errata sheet for that. 8 JUDGE CRAINE: Okay. Any -- 9 MS. PROCTOR: I don't have a cover letter. 10 MS. ANDERL: You don't have a cover letter? 11 MS. PROCTOR: I don't have a cover letter. 12 MS. ANDERL: Your Honor, I'm advised that 13 perhaps the packets that I distributed to the parties 14 are missing the cover letter. The cover letter is 15 down at the Records Center. I can obtain copies 16 during the break and make sure that it accompanies 17 each of the filing packages to the parties, then, and 18 I'll do that. 19 JUDGE CRAINE: Thank you. 20 MS. ANDERL: Perhaps only Ms. Proctor. 21 JUDGE STAPLETON: We'll make a copy of that 22 right now for Ms. Proctor. Send a copy to the Bench. 23 MS. PROCTOR: I don't think it's critical. 24 JUDGE CRAINE: Let's move on to the other 25 preliminary matter, then, which is Mr. Lee can be 00010 1 available from GTE to testify on some of the issues 2 he addressed in his testimony on Saturday -- or 3 excuse me, Friday. And Mr. Powell, perhaps you could 4 tell us the topics that he feels comfortable 5 addressing at this point. 6 MR. POWELL: Yes, sir. For the benefit of 7 the parties, Judge Craine and I have had some off the 8 record discussions about whether, in an effort to 9 rebalance the amount of work between this month and 10 next month, a GTE witness might be available to 11 testify this week. 12 And Mr. Lee is here. As the parties know, 13 his testimony ranges from general issues of policy 14 and appropriate pricing to the markup of the TELRICs 15 for UNE pricing, the ultimate UNE prices that GTE is 16 seeking. He also has pricing testimony with respect 17 to issues such as NRCs and collocation. 18 In an effort to try to identify an area 19 that is susceptible to being cordoned off from the 20 rest of Mr. Lee's testimony, he and I thought, and 21 I've discussed this with Judge Craine this morning, 22 that he could be available to testify tomorrow on 23 general policy questions, as well as UNE pricing 24 issues. 25 And Ms. Proctor or anyone else who does not 00011 1 have copies of his testimony available, we can make 2 arrangements to get copies to you today. He has 3 several pieces of testimony, and I haven't had the 4 chance yet this morning to go through them all to 5 figure out exactly where we would draw the lines, but 6 I think, in the main, his initial testimony on July 7 the 9th would be the -- and his reply testimony on 8 August the 20th would be the primary focus of the 9 parties' cross-examination inquiries for Mr. Lee on 10 those issues. But we can certainly make arrangements 11 off the record to get copies to whoever may need 12 copies. 13 JUDGE CRAINE: Okay. Now, with that, I 14 think what I'd like to do is leave it to the parties 15 to discuss at the lunch break how they'd like to 16 handle the imbalance between our October 17 cross-examination and the December cross-examination, 18 and then discuss it after lunch, if that's all right. 19 Ms. Proctor. 20 MS. PROCTOR: Mr. Craine, is Mr. Lee's 21 appearance tomorrow a fait accompli? 22 JUDGE CRAINE: Well -- 23 MS. PROCTOR: Because this is not an issue 24 that had been previously discussed, and I think Mr. 25 Powell has recited that his conversations were with 00012 1 you, not with any of the other parties. As Mr. 2 Powell noted, I do not even have a copy of Mr. Lee's 3 testimony. We've just been handed revisions to Mr. 4 Buhler's testimony, and Mr. Buhler will be testifying 5 tomorrow, as well. 6 I do not personally see that I am going to 7 be able to prepare adequately for cross-examination 8 of Mr. Lee at this time, and believe that, on the 9 pricing issues, and in particular, the markup issues, 10 and believe that my client would be prejudiced if Mr. 11 Lee is called at this time and we are precluded from 12 conducting cross-examination as was originally 13 scheduled in December. 14 I do not anticipate that my 15 cross-examination of Mr. Lee would be any longer than 16 my estimated cross-examination of the US West 17 witnesses, which I believe may have ranged in the 18 half-hour, 45-minute range. 19 MS. ANDERL: Your Honor, Lisa Anderl for US 20 West. May I just ask if the Bench has a matrix or 21 calculation of sorts that could be shared with the 22 parties with regard to the amount of cross that was 23 estimated for October and December? It may be that 24 if the parties were able to look at the December 25 estimates and see what goes into the 25 hours, we 00013 1 might be able to provide you with revised estimates 2 that one might hope would more realistically fit in 3 the December time frame. 4 I just don't -- I know what I estimated. I 5 just don't have a comprehensive understanding of what 6 everyone else did. 7 JUDGE CRAINE: We have a sheet that we can 8 copy and provide to the parties at a break. So let's 9 leave the topic now until the parties have a chance 10 to look at that sheet and discuss it at lunch, and 11 then we'll talk about it again afterwards. 12 Any other preliminary matters? Okay. 13 Let's have Mr. Turner come forward, then. 14 Whereupon, 15 STEVEN TURNER, 16 having been first duly sworn, was called as a witness 17 herein and was examined and testified as follows: 18 JUDGE CRAINE: Be seated. Okay. The only 19 party I have requesting cross-examination time for 20 Mr. Turner was US West. Ms. Anderl. 21 MS. ANDERL: Thank you, Your Honor. I had 22 a discussion with GTE before we started about whether 23 I would go first or they would, so I suspect they 24 think they have some cross. I just thought I'd throw 25 that out there before we started. 00014 1 JUDGE CRAINE: Mr. Powell. 2 MR. POWELL: Ms. Anderl is correct. We may 3 have some very limited cross of this witness, but it 4 will depend on how thoroughly she covers it. 5 JUDGE CRAINE: Well, let's go ahead and 6 take US West first, then. 7 MR. KOPTA: Judge Craine, would you like 8 some foundation, the normal order of things? 9 JUDGE CRAINE: Well, let me ask the parties 10 -- do the parties want to take the time to go through 11 foundational things, or are the parties willing to 12 stipulate to the foundation for the testimony? 13 MR. JENKINS: Your Honor, just a point of 14 clarification. Ms. Murray does have two minor 15 corrections to her testimony, but other than that, we 16 don't have any problems stipulating the foundation. 17 MR. KOPTA: It might just be easier to go 18 ahead with the standard three questions or four 19 questions. 20 JUDGE CRAINE: All right, go ahead. 21 D I R E C T E X A M I N A T I O N 22 BY MR. KOPTA: 23 Q. Mr. Turner, would you state your name and 24 business address for the record, please? 25 A. Steven E. Turner, with Kaleo Consulting. 00015 1 My address is 1130 Creekwood Drive, Garland, Texas, 2 75044. 3 Q. Do you have before you what's been marked 4 for identification as Exhibit 501, identified as the 5 Collocation Response Testimony of Steven E. Turner? 6 A. Yes, I do. 7 Q. And is that exhibit true and correct, to 8 the best of your knowledge? 9 A. Yes, it is. 10 Q. Was this exhibit prepared by you or under 11 your direction and control? 12 A. Yes, it was. 13 Q. If I asked you the questions that are 14 contained in this exhibit, would your answers today 15 be the same as those contained in the exhibit? 16 A. They would. 17 MR. KOPTA: At this time, I would offer for 18 admission Exhibit 501. 19 JUDGE CRAINE: Any objection? It's 20 received, then. 21 MR. KOPTA: Mr. Turner is available for 22 cross-examination. 23 JUDGE CRAINE: Ms. Anderl. 24 C R O S S - E X A M I N A T I O N 25 BY MS. ANDERL: 00016 1 Q. Good morning, Mr. Turner. 2 A. Good morning. 3 Q. I'm Lisa Anderl, representing US West 4 Communications. Are you familiar with the FCC order 5 on physical collocation that was released on June 6 13th, 1997? 7 A. Yes, I am. 8 Q. Did you read that FCC order in preparation 9 for this hearing? 10 A. Yes, I did. 11 Q. Did you read it prior to the time that you 12 prepared your testimony? 13 A. Yes, I did. 14 Q. Have you read it since then? 15 A. Since I -- since when? 16 Q. Since you prepared your testimony and filed 17 it on September 18th? 18 A. No, I have not. 19 Q. Pull the microphone closer, please. 20 A. Sure. If I sound a little funny, too, my 21 ears are plugged up from the flight, so forgive me. 22 Q. You're in good company. There are a lot of 23 people in the room, I think, in that situation. Did 24 you read the Commission orders in this docket, 25 beginning with the Eighth Supplemental Order, through 00017 1 and including the 16th Supplemental Order, in 2 preparation for this hearing today? 3 A. I believe that I did. I can't necessarily 4 say that I can refer to them in that form. If I saw 5 them again, I could tell you for sure. 6 Q. You weren't a witness in Phase I of this 7 proceeding, were you? 8 A. No, I was not. 9 Q. Are you familiar with the testimony and 10 evidence that was placed on the record in Phase I of 11 this docket? 12 A. No, I'm not. 13 Q. Did you read any of the testimony that was 14 submitted in Phase I? 15 A. Can I ask you a question? Is the July 9th 16 testimony that was prepared, is that Phase I 17 testimony? 18 Q. Perhaps I should ask you, are you familiar 19 with what we mean when we say Phase I of this 20 proceeding? 21 A. I'm vaguely familiar with it. 22 Q. If I were to explain to you that Phase I 23 included everything up to and including the Eighth 24 Supplemental Order in this docket, would that clarify 25 your understanding? 00018 1 A. No, it would not. 2 Q. It would not, okay. Would you understand 3 that anything that was filed after June of 1998 would 4 include Phase II of this docket? 5 A. No. I mean, I could tell you what I 6 reviewed in terms of direct testimony that I looked 7 at, but I actually specified that in my rebuttal 8 testimony, to my recollection. I actually spelled 9 out each of the pieces that I reviewed. 10 Q. Mr. Turner, are you aware of when this 11 docket began, was first opened by the Commission? 12 A. No, I'm not. 13 Q. Are you aware of whether or not US West 14 filed, in Phase I of this proceeding, a number of 15 cost studies in the January through April 1997 time 16 frame? 17 A. I'm generally aware of that from reading 18 the orders that I did review. 19 Q. Is it correct that you did not review any 20 of those studies? 21 A. When did you file -- let's see here. I've 22 got dates on your cost studies. I reviewed your 23 collocation cost studies. I can look on them to see 24 what date they were filed, if you'd like for me to. 25 Q. Would you please tell me which collocation 00019 1 cost studies of US West's that you reviewed and when 2 they were filed with the Commission? 3 A. I reviewed -- it says here on the cover, 4 Executive Summary, State of Washington, Prescribed 5 Physical and Virtual Collocation Cost Study, May 6 1998, Washington Expanded Interconnection Channel 7 Termination, Physical Virtual EICT, Recurring Cost 8 Study, Local Interconnection Service Prescribed Lives 9 at 9.63 Percent Common -- or Com, excuse me, no 10 common or attributable cost. That was also May of 11 1998. 12 I also looked at Washington Expanded 13 Interconnection Channel Termination, EICT, Virtual 14 Physical, 1996 Nonrecurring Cost Study. The study 15 date for that was October of 1996. Those were the 16 documents that I reviewed. 17 Q. Those are the only cost studies that you 18 reviewed? 19 A. Yes, that's correct, for US West. 20 Q. Would it be correct, then, that you did not 21 read the hearing transcripts from the hearings that 22 occurred in this docket in July of 1997? 23 A. No, I did not read those transcripts. 24 Q. Did you read any of the testimony that was 25 filed in this docket that was cross-examined during 00020 1 those July 1997 hearings? 2 A. No, I did not. 3 Q. Did you review Exhibits C-115 and 116 from 4 the prior phase of this docket? 5 A. I'm not familiar with them by those names, 6 but given my preceding answer, the answer's probably 7 going to be no. 8 Q. To the extent that those were cost studies, 9 is it correct that you've already identified which 10 cost studies you did review? 11 A. Yes, I have. 12 Q. Are you aware of whether or not US West 13 filed, in Phase I of this proceeding, a document 14 entitled Cost Manual? 15 A. No, I'm not aware of that. 16 MS. ANDERL: Your Honor, may I approach the 17 witness? 18 JUDGE CRAINE: Yes. 19 Q. Mr. Turner, I've placed before you a 20 three-ring binder. Do you recognize the document by 21 the cover page? 22 A. No, I do not. 23 Q. Could you please read the cover page into 24 the record? 25 A. US West Communications Cost Manual, Volume 00021 1 I, Cost Methodology and Descriptions of Annual Cost 2 Factors and Models. 3 Q. Have you ever seen that document before, 4 Mr. Turner, to the best of your knowledge? 5 A. No, I have not. 6 Q. Would you accept, subject to your check, 7 that that document was offered and admitted as an 8 exhibit during the July 1997 hearings in this docket? 9 A. Subject to check, sure. 10 MS. ANDERL: I'm not going to ask any 11 questions about the document, Your Honor. Shall I 12 just retrieve it? 13 JUDGE CRAINE: Sure. 14 Q. Mr. Turner, do you have any reason to 15 believe that that document does not contain a 16 description of US West's costing methodology? 17 MR. KOPTA: I would object at this point. 18 He's not familiar with the document, and so I don't 19 see that there's any point in pursuing what is or is 20 not in that particular document with this witness. 21 MS. ANDERL: I'll withdraw the question. 22 Q. When you criticized US West for the 23 methodology employed in creating cost studies in this 24 docket, it is correct, is it not, that you had not 25 reviewed US West's methodology, as set forth in that 00022 1 cost manual? 2 A. I did not review that cost manual. The 3 criticisms that I was providing in that area were 4 directed towards the actual cost studies that I 5 reviewed related to physical and virtual collocation. 6 And in that regard, there was no information provided 7 in those studies or any reference materials that were 8 referred to from those studies that indicated that a 9 methodology was being used at all. 10 Q. Did you ask anyone whether that was the 11 case? 12 A. I mean, I spoke with the clients that I was 13 working for in this and tried to procure all 14 materials that had been filed by US West related to 15 collocation. 16 Q. And those were materials that were filed 17 subsequent to May of 1998? 18 A. I didn't give a date certain. I was 19 looking for any material that related to the filing 20 of cost studies for physical and virtual collocation 21 here in Washington by US West. 22 Q. When were you retained by the parties in 23 this case to give testimony in this matter? 24 A. In August 1998. 25 Q. How much time did you spend reviewing US 00023 1 West's cost studies prior to preparing your 2 testimony? 3 A. I probably spent approximately 40 or 50 4 hours. You have to understand that I have also 5 reviewed the cost studies from US West in Minnesota, 6 as well, so I was generally familiar with the 7 material when I stepped into the process, so it 8 wasn't like I was starting from scratch. I'd also 9 reviewed the materials that US West had filed in 10 Nebraska, as well. 11 So again, I'm not saying that I've used 12 those numbers here in any way, they're proprietary to 13 the states, but I wouldn't necessarily determine that 14 just from the number of hours that I spent reviewing 15 in Washington, that that should be the limit of my 16 experience looking at US West's collocation cost 17 studies. I started looking at US West collocation 18 cost studies back in, I believe, December of 1997, 19 when I was working in the Minnesota case. 20 Q. Is it your position that US West's physical 21 collocation costs should be developed based on a 22 forward-looking central office design? 23 A. I believe that it should be based on a 24 systematic approach, and an approach would be to lay 25 out a forward-looking central office design. 00024 1 Q. So is your answer to my question yes? 2 A. Yes, it would be yes. 3 Q. Do you believe that the construct of 4 costing a forward-looking central office is required 5 by the FCC's physical collocation or the FCC's First 6 Report and Order in implementing the 7 Telecommunications Act? 8 A. What was the first document you were 9 referring to? Is it the Second Report and Order? 10 Q. Sorry. Yes, when I refer to the FCC's 11 Collocation Order, I'm referring to the June 13th, 12 1997 order. 13 A. With regards to that document, the FCC 14 stated that -- if I can find that real quick. I'll 15 just say generally what I understand from reading the 16 Second Report and Order, the June 13th document, is 17 that the FCC was looking for the participants in that 18 proceeding to provide both the methodology that they 19 were using to develop cost and the cost inputs that 20 they determined drove those costs. There was no 21 mention necessarily of a forward-looking central 22 office. 23 It's my understanding, although I'm not an 24 economist, it's more my understanding from the First 25 Report and Order that the concepts that go into 00025 1 developing nondiscriminatory cost-based prices 2 involve using a TELRIC approach. And part of that 3 would be looking at a forward-looking central office. 4 Q. So is it your testimony that that is 5 required by the FCC's order in the physical 6 collocation docket or not? 7 A. I believe that it would be, but it would be 8 specific to looking at things such as cabling 9 lengths, power lengths, the layout within the central 10 office. I'm not talking about a central office that 11 does not exist, which is sometimes, you know, the 12 counterpoint. I'm talking about looking at central 13 offices as they would be designed currently and 14 identifying from those how you would develop min and 15 max cable lengths, so that you could properly cost 16 out things like interconnection and power. 17 Q. Maybe I don't understand your definition of 18 what a forward-looking central office is, then. 19 Could you please explain that? 20 A. It would be one that would be engineered in 21 such a way that it takes into account the space 22 requirements for technology that you know about today 23 going forward, and also takes into account the need 24 for collocation. It would use best practices 25 associated with engineering the space, engineering 00026 1 cable runs, and the placement of key components 2 throughout the central office. 3 Q. Are you aware if any such central offices 4 exist today in incumbent -- in US West's Washington 5 serving area? 6 A. I haven't had an opportunity to tour all of 7 your offices to be able to make such a statement. It 8 doesn't make it any less relevant that you need to 9 use some form of a model or an approach to 10 understanding how offices are laid out to develop 11 cost. 12 Q. Is it your understanding that the central 13 office that you would model is required to be in the 14 same location as the existing central offices? 15 A. That was not relevant to the types of 16 testimony that I provided here. 17 Q. You don't have an understanding of that or 18 not? 19 A. It's not -- my answer is it's not relevant 20 to this question, where the office is at. 21 Q. Well, in modeling a forward-looking central 22 office, Mr. Turner, wouldn't you have to take into 23 account the cost of the land on which the central 24 office sits? 25 A. I see where you're -- I thought you were 00027 1 coming from the spatial relationships we'v