00263 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 II and Termination, and Resale ) Pages 263-554 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 16, 1998, at 9:12 a.m., at 1300 17 Evergreen Park Drive Southwest, Olympia, Washington, 18 before Administrative Law Judge KARL CRAINE and 19 CHAIRWOMAN ANNE LEVINSON and COMMISSIONERS WILLIAM R. 20 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. 00264 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 Shannon Smith, 4 Assistant Attorney General, P.O. Box 40128, Olympia, Washington 98504-0128. 5 PUBLIC COUNSEL, by Robert 6 Manifold, Attorney at Law, 900 Fourth Avenue, #2000, Seattle, Washington 98164. 7 NEXTLINK WASHINGTON, TCG SEATTLE, 8 and ELECTRIC LIGHTWAVE, INC., by Gregory J. Kopta, 2600 Century Square, 1501 Fourth Avenue, Seattle, 9 Washington 98101-1688. 10 GTE, by Lewis Powell and Robert Merhige, Attorneys at Law, Hunton & Williams, 951 E. 11 Byrd Street, Richmond, Virginia, 23219, and Christopher S. Huther, Attorney at Law, Collier, 12 Shannon, Rill & Scott, PLLC, 3050 K Street, N.W., Washington, D.C. 20007. 13 COVAD COMMUNICATIONS COMPANY, by 14 Prince Jenkins, Attorney at Law, 2330 Central Expressway, Santa Clara, California, 95050. 15 MCI WORLDCOM, by Rogelio Pena, 16 Attorney at Law, 707 17th Street, Suite 3600, Denver, Colorado, 80202. 17 TRACER, by Arthur A. Butler, 18 Attorney at Law, 601 Union Street, Suite 5450, Seattle, Washington 98101-2327. 19 20 21 22 23 24 Barbara L. Spurbeck, CSR 25 Court Reporter 00265 1 ____________________________________________________ 2 INDEX OF WITNESSES 3 ____________________________________________________ 4 WITNESS: PAGE: 5 ROY LATHROP 6 Direct Examination by Mr. Pena 268 7 Cross-Examination by Ms. Anderl 273 8 Cross-Examination by Mr. Merhige 298 9 Cross-Examination by Ms. Smith 309 10 Cross-Examination by Ms. Proctor 312 11 Cross-Examination by Mr. Jenkins 313 12 Examination by Dr. Gabel 314 13 Recross-Examination by Ms. Proctor 321 14 Examination by Dr. Gabel 322 15 Recross-Examination by Ms. Anderl 323 16 THOMAS REGAN 17 Direct Examination by Mr. Jenkins 325 18 Cross-Examination by Mr. Powell 327 19 Cross-Examination by Ms. Anderl 354 20 Examination by Chairwoman Levinson 385 21 Examination by Commissioner Hemstad 387 22 Examination by Dr. Gabel 391 23 Redirect Examination by Mr. Jenkins 393 24 Examination by Dr. Gabel 399 25 00266 1 DEAN BUHLER 2 Direct Examination by Mr. Devaney 414 3 Cross-Examination by Ms. Proctor 420 4 Cross-Examination by Mr. Pena 441 5 Cross-Examination by Mr. Kopta 462 6 Cross-Examination by Ms. Smith 487 7 Cross-Examination by Mr. Manifold 505 8 Examination by Dr. Gabel 513 9 Examination by Chairwoman Levinson 522 10 Examination by Commissioner Hemstad 524 11 Recross-Examination by Ms. Proctor 526 12 Recross-Examination by Mr. Kopta 538 13 Recross-Examination by Ms. Proctor 542 14 Redirect Examination by Mr. Devaney 542 15 Recross-Examination by Mr. Pena 552 16 17 18 19 20 21 22 23 24 25 00267 1 ____________________________________________________ 2 INDEX OF EXHIBITS 3 ____________________________________________________ 4 EXHIBIT: MARKED: OFFERED: ADMITTED: 5 Number 512 -- 270 271 6 Number 513 -- 270 -- 7 Number 514 -- 326 326 8 Numbers 515-532 -- 417 420 9 Number C-533 412 417 420 10 Number C-534 414 506 506 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 00268 1 JUDGE CRAINE: We'll go ahead and take the 2 witness, if you'll stand, please. 3 Whereupon, 4 ROY LATHROP, 5 having been first duly sworn, was called as a witness 6 herein and was examined and testified as follows: 7 JUDGE CRAINE: Be seated. Okay, direct. 8 D I R E C T E X A M I N A T I O N 9 BY MR. PENA: 10 Q. Could you state your name and business 11 address for the record, please? 12 A. My name is Roy Lathrop. My business 13 address is 1801 Pennsylvania Avenue, N.W., 14 Washington, D.C., 20006. 15 Q. And do you have before you what have been 16 marked for identification as Exhibits 512 and 513? 17 A. Yes, I do. 18 Q. Are those documents true and correct, to 19 the best of your knowledge? 20 A. Yes, they are. 21 Q. Were they prepared by you? 22 A. Yes. 23 Q. Do you have any corrections? 24 A. Yes, I do. 25 Q. Could you tell me those corrections? 00269 1 A. Exhibit 512, on page 22, lines 10 through 2 13, the last sentence in that paragraph should be 3 deleted in its entirety. Then, on the same page, 4 line 14, after the words "12 fibers" should be 5 inserted the words "and three collocators." 6 And in the following line, 15, the word 7 "implicitly" should be replaced by the word 8 "apparently." And the phrase that continues on to 9 line 16, the phrase "are four conduits" should be 10 replaced by "is one conduit." 11 MS. ANDERL: I'm sorry, Mr. Pena. I lost 12 that last correction. 13 MR. PENA: It's the phrase beginning on 14 line 15, the last words, "there are," continuing to 15 line 16, "four conduits." He's changing that to "is 16 one conduit." Did you get it? 17 MS. ANDERL: No. Could the witness read 18 the sentence, how it's supposed to read now? 19 JUDGE CRAINE: Go ahead. 20 THE WITNESS: The second sentence in that 21 second paragraph that begins on line 14 should read, 22 Since there are typically three innerducts per 23 conduit, USWC apparently assumes there is one conduit 24 in the entrance enclosure between the manhole and the 25 cable vault. 00270 1 MS. ANDERL: Thank you. 2 THE WITNESS: The next correction is on 3 page 26, line four. The number 2346.01 should be 4 replaced with the number 1684.80. And then, on page 5 30, on line two, the phrase "reduced by at least" 6 should be replaced with the word "about." So that 7 sentence would now read, The nonrecurring charge 8 should be about one-tenth, and even then is generous. 9 And also on page 30, the first -- the 10 sentence that begins on line 13 should end on line 11 13, and the rest of that sentence, on lines 14 and 12 15, that begins "some of which" and ends "should be 13 denied" should be deleted. So that the first 14 sentence in the second full paragraph on page 30 15 should read, "GTE includes costs associated with 16 conduit and manhole material," period. 17 Q. Are those all your corrections? 18 A. Yes. 19 Q. Now, with those corrections, if I asked you 20 the questions appearing in your testimony again here 21 today, would your answers be the same? 22 A. Yes, they would. 23 MR. PENA: Your Honor, I would move that 24 the exhibits be admitted. 25 JUDGE CRAINE: Any objection to 512? Since 00271 1 there is none, I will receive it. Ms. Anderl, I 2 understand you have an objection to 513? 3 MS. ANDERL: Yes, Your Honor. I do not 4 believe that MCI was authorized to file testimony on 5 September 9th. Furthermore, even though that 6 testimony, in the ordinary course of the Commission's 7 practice, is permitted to be served on the parties by 8 regular mail, and that is what MCI did in this case, 9 I believe that that was highly prejudicial to us, 10 since we did not, in fact, get it until Wednesday, 11 the day before the hearing, and had no real 12 opportunity to review it, since when it came in at 13 4:00 in the late mail Wednesday afternoon, we were 14 already down here and going into hearings yesterday 15 morning. So I don't believe we've had a reasonable 16 opportunity to review it. 17 I know it's short, but nonetheless, that 18 issue, coupled with the fact that I don't think that 19 MCI was even authorized to file testimony on the 9th, 20 leads to my objection. 21 JUDGE CRAINE: Mr. Pena. 22 MR. PENA: Your Honor, I do believe it's 23 proper reply testimony to testimony filed by other 24 parties. And in terms of the filing, I apologize, 25 Lisa, I was under the understanding that parties got 00272 1 it electronically, along with regular mail. And I 2 have nothing else. I honestly thought that the 3 testimony had been filed electronically. 4 MS. PROCTOR: It was. I got it. 5 MS. ANDERL: I don't believe that I did, 6 although I get, like, 50 e-mails a day. 7 MS. PROCTOR: So you don't know would be 8 the proper response. 9 MS. ANDERL: No, I think the proper 10 response is I don't believe that I did. 11 MS. PROCTOR: The testimony also doesn't 12 address US West. 13 MS. ANDERL: It does to some extent, to the 14 extent that the other parties address US West. 15 JUDGE CRAINE: I'm going to take this under 16 advisement. I'd like Ms. Anderl to cross-examine to 17 the extent she can. If we end up receiving it and 18 there's a point that US West needs to cross-examine 19 on, we'll arrange for a conference call or something. 20 But I'm going to have to check into what our filing 21 requirements were and the scope of permissible 22 responses to the September 18th testimony. 23 MR. PENA: Thank you, Your Honor. 24 JUDGE CRAINE: So what I'd like to do is 25 take it under advisement and proceed. Go ahead. 00273 1 MS. ANDERL: I understand. Thank you, Your 2 Honor. 3 JUDGE CRAINE: Any other objections to this 4 testimony? Okay. I have US West as the only party 5 -- excuse me, US West and Staff as the parties for 6 cross-examination. US West I have down for 45 7 minutes. 8 MS. ANDERL: Yes, thank you, Your Honor. 9 In discussing this matter with Counsel for GTE, I 10 believe that they also have some questions. 11 JUDGE CRAINE: Is that correct? 12 MR. MERHIGE: That is correct. 13 JUDGE CRAINE: How much time do you -- 14 MR. MERHIGE: I think we actually had 15 initially indicated 30 minutes, but I think we can do 16 it in 10 minutes. 17 JUDGE CRAINE: Okay, thank you. 18 MS. ANDERL: And I think my estimate's 19 still pretty right on, so -- 20 JUDGE CRAINE: Well, you've got the biggest 21 chunk of time, so we'll take you first. 22 MS. ANDERL: Thank you. 23 C R O S S - E X A M I N A T I O N 24 BY MS. ANDERL: 25 Q. Good morning, Mr. Lathrop. 00274 1 A. Good morning. 2 Q. I'm Lisa Anderl, representing US West 3 Communications. Have you had an opportunity to 4 review the testimony that was filed by US West on 5 October 9th, specifically the testimony filed by Gary 6 Fleming and the supporting cost material? 7 A. I flipped through it. I did not review it 8 in any detail. 9 Q. Did your review of the testimony disclose 10 to you that he had sponsored a new EICT cost study? 11 A. Yes. 12 Q. Did you review the assumptions -- well, did 13 you review that cost study? 14 A. Again, not in any detail. I was served by 15 -- I don't know if it was regular mail or MCI 16 WorldCom's interoffice mail, but I also got it 17 several days later. 18 Q. Did you happen to glance at the -- I 19 believe it's either the cover page or one or two 20 pages in, which identifies that several changes were 21 made, some of which specifically in response to your 22 testimony? 23 A. Yes, I recall a few of the components that 24 I listed as unnecessary, if I recall correctly, were 25 removed. My concern is that I literally did flip 00275 1 through the pages and tried to scan some of it, so I 2 don't know whether it -- I know it responded, to some 3 extent, to the testimony I filed. I don't know if it 4 completely accepted my position. 5 Q. Okay. Did you note whether or not it 6 indicated that certain of the items that you 7 designated as unnecessary, such as, I think, pin 8 sleeves, were removed? 9 A. Yes, there were a few items. I believe it 10 also stated that -- I don't know if it was included 11 in that cost study, but the length of those cables 12 was planned to be reduced perhaps in a later filing, 13 although it may have been in that filing. I assumed 14 that I'd get an opportunity to file responsive 15 testimony at a later date, since the proceeding has 16 shifted a little bit and US West is going to be 17 filing testimony responsive to Mr. Sobieski's 18 testimony. 19 Q. Is it your understanding that -- and this 20 may be something I have to work out with counsel, but 21 is it your understanding that you were planning on 22 addressing Mr. Fleming's testimony in a later round 23 of responsive testimony, then? 24 A. I guess not -- I don't know the answer to 25 that question, because not having reviewed it 00276 1 completely, it may be that I would work with counsel 2 and there would be cross-examination that we would 3 develop based on that. But at this stage, I'm not 4 sure what the schedule is to accommodate one of the 5 more recent Commission orders of October 2nd, I 6 believe. 7 Covad -- the Commission states that Covad 8 and other parties may file reply testimony no later 9 than November 23rd, 1998, which would reply to US 10 West's testimony, I guess commenting on Mr. 11 Sobieski's testimony that was initially not going to 12 be in the case and now is going to be in the case, to 13 some limited extent. 14 Q. Thank you. That was a good summary. 15 A. Yikes. That's off the cuff. 16 Q. Did you note what the new cable length was 17 identified as on the revised EICT study? 18 A. No. 19 Q. If I were to tell you that it has been 20 reduced from the -- well, what is your recommended 21 cable length? I think that you found the 400 to 22 600-foot range to be unacceptable in your view; is 23 that right? 24 A. Yes, and I think that was a point with 25 which US West's witness agreed. And my 00277 1 recommendation in Exhibit 512 is 165 feet, based on 2 principles I outline in the testimony. And I noted 3 that US West's cable length for voice grade cable is 4 actually less than that in its initial filing. 5 Q. So if US West's revised cable length for 6 the EICT cost study following October 9th were in the 7 neighborhood of 165 feet, that would be acceptable to 8 you? 9 A. Yes. 10 Q. On page five, line five of your testimony, 11 your direct -- and I think I'm only going to ask you 12 questions about your direct at this point. Lines 13 five through seven -- well, is that right? Yes. I'm 14 sorry, it's line eight. You state that collocation 15 charges must reflect cost causation to the extent 16 feasible. What do you mean by that? 17 A. That a proper cost study examines and 18 provides the cost of elements based on those 19 functions or elements that are related to the cost. 20 For example -- this may help. Power is based on -- 21 the cost of power is based on the equipment that 22 draws the power, and not on square footage that the 23 equipment takes up. 24 This was an example in the FCC's -- I 25 believe in the FCC's order that shifted the cost of 00278 1 power -- a cost causation applied to power would cost 2 power based on the equipment or on the equipment that 3 draws the power, as opposed to the floor space the 4 equipment takes up in a central office. So I believe 5 costs should be based on those things that cause 6 those costs to be incurred. 7 Q. And then the activity and the individual or 8 company which causes those costs should be charged 9 for the prices for recovery of those costs? 10 A. Yes, to some extent. That would include, 11 for example, costs that are shared amongst causers. 12 For example, power plant, to extend this example, 13 power plant in the central office is not caused by 14 the collocators, although the collocators use a share 15 of that power plant. The power's both the incumbent 16 LEC's equipment, as well as the collocator's 17 equipment. 18 Similarly, if a collocator happens to place 19 equipment at a time when, in the natural course of 20 events, the incumbent would add significantly to its 21 power plant, that incidence of timing would not 22 necessarily -- should not necessarily be imposed on 23 the collocator, so the -- while I can agree with your 24 statement that the costs should be incurred by the 25 collocator, you have to be very careful in how you 00279 1 define the type of cost and what the cost element is. 2 Q. On page seven of your testimony, line 14, 3 and you may want to take a look at this, you say the 4 proposed prices on which US West's collocation costs 5 are based. Do you mean that the other way around? 6 A. Yes, I do. Thank you. 7 Q. You're welcome. 8 JUDGE CRAINE: So you're going to exchange 9 the word cost for prices, and vice versa? 10 THE WITNESS: Yes, if I may. 11 Q. On page eight, you mention that US West and 12 GTE have not addressed cageless collocation. Is that 13 a criticism of US West's filing in this instance or 14 just an observation? 15 A. I think both. In response to a discovery 16 request that initially was objected to by US West and 17 was, I guess, overruled and permitted, US West, in 18 its standards and procedures for collocation, lists 19 both shared and cageless, which I believe it terms 20 uncaged. 21 And as I explain on page nine, that there's 22 the problems the collocators face in time and cost 23 with obtaining collocation, to a large degree, at 24 least have the opportunity to be alleviated with 25 these forms of collocation that US West actually 00280 1 offers and GTE, I believe, offers, or will soon 2 offer. 3 And in an examination of their costs, I 4 think the problem I state with individual case basis 5 costs could occur if those costs are not addressed 6 all at the same time in one proceeding. In other 7 words, if cageless and shared collocation are not 8 addressed and this proceeding is concluded, then, if 9 a collocator wants to avail themselves of those 10 opportunities, they may be subject to individual case 11 basis charges because there are no tariffed rates. 12 Q. Isn't it true that the terms and conditions 13 for collocation are generally, if not exclusively, 14 contained in the individual interconnection 15 agreements between the parties? 16 A. That may be true. There are also, since 17 there are several parties here, the legal issue is 18 not clear to me as to what happens, whether a cost 19 analysis proceeding, such as this one, or one the 20 Commission may have would replace those 21 interconnection agreements or not. 22 Q. Do you have any reference to any Commission 23 order which you contend required US West or GTE to 24 address common or cageless? 25 A. No. 00281 1 Q. What is cageless collocation, as you 2 understand it? 3 A. It is the placement of collocators' 4 equipment in the same equipment lineups in the 5 central office as the incumbent LEC's equipment. 6 However, unlike virtual collocation, in which that 7 equipment is placed in the same lineups, the 8 ownership of the equipment is retained with the 9 collocator. The collocator is then able to avoid 10 costs for training the incumbent's personnel on that 11 equipment, if it is new, they're able to avoid 12 maintenance charges and, to some extent, at least the 13 hope is to get more quicker maintenance. 14 If there's some sort of maintenance problem 15 today, the collocator, in virtual collocation, is 16 completely reliant on the ILEC to do things -- simple 17 things, such as replace a line card, that the 18 collocators can do of their own accord. 19 Q. Are you aware of the specifics of how US 20 West offers cageless collocation? 21 A. No, I'm not. In a Minnesota proceeding in 22 which I was a witness, we cross-examined the US West 23 witness, who was unable to explain that to us. And I 24 must admit that I don't recall whether the discovery 25 response I just referenced explained in detail 00282 1 whether the event I just explained would, in fact, 2 occur. That is, that the collocator would be able to 3 access their equipment for maintenance purposes. 4 Q. When a collocator requests virtual 5 collocation, is it your understanding that that 6 collocator is charged for floor space on a 7 per-square-foot basis for virtual? 8 A. Generally, yes. It really depends on the 9 state. We have proposed, in other jurisdictions, 10 that a collocator be entitled to pay on a 11 per-quarter-rack basis, because the relay racks are 12 essentially bookshelf-like devices that collocators 13 place their equipment in. The equipment that's 14 placed wouldn't necessarily take up a whole rack, so 15 that a collocator shouldn't necessarily have to pay 16 for a whole rack if they don't use a whole one, 17 because the next collocator that comes in could fit 18 their -- it's sort of like stereo equipment that fits 19 into these racks. 20 So although in other testimony I've said 21 you could conceivably price this on a per-rack-inch 22 basis, that might be difficult to administer, so 23 we've recommended quarter rack. I believe Bell 24 Atlantic -- I don't recall if it's a state or federal 25 tariff -- charges on a per-half-rack basis for 00283 1 virtual collocation, recognizing the same thing, that 2 the telecommunications equipment that is placed does 3 not take up the whole seven feet or so that a relay 4 rack offers. 5 Q. When you say relay rack, do you mean that 6 to be the same as an equipment bay? 7 A. Yes, I use those terms interchangeably. 8 Q. Do you have any understanding whether or 9 not US West requires cageless physical collocation to 10 be purchased on a minimum of a bay at a time basis? 11 A. I suspect yes. The problem I have is I 12 define physical collocation to be what it has 13 traditionally been, which is the collocator's 14 equipment is in a segregated part of the CO, usually 15 caged off, so physical cageless, if I recall, or 16 physical -- I think that's what you said -- are two 17 different things in my mind. 18 Q. Okay. Understand, when I ask you the 19 questions, Mr. Lathrop, that physical collocation is 20 when the collocator owns the equipment, and it's 21 either in a cage or not, depending on whether I say 22 caged or cageless. 23 A. Will you be using the term shared? 24 Q. No. 25 A. Okay. 00284 1 Q. Are those definitions acceptable to you, 2 for purposes of these questions? 3 A. I'll try and explain if I have problems 4 using them. Thanks for clarifying that. 5 Q. With that clarification, that's probably 6 all the questions that I have on that. Who knows, I 7 could come back to it. As you use the term on page 8 nine of your testimony, POT bay, P-O-T bay, what does 9 that mean? 10 A. Do you mean what is a point of termination 11 or -- 12 Q. Well, what is the function and physical 13 description of a point of termination bay? 14 A. I guess the easiest explanation in the 15 context here is I'm explaining in my testimony what 16 components are required for collocation, and when the 17 collocator's equipment is placed in the central 18 office, it needs to be connected to a cross-connect 19 device for voice grade. It's usually a main 20 distribution frame, or MDF, or a cosmic frame, which 21 is another type of the same device. And there's no 22 physical reason why the collocator's equipment could 23 not be cabled directly from their equipment in a cage 24 or not in a cage directly to this cross-connect 25 device. 00285 1 However, what typically happens is the 2 collocator places a bay and equipment rack in between 3 their equipment and the cross-connect device, and 4 there are a couple of reasons. One is the collocator 5 needs to be able to test their equipment and they 6 need access to the testing point. The ILECs 7 typically do not permit the collocators to have 8 access to their main distribution frame. That 9 requires there be some other place where the parties 10 can have access. So there's no reason why you 11 couldn't -- a technical reason why you couldn't cable 12 straight to the MDF, but what is common is that this 13 point of termination bay is used for access to 14 testing and those sorts of things. 15 Q. Are you familiar with the SPOT bay concept, 16 as US West has described it in its testimony, single 17 point of termination bay? 18 A. Generally, yes. 19 Q. Functionally, doesn't it do the same thing 20 as the POT bay? 21 A. No. In fact, it's very different, as I 22 explain to some degree in Exhibit 513. But what US 23 West is proposing is an additional point of 24 termination and additional cross-connect place in 25 between the MDF and the collocator's equipment. What 00286 1 this requires is extra cabling, extra points of 2 termination, which means extra points of network 3 failure, and their potential coordination problems. 4 So that today, cabling from the SPOT frame, 5 a POT bay, from the collocator's cage to the MDF, 6 when a customer wants to choose that CLEC, there's a 7 cross-connect run from one side of the MDF to the 8 other side. With the SPOT bay, there's extra work 9 that needs to be done. That same cross-connect would 10 need to be run, but another one would need to be run 11 at the SPOT frame under US West's proposal. And the 12 same issues of access arise; that there's no one 13 party that's given access to that SPOT frame. 14 So what I say in Exhibit 513 is that it 15 introduced extra costs because there's extra 16 equipment the collocator presumably would have to pay 17 for, there's extra cabling involved, extra work 18 involved, and that's my understanding of using the 19 SPOT frame concept for collocation under US West's 20 proposal. 21 Q. Isn't it correct that the SPOT frame would 22 give you access for testing in the same manner that 23 the POT bay does, as you described it? 24 A. No, because the POT bays are typically 25 located in close proximity to the collocator's 00287 1 equipment. In a tour of a central office I went on 2 as part of the Minnesota proceeding, the SPOT frame 3 that US West had deployed in the central office was 4 multiple floors away. That would probably require 5 access in the CO, security concerns that US West had, 6 so it was inconvenient and leads to additional cost, 7 because, again, that cable has to be routed several 8 floors away and the additional device paid for. 9 Q. Do you know whether or not US West has 10 included any costs for the SPOT bay in its physical 11 collocation cost study? 12 A. I don't recall seeing any in the cost study 13 that I reviewed, and I don't know if there are any in 14 the ones that were recently filed. 15 Q. You contend that a forward-looking central 16 office is unlikely to be more than three stories 17 high; is that correct? 18 A. Absolutely. 19 Q. Have you performed any study to support 20 that contention? 21 A. In a way, yes. In response to a discovery 22 request -- well, first, US West's existing central 23 offices in Washington, I believe 89 percent of them 24 are three floors or less. And I actually, as I 25 mention in my testimony, have been part of a cost 00288 1 study effort sponsored by MCI initially, now MCI 2 WorldCom and AT&T, to develop a forward-looking cost 3 model of collocation, and a three-story central 4 office is more than generous-sized to fit the types 5 of equipment that would be placed today if a central 6 office were to be built today. 7 Q. What was your involvement in that study? 8 A. Can you -- 9 Q. What did you do, you personally? 10 A. I met with the consultants and in-house 11 people that we had. We were developing both a policy 12 position paper, a white paper, as well as a cost 13 study. And I coordinated, on MCI's side, the 14 technical people and the costing consultants, so I 15 helped draft versions of t