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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		DOCKET NO.  UT-960369
		
		DOCKET NO.  UT-960370
		
		DOCKET NO.  UT-960371
		
		          (PHASE II)
		
		U S WEST’S RESPONSE TO THE COMMISSION’S CALL FOR ANSWERS TO AT&T’S MOTION TO 
STRIKE
		 

 U S WEST Communications, Inc. (U S WEST) hereby files this response to the 
Commission’s call for answers to AT&T’s motion to strike U S WEST’s shared 
transport testimony.  U S WEST does not believe that AT&T’s motion should be 
granted, for all the reasons set forth in U S WEST’s November 16, 1998 filing 
in response to the Administrative Law Judge’s ruling.  
 The most compelling reason to deny that motion is that U S WEST’s filing was 
directly responsive to a Commission order requiring shared transport testimony 
and cost and pricing analysis.  A portion of U S WEST’s earlier response is set 
forth below, explaining why AT&T’s motion is without merit.
There is No Basis for AT&T’s Motion
 AT&T has essentially moved to strike U S WEST’s submission on the grounds that 
AT&T disagrees with U S WEST’s advocacy.  U S WEST respectfully suggests that 
this is what responsive testimony is for.  
 AT&T cites no Commission, FCC, or court order as a basis for striking the 
testimony, nor does AT&T assert that the filing is not in compliance with the 
Commission directive to produce a shared transport cost study.  In fact, the 
FCC’s order as it pertains to pricing is of no force and effect; the FCC’s 
pricing rules having been stayed and then vacated two years ago. Further, if 
AT&T had bothered to read U S WEST’s testimony, AT&T would know that U S WEST 
presents a detailed analysis of how and why its costing and pricing proposal is 
consistent with the Eighth Circuit’s order and the Commission’s orders in this 
docket.
 AT&T expressly acknowledges, at paragraph 2 of its motion, that “U S WEST 
presents cost estimates, not on a minute-of-use basis, but for DS0 and DS1 
capacity.”  As will be discussed below, this is not even entirely correct, as 
costs on a minutes-of-use basis can be derived from the filed study, but in any 
event, this is exactly what the Commission required of U S WEST in the 14th 
Supplemental Order.  There, at paragraph 41, the Commission directed U S WEST 
to “develop a cost estimate for direct transport that is consistent with the 
Eighth Circuit Court’s finding that the ILECs must provide shared transport.”  
Thus, there is no basis upon which the testimony can be stricken.  If AT&T 
disagrees with DS0/DS1 pricing, AT&T can simply say so in its responsive 
testimony. In fact, in its responsive testimony, AT&T expressly acknowledges 
that U S WEST’s costs are first developed on a per minute of use basis, 
completely contradicting the claim made in its motion to strike.  See, Denney 
testimony of November 13, 1998, page 2, line 8.  
 It is evident from the motion that AT&T’s real reason for filing was to obtain 
an extension of time and to further delay the schedule in this matter.  That is 
an issue that AT&T could properly raise in a request for a continuance, but is 
improper here.  AT&T and other parties have suggested to the Commission that 
more time is necessary for the development of the record in this case, but the 
Commission has ruled that it wishes to resolve these issues without additional 
delay.  AT&T should adhere to the schedule already established, and devote its 
resources to developing responsive testimony instead of burdening the 
Commission and the parties with ill-founded motions and disguised requests to 
add months to the schedule.
 Furthermore, events have shown that AT&T was able to prepare and file 
responsive testimony on November 13, and to file responsive comments to U S 
WEST’s November 16, 1998 filing.  Thus, it does not appear that the delay 
originally sought by AT&T was necessary. 
 U S WEST notes that AT&T has already been granted some of the relief it 
requested.  The opportunity now to file an answer cannot correct that harm, but 
the Commission should rule on the remaining relief requested by AT&T and deny 
AT&T’s motion.
 Respectfully submitted this 25th day of November, 1998.

      U S WEST Communications, Inc.



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