PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
I. D. #5642
ENERGY DIVISION RESOLUTION E-3998
6/15/06
Resolution E-3998. San Diego Gas and Electric Company (SDG&E). Proposal for a new Unmetered Service Rate Schedule where meters for small loads are uneconomical or not permitted on public rights of way by local governments.
By Advice Letter (AL) 1780-E Filed on 3/15/06 and Substitute sheets of 4/14/06.
__________________________________________________________
SUMMARY
This Resolution approves SDG&E's AL 1780-E as modified. A new Rate Schedule UM for Unmetered Electric Service is approved, as is Form 155-100 an Application and Contract for Unmetered Service under Schedule UM. Utility charges to initiate service and for service calls are deleted from the Schedule and Contract, and SDG&E must add the range of its hourly charges for auditing the device locations and energy consumptions.
BACKGROUND
SDG&E and other electric utilities often receive requests for unmetered service for small loads. These loads are primarily for communication devices (cell and WiFi antennae) mounted mostly on streetlight posts, where metering would be uneconomical and meter installations obstructive or restricted by local governments. In order to streamline the provision of this type of service, SDG&E is proposing a new Rate Schedule UM in lieu of formerly executed specific contracts. SDG&E used SCE's Schedule WTR and its related contract form as the model for their proposed tariff. SCE's Schedule WTR, Wireless Technology Rate was effective April 1, 2006.
NOTICE
Notice of AL 1780-E was made by publication in the Commission's Daily Calendar. SDG&E states that a copy of the Advice Letter was mailed and distributed in accordance with Section III-G of General Order 96-A.
PROTESTS
No protests were received to this AL, however the Energy Division considers the charges proposed in this AL beyond the scope of an AL and not justified by extra costs to the utility beyond the costs accounted for in rates of the comparable Schedule A.
On March 14, 2006 NextG Networks commented favorably to SDG&E's AL.
The following is a more detailed summary of the major issues raised by the Energy Division.
DISCUSSION
SDG&E's proposed Rate Schedule is based on a similar SCE Rate Schedule, but SDG&E would permit higher consumption per device and would impose extra charges. SCE does not levy extra charges under their equivalent tariff.
SDG&E's proposed schedule allows for up to 2700 kWh per month per device, while SCE's Schedule WTR is limited to 500 kWh per month per device. Both utilities require the customer to provide a fuse and box, locked by the utility.
The consumption on the proposed schedule is limited by fuses and charged at a flat monthly rate for each fuse size.
The rates for the unmetered service of both utilities are based on their general service rates, including the Basic Service Fee of $ 9.10 for SDG&E and Customer Charge of $ 5.09 for SCE.
However SDG&E's proposed tariff includes an additional $100 one-time charge per device and a $113 charge for each visit unless caused by SDG&E.
SCE does not require these extra charges, but only a nominal lock charge.
SDG&E states that the initiation charge for this unmetered service covers inspection and a lock for the fuse box. SDG&E provided labor rate and job duration information supporting this initiation charge, but did not show why that is not already included in its Basic Service Fee and distribution rates as for metered service. SDG&E states only that its cost for a coordinated meeting for each device is more than its usual cost to set a meter, make a monthly meter reading, and cover meter maintenance and testing costs. SDG&E's Basic Service Fee is nearly double SCE's comparable fee.
Similarly, we do not agree with the $113 fee for each visit to a device, even for reasons beyond the utility's control. SDG&E already states in the proposed schedule that the customer may have to pay for maintenance costs exceeding its normal maintenance expenses resulting from, but not limited to, vandalism. SDG&E therefore acknowledges that maintenance is already included in the regular Basic Service Fee and distribution rates. Additional charges and fees do not apply to SDG&E's service under Schedule A.
SDG&E further states in its Application and Contract for Unmetered Service for Schedule UM that it will charge for auditing the device location and energy consumption at its discretion, up to annually. While auditing seems a necessary and additional task for this kind of service, the open ended costs for it raise concerns. At least a personhour rate range for such auditing should be stated in Schedule UM and the Contract to allow the customer some measure of verification of such charges, along with reasonable notice of field audits.
SDG&E states that NextG is waiting to be the first customer under Schedule UM and is willing to pay the proposed extra charges.
While NextG may be willing and able to pay these charges because of expediency, this proposed schedule is valid for other customers, some of them less willing or able to pay more than Schedule A for comparable service. We should not forget that commercial customers will simply pass on these costs to ultimate consumers of their products and services.
Another concern is SDG&E's request for a new rate schedule via the AL process. Since the proposed rates are identical to existing Schedule A it might be appropriate because SCE's similar Schedule WTR was approved by AL. However SDG&E's extra charges represent a rate increase. SDG&E may include its proposed extra charges in its next General Rate Case, based on its experience at that time justifying extra charges, if any.
COMMENTS
Public Utilities Code section 311(g) (1) provides that this resolution must be served on all parties and subject to at least 30 days public review and comment prior to a vote of the Commission. Section 311(g) (2) provides that this 30-day period may be reduced or waived upon the stipulation of all parties in the proceeding.
The 30-day comment period for the draft of this resolution was neither waived nor reduced. Accordingly, this draft resolution was mailed to parties for comments, and will be placed on the Commission's agenda no earlier than 30 days from today
FINDINGS
1. SDG&E proposes a new Rate Schedule UM and Application and Contract for Unmetered Service, primarily for wireless communication devices mounted on street lighting poles where local government does not permit meter installations or where this would be uneconomical.
2. The new schedule has identical rates to SDG&E's Schedule A, General Service and is modeled after SCE's approved Schedule WTR.
3. The consumption on the proposed schedule is limited by fuses and charged at a flat monthly rate for each fuse size.
4. The proposed Schedule UM includes the same Basic Service Fee for billing, meter reading, maintenance, testing and service calls as charged for the metered service under Schedule A.
5. In addition to the Schedule A charges, SDG&E would charge $100 for initiation of service on each device and $113 for each service call, unless caused by SDG&E.
6. SCE does not charge such additional fees. SDG&E has not provided credible evidence of cost beyond that for similar metered service.
7. New rates and charges are subject to Applications and SDG&E may apply for them in a General Rate Case.
8. The proposed auditing costs are not defined in Schedule UM and the Contract.
9. The Basic Service Fee of $ 9.10 is not spelled out in the proposed Schedule UM.
10. Commercial customers are able to pass through extra fees and costs to ultimate consumers of their products and services.
THEREFORE IT IS ORDERED THAT:
1. The request of SDG&E to establish a new Rate Schedule UM and Application and Contract for Unmetered Service, Form 155-100, as requested in Advice Letter AL 1780-E is approved with modifications.
2. Service initiation and service call fees shall be deleted from the Schedule and Contract. SDG&E shall apply for such fees in an Application.
3. The proposed auditing costs shall be defined at least by a personhour range in the Schedule and Contract.
4. The Basic Service Fee of $ 9.10 shall be stated in Schedule UM.
5. The proposed Schedule UM and Application and Contract Form 155-100 shall be revised as ordered above and resubmitted within 30 days of this order.
This Resolution is effective today.
I certify that the foregoing resolution was duly introduced, passed and adopted at a conference of the Public Utilities Commission of the State of California held on June 15, 2006; the following Commissioners voting favorably thereon:
_______________
STEVE LARSON
Executive Director
ID #5642
May 2, 2006 E-3998
TO: PARTIES TO ADVICE LETTERS SDG&E 1780-E
Enclosed is draft Resolution E-3998 of the Energy Division. It will be on the agenda at the June 15 Commission meeting. The Commission may then vote on this Resolution or it may postpone a vote until later.
When the Commission votes on a draft Resolution, it may adopt all or part of it as written, amend, modify or set it aside and prepare a different Resolution. Only when the Commission acts does the Resolution become binding on the parties.
Parties may submit comments on the draft Resolution.
An original and two copies of the comments, with a certificate of service, should be submitted to:
Jerry Royer
Energy Division
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102
A copy of the comments should be submitted to:
Werner Blumer
Energy Division
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102
Fax: 415-703-2200
Email: wmb@cpuc.ca.gov
Any comments on the draft Resolution must be received by the Energy Division by May 18, 2006. Those submitting comments must serve a copy of their comments on 1) the entire service list attached to the draft Resolution, 2) all Commissioners, and 3) the Director of the Energy Division, on the same date that the comments are submitted to the Energy Division.
Comments shall be limited to five pages in length plus a subject index listing the recommended changes to the draft Resolution, a table of authorities and an appendix setting forth the proposed findings and ordering paragraphs.
Comments shall focus on factual, legal or technical errors in the proposed draft Resolution. Comments that merely reargue positions taken in the advice letter or protests will be accorded no weight and are not to be submitted.
Replies to comments on the draft resolution may be filed (i.e., received by the Energy Division) on May 25, 2006, 7 days after comments are filed, and shall be limited to identifying misrepresentations of law or fact in the comments of other parties. Replies shall not exceed five pages in length, and shall be filed and served as set forth above for comments.
Late submitted comments or replies will not be considered.
Ken Lewis
Program Manager
Energy Division
Enclosure: Service List
CERTIFICATE OF SERVICE
I certify that I have by mail this day served a true copy of Draft Resolution E-3998 on all parties in
these filings or their attorneys as shown on the attached list.
Dated May 2, 2006 at San Francisco, California.
___________
Jerry Royer
NOTICE
Parties should notify the Energy Division, Public Utilities
Commission, 505 Van Ness Avenue, Room 4002
San Francisco, CA 94102, of any change of address to
ensure that they continue to receive documents. You
must indicate the Resolution number on the service list
on which your name appears.
Service List R.0212004
BARBARA R. ALEXANDER CONSUMER AFFAIRS CONSULTANT 83 WEDGEWOOD DRIVE WINTHROP, ME 4364 |
ATTORNEY AT LAW MARILYN ASH MPOWER COMMUNICATIONS CORP. 175 SULLYS TRAIL, SUITE 300 PITTSFORD, NY 14534 |
MARK ASHBY CINGULAR WIRELESS 5565 GLENRIDGE CONNECTOR, STE 1700 ATLANTA, GA 30342 | ||
LAEL ATKINSON COVAD COMMUNICATIONS COMPANY 816 CONGRESS AVENUE, SUITE 1100 AUSTIN, TX 78701 |
ATTORNEY AT LAW SEAN P. BEATTY COOPER, WHITE & COOPER, LLP 201 CALIFORNIA ST., 15TH FLOOR SAN FRANCISCO, CA 94111 |
ATTORNEY AT LAW JEFFREY F. BECK COOPER, WHITE & COOPER ,L.L.P. 201 CALIFORNIA ST., 17TH FLOOR SAN FRANCISCO, CA 94111 | ||
W. LEE BIDDLE FERRIS AND BRITTON, APC 401 W. A ST., SUITE 1600 SAN DIEGO, CA 92101 |
ATTORNEY AT LAW LEON M. BLOOMFIELD WILSON & BLOOMFIELD LLP 1901 HARRISON STREET, SUITE 1620 OAKLAND, CA 94612 |
MANAGER-STATE GOVERNMENT AFFAIRS CHARLES E. BORN FRONTIER, A CITIZENS TELECOMMUNICATIONS PO BOX 340 ELK GROVE, CA 95759 | ||
DOUGLAS H. BOSCO HOLLAND & KNIGHT, LLC 50 CALIFORNIA STREET, SUITE 2800 SAN FRANCISCO, CA 94111 |
ATTORNEY AT LAW STEPHEN B. BOWEN BOWEN LAW GROUP 235 MONTGOMERY STREET, SUITE 920 SAN FRANCISCO, CA 94104 |
ATTORNEY AT LAW PETER A. CASCIATO PETER A. CASCIATO P.C. 355 BRYANT STREET, SUITE 410 SAN FRANCISCO, CA 94107 | ||
SENIOR COUNSEL GREGORY L. CASTLE SBC CALIFORNIA 525 MARKET STREET, RM. 2022 SAN FRANCISCO, CA 94105 |
DARLENE M. CLARK AT&T COMMUNICATIONS OF CALIFORNIA, INC. 795 FOLSOM STREET, SUITE 2169 SAN FRANCISCO, CA 94107 |
ATTORNEY AT LAW JOHN CLARK GOODIN MACBRIDE SQUERI RITCHIE & DAY LLP 505 SANSOME STREET, 9TH FLOOR SAN FRANCISCO, CA 94111 | ||
REGINA COSTA THE UTILITY REFORM NETWORK 711 VAN NESS AVENUE, SUITE 350 SAN FRANCISCO, CA 94102 |
NANCY DAVIS VERIZON WIRELSS 15505 SAND CANYON AVENUE, E305 IRVINE, CA 92618 |
ATTORNEY AT LAW MICHAEL B. DAY GOODIN MACBRIDE SQUERI RITCHIE & DAY LLP 505 SANSOME STREET, SUITE 900 SAN FRANCISCO, CA 94111 | ||
LUPE DE LA CRUZ AARP CALIFORNIA 980 9TH STREET, NO. 700 SACRAMENTO, CA 95814 |
JANE DELAHANTY U.S. TELEPACIFIC CORP. 515 S. FLOWER STREET, 47TH FLOOR LOS ANGELES, CA 90071-2201 |
ATTORNEY AT LAW RANDOLPH W. DEUTSCH SIDLEY, AUSTIN, BROWN & WOOD, LLP 555 CALIFORNIA STREET SAN FRANCISCO, CA 94104 | ||
LOS ANGELES DOCKET OFFICE CALIFORNIA PUBLIC UTILITIES COMMISSION 320 W. 4TH STREET, SUITE 500 LOS ANGELES, CA 90013 |
ATTORNEY AT LAW ELAINE M. DUNCAN VERIZON CALIFORNIA INC. 711 VAN NESS AVENUE, SUITE 300 SAN FRANCISCO, CA 94102 |
EUGENE M. ENG VERIZON CALIFORNIA, INC. 112 LAKEVIEW CANYON ROAD THOUSAND OAKS, CA 91362 | ||
ATTORNEY AT LAW BOB FINKELSTEIN THE UTILITY REFORM NETWORK 711 VAN NESS AVENUE, SUITE 350 SAN FRANCISCO, CA 94102 |
TELECOM POLICY ANALYST MAUREEN K. FLOOD HARRIS, WILTSHIRE & GRANNIS LLP 1200 EIGHTEENTH STREET, NW WASHINGTON, DC 20036 |
Faline Fua CALIF PUBLIC UTILITIES COMMISSION 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 | ||
DOUG GARRETT COX CALIFORNIA TELCOM LLC 2200 POWELL STREET, SUITE 1035 EMERYVILLE, CA 94608 |
Janice L. Grau CALIF PUBLIC UTILITIES COMMISSION 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 |
DIRECTOR, GOVERNMENT AFFAIRS JOHN GUTIERREZ COMCAST PHONE OF CALIFORNIA, LLC 12647 ALCOSTA BLVD., SUITE 200 SAN RAMON, CA 94583 |
ESQUIRE CORALETTE HANNON AARP LEGISLATIVE REPRESENTATIVE 6705 REEDY CREEK ROAD CHARLOTTE, NC 28215 |
CHARLES HARAK NATIONAL CONSUMER LAW CENTER 77 SUMMER STREET, 10TH FLOOR BOSTON, MA 2110 |
REGULATORY DIRECTOR CRYSTAL HERBERSTON QWEST COMMUNICATIONS CORPORATION 1801 CALIFORNIA STREET, SUITE 4700 DENVER, CO 80202 | ||
YVETTE HOGUE 140 NEW MONTGOMERY STREET, ROOM 915 SAN FRANCISCO, CA 94105 |
LAURA L. HOLLOWAY NEXTEL COMMUNICATIONS, INC. 2001 EDMUND HALLEY DRIVE RESTON, VA 20091 |
Charlyn A. Hook CALIF PUBLIC UTILITIES COMMISSION 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 | ||
James W. Howard CALIF PUBLIC UTILITIES COMMISSION 770 L STREET, SUITE 1050 SACRAMENTO, CA 95814 |
DIRECTOR-STATE AFFAIRS ANDREW O. ISAR ASSOCIATION OF COMMUNICATIONS ENTERPRISE 7901 SKANSIE AVE., SUITE 240 GIG HARBOR, WA 98335 |
LAURIE ITKIN CRICKET COMMUNICATIONS, INC. 10307 PACIFIC CENTER COURT SAN DIEGO, CA 92121 | ||
Izetta C. R. Jackson CALIF PUBLIC UTILITIES COMMISSION 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 |
MARKET ATTORNEY, CONSULTANT KRISTIN JACOBSON NEXTEL OF CALIFORNIA, INC. 1255 TREAT BLVD., SUITE 800 WALNUT CREEK, CA 94596 |
ALEJANDRO JIMENEZ CINGULAR WIRELESS 2521 MICHELLE DRIVE, 2ND FLOOR TUSTIN, CA 92780 | ||
JOSE JIMENEZ COX CALIFORNIA TELCOM, L.L.C. 2200 POWELL STREET, SUITE 1035 EMERYVILLE, CA 94608 |
ATTORNEY AT LAW MARC D. JOSEPH ADAMS BROADWELL JOSEPH & CARDOZO 601 GATEWAY BLVD. STE 1000 SOUTH SAN FRANCISCO, CA 94080 |
ROBERT N. KITTEL U.S. ARMY LITIGATION CENTER 901 N. STUART STREET, SUITE 700 ARLINGTON, VA 22203-1837 | ||
REGIONAL VICE PRESIDENT REX KNOWLES XO COMMUNICATIONS SERVICES, INC. 111 EAST BROADWAY, SUITE 1000 SALT LAKE CITY, UT 84111 |
COUNSEL STEPHEN H. KUKTA SPRINT NEXTEL 201 MISSION STREET, SUITE 1400 SAN FRANCISCO, CA 94105 |
ATTORNEY AT LAW LESLA LEHTONEN CALIFORNIA CABLE & TELECOM ASSOCIATION 360 22ND STREET, SUITE 750 OAKLAND, CA 94612 | ||
Tom Long CALIF PUBLIC UTILITIES COMMISSION 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 |
LEGAL ASSISTANT JACQUE LOPEZ VERIZON CALIFORNIA INC 112 LAKEVIEW CANYON ROAD THOUSAND OAKS, CA 91362 |
ATTORNEY AT LAW CHRISTINE MAILLOUX THE UTILITY REFORM NETWORK 711 VAN NESS AVENUE, SUITE 350 SAN FRANCISCO, CA 94102 | ||
MICHAEL MANCHESTER 1749 10TH STREET, NO. 1 SANTA MONICA, CA 90404 |
CINDY MANHEIM CINGULAR WIRELESS PO BOX 97061 REDMOND, WA 98073-9761 |
ATTORNEY AT LAW DAVID J. MARCHANT DAVIS WRIGHT TREMAINE LLP ONE EMBARCADERO CENTER, STE. 600 SAN FRANCISCO, CA 94111-3834 | ||
Monica L. McCrary CALIF PUBLIC UTILITIES COMMISSION 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 |
ATTORNEY AT LAW JAMES W. MCTARNAGHAN STEEFEL, LEVITT & WEISS ONE EMBARCADERO CENTER, 30/F SAN FRANCISCO, CA 94111 |
Karen Miller CALIF PUBLIC UTILITIES COMMISSION 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 | ||
WILLIAM K. MOSCA COMCAST BUSINESS COMMUNICATIONS, INC. 10 INDEPENDENCE WAY WARREN, NJ 7059 |
SENIOR COUNSEL KATHERINE K. MUDGE COVAD COMMUNICATIONS COMPANY 7000 NORTH MOPAC EXPRESSWAY, 2D FL AUSTIN, TX 78731 |
MIKE MULKEY ARRIVAL COMMUNICATIONS 1807 19TH STREET BAKERSFIELD, CA 93301 |
EXECUTIVE DIRECTOR NIKAYLA K. NAIL THOMAS CALTEL 515 S. FLOWER STREET, 47/F LOS ANGELES, CA 90071 |
ESTHER NORTHRUP COX CALIFORNIA TELCOM 5159 FEDERAL BLVD. SAN DIEGO, CA 92105 |
ATTORNEY AT LAW WILLIAM NUSBAUM THE UTILITY REFORM NETWORK 711 VAN NESS AVENUE, SUITE 350 SAN FRANCISCO, CA 94102 | ||
TERESA M. ONO AT&T COMMUNICATIONS OF CALIFORNIA, INC. 525 MARKET ST. 18TH FLOOR, 4 SAN FRANCISCO, CA 94105 |
ATTORNEY AT LAW CARL K. OSHIRO CSBRT/CSBA 100 PINE STREET, SUITE 3110 SAN FRANCISCO, CA 94111 |
JEAN PARKER WORKING ASSETS 101 MARKET STREET, SUITE 700 SAN FRANCISCO, CA 94105 | ||
JUDY PAU DAVIS WRIGHT TREMAINE LLP ONE EMBARCADERO CENTER, SUITE 600 SAN FRANCISCO, CA 94111-3834 |
EXECUTIVE DIRECTOR SUSAN PEDERSEN CELLULAR CARRIERS ASSOC. OF CALIFORNIA 980 NINTH STREET, SUITE 2200 SACRAMENTO, CA 95814 |
ALAN L. PEPPER MITCHELL SILBERBERG & KNUPP LLP 11377 W OLYMPIC BLVD., SUITE 200 LOS ANGELES, CA 90064-1683 | ||
Joey Perman CALIF PUBLIC UTILITIES COMMISSION 320 WEST 4TH STREET SUITE 500 LOS ANGELES, CA 90013 |
JEFFREY M. PFAFF SPRINT PCS 6450 SPRINT PARKWAY OVERLAND PARK, KS 66251-6100 |
Dale Piiru CALIF PUBLIC UTILITIES COMMISSION 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 | ||
MARIA POLITZER CALIFORNIA CABLE & TELECOM ASSOCIATION 360 22ND STREET, NO. 750 OAKLAND, CA 94612 |
LITIGATION PROGRAM DIRECTOR PAMELA PRESSLEY FOUNDATION FOR TAXPAYER&CONSUMER RIGHTS 1750 OCEAN PARK BLVD., SUITE 200 SANTA MONICA, CA 90405 |
LUPITA REYES VERIZON CALIFORNIA, INC. 600 HIDDEN RIDGE IRVING, TX 75038 | ||
ATTORNEY AT LAW KATHERINE S. RITCHEY JONES DAY 555 CALIFORNIA STREET, 26TH FLOOR SAN FRANCISCO, CA 94104 |
RUMMELSBURG ROD CNM NETWORK, INC. 4100 GUARDIAN STREET SIMI VALLEY, CA 93063 |
DIRECTOR-STATE REGULATORY AFFAIRS MICHAEL R. ROMANO LEVEL 3 COMMUNICATIONS, LLC 8270 GREENSBORO DRIVE, SUITE 900 MCLEAN, VA 22101 | ||
EXECUTIVE VICE PRESIDENT BARRY ROSS CALIFORNIA TELEPHONE ASSOCIATION 1851 HERITAGE LN STE 255 SACRAMENTO, CA 95815-4923 |
Sarita Sarvate CALIF PUBLIC UTILITIES COMMISSION 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 |
GAYATRI SCHILBERG JBS ENERGY 311 D STREET, SUITE A WEST SACRAMENTO, CA 95605 | ||
ATTORNEY AT LAW MARK P. SCHREIBER COOPER, WHITE & COOPER, LLP 201 CALIFORNIA STREET, 17TH FLOOR SAN FRANCISCO, CA 94111 |
TERRENCE E. SCOTT SBC ADVANCED SOLUTIONS, INC. 2623 CAMINO RAMON, ROOM 2C111 SAN RAMON, CA 94583 |
DEBORAH R. SCOTT FRONTIER, A CITIZENS COMMUNICATIONS CO. PO BOX 340 ELK GROVE, CA 95759 | ||
JOHN T. SCOTT III VERIZON WIRELESS 1300 I STREET, N. W., SUITE 400W WASHINGTON, DC 20005 |
JOHN T. SCOTT III VERIZON WIRELESS 1300 I STREET, N. W., SUITE 400W WASHINGTON, DC 20005 |
ATTORNEY AT LAW EARL NICHOLAS SELBY LAW OFFICES OF EARL NICHOLAS SELBY 418 FLORENCE STREET PALO ALTO, CA 94301 | ||
GLENN SEMOW CALIFORNIA CABLE & TELECOMM. ASSOC. 360 22ND STREET, STE. 750 OAKLAND, CA 94612 |
ATTORNEY AT LAW MICHAEL SHAMES UTILITY CONSUMERS' ACTION NETWORK 3100 FIFTH AVENUE, SUITE B SAN DIEGO, CA 92103 |
ATTORNEY AT LAW DAVID A. SIMPSON SIMPSON PARTNERS LLP 900 FRONT STREET, SUIT3 300 SAN FRANCISCO, CA 94111 |
ATTORNEY KRISTIN L. SMITH QWEST COMMUNICATIONS CORPORATION 1801 CALIFORNIA STREET, SUITE 4900 DENVER, CO 80202 |
Richard Smith CALIF PUBLIC UTILITIES COMMISSION 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 |
ROBERT SPANGLER SNAVELY ING & MAJOROS O'CONNOR & LEE INC 1220 L STREET N.W. SUITE 410 WASHINGTON, DC 20005 | ||
TERRANCE SPANN US ARMY LEGAL SERVICES AGENCY 901 N. STUART STREET, SUITE 700 ARLINGTON, VA 22203-1837 |
ETHAN SPRAGUE PAC-WEST TELECOMM, INC. 1776 W. MARCH LANE, SUITE 250 STOCKTON, CA 95207 |
ATTORNEY AT LAW GLENN STOVER STOVER LAW 301 HOWARD STREET, SUITE 830 SAN FRANCISCO, CA 94105-6605 | ||
REGULATORY TEAM JOSH P. THIERIOT PAC-WEST TELECOMM 1776 W. MARCH LANE, SUITE 250 STOCKTON, CA 95207 |
JOSH THIERIOT PAC-WEST TELECOMM, INC. 1776 W. MARCH LN, STE. 250 STOCKTON, CA 95207 |
MARGARET L. TOBIAS TOBIAS LAW OFFICE 460 PENNSYLVANIA AVENUE SAN FRANCISCO, CA 94107 | ||
ESQUIRE JAMES M. TOBIN TWO EMBARCADERO CENTER, SUITE 1800 SAN FRANCISCO, CA 94111 |
ATTORNEY AT LAW SUZANNE TOLLER DAVIS WRIGHT TREMAINE ONE EMBARCADERO CENTER, SUITE 600 SAN FRANCISCO, CA 94111 |
ATTORNEY AT LAW CHRISTINA V. TUSAN CALIFORNIA DEPARTMENT OF JUSTICE 300 SOUTH SPRING ST., 11TH FLOOR LOS ANGELES, CA 90012 | ||
ATTORNEY AT LAW MARY E. WAND MORRISON & FOERSTER LLP 425 MARKET STREET SAN FRANCISCO, CA 94105 |
Linda J. Woods CALIF PUBLIC UTILITIES COMMISSION 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 |
Linette Young CALIF PUBLIC UTILITIES COMMISSION 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 | ||
Jason J. Zeller CALIF PUBLIC UTILITIES COMMISSION 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 |
