The OIR proposed to rename the "registration Certificate of Public Convenience and Necessity" a "registration certificate" or a "registration license" to clearly distinguish between the certification granted under § 1001 and the registration authorized by § 1013.
Sempra states that the term "registration CPCN" is potentially confusing, and that a designation such as "registration certificate" or "registration license" will help prevent confusion.
UCAN also recommends that the Commission identify the authorizing document as a "registration certificate" to reduce confusion. UCAN further recommends that the Commission not designate the authorizing document a "registration license" because, according to UCAN, the term "license" implies that the registration certificate holder has passed a qualifying examination and acquired a special status such as a drivers' license, real estate license, or contractor license.
ExteNet opposes changing the name of the authorizing document to the extent the Commission intends to retroactively convert existing NDIECs' unlimited certificates to limited-duration licenses.
DRA states that the Public Utilities Code adequately differentiates a CPCN from a registration certificate of an NDIEC.
As stated in the OIR, the designation of the authorizing registration document as a "CPCN" has resulted in confusion. Because § 1013(a) provides that a telephone corporation operating in California must either have a CPCN or be registered, we conclude that it is not appropriate to refer to the authority granted to registrants as a "CPCN." We believe that either "registration license" or "registration certificate" is a more appropriate designation. However, because a CPCN is sometimes also referred to as a "certificate," we prefer the term "registration license" to minimize any potential confusion between it and a CPCN granted pursuant to § 1001. Therefore, we rename the authorization granted through the simplified registration process, pursuant to § 1013, a "registration license."13
We define a "registration license" as the interexchange authority granted pursuant to § 1013 through the simplified registration process established by D.97-06-107, (previously referred to as a "CPCN").
The terms "registration license holder", "registration licensee", or "registrant" are used interchangeably, and refer to an entity (i.e., a prepaid debit card provider required by § 885 to register, or an interexchange carrier) that obtained or obtains interexchange authority through the simplified registration process established by D.97-06-107 pursuant to § 1013, that does not hold interexchange authority obtained through the Commission's application process pursuant to § 1001.
Thus, an entity with interexchange authority obtained through the Commission's regular application process pursuant to § 1001, even if the entity is also registered through the simplified registration process pursuant to § 1013, is not a registration license holder, registration licensee or registrant that is subject to the requirements of this Decision.
13 Telephone corporations obtaining operating authority in this way remain subject to all the obligations of a public utility under the Public Utilities Code.