8. Comments on Proposed Decision

The proposed decision of the ALJ in this matter was mailed to the parties in accordance with Section 311 of the Public Utilities Code and comments were allowed under Rule 14.3 of the Commission's Rules of Practice and Procedure. Comments were filed on April 1, 2008, and reply comments were filed on April 7, 2008.

The Joint Telecommunications Carriers opposed any type of split and stated that splits are an obsolete form of area code relief. In separate comments, AT&T California¹⁵ objected to being required to use notices mailed separately from a customer's bill. AT&T explained that bill notices can be more effective, and are allowed in the statutes. Cox California Telcom, LLC, dba Cox Communications intervened in support of a split but recommended that Area B retain the 760 area because the majority of customers are located in Area B. The Division of Ratepayer Advocates supported split alternative one.

In addition to the formal comments, the Commission's Public Advisor also received over 50 written comments from individuals and community leaders supporting alternative one because it keeps all of Imperial County in one area code.

In reply, Cox stated that more customers in Area B complained about the inconvenience of changing area codes so this area should retain the 760 area code. If not, Cox supported an overlay. The Joint Carriers reiterated that any split creates winners and losers, unlike an overlay.

In response to the comments, the Proposed Decision was revised to adopt split alternative one, rather than split alternative four.

¹⁵ AT&T California, Cox and the Division of Ratepayer Advocates each submitted unopposed motions for party status, all of which are granted.