8. Limiting Use of Advice Letter Process

SCE's application also requested that future product orders involving new construction be subject only to the advice letter process and not the § 851 application process. ORA opposes this, recommending instead that the Commission continue to require the filing of an application pursuant to § 851 when new construction is required. After discussion with ORA, SCE agreed to withdraw its request for a more informal process when new construction is involved. Thus, any and all future product orders with Sprint for fiber that was not constructed and owned by SCE by November 26, 2003, even if subject to the Lease Agreement approved in this proceeding, is to be approved only through the Commission's § 851 application process. Our order today memorializes this agreement.