COMMENTS

On February 15, 2000 the Telecommunications Division received comments from ORA concerning Pacific's request.

It is ORA's position that they are in favor of streamlining the NRF monitoring reports. However, according to ORA, the proposed USOA Summary Report is not comparable with Column #1 of the Intrastate Earnings Monitoring Report (IEMR). ORA pointed out various discrepancies between the two reports including a $12 million dollar difference in total operating revenue, and a $7 million dollar difference in total operating expenses. Because of these discrepancies and the lack of comparability between the USOA Summary Report and the IEMR, ORA requested that the changes proposed by Pacific should not be adopted.

ORA recommended that Pacific provide a mapping and translation of each USOA account to track and support Column #1 of the IEMR, and also recommended that Pacific provide mapping and translation for the 1998 and 1999 IEMR's. This process would allow ORA and the commission to view and track the inputs for each account, and verify that the USOA Summary Report is an accurate representation of the IEMR and the 13 reports it is replacing.

On August 31, 2000, Pacific responded to ORA's comments by supplementing its initial filing. The supplement contained a mapping and translation of the USOA summary report to Column #1 of the IEMR as well as reconciliation reports of each USOA account to Column #1 of the IEMR from January 2000 through July 2000.

After reviewing the supplement, ORA stated in a letter dated December 14, 2000 that it is now satisfied with Pacific's requested modifications to its reporting requirements as set forth in its December 7, 1999 letter. However, ORA recommends that in granting Pacific's request, Pacific should be required to provide the reconciliation reports for August through December 2000 as they become available. ORA recommends that the proposed changes should be implemented with the January 2001 monitoring reports.