3. The Protests

The Division of Ratepayer Advocates ("DRA") and The Utility Reform Network ("TURN") protested the application. DRA alleges that Verizon and Frontier predict improved customer practices after the merger, yet they have made no commitments or provided any evidence to support their claims. DRA asserts that the application should be supplemented to include specific commitments with regard to rate and service quality protections for the affected customers. TURN is similarly concerned about the vagueness of consumer protections in the application. TURN seeks to determine the appropriate level of California - specific merger savings and the appropriate allocation of those savings; whether the proposed merger will harm service quality for California consumers impacted by the proposed transaction and if so what conditions are necessary to mitigate any harmful effects; and whether the proposed merger will have a negative or positive impact on state and local economies.