Procedural Requirements Under Rule 16.4

Rule 16.4 of the Commission's Rules of Practice and Procedure (Rules) governs the process for the filing and consideration of petitions for modification. Rule 16.4(b) requires that a petition for modification concisely state the justification for the proposed relief and to propose specific wording for all requested modifications. BRT's Petition contained a concise but thorough statement of justification for the proposed modifications. Hence, this requirement has been fulfilled.

Rule 16.4(d) requires that a petition for modification must be filed and served within one year of the effective date of the decision for which modification is being proposed. BRT filed its petition for modification of D.10-11-022 within one year of its issuance, so is therefore in compliance with this requirement.

Hence, we conclude that BRT's Petition complies with the procedural requirements of Rule 16.4.