2. Comments on Initially Proposed Rules

Following issuance of the OIR, the Chief Administrative Law Judge sent our Notice of Proposed Regulatory Action to the Office of Administrative Law, which duly printed the notice in the California Regulatory Notice Register (Register) of February 26, 1999. We held a workshop on March 3 and provided for concurrent opening comments (due March 22) and concurrent reply comments (due April 12.)

The following parties filed opening comments: Pacific Bell; Roseville Telephone Company (Roseville); GTE California Incorporated, GTE West Coast Corporation, and GTE Communications Corporation (filing jointly and collectively referred to as GTE); a group of telecommunications utilities calling themselves the "Smaller Independent LECs;"² a group of energy utilities calling themselves the "Joint Energy Utilities;"³ the Commission's Office of Ratepayer Advocates (ORA); Greenlining Institute and Latino Issues Forum (filing jointly and collectively referred to as Greenlining); and The Utility Reform Network (TURN). Four of these parties (GTE, TURN, ORA, and Pacific Bell) also filed reply comments. Lastly, two parties filed reply comments only: AT&T Communications of California, Inc. (AT&T); and MCI WorldCom, Inc. (MWCOM).

² The Smaller Independent LECs (i.e., local exchange carriers) include Calaveras Telephone Company, Cal-One Telephone Co., Ducor Telephone Company, Foresthill Telephone Co., The Ponderosa Telephone Co., and Sierra Telephone Company, Inc. ³ The Joint Energy Utilities include Pacific Gas and Electric Company (PG&E), San Diego Gas & Electric Company (SDG&E), Southern California Gas Company (SoCalGas), and Southern California Edison Company (Edison). SDG&E and SoCalGas are represented by Sempra Energy (Sempra), with which they are affiliated. Elsewhere in today's decision, we simply refer to Sempra.