ORA Comments/Commission Responses

1. Modify proposed Rule 77.7(c) to permit reply comments on draft resolutions and alternates to resolutions. (Opening Comments, pp. 2-3.)

[AT&T and GTE support.]

Response: Agree. As adopted in today's decision, Rule 77.7(c) allows reply comments on draft resolutions and alternates.

2. The scheduling treatment for alternates to resolutions, which mirrors the scheduling treatment in Rule 77.6(f) for alternates to proposed decisions, should be formalized by explicit inclusion in proposed Rule 77.7. (Opening Comments, pp. 3-4.)

Response: Reject. As noted in the OIR at page 5, the Commission expects that in general it will serve any alternate resolution at least 14 days before taking action on the alternate and the resolution to which the alternate relates. However, the Commission will not necessarily do so in every such instance. The Commission, in any event, will observe the statutory minimum period (10 days) relating to service and consideration of alternates. See Public Utilities Code Sec. 311(e).

3. Oppose GTE's proposal to waive public review and comment for all resolutions related to advice letters filed by telecommunications service providers. (Reply Comments, pp. 1-2.)

Response: Agree (no change necessary). See Response to GTE Comment #1.

4. Oppose Pacific Bell's proposal to waive or reduce review and comment period when the Commission deems that the protests to an advice letter are frivolous. (Reply Comments, pp. 2-3.)

Response: Agree (no change necessary). See Response to Pacific Bell Comment #3.

5. Support TURN's proposal to expand, where appropriate, the page limit on comments. (Reply Comments, pp. 3-4.)

Response: Reject (no change necessary). See Response to TURN Comment #4.