ISSUE

ORA

SBC-CA

Verizon-CA

Citizens (Frontier)

SureWest

MCI1Cox

CCTA

Time Warner Telecom

CSBR/ CSBA

DOD

TURN

DRA2PRICING FLEXIBILITY

"Basic" Service definition for pricing flexibility proposal (Not intended to redefine residential basic service in D.96-10-066) Primary res, bus lines, and PBX trunks, incl: local usage, ZUM, EAS, recurring and non recurring charges; addl lines for bus/PBX trunks; toll restriction, caller ID blocking and information service blocking. Possible Phase 2 issue: addl svces for the disabled. [May be better handled through a competitively neutral credit to qualifying customers.] Primary residential line including: local usage, ZUM, EAS and recurring charges.Primary residential and business single line and non recurring charges for service establishment thereof.

Primary residential lines

Price-capped at current levels (subject to continuous monitoring and review after 3 years). Full downward pricing flexibility.

Maintained at current levels "temporarily" until no later than June 1, 2007, to allow a reasonable time for review of public policy programs in Phase 2.

Price-capped at current level; automatically eliminated after 3 years. Full downward Flexibility.

Price-capped at current levels "temporarily" until June 1, 2007, or until 2 years from the conclusion of Phase I of the proceeding at the latest. This will allow a reasonable time for review of public policy programs in Phase II. Full downward Flexibility

Price-capped at current levels "temporarily" until June 1, 2007, or until 2 years from the conclusion of Phase I of the proceeding at the latest. Full downward Flexibility.

De-tariff, replace with customer contracts.

Establish price caps at current rates or after subsidy rebalancing for 3 years; allow inflation adjustments annually thereafter. Price must be set above a cost-based price floor.

Establish price caps at current rates for 3 years; allow inflation adjustments annually thereafter.

Establish price caps at current rates or after rebalancing for 3 years; allow inflation adjustments annually thereafter. Price above a cost-based price floor.

Price capped for near future. Downward pricing flexibility.

Revenue cap as basic service.). Review in 3 years.

Prices capped at current rates / downward flexibility limited to price floors (Basket 1).

Same as TURN

Additional residential lines

Flexibly priced.

Flexibly priced.

Flexibly priced.

Flexibly priced.

Flexibly priced.

De-tariff, replace with customer contracts.

No distinction made for addl lines. Treat all residential lines the same.

No distinction made for addl lines. Treat all residential lines the same. Contingent on first reforming the CHCF-B and eliminating the presumption of revenue neutrality.

No distinction made for addl lines. Treat all residential lines the same. Eliminate revenue neutrality as a regulatory principle and reform CHCF-B prior to changes.

Price capped for near future. Downward pricing flexibility.

Revenue cap as basic service. Review in 3 years.

Prices increased based on price cap mechanism / decreases limited to price floors (Basket 2).

Same as TURN, but price caps where additional lines are necessary for people with disabilities (details established in Phase II).

Single-line business services (1MB)

Price-capped at current levels (subject to continuous monitoring and review after 3 years).

Flexibly priced.

Price-capped at current level (only the access line itself, not usage); automatically eliminated after 3 years; full downward flexibility.

Flexibly priced.

Flexibly priced.

De-tariff, replace with customer contracts.

Price must be set above a cost-based price floor. Establish price caps at current rates or after rebalancing for 3 years; allow inflation adjustments annually thereafter.

Retain price floor. Establish price caps at current rates for 3 years; allow inflation adjustments annually thereafter.

Price above a cost-based price floor. Establish price caps at current rates or after rebalancing for 3 years; allow inflation adjustments annually thereafter.

Price capped for near future. Downward pricing flexibility.

Revenue cap as basic service. No limit to number of lines. Review in 3 years.

Prices increased based on price cap mechanism / decreases limited to price floors - up to 5 lines. (Basket 3).

Not addressed

PBX trunks

Treated the same as business basic services. Price-capped at current levels (subject to continuous monitoring and review after a 3-year period.)

Flexibly priced.

Flexibly priced.

Flexibly priced.

Flexibly priced.

De-tariff, replace with customer contracts.

Flexibly priced.

Flexibly priced. Contingent upon first reforming CHCF-B and elimination of presumption of revenue neutrality.

Flexibly priced. Contingent upon reforming CHCF-B prior to PBX trunk pricing flex and elimination of presumption of revenue neutrality.

Not addressed.

Revenue cap as basic service toT-1 level. Additional PBX trunks flexibly priced Review in 3 years.

Not specifically addressed - unclear as to which basket.

Not addressed

Residential inside wire maintenance plans

Price-capped at current levels for 3 years (subject to continuous monitoring and review after a 3-year period.)

Flexibly priced.

Flexibly priced.

Full pricing flexibility starting in Phase I; detariff in Phase II;

Flexibly priced.

De-tariff, replace with customer contracts.

Not addressed.

Not addressed.

Not addressed.

Not addressed.

Not addressed.

Price-capped at current levels for 3 years (renewable after review).

Same as TURN.

E911 (PSAP)

911 services are excluded from pricing flexibility, including end users' access to 911.

911 services are excluded from pricing flexibility proposal.

911 services are excluded from pricing flexibility proposal.

911 services are excluded from pricing flexibility proposal.

911 services are excluded from pricing flexibility proposal.

Not addressed.

Not addressed.

Not addressed.

Not addressed.

Not addressed.

911 services are excluded from pricing flexibility proposal..

911 services are excluded from pricing flexibility proposal.

911 services are excluded from pricing flexibility proposal.

New services

Flexibly priced. Advice letter filing subject to protest and suspension if questions arise whether a service is truly new. Same disclosure requirements as for bundles.

Flexibly priced.

Flexibly priced.

Flexibly priced.

Flexibly priced.

No regulation of new services.

Flexibly priced, if truly new.

Flexibly priced, if truly new.

Flexibly priced, if truly new. Applicable to ILECs only.

Flexibly priced.

Flexibly priced..

Price regulated. Make case by case determination.

Same as TURN.

Packages and bundles

Flexibly priced; Full disclosure to customers re: ability to buy individual price regulated services at regulated rates, rather than bundles.

Flexibly priced.

Flexibly priced.

Flexibly priced. No limitations on bundling.

Flexibly priced. No limitations on bundling.

De-tariff, replace with customer contracts.

Flexibly priced, except bundles that include basic service must impute basic service price.

Flexibly priced, except bundles that include basic service must impute basic service price. Elimination of other existing pricing requirements for bundles contingent upon first reforming CHCF-B and elimination of presumption of revenue neutrality.

No bundling of basic service with enhanced services permitted , if enhanced service is not available separately e.g. Naked DSL. All bundles that include partially competitive service must use sum of the price floors or tariffed rate for imputation. Elimination of other existing pricing requirements for bundles, contingent upon first reforming CHCF-B and elimination of presumption of revenue neutrality. Applicable to ILECs only.

Flexibly priced for bundles.

Flexibly priced.

Prices increased based on price cap mechanism/ decreases limited to price floors (Basket 2).

Same as TURN plus: Where services that are offered as part of a bundle are not accessible, people with disabilities should be able to eliminate such services and still get the bundle-related savings for the other services. Principle established in Phase I. Details established in Phase II.

Promotions

No limitations; informational advice letter filing only, subject to protest in some cases (to be determined in Phase 2.)

No limitations. One-day notice via letter to CPUC's Executive Director.

No limitations.

No limitations.

No limitations.

No limitations.

Prohibit geographic-specific promos and promos that involve any service or bundle containing a service subsidized by CHCF-B. Limit promos for the same service to 90 days in a 12-month period, and retain ILEC price floor requirements for promos. Agree with concept of ILEC/CLEC parity for most other rules

Prohibit geographic-specific promos and promos that involve any service or bundle containing a service subsidized by CHCF-B. Limit promos for the same service to 90 days in a 12-month period, and retain price floor requirements for promos. Agree with ILEC/CLEC parity for most other rules. However expansion of existing flexibility for ILECs contingent upon prior CHCF-B reform and the elimination of the presumption of revenue neutrality.

Prohibit geographic-specific promos and promos that involve any service or bundle containing a service subsidized by CHCF-B. Limit promos for the same service to 90 days in a 12-month period, and retain price floor requirements for promos. In Reply suggest ILEC/CLEC parity for most rules incl. time limit, but ILECs price floor reqmt retained. Eliminate revenue neutrality as a regulatory principle and reform CHCF-B prior to change..

Flexibly priced.

No limitations. 1-day notice.

Time limits of 90 days on promotions. Beyond 90 days must be offered for resale.

Same as TURN plus: Providers should be required to make customers with disabilities aware of the services and products that they provide for their benefit. Principle regarding the need to provide such information established in Phase I. Details established in Phase II.

Relationship of CHCF-B to pricing flexibility proposal

No recoupment of price/revenue decreases from CHCF-B; no geographically deaveraged pricing flexibility for primary residential lines until CHCF-B issues are addressed. Phase 2 issue: Problem of unlimited downward pricing flexibility if CHCF-B subsidies are not available to all competitors. Monitor for possible effects on competition and promptly correct if problems noted.

Phase 2 issue. Address implications of full pricing flex for primary line residential basic service on public policy programs, including CHCF-B. In the interim, draw from CHCF-B will continue to be based on existing primary line residential service rate.

Issues re CHCF-B need not nor should not preclude or delay CPUC's prior adoption of increased pricing flexibility in context of URF. Verizon's proposal for a three-year transitional period allows sufficient time for CPUC to address HCF-B and related issues in a separate proceeding. Verizon will not seek additional CHCF-B draws based on the utilization of any downward pricing flexibility granted in URF.

Pricing flexibility and other Phase I URF reforms should occur prior to, and independent of, any CHCF-B examination. Frontier will not seek additional CHCF-B draws resulting from exercising downward pricing flexibility on the residential primary line rate granted in URF.

Pricing flexibility and other Phase I URF reforms should occur prior to, and independent of, any CHCF-B examination. SureWest will not seek additional CHCF-B draws based on the utilization of any downward pricing flexibility granted in URF.

Universal service needs to be addressed prior to ILEC deregulation.

Prior to allowing ILECs to flexibly price services supported in some parts of the state by HCF-B, eliminate the subsidy.

No pricing flexibility for the ILECs until CHCF-B is reformed

No pricing flexibility for ILECs until CHCF-B reformed.

CHCF-B subsidy to appear as explicit credits on bills for primary residential lines.

No recoupment of price/revenue decreases from CHCF-B. Phase 2 issue: Problem of unlimited downward pricing flexibility if CHCF-B subsidies are not available to all competitors. Monitor for possible effects on competition and promptly correct if problems noted.

Not addressed

Price Ceilings (non basic services)

Pricing flexibility permitted only provisionally, for non-essential services, & subject to continuous monitoring, review, and possible reversal after 3-years.

Eliminate.

Eliminate.

Eliminate.

Eliminate.

Eliminate.

Eliminate.

Eliminate Contingent upon first reforming CHCF-B and eliminating presumption of revenue neutrality

Oppose absent first addressing CHCF-B reform and eliminating presumption of revenue neutrality.

Elimination - implied.

Eliminate.

Basket approach with price caps adjusted by GDPPI and productivity factor.

Definition of "basic services" must take into account needs of people with disabilities. Principle that "basic services" include services that are necessary for people with disabilities established in Phase I. Details established in Phase II..

Price Floors

Eliminate. Commission does not endorse the legality of price reductions.

Eliminate.

Eliminate.

Eliminate.

Eliminate.

Eliminate.

Maintain for ILECs' basic services and require imputation of the basic service price in bundles that contain a basic service.

Maintain for ILECs' basic services and require imputation basic service price in bundles that contain a basic service. Elimination f other existing price floor and imputation reqmnts contingent on first reforming CHCF-B and elimination of the presumption of revenue neutrality.

Retain price floors for partially competitive services and use the sum of the price floors formula for imputation

Flexibly priced.

TSLRIC floor for basic services. Imputation for basic local exchange services would be set at the UNE-L floor.

TSLRIC +10% contribution or UNE rates. Investigate further in Phase 2.

Same as TURN

Geographic Deaveraging

All services but only downward flexibility for "basic" services. No recoupment of price/revenue decreases from CHCF-B; no geographically deaveraged pricing of primary residential lines until CHCF-B issues are addressed.

Not expressly proposed in Phase 1 but support.

As a redundant safeguard, maintain statewide rate uniformity for retail tariffed services for 3 years, then eliminate. [Note: Verizon is willing to consider a more narrowly tailored safeguard.]

Flexibility to deaverage all non-basic services in Phase I; maintain company-specific statewide rate uniformity for residential basic service following Phase I; address full deaveraging in Phase II.

Not expressly proposed in Phase 1 but support.

Not addressed.

Maintain geographically averaged rates for ILECs.

Maintain geographically averaged rates for ILECs.

Maintain geographically averaged rates for ILECs.

Not addressed.

All services but only downward flexibility for basic services.

Maintain geographically averaged rates for ILECs.

Not addressed.

PRICING PROCESS

Cost Support for Advice Letters / Contracts

Advice letters

1-day - $ decrease and new services. 30-day $ increase. 25-day cust notice for price increases. Terms and conditions remain subject to protest and suspension, for example, for failure to meet disclosure requirements for new and bundled services or for effective diminution of a "basic" price-capped service. See "Packages and Bundles."

1-day - $ decrease / increase. 25-day customer notice for price increase. Limited grounds for protest.

1-day - $ decrease / increase. 1-day - new services. 25-day customer notice for price increase. Limited grounds for protest.

1-day - $ decrease / increase. 25-day customer notice for price increases. Limited grounds for protest.

1-day - $ decrease / increase. 25-day customer notice for price increases. Limited grounds for protest.

Eliminate.

ILEC/CLEC parity. 1-day - $ decrease. 30-day $ increase. 25-day customer notice for price increases.

ILEC/CLEC parity. 1-day - $ decrease. 30-day $ increase. 25-day customer notice for price increases.

ILEC/CLEC parity. 1-day - $ decrease. 30-day $ increase. 25-day customer notice for price increases.

Not addressed.

1-day - $ decrease, new services and bundles. 30-day $ increase. 25-day cust notice for price increases.

1-day - $ decrease. 30-day $ increase. 30-day cust notice for $ increase and new services. Need to address review of terms and conditions other than price

Not addressed

Contracts [not pole attachments]

Effective on own terms. 15-day filing req.

Effective on own terms. 15-day filing reqmt.

Effective on own terms. 30-day filing reqmt.

Effective on own terms. No filing reqmt.

Effective on own terms. No filing reqmt.

Contracts for all customer services to replace tariffs.

Parity for timing of filing ILEC/CLEC req. Impute basic service rates into contracts that include basic services, standalone or bundled.

Parity for timing of filing ILEC/CLEC req. Impute basic service rates into contracts.

Parity for timing of filing ILEC/CLEC req. Impute tariffed service rates into contracts.

Not addressed.

Effective on own terms. 15-day filing reqmt.

Not permitted for Basket 1, 2 or 3 products.

Not addressed.

Grandfathering and/or Withdrawal of service

Not permitted for any price capped/ price-regulated service. For other "non-basic" services, defer this issue to Phase 2.

1-day advice letter. 25-day customer notice. Res/Bus Access lines excluded from 1-day advice letter proposal.

Not addressed.

1-day advice letter period for grandfathering; 25-day advice letter period for withdrawal. 25-day customer notice. Res/Bus Access lines excluded.

1-day advice letter period for grandfathering; 25-day advice letter period for withdrawal. 25-day customer notice. Res/Bus Access lines excluded.

Not specifically addressed.

Not specifically addressed.

Not specifically addressed.

Not specifically addressed.

Not addressed.

Not addressed.

Need to ensure CPUC ability to determine impact on customers, public comment/protest.

Same as TURN plus there must be restrictions on the withdrawal of services that are relied on by people with disabilities.

EARNINGS REGULATION

Earnings Regulation Eliminate earnings regulation but continue to report intrastate earnings according to Commission requirements. Subject to review and possible reversal in 3 years.Eliminate earnings regulation; eliminate price cap and sharing mechanism.Eliminate earnings regulation; eliminate price cap and sharing mechanism.Eliminate earnings regulation; eliminate price cap and sharing mechanism. Price cap or similar filing should continue for Frontier to account for fluctuations in federal USF draws.Eliminate earnings regulation; eliminate price cap and sharing mechanism.Eliminate earnings regulation.No longer required except to address rate increases for basic service. Eliminate revenue neutrality as a regulatory principle prior to change in rules.No longer required except to address rate increases for basic service. Continue earnings reg until the presumption of revenue neutrality is eliminated.Inflation adj for ILECs basic services; eliminate Productivity factor. No longer required except to address rate increases for basic service. Eliminate revenue neutrality as a regulatory principle prior to change in rules. Not addressed.Eliminate earnings regulation ILEC may seek increase in basic service revenue cap if revenue shortfall based on DEC.

Rate Rebalancing

Oppose automatic rate increases for revenue neutrality.

Not addressed.

Maintain revenue neutrality, i.e., Commission-mandated rate reductions in price-regulated services should afford parties an opportunity to make offsetting rate changes to other price-regulated services.

Maintain revenue neutrality, i.e., Commission-mandated rate reductions in price-regulated services should afford parties an opportunity to make offsetting rate changes to other price-regulated services.

Maintain revenue neutrality, i.e., Commission-mandated rate reductions in price-regulated services should afford parties an opportunity to make offsetting rate changes to other price-regulated services.

None.

Oppose automatic rate increases for revenue neutrality. Prior to allowing ILECs to flexibly price services supported in some parts of the state, by HCF-B, rates should be rebalanced to eliminate the subsidy. If public policy prevents such rebalancing, pricing flexibility should not be permitted.

Oppose . given that it presumes revenue neutrality.

Oppose.

Not addressed.

Within revenue cap, rate rebalancing permitted.

Oppose rate increases for revenue neutrality.

Not addressed

Imputation of Yellow Page revenue

No effect on current rates, no change to statute. Continue current reporting requirements.

Eliminate.

Eliminate.

Eliminate.

Eliminate.

No position.

Not addressed.

Contingent on the elimination of the presumption of revenue neutrality

Eliminate revenue neutrality as a regulatory principle prior to change in rules.

Not addressed.

Maintain only if ILEC claims basic service revenue short fall.

No effect on current rates, no change to statute. Continue current reporting requirements.

Not addressed.

Gain on Sale of Assets - allocations

Shareholders retain all gains and bear all losses. (Note: ORA's position(s) on this and other issues are subject to change if ORA's proposal is not adopted as a complete package.)

Shareholders retain all gains and bear all losses.

Shareholders retain all gains and bear all losses.

Shareholders retain all gains and bear all losses.

Shareholders retain all gains and bear all losses.

No position for ILECs. Exempt sale or transfer of assets by competitive telecom carriers from CPUC review & approval.

GOS of previous rate base assets should be treated depending on when asset acquired.

GOS of previous rate base assets should be treated depending on when asset acquired.

GOS of previous rate base assets should be treated depending on when asset acquired.

Not addressed.

GOS of previous rate base assets should be treated depending on when asset acquired.

GOS of previous rate base assets should be treated depending on when asset acquired.

Same as TURN

MONITORING/SERVICE QUALITY/ETC.

Service Quality Phase 2 issue. Continuation of ARMIS SQ monitoring data even if terminated by the FCC.Uniform rules; SQ OIR or Phase 2.Uniform rules; SQ OIR.Uniform rules; SQ OIR.Uniform rules; SQ OIR.Eliminate service quality standards and rules unless they are necessary for consumer protection of public health and safety.

Accounting Rules

Phase 2 issue. Possibly USOA with CA overlays for Yellow Pages, inside wire, and affiliated transactions (as noted below.)

Eliminate all CA specific acct rules and defer to FCC acctg rules.

Conform financial reporting requirements to ARMIS.

Conform financial reporting requirements to ARMIS.

Conform financial reporting requirements to ARMIS.

Not specifically addressed.

Standardize CLEC/ILEC rules.

Standardize CLEC/ILEC rules. ,contingent upon prior elimination of presumption of revenue neutrality.

Standardize CLEC/ILEC rules. Eliminate revenue neutrality as a regulatory principle and reform CHCF-B prior to change in acctg rules.

Not addressed.

Conform reporting requirements to ARMIS.

Phase 2 issue.

Not addressed

Monitoring

Phase 2 issue. Streamline; replace many with ARMIS reports with CA overlays; additional reporting to monitor competition and related pricing effects; service quality; and availability of & subscribership rates for advanced services.

Phase 1 -Eliminate co-specific reports. Adopt principle of consistent requirements across carriers. Phase 2 - Any proposals for reports should show benefits outweighs cost, new reports must contain a sunset provision.

Monitoring reports should be consistent with URF goals. Eliminate NRF reports. Streamline and replace largely by ARMIS reports.

Phase 1 - Eliminate all Commission mandated NRF monitoring reports. Phase 2 - identify specific reports that are appropriate to URF. Reports should be consistent for all carriers.

Phase 1 - Eliminate all Commission mandated NRF monitoring reports. Phase 2 - identify specific reports that are appropriate to URF. Reports should be consistent for all carriers.

Eliminate. Do not adopt requirements similar to FCC ARMIS requirements.

Streamline; uniform reporting requirements. Workshop or other processes to workout details, e.g. Phase II of URF.

Streamline; uniform reporting requirements. Workshop or other processes to workout details.

Streamline; uniform reporting requirements. Workshop or other processes to workout details.

Not addressed.

Conform reporting requirements to ARMIS.

Phase 2 issue. Streamline; perhaps replace many with ARMIS reports; additional reporting to monitor competition, service availability and service quality.

Need reporting and monitoring on disability-related service quality (including customer satisfaction). Principle established in Phase I. Details established in Phase II.

Audit Requirements

Phase 2 issue.

Phase 2 issue. Streamline; consistent requirements across carriers.

Streamline.

Phase 2 issue; Streamline; consistent requirements across carriers.

Phase 2 issue; Streamline; consistent requirements across carriers.

Eliminate.

Streamline; consistent req across carriers. Workshop or other processes to workout details.

Streamline; consistent req across carriers. Workshop or other processes to workout details. Contingent on prior elimination of presumption of revenue neutrality.

Streamline; consistent req across carriers. Workshop or other processes to workout details. Eliminate revenue neutrality as a regulatory principle prior to change in rules.

Not addressed.

Not addressed

Phase 2. Need more audits to ensure just and reasonable rates and avoid cross-subsidy including broadband cost analyses.

Same as TURN

Affiliate Transactions

Phase 2 issue.

Eliminate all co-specific rules; defer to FCC rules.

Eliminate reporting requirements, conform to FCC rules.

Eliminate reporting requirements, conform to FCC rules.

Eliminate reporting requirements, conform to FCC rules.

Not specifically addressed.

Eliminate rules for ILECs if price floors kept for basic service; No rules for CLECS.

Eliminate if price floors kept for basic service. Contingent upon prior elimination of presumption of revenue neutrality.

Eliminate if price floors kept for ILEC services; and presumption of revenue neutrality is eliminated. No rules for CLECS.

Not addressed.

Not specifically addressed.

Phase 2 issue.

Not addressed.

Customer disclosure requirements *CBOR - Consumer Bill of Rights proceeding

Uniformity across carriers to the extent possible. Phase 2 issue, e.g., adopt disclosure requirements as described under "Packages and Bundles."

Phase 1, adopt a policy that customer disclosure reqmts should be adopted uniformly to the extent reasonably feasible and the specifics addressed in the CBOR.* Any un-uniform disclosure reqmts remaining after CBOR should be considered for elimination in Phase 2.

Adopt a policy that any customer disclosure requirements should be adopted uniformly to the extent reasonably feasible and the specifics addressed in the CBOR

Agree that any customer disclosure requirements should be adopted uniformly to the extent reasonably feasible and the specifics addressed in the CBOR

Agree that any customer disclosure requirements should be adopted uniformly to the extent reasonably feasible and the specifics addressed in the CBOR

Not addressed.

Not addressed.

Not addressed.

Not addressed.

Not addressed.

Not addressed.

Phase 2 issue.

Not addressed.

Timing and Scope of next review, if any.

Review within 3 years to determine whether adopted framework is achieving its stated goals, or sooner if problems are detected. Mechanism for prompt remedial action in case monitoring program indicates framework's failure (i.e., adopt "fail-safe" mechanism(s), such as restoration of price caps.) Expedited resolution of complaints (e.g., a complaint by a competitor or customer is resolved in 90 days or plaintiff's request for relief is automatically granted absent good cause for delay.)

No automatic review needs to be scheduled. The CPUC retains authority to initiate a review of any aspect of the adopted regulatory framework at any time it deems it appropriate to do so.

All remaining transitional constraints on pricing flexibility (e.g., price caps for "basic" services and statewide retail tariffed rate uniformity) should be automatically eliminated in 3 years.

Any pricing constraints that remain at the conclusion of Phase I should be automatically removed by June 1, 2007, or by 2 years from the conclusion of Phase I of the proceeding at the latest. Frontier acknowledges the CPUC's existing authority to initiate a review of any aspect of the adopted regulatory framework at any time it deems it appropriate to do so.

Any pricing constraints that remain at the conclusion of Phase I should be automatically removed by June 1, 2007, or by 2 years from the conclusion of Phase I of the proceeding at the latest. The CPUC retains authority to initiate a review of any aspect of the adopted regulatory framework at any time it deems it appropriate to do so.

Review in 3 years.

Same as TURN

POLICY ISSUES

Competitive assessment The current level of competition does not justify broad elimination of price caps at this time; however, ORA is willing to experiment with greater regulatory flexibility for less-essential services, subject to the other protections identified in ORA's proposal.The telecommunications marketplace has multiple providers (traditional wireline companies, wireless companies, cable companies, VoIP providers, wireless internet providers, and other intermodal competitors) offering multiple services over multiple technologies. Consumer preference and choice drive pricing and packaging of services, and no communications provider has the ability to sustain prices above competitive levels. Today's broad-based, dynamic communications environment promotes product diversity and disciplines competitors' prices. Competitors include both intra-modal (wireline) providers, and inter-modal (wireless, cable, and VoIP) providers. Competitive analyses that consider only a single mode of competition and fail to accommodate or control for market dynamics (such as the effects of technological change and regulatory obligations) are fundamentally flawed, incomplete, and provide no useful information about market power.Both the California telecommunications market generally - and Frontier's service territory specifically - demonstrate significant competition between a variety of intermodal and intramodal competitors. Dramatic changes and competitive developments in the telecommunications landscape have rendered the NRF structure obsolete, and justify the creation of a Uniform Regulatory Framework, which should incorporate broad pricing flexibility and significant regulatory streamlining. Any measurement/assessment of market should include impacts of all modes of service.The competitive landscape for the four NRF ILECs has changed dramatically, as numerous competitive opportunities exist for customers from a variety of intermodal and intramodal telecommunications services. Dramatic changes and competitive developments in the telecommunications landscape have rendered the NRF structure obsolete, and justify the creation of a Uniform Regulatory Framework, which should incorporate broad pricing flexibility and significant regulatory streamlining. Any measurement/assessment of market should include impacts of all modes of service. Drastic disagreement among the parties on current competitive levels and potential for changes; also drastic disagreement on what services are complements to or substitutes for each other; Full assessment of market dominance needs to be done by Commission before reducing ILEC regulation.Drastic disagreement among the parties on current competitive levels and potential for changes; also drastic disagreement on what services are complements to or substitutes for each other; Full assessment of market dominance needs to be done by Commission before reducing ILEC regulation.ILECs retain market power in mass market (i.e. residence and small business). ILECs lack market power in enterprise market.ILECs have significant market power. Competition insufficient to justify extensive price deregulation.ILECs seem to have considerable market-power. As it stands, the Commission lacks sufficient information to gauge competitive conditions.