Reason for the Requested Modification

Joint Applicants argue that the advice letter process will lessen the regulatory burden facing the Commission. Moreover, the process has several protective features to ensure that every interested carrier has an opportunity to express its views on proposed revisions to the JPSA metrics. Those features include notice of and opportunity to participate in a settlement conference, publication of the proposed changes in the form of an advice letter, and the chance for affected carriers to protest and be heard on the filing. Finally, in the case of any protest to the advice letter, the Joint Applicants propose that the advice letter not go into effect unless the Commission affirmatively approves it. The Joint Applicants assert that this modification will eliminate the significant delays of the past in getting agreed-to JPSA changes approved.