VIII. Comments on Draft Decision

The Commission mailed the draft decision of the ALJ in this matter to the parties in accordance with Section 311(g)(1) and Rule 77.7 of the Rules of Practice and Procedure. Comments were filed by Verizon, Joint Commenters, and Telscape. Reply comments were filed by Verizon, Joint Commenters, Covad, ORA, and TURN.

In general, Verizon urges adoption of its own interim pricing proposals rather than interim UNE rates based on Verizon New Jersey rates. Joint Commenters and Covad support the Draft Decision, but urge corrections to make interim UNE rates more closely mirror those of Verizon New Jersey. Covad, a digital subscriber line (DSL) provider, stresses that Verizon's loop rates must be priced according to TELRIC or Verizon will likely dominate the DSL market. ORA and TURN support the Draft Decision as written. Telscape, a CLC, urges changes regarding the effective date of nonrecurring charges. These specific comments have been addressed throughout the text of the order where appropriate.