VII. Applicant's Reply to Protests

Applicants represented in their November 4, 1999 response to ORA's protest that the application provides more than a sufficient basis to approve the proposed merger. Given that none of the Applicants have gross annual California revenues exceeding $500 million, Applicants contend that there should be no question that § 854(b) and (c) are not applicable to the proposed merger. Consistent with § 854(a), Applicants presented additional information in their reply to substantiate that the proposed merger is in the public interest.

A review of this information shows that there is sufficient information available in this proceeding to assess whether the proposed merger is in the public interest. Hence, an evidentiary hearing is not necessary to address public interest.