In its Opening Comments, ORA indicates that a group of Small LECs filed a request for delay of their duty to implement intraLATA equal access until this proceeding was decided. (A.99-06-009.) In that application, Foresthill and Ducor stated that they had not yet implemented interLATA presubscription and requested that they be permitted to delay implementation of interLATA equal access until they implement intraLATA equal access, citing cost efficiencies and reduced customer confusion.