c) Detariffing Authorization Under Public Utilities Code Section 495.7

In their application for rehearing, TURN and DRA raise a number of arguments supporting their contention that section 495.7 does not authorize the Commission to detariff all telecommunications services on its own motion. TURN and DRA also argue that the Commission's reliance on the FCC's efforts to detariff long distance service is misplaced. We find that TURN and DRA's arguments are not ripe for review at this time, as we have deferred final determination of the detariffing issue pending consideration of parties' comments on the legal and implementation issues associated with detariffing. The arguments TURN and DRA raise here track the arguments raised in their September 29, 2006, comments on detariffing filed in Phase II, and would more appropriately be addressed in the Phase II decision concerning detariffing. If TURN and DRA conclude that the Commission has made a legal error in its ultimate decision concerning detariffing, they may challenge the alleged error in an application for rehearing of that decision.