3. The Petitions for Modification

On September 1, 2006, Verizon filed its Petition to Modify D.06-03-025. In its petition, Verizon states that it is evident from objections interposed to several Advice Letters Verizon filed on April 14, 2006 in compliance with that decision, that there is uncertainty and ambiguity within the industry as a result of certain parts of the decision, as well as additional practical concerns that Verizon has identified in attempting its implementation.

Verizon proposes changes in three areas as follows:

1. The UNEs delisted by the Federal Communications Commission (FCC) in its Triennial Review Order (TRO) and the Triennial Review Remand Order (TRRO) should not appear in D.06-03-025, Appendix A or Verizon's Interconnection Agreements;

2. The Commission should modify or restate rates for tandem switching and interoffice switching, multiplexing and dark fiber, and

3. Additional issues require clarification or modification.

No party filed in opposition to Verizon's Petition to Modify.

Also on September 1, 2006, Verizon filed a motion for leave to file confidential materials under seal, namely Exhibit D (Multiplexing and Dark Fiber Rate Restructure Workpaper).

On July 10, 2007 Verizon and Covad together filed a Joint Petition to Modify D.06-03-025 to eliminate the "ADSL on Copper Loop" Adder set forth in Appendix A of D.06-03-025. In conjunction with the Joint Petition, Verizon withdrew the proposal made in its pending Petition for Modification of D.06-03-025, in which it requested that the Commission clarify that the $6.74 "ADSL on Copper Loop" item in Appendix A was an adder to a copper loop for which ADSL service has been provisioned. Verizon states that in all other respects, its initial Petition for Modification remains pending. On August 9, 2007, the California Association of Competitive Telecommunications Companies (CALTEL) filed in support of the Joint Petition.