II. Allegations of the Complaint

ORA alleges (and Pacific denies) that Pacific's residential repair service violates the following statutes and a Commission order:

· Pacific's long repair intervals violate § 451, which requires Pacific to furnish "...adequate, efficient, just, and reasonable service..." as is "...necessary to promote the safety, health, comfort and convenience of its patrons...and the public."

· Pacific's failure to provide customers with an opportunity to request a 4-hour appointment period violates § 451.

· Pacific's long repair intervals and high customer dissatisfaction levels, since its merger with SBC, violate OP 2 of D.97-03-067, and thus also violate § 702.