4. Comments on Proposed Decision

The proposed decision of Commissioner Chong in this matter was mailed to the parties in accordance with Section 311 of the Public Utilities Code and Rule 14.3 of the Commission's Rules of Practice and Procedure. Comments were filed on August 13, and reply comments were filed on August 20, 2007. Parties filing comments are AT&T, California Association of Competitive Telecommunications Companies (CALTEL), Cox/Time Warner/XO, DRA, Small LECs, Sprint Nextel, SureWest, TURN, and Verizon. Parties filing reply comments are all of the foregoing except CALTEL, Small LECs, and TURN. We note, however, that in TURN's reply comments on today's companion decision, TURN touches upon several of the Industry Rules, and we have taken TURN's reply comments into consideration in our responses.

In general, commenters support the rules overall, but ask for clarifications to some rules and suggest that several rules should be updated. Some proposals are controversial; for example, the principles governing protests to advice letters (discussed here and in the accompanying URF Phase II decision) generate concerns among some consumer and utility representatives. In the following discussion, we respond to all of the comments and reply comments, organizing our response by rule number.